The Civil Aviation Authority (CAA) has formally opened a public consultation on the Ministry of Defence (MoD) proposal to change airspace regulations around RAF Waddington to allow armed Protector drones to operate from the base from 2023. In short, these changes will put in place a ‘danger area’ around Waddington to allow the drones to take-off and land.
Currently the UK’s fleet of armed Reaper drones are not permitted to fly within the UK as they were not built to appropriate standards. However the MoD argues that its new drone – called SkyGuardian by the manufacturer but labelled ‘Protector’ by the MoD – has been built to stricter construction standards that should allow it to be certified to fly within UK airspace. Separate from the construction issue is the very significant question as to whether large drones (military or otherwise) can fly safely in airspace alongside other aircraft. Drone advocates argue this can be done though using electronic ‘Detect and Avoid’ (DAA) equipment but this is as yet largely untried and untested.
While this consultation is therefore limited in that it is focuses only on specific airspace changes around Waddington rather than wider questions about the safety of opening UK airspace to large drones, we would urge those concerned about these developments to respond via the dedicated webpage. All members of the public are invited to respond and it should only take a few minutes. The consultation is open until 30 November.
Filling in the response form is slightly complication, not least as the MoD have folded in a consultation on the Red Arrows (RAF Aerobatic Team) moving from RAF Scampton to RAF Waddington. Here’s a short guide that should help:
- Questions 1-7 ask for information about the responder and are fairly straight forward.
- Question 8 asks if you support or oppose the Airspace Change Proposal. We would urge you to oppose the change.
- Questions 9 – 11 ask about different aspects of the air change proposal and to position yourself on a scale of support or objection– again we would urge you to object.
- Questions 12-13 ask for you to explain you support or objection. Here you can add your reason for objecting. See below for some thoughts which you may want to copy or put into your own words.
- Questions 14-15 ask if you have any other contributions to make.
There are several documents that have been put together by the Ministry of Defence as part of the consultation including ‘Enabling RPAS and RAF Aerobatic Team Operations Out of RAF Waddington’ and ‘Frequently Asked Questions’.
“If you oppose this proposal, please explain why”
In answer to this question you may want to say something like:
- I object to this proposal as I believe it will endanger airspace users, those living and working in the immediate vicinity of RAF Waddington and those beyond. Remotely controlled aircraft are dangerous and evidence shows that they are particularly prone to accident during take-off and landing. RAF Waddington is surrounded by housing, local businesses, a major road and a school. It seems an unnecessary risk for this significant change – which for the very first time allows large uncrewed aircraft to operate beyond visual line of sight on a regular basis – to be based in a populated area.
- I also object as this change will enable large remotely controlled drones to fly within the UK before safety measures – such as properly tested and approved ‘Detect and Avoid’ equipment – are in place. According to the consultation documents it is only a “working assumption” that DAA equipment will enable Protector to fly within Classes A and C airspace without restriction. At the same time, the consultation document makes clear that a proper and satisfactory argument that Protector can operate safely within the TRA has yet to be made by the Ministry of Defence.
- Separately, the Ministry of Defence have also made clear that they intend to open a training hub at RAF Waddington both for RAF crews to train on Protector but also for other international militaries to train to use similar uncrewed aircraft. While the consultation documentation suggests that Protector flights will initially be limited – with 1 or 2 aircraft in the air at any one time up to 3 times per week – this is clearly intended to grow and this will inevitably increase the safety risk.
- Finally, I also object to this change as it will allow large remotely controlled drones to fly within the UK on a regular basis without proper national debate about the use of these systems or assessment of the wider risks of opening UK skies to BVLOS drones.
To give your view to the CAA on this matter click here
If you receive a specific response to your submission, or are contacted about it in any way, please do contact us. Thank you.
For further reading see our detailed briefing (left) and short factsheet (right) on Protector – click images to open.