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Law Commission consultation on aviation autonomy
Closes
20 Jul 2024
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VTOLs
Consultation Question 8: We provisionally propose that a person overseeing a VTOL flying automatically, who monitors its course and is able to intervene and change its course at any time should continue to be classified as a “remote pilot”. Do you agree?
Yes
No
Other
Please expand on your answer below
Consultation Question 9: We provisionally propose that in a commercial air transport operation a remote pilot as defined in the UK UAS Delegated Regulation 2019/945 should have the responsibilities of the commander of an operation within the meaning of the UK Air Operations Regulation 965/2012. Do you agree?
Yes
No
Other
Please expand your answer below
Consultation Question 10: We provisionally propose that the remote pilot of a VTOL should be required to ensure that:
1. the aircraft is airworthy;
2. specified instruments and equipment are installed and operative;
3. the mass of the aircraft and centre of gravity location are such that the flight can be conducted within prescribed limits;
4. all cabin baggage, hold luggage and cargo is properly loaded and secured; and
5. aircraft operating limitations will not be exceeded at any time during flight.
Do you agree?
(Tick all that you agree with)
Please expand on your answer below
Consultation Question 11: We seek views as to whether there are additional operational responsibilities that a remote VTOL pilot should be required to fulfil.
Please share your views below
Consultation Question 12: We provisionally propose that the remote pilot-in-command should be responsible for, amongst other things, ensuring passengers are:
given a safety briefing; and
seated and wear seat belts during take-off and landing.
Do you agree?
Yes
No
Other
Please expand on your answer below
Consultation Question 13: We provisionally propose that air operators (rather than the remote pilot-in-command) should be responsible for preventing passengers from boarding:
who appear drunk or under the influence of drugs; or
whose carriage would, in the view of the operator’s employees, endanger the safety of the aircraft or other passengers.
Do you agree?
Yes
No
Other
Please expand on your answer below
Consultation Question 14: We provisionally propose that the remote pilot-in-command should have the power to take reasonable measures, including authorising the restraint of passengers, as set out in section 94 of the Civil Aviation Act 1982. Do you agree?
Yes
No
Other
Please expand on you answer below
Consultation Question 15: We provisionally propose that a person on board a VTOL aircraft (other than a crew member) should be able to take reasonable measures to protect the safety of the aircraft or of persons or property on board. Do you agree?
Yes
No
Other
Please expand your answer below
Consultation Question 16: We seek views on whether the powers of crew on board a VTOL aircraft should be broadened to reflect those of the pilot-in-command under the Civil Aviation Act 1982 to:
take reasonable measures to protect the safety of the aircraft or persons or property on board;
maintain good order and discipline; or
enable the crew to disembark or deliver a person.
Please share your views below
Consultation Question 17: We provisionally propose that passengers should be able to contact a member of crew at all times during an operation. Do you agree?
Yes
No
Other
Please expand on your answer below
Consultation Question 18: We provisionally propose that it should be a criminal offence for a remote pilot of a VTOL to act in that capacity when their performance is impaired through drink or drugs. Do you agree?
Yes
No
Other
Please expand on your answer below
Consultation Question 19: We provisionally propose that it should be a criminal offence for a person to act as the remote pilot of a VTOL when the level of alcohol in their blood, breath or urine is over a prescribed limit. Do you agree?
Yes
No
Other
Please expand on your answer below
Consultation Question 20: We provisionally propose that the remote pilot should be subject to the reporting obligations currently applicable to pilots under the Air Operations Regulation. Do you agree?
Yes
No
Other
Please expand on your answer below
Consultation Question 21: We provisionally propose that a remotely piloted VTOL should be required to be capable of detecting and recording information relating to accidents and near accidents for the purposes of reporting it. Do you agree?
Yes
No
Other
Please expand on your answer below
Consultation Question 22: We provisionally propose that licences should be required for remote VTOL pilots. So far as appropriate, these should follow the classes and ratings adopted for crewed VTOLs. Do you agree?
Yes
No
Other
Please expand on your answer below
Consultation Question 23: We provisionally propose that operators of remotely piloted VTOL should be certified. Do you agree?
Yes
No
Other
Please expand on your answer below
Consultation Question 24: We provisionally propose that operators of remotely piloted VTOLs should continue to be required to:
(1) have the means necessary for the scale and scope of operations planned;
(2) use only suitably qualified and trained personnel;
(3) implement a management system to ensure safety;
(4) ensure operations only take place in accordance with the operations manual;
(5) establish procedures to minimise the consequences to safe flight operations of disruptive passenger behaviour;
(6) develop and maintain security programmes suitable for the aircraft and type of operation;
(7) have a management system to prevent fatigue.
(8) ensure the continuing airworthiness of the aircraft; and.
(9) establish procedures for any reasonably foreseeable emergency situation.
Do you agree?
(Tick all that you agree with)
Please expand on your answer below
Consultation Question 25: We seek views as to whether there are additional responsibilities that operators of remotely piloted VTOLs should need to fulfil.
Please share your views below
Consultation Question 26: We seek views as to whether the law should permit remote pilots to act as pilot-in-command for more than one VTOL at the same time.
Please share your views below
Consultation Question 27: We seek views on whether there should be an upper limit to the number of VTOLs for which a remote pilot can act as pilot-in-command at the same time.
Please share your views below
Consultation Question 28: We seek views as to what additional safeguards should be introduced for remote pilots piloting multiple VTOLs.
Please share your views below
Consultation Question 29: We seek views as to whether there should be a role for a person supervising the flight of an autonomous passenger-carrying VTOL and acting as a point of contact in relation to it. What powers or responsibilities should such a person have?
Please share your views below
Consultation Question 30: Should the law permit an uncrewed VTOL to transition between remotely piloted and autonomous flight during an operation?
Yes
No
Other
Please expand on your answer below
Consultation Question 31: We seek views as to whether initial airworthiness standards for uncrewed VTOLs should include accessibility standards for persons with disabilities and reduced mobility
Please share your views below
Consultation Question 32: We seek views as to whether the CAA should be able to include accessibility standards within the licences granted to uncrewed VTOL operators.
Please share your views below
Consultation Question 33: We seek consultees’ views on any other issues with the current legal framework as it relates to operations involving remotely piloted and autonomous VTOLs.
Please share your views below
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