At the end of March, the CAA released a revised version of CAP 722 (Sixth Edition March 2015) in which they clarified the rules around the use of sub 7kg SUSA in congested areas. The ‘Congested Areas Operating Safety Case (CAOSC)’ was re-named UAS Operating Safety Case (UAS OSC).
Formerly known as the ‘Congested Areas Operating Safety Case (CAOSC)’, the UAS Operating Safety Case (UAS OSC) has been devised using the ConOps methodology to give a flexible method by which the applicant can provide the CAA with a safety argument for intended operations. Each application for a permission to operate must be accompanied by a UAS OSC.
Although it was common practice within the industry to operate sub 7kg SUSA in congested areas without submitting (what was then) a CAOSC, the previous editions of CAP 722 did not exempt sub 7kg SUSA from this requirement but rather sub 7kg SUA. As soon as ‘any form of surveillance or data acquisition’ equipment is added to an SUA, it becomes an SUSA. It was only SUA with a mass of 7kg or less where a permission to operate within a congested area at least 50m clear of third parties etc,, was normally given ‘as standard’. Hence, technically any SUSA, whether below or above 7kg, would have required a CAOSC to be submitted to operate in a Congested Area.
All SUAS and SUSA operators applying for permission to operate in congested areas are required to complete a CAOSC in the format detailed at the Congested Areas Operations Safety Case Template. SUA of 7 kg or less are not required to use the CAOSC for a standard permission1
1For SUA with a mass of 7 kg or less a permission to operate within congested areas, at least 50 m clear of third parties etc., is normally given ‘as standard’.
However, with the release of CAP 722 (Sixth Edition March 2015) this has now been amended to include SUSA and reads as follows:
Page 39 – Section 3.25
The standard CAA permission for SUA/SUSA in the 7 kg or less category allows flight in congested areas to within 50 metres of persons, structures etc. (or within 30 metres if the persons are under the control of the person in charge of the aircraft). This category of SUA/SUSA cannot fly within 150 metres of open-air assemblies of 1,000 people or more where only a standard permission has been granted.
This clarification has removed any doubt about operating sub 7kg SUSA in congested areas and will no doubt be welcomed within the industry. Operating in congested areas brings its own challenges and whether or not permissions need to be sought, it is important that operators are aware of the additional risks and do everything they can to mitigate them. It is also important to check with your insurer to make sure that you are covered to operate in congested areas.