Open Letter to the UK CAA – sUAS Information

Pricey Mr Bishton,

Do I’ve dementia? I ask as a result of on Friday the thirteenth the RPAS staff did not renew my firm’s Operational Authorisation for Drone Mild Exhibits, owing to a discovering, wherein they claimed, “We should not have assurance that you’re of appropriate competence to carry the position of Accountable Supervisor”. Now, as this was the second renewal of this Operational Authorisation they usually had no issues relating to my competence on earlier renewals, both they had been incompetent to challenge me with Operational Authorisation within the first place, or I’ve developed a nuero degenerative illness over the past 12 months with out my noticing.

The RPAS unit have obvious issues over my competency as they declare that I’ve not offered them with flight particulars for the Morecambe Bay Medical Shuttle, one of many 17 Future Flight Problem Part 3 initiatives that the Industrial Technique Problem Fund paid the CAA thousands and thousands to help, however in our case, as a result of I beforehand submitted a criticism (22/167) you didn’t help.

On August tenth 2023, Piers Gow from RPAS, reasonably than exhibiting any skilled courtesy by contacting a member of Electrical Aviation Restricted, referred to as our NHS accomplice’s switchboard and requested to talk to the “Drone mission supervisor”. A letter threatening “escalation” adopted based mostly on the wrong assumptions Mr Gow had made about our flights, while speaking to a clinician with no expertise of working drones. This was “Tortious Interference” and had the impact of terminating all flights from the Hospitals round Morecambe Bay. On the seventeenth of August, 2023, our legal professionals wrote to the Workplace of Normal Counsel asking for a proof as to Mr Gow’s actions and talked about that the CAA could have breached part 23 of the Civil Aviation Act. Throughout this letter it was mooted that I “could also be topic to destructive remedy by the CAA”. 484 days later, our legal professionals are nonetheless awaiting a proper response.

The Morecambe Bay mission closed in March 2024 and following the publication of the DfT’s Future Flight Motion plan, we took the choice to shut Electrical Aviation Restricted, as there was no means to supply any type of industrial service for an additional three years, owing to the CAA’s excellent tempo of innovation. On the fifth of April 2024, Callum Holland (RPAS Sector Lead) emailed me stating, “Myself and Kevin wish to have an off-the-cuff dialog with you to speak about your ambitions on this area.” I responded absolutely and answered any questions that the Head of RPAS and the Sector Lead could have had about our Morecambe Bay operations. On the seventeenth of June, 2024, we made the voluntary software at Firms Home to strike Electrical Aviation Restricted off and accordingly the corporate was struck off the register on the third of September.

On the fifth of September 2024, Philip Lockey (additionally claiming to be RPAS Sector Lead) despatched an e mail to my private e mail handle requesting for Particular Class operations, Flight logs, Incident logs, Website Surveys and Plane Telemetry. That is ironic, as there have been no flights throughout the time interval requested, owing to the tortious interference, by the RPAS staff in August 2023, that had halted Particular class flights. We commenced a criticism for using my private e mail handle, as certainly the right kind would have been to e mail the handle offered on the PDRA01 certificates for Particular class operations? Extra importantly our authorized counsel wrote to the RPAS staff and OGC, knowledgeable them that each one communications have to be routed by means of their workplace and that the corporate not existed. Sadly and discourtesly, to this date, but once more, no response has been recived.

Regardless of receiving authorized counsel notification, RPAS continued to ship emails to my private handle. A observe up was obtained on the tenth of October and on the seventeenth of October 2024, Mr Lockey, this time knowledgeable us: “that failure to supply entry to an authorised individual in accordance with UAS.SPEC.090 is a legal offence liable to prosecution beneath the Air Navigation Order 2016 and do you have to fail to supply me entry to stated paperwork the CAA could think about prosecuting you for this offence.” His use of the phrases “present me” means that Mr Lockey is writing beneath his private motivation, receiving no authorized steerage and that maybe RPAS threaten Prison Prosecution, with out, satirically, following any type of Normal Working Proceedure.

Half 37 of the Firms Act 2006, part 1140, “Service of paperwork on administrators, secretaries and others”, clearly states in paragraph 1: “A doc could also be served on an individual to whom this part applies by leaving it at, or sending it by put up to, the individual’s registered handle.” No provision is given for the service of paperwork by sending requests to administrators’ private e mail addresses. On the seventh of November, Kevin Woolsey, Head of RPAS, as soon as once more, breached skilled etiquette and despatched to my private e mail, cc-ing in our authorized counsel, a letter which confirmed that the CAA weren’t prosecuting me beneath Article 265A (3) & (6)(d)(vii) of the Air Navigation Order 2016. He continued: “Your failure to supply entry to the requested materials fails to guarantee the CAA that you’re an accountable individual. This strategy of failing to have interaction with the regulator in assembly one’s statutory necessities inside the UAS framework leaves a query over whether or not the CAA can fulfill itself that it’s Article 12 of UK Regulation (EU) 2019/947 obligations may be met nor whether or not any future operations might be absolutely complied with.”

Firstly, there have been no qualifying flights within the time interval requested. Subsequent, technically the requests had been by no means made, and eventually, our authorized counsel wrote to Kevin’s staff informing them interact with us, which they did not do. Kevin now believes that I’m not “of appropriate competence to carry the position of Accountable Supervisor” for a completely separate and unconnected authorized entity, Electrical Airshows Restricted. This has the impact that my firm must cancel reveals and commercially let clients down and as such our place is reserved.

On Friday thirteenth December, my legal professionals issued discover that we require a evaluation beneath Regulation 6 of the RPAS resolution making course of. We request that the Regulation 6 listening to be made public and dwell streamed.

I fully perceive the necessity for efficient regulation, particularly on a brand new and upcoming, technically superior business sectors equivalent to UAS, however the lack of professionalism proven by the RPAS unit leaves me with grave issues. The behaviour of the CAA, since my criticism again in 2022 has lead me to query if article 1(3)(c) of the Safety from Harassment Act 1997 has been breached.

Please might you ask that OGC present full responses to all overdue authorized correspondence, and in mild of the entire above, might you affirm that you just consider Kevin, is actually, an Accountable Supervisor?

Lastly, might you please ask your employees to discover ways to spell Morecambe.

With the compliments of the season.

Dr Chris Crockford.

Associated