Confidential Human Factors
Incident Reporting Programme
The Charity
Aviation
Maritime
GA1371
Initial Report
Until such time as EC provides a practical solution, we [the paragliding/ hang-gliding community] rely on CANP (UK AIP ENR 1.10 Ch 5) to deconflict between military low-flying aircraft and paragliders/ hang-gliders around busy sites. The Military Airspace Management Cell (MAMC) provides this service, which gives us short-notice access to the NOTAM system: generally, the best compromise between an accurate weather forecast and sufficient notification to military crews (by 8pm the night before). A few years ago, the system was expanded, and CANPs now appear as warning NOTAMs, which means they can be seen by civilian pilots as well. By way of background, the BHPA recommended that our sites are not marked on charts because they are inactive most of the time, which can encourage complacency, hence favouring CANP instead.
Some enthusiastic paragliding pilots have developed an online CANP notification tool (CANP for free fliers at https://canp.logans.me.uk/) which makes it very easy to submit a CANP. It’s not compulsory, and there are limitations, but it seems to work pretty well (particularly on a smartphone). The key point is that the tool isn’t essential, it just makes things easy for lazy pilots. CANPs are still pretty easy to submit by old fashioned email; however, we have found that, by making it simple, the tool has encouraged our members to use something that isn’t compulsory. Three clicks, phone number and email, and SUBMIT. The MAMC then provides an acknowledgement email to the initiator. It works really well.
I notice that the British Model Flying Association (BMFA) tend to make block NOTAM bookings for each location – often extending to the maximum 3-month period allowed. I suspect that they have similar weather constraints to ourselves and, that being the case, I suggest that this leads to NOTAM ‘clutter’; arguably one of the reasons for NOTAM incursions. BMFA members are perfectly entitled to use CANP, but use block NOTAMs instead. I suggest that we could promote the use of CANP by the model aircraft community (both the BMFA and the Large Model Aircraft Association (LMAA)) using the paragliding CANP tool in an attempt to minimise block NOTAMs.
One bonus is that the utility publishes existing notifications and filters out duplication, thus reducing the workload for MAMC. We’ve also found the historical usage by site, club and month to be really useful. The one fly in the ointment is that neither MAMC nor CAA AR Ops is open over the weekend, so notifications for a Monday have to be submitted several days in advance, without access to an accurate weather forecast.
The tool’s author has offered the code (and probably some advice) for free. If the BMFA or LMAA choose to use it for their own purposes, then there would be work involved in loading the database with all their clubs and sites.
Military Airspace Management Cell (MAMC) Comment
We currently receive CANP requests via email; the tool used by users inputs their data on their application and generates the request to us in the form of an email. We then promulgate an H-series NOTAM for the request. But we would only do this for drones/models etc operating visual line of sight and up to a max altitude of 400ft AGL. Anything beyond 400ft AGL is processed by AR Ops at the CAA. Their procedure for Airspace Co-ordination and Obstacle Management (of drones above 400ft and other activity categories) is at link https://applications.caa.co.uk/CAAPortal/servlet/SmartForm.html?formCode=BAL).
British Model Flying Association (BMFA) Comment
We do refer members to use CANP and include some guidance in our Members’ Handbook at https://handbook.bmfa.uk/9-the-bmfa-guidelines-and-safety-codes-for-model-flying (see section 9.5). It is also set out within UK Regulation (EU) 2019/947 ‘UAS Regulation’ (https://regulatorylibrary.caa.co.uk/2019-947-pdf/PDF.pdf). We could very easily create a portal (similar to the BHPA’s) which would fire off a notification to MAMC (we created a similar system for Occurrence Reports which automatically sends them to AAIB, CAA and CHIRP). We’d like to make these additional points though:
- We have 800+ clubs who are all permitted to operate model aircraft <7.5Kg within VLOS at altitudes > 400ft agl.
- We have no permissions to operate multi-rotor drones above 400ft or any mechanism to permit them in any circumstances.
- It is only those clubs operating aircraft >7.5Kg at altitudes >400ft agl that require a BMFA Site Permit which, to be enabled, requires an airspace notification. UK Regulation (EU) 2019/947 states that the ‘primary means of notification is via a NOTAM’, so at present that’s what we’re stuck with.
- We do have some sites with a permanent listing in the AIP, but in practical terms this does not give the same level of visibility as a NOTAM.
We agree that NOTAMs are less than ideal for our purposes, but at present it seems to be what we’re stuck with as it’s something that all airspace communities utilise. A system similar to the BHPA CANP process but which notifies all airspace users would certainly be of interest to us.
CHIRP Comment
The reporter’s suggestion of using the BHPA’s CANP app (or similar) for model aircraft flying would appear at first thought to have considerable merit. Although many such flights may not require formal notification, if the system was sufficiently easy to use and undemanding in application, then the increased awareness of model aircraft flying at BMFA and LMAA sites would potentially be of benefit to all. However, there are practical limitations in the potential numbers of such flights and the resources required to translate the CANP notifications into H-series NOTAMs. If the suggestion was taken up then it will probably be important at least initially to limit the associated CANPs to those activities above 400ft so as not to flood the CANP/NOTAM system with numerous entries for relatively frequent below-400ft activities that would not be so relevant to GA generally flying above 500ft.
Ultimately, using the new CANP/NOTAM approach would make any such NOTAMs more time-relevant, specific and hopefully encourage better NOTAMs to be submitted through a more user-friendly application. As the reporter states, in order to use the new app, the BMFA would have to upload their flying sites, but this was not thought to be an insurmountable issue.
Finally, rather than involve MAMC in translating CANP into H-series NOTAMs, an automated system would have great utility that could also extend beyond weekday-only NOTAM generation. Constraining the CANP app to defined outputs would probably be required in order to prevent spurious CANP entries being input in error and then being rejected by the automated NOTAM generator. There would also need to be some form of validation of user to ensure cyber security and prevent attacks.
UK Regulation (EU) 2019/947 ‘UAS Regulation’ (https://regulatorylibrary.caa.co.uk/2019-947-pdf/PDF.pdf), Appendix A – Article 16, GM1 Article 16(1) UAS Operations in the Framework of Model Aircraft Clubs and Associations, states:
NOTIFICATION OF MODEL AIRCRAFT ACTIVITY TO OTHER AIRSPACE USERS
Consideration should be given to the need to notify other airspace users of model aircraft activity, when operating within the terms of an Article 16 authorisation. This should be identified at the time of application, during the risk assessment process.
Generally, this includes when operating above 400ft AGL as part of a display, or when operating a large model aircraft above 400ft.
Model aircraft operating within an aerodrome FRZ may be notified to other airspace users, via a NOTAM. This is at the discretion of the aerodrome ATS unit, and the recommendations set out in AIP section ENR 1.1 – 4.1.8.13.
Generally, a VLOS [Visual Line of Sight] operation of a model aircraft does not require notification when above 400ft, when stated within the terms of the Article 16 authorisation and when outside controlled airspace.
The primary means of notification is via a NOTAM. A NOTAM highlights important operational information to pilots, which is checked as part of the brief before departure. NOTAMs are issued by the NOTAM office at NATS, and can be arranged by the CAA, individual operators, aerodromes or other agencies as necessary.
A NOTAM should be used to highlight unusual model aircraft activity to other pilots for awareness. This includes displays above 400ft, large model aircraft operating above 400ft and in some cases, when operating within an aerodrome FRZ. A NOTAM may be requested via the online form, available from the CAA website, or, for an aerodrome ATZ, by the aerodrome contacting the NOTAM office.
In general, a NOTAM should not be raised for an activity which is also notified within the AIP (section 5.5 (aerial sporting and recreational activities). However, it is acknowledged that some sites in some instances (large display events for example) may need additional notification, in order to improve their visibility to airspace users, particularly the VFR GA community. In this case, a NOTAM in addition to the AIP entry may be requested for ‘an intense area of model aircraft activity’. These should be requested when necessary via the online form, available here.
Key Issues relating to this report
Dirty Dozen Human Factors
The following ‘Dirty Dozen’ Human Factors elements were a key part of the CHIRP discussions about this report and are intended to provide food for thought when considering aspects that might be pertinent in similar circumstances.
- Resources – a suggestion for the use of a simple app for notification of model aircraft flights.
- Awareness – provision of time-relevant, specific model aircraft flight information.
- Communication – better awareness of model aircraft flights by the GA/military community.