Helter Skelter Studios use Drones - Renewing the PfCO (Permission to fly for Commercial Operations) is mandatory and involves a fair amount of work. We thought we'd share the results of our successful renewal because not only is it a lot of work, but it's also expensive. £190 renewal fee, of which only £66 may be returnable if the application is rejected due to significant errors or omissions.

Check the CAA website - They clearly flag the things that will make an application fail. These include having the wrong documents referenced and having the wrong version of the right documents referenced. This means that whereas last year we referenced CAP1687, this has been replaced by CAP1763. Therefore citing CAP1687 is redundant and an automatic fail. The correct version of ANO as of today is 2016, 2019 Amendment. Something that has been tightened up on this year is the content of the Pilots log. It is not enough to record total hours for a mission, the logs need to show the actual flight times - if you change the battery twice, then that means three separate entries in the log.

List of Documents

The complete list of documents that need to be referenced in a PfCO application in August 2019 is

ANO  2019 Revision, 2016

CAP 382 Revision 10 Dec 2016

ECCAIRS  ECCAIRS Portal for incident reporting

CAP 393 Revision 5.6 21/03/19

SI 2019/261 13/03/19

CAP 722 Revision 7 30 July 2019

CAP 1763 Revision 2 28 Feb 2019

Check each and every one of these dates as the CAP documents are 'live' and constantly revised. Also be aware that CAP382, 722 and 1763 are guidance documents which are folded into the ANO at which point they are statute.

Mandatory Inclusion

Ensure that Articles 94, 94(A), 94(B) & 94(G) are inserted in full into the document. Note that articles C, D, E & F do not need to be included until November 2019.

Ensure Article 95 is included in full.


Other things to look out for include terminology

Last year's "Accountable Manager" is this year's "SUA Operator" - make this change everywhere in the document, retaining the words "Accountable Manager" only in the signature.

Last year's "Pilot in Command" or "PiC" becomes "Remote Pilot" or "RP"


Definitions of permissible flights near airports and the requirements for permissions. Particularly important here is the observation that the No Fly Zone is treated as spherical rather than cylindrical, reflecting the fact that at the edges of the existing controlled zones aircraft will, unless they are about to crash, be considerably higher than 400ft.

There is also clarification about the meaning of 400ft - it applies to the earth's surface, not to the roofs of tall buildings. So you can fly 400 ft from the top of a hill, but not 400ft from the top of a skyscraper.


The Operations manual is intended to be a living document and is the go-to document for anyone flying drones for your company. Therefore it makes a lot more sense to update it regularly than to leave it until the last minute!

Dates for the Calendar

November 2019 - wrap ANO Articles C, D, E & F into the document.

30 November 2019 - New laws will require owners of drones weighing 250 grams or more to register with the Civil Aviation Authority ( CAA ) and for drone pilots to take an online safety test to ensure the UK's skies are safe from irresponsible flyers. These requirements will come into force on 30 November 2019.