Beyond Visual Line of Sight: Ensuring Safety in BVLOS Operations in the UK

Operating drones beyond visual line of sight (BVLOS) in the UK opens up significant opportunities for industries such as logistics, infrastructure inspections, and environmental monitoring. However, BVLOS operations involve higher risks and stringent regulatory requirements. Adherence to the Civil Aviation Authority’s (CAA) guidance, particularly CAP 722, is essential to demonstrate safety and compliance with UK Regulation (EU) 2019/947. Operators must prepare a robust safety case to address these risks and meet regulatory expectations.

Key Risks in BVLOS Operations

BVLOS flights differ significantly from visual line of sight (VLOS) operations, introducing challenges such as:

1.  Airborne Collision Risks

The lack of direct visual monitoring increases the likelihood of conflicts with other airspace users or physical obstacles.

2. Communication Failures

Long-range operations are dependent on reliable command-and-control (C2) links, which may experience interference or loss over extended distances.

3.  System Reliability

Failures in propulsion, navigation, or onboard systems can lead to accidents far from the operator’s ability to intervene.

4.  Operational Complexity

BVLOS operations require integration into potentially congested or controlled airspace, increasing the risk of unauthorised intrusions or deviations.

UK Regulatory Framework for BVLOS

In the UK, BVLOS operations are governed by UK Regulation (EU) 2019/947, which places them within the Specific category unless conducted under predefined Standard Scenarios (STS). Key documents guiding these operations include:

• CAP 722: The principal CAA guidance for drone operations, detailing safety management, risk mitigation, and operational planning.

  
  

• CAP 3038: A CAA publication providing an overview of considerations for BVLOS operations, emphasising key areas such as detect-and-avoid systems, C2 link resilience, and contingency planning. CAP 3038 does not prescribe specific guidance but outlines the high-level principles and challenges operators must address when preparing a safety case.

  
  

• UK Regulation (EU) 2019/947: originally a European Union regulation, was adopted into UK law following Brexit. It provides the legal framework for unmanned aircraft system (UAS) operations within the UK, focusing on the safety, categorisation, and authorisation of drone flights. This regulation is essential for BVLOS (Beyond Visual Line of Sight) operations as it establishes the overarching requirements for ensuring safe integration of drones into the airspace.

Building a Safety Case for BVLOS Operations

To gain operational authorisation for BVLOS flights, operators must submit a safety case demonstrating that all risks have been identified, assessed, and mitigated to an acceptable level. Key elements include:

1. Risk Assessment Using Established UK Methodologies

Identify and assess risks using approved risk assessment frameworks that align with CAA expectations. Focus on air risks (e.g., mid-air collisions) and ground risks (e.g., potential harm to people or property).

2. Command-and-Control (C2) Link Reliability

Provide evidence of a robust and redundant communication system capable of maintaining a stable connection throughout the operation. Include testing data to validate performance.

3. Detect-and-Avoid Systems

Address how the drone will safely separate from other airspace users. While fully autonomous detect-and-avoid capabilities are not yet mandated, operators must demonstrate how risks are mitigated using currently available systems or procedural controls.

4. Contingency and Emergency Procedures

Submit detailed plans for handling potential failures, including predefined emergency landing areas and automated return-to-home functions. Ensure these are aligned with CAP 722 requirements.

5. Flight Planning and Airspace Management

Demonstrate compliance with UK airspace rules, including segregation or integration into controlled airspace where necessary. Pre-flight planning should incorporate geospatial awareness and NOTAM checks.

6. Operator Competency and Training

Operators must hold the necessary qualifications (e.g., a General Visual Line of Sight Certificate [GVC]) and undergo additional BVLOS-specific training to handle the complexities of these operations.

7. Documentation and Record-Keeping

Maintain detailed records of all operational plans, risk assessments, and flight logs. This documentation supports compliance checks and demonstrates a commitment to ongoing safety management.

Compliance and the Future of BVLOS in the UK

The CAA’s emphasis on safety and risk management ensures that BVLOS operations are conducted responsibly. While CAP 3038 provides overarching considerations, CAP 722 and the requirements of UK Regulation (EU) 2019/947 form the backbone of the approval process. A well-prepared safety case that addresses all risks comprehensively is critical to gaining authorisation for BVLOS operations.

By adhering to established methodologies and focusing on safety, operators can unlock the full potential of BVLOS technology while maintaining the trust of regulators and the public.

How Drone Docs Can Help Produce a Compliant UAV Operating Safety Case

Producing a compliant UAV Operating Safety Case (OSC) for complex operations like Beyond Visual Line of Sight (BVLOS) can be challenging. One key to ensuring compliance with UK regulatory requirements, such as UK Regulation (EU) 2019/947, is creating a comprehensive and detailed safety case. Drone Docs, a business specialising in safety case development, offers expert services for writing OSC manuals tailored to meet the regulatory standards set by the Civil Aviation Authority (CAA).

Here's how Drone Docs can support UAV operators in producing a compliant and robust safety case for BVLOS operations:

Comprehensive Risk Assessment and Mitigation

A critical component of any safety case is identifying, assessing, and mitigating operational risks. Drone Docs can assist operators by:

• Conducting Thorough Risk Assessments: Drone Docs works with clients to identify potential hazards specific to their UAV operation, such as mid-air collisions, communication failures, or system malfunctions.

• Developing Risk Mitigation Strategies: The team at Drone Docs provides expert guidance on appropriate risk mitigation measures, ensuring that all risks are addressed in line with regulatory requirements.

  
  

Organised Flight and Operational Logs

A safety case requires evidence that the UAV is fit for operation and has a track record of safe performance. Drone Docs helps operators gather and present essential documents such as:

• Flight Logs: Detailed records of previous flights, including key operational data, which demonstrate the UAV’s reliability and airworthiness.

• Maintenance Records: Documentation of regular maintenance and technical checks to ensure the UAV remains in optimal condition.

• Incident Reports: Drone Docs can help operators compile a history of any previous incidents, detailing how they were handled and what steps were taken to prevent future occurrences.

These logs provide the proof needed to show that the operator is committed to safe operations.

UAV Technical Specifications

The safety case must demonstrate that the UAV meets all technical and performance requirements for BVLOS operations. Drone Docs assists in compiling the necessary technical documentation, such as:

• UAV Design and Performance Information: Specifications on drone capabilities, including endurance, payload capacity, and relevant safety features like detect-and-avoid systems.

• Command-and-Control (C2) System Documentation: Evidence that the UAV’s C2 link is reliable, with backups and redundancy built into the system to ensure continuous operation.

• System Testing Records: Drone Docs can help operators compile test data that validates the drone's performance, particularly for BVLOS operations.

These technical documents show that the UAV is capable of meeting the demands of BVLOS operations.

Standard Operating Procedures (SOPs)

For BVLOS operations, a well-defined set of operating procedures is essential. Drone Docs assists clients in writing clear, actionable SOPs, including:

• Pre-Flight and Post-Flight Procedures: Step-by-step instructions for preparing the UAV before each flight, along with post-flight inspection and data management.

• Emergency and Contingency Plans: Drone Docs ensures that operators have well-documented procedures for responding to failures, such as communication loss or system malfunction, including automated return-to-home or emergency landing protocols.

These procedures ensure that operations are conducted safely and in compliance with regulatory expectations.

Operator Training and Competency Documentation

The safety case must show that the remote pilot and crew have the necessary qualifications and skills for BVLOS operations. Drone Docs helps operators by:

• Compiling Training Records: Ensuring that all training, including BVLOS-specific courses, is documented, demonstrating that pilots meet the required competency standards.

• Certifications and Qualifications: Drone Docs ensures that documentation for certifications like the General Visual Line of Sight Certificate (GVC) are properly included in the safety case.

  
  

To find out more you can call us on 01353 880988 or email info@dronedocs.co.uk