This document is published by National Highways.

This document forms part of the works specification. It does not purport to include all the necessary provisions of a contract. Users are responsible for applying all appropriate documents applicable to their contract.

Legislation and guidance applicable to drone platform operation and management are still rapidly evolving. While every effort has been made to ensure that this document is correct, users are reminded to always check that they are complying with the most recent legislation and working to the latest guidance.

This document details requirements that govern the use of unmanned aerial systems, commonly referred to as drones, for / on behalf of the Overseeing Organisation.

The Overseeing Organisations recognise the benefits that using drone platforms can offer, allowing work to be undertaken in safer, smarter, and more efficient ways. With drones being more accessible and widely used throughout the highways (and related) industries, it is critical to ensure their use is safe for everyone.

Uncontrolled drones have the potential to damage infrastructure assets, distract road users, and disrupt other safety-critical airborne and ground-based activities. Whilst all risks associated with their use cannot be eliminated, these should be recognised, assessed, and mitigations and protections planned and implemented.

Accordingly, this document contains requirements that apply to the use of drones, over and above those defined by the regulator, the Civil Aviation Authority.

The assumptions made in GG 101 [Ref 4.N] apply to this document.

1.1 This document shall be applied to the planning and undertaking of all drone activity for / on behalf of the Overseeing Organisation or using Overseeing Organisation property for take off or landing.

NOTE A ‘drone activity’ is any operation that employs a UAS as defined by CAA ANO 2016 UKSI 2016/765 [Ref 1.N]Schedule 1.

1.2 This document shall be implemented forthwith on all schemes involving the use of UAS on the Overseeing Organisations’ motorway and all-purpose trunk roads according to the implementation requirements of  GG 101 [Ref 4.N].

1.2.1 Drone operations are frequently associated with a broad range of highways-related activities, including construction, operation/maintenance, surveying, incident management, and traffic management. Accordingly, the requirements, controls, and processes that apply to those specific activities should be acknowledged by users of this document.

1.3 The requirements contained in GG 101 [Ref 4.N] shall be followed in respect of activities covered by this document.

2.1 Roles and responsibilities shall be agreed for each project, including identification of those responsible and accountable for each activity corresponding to the requirements within this document.

2.1.1 Where present, this should include identification of those responsible and accountable for any additional requirements that apply to the Overseeing Organisation.

4.1 Planning and undertaking operation of drones for / on behalf of the Overseeing Organisation must comply with the CAA legislation regarding regulatory compliance and Operational Authorisation in CAP 1789A [Ref 7.N].

NOTE 1 This refers to the UAS Implementing Regulation, which acts as a summary of the current and applicable regulations across a suite of CAA documents.

NOTE 2 The CAA routinely publish further updates to requirements, guidance, and advice, on what is expected in terms of UAS Operator, remote pilot, and unmanned aircraft observer competency and associated permissions.

4.2 The UAS Operator shall provide evidence that they hold an Operational Authorisation from the CAA to undertake that drone activity.

NOTE Operational Authorisation will vary and can include different categories of activity and classes of drone.

4.5 For all operations within the CAA 'Open' or 'Specific' categories, the UAS Operator shall provide evidence of CAA Operational Authorisation, including:

NOTE Even though a specific category operational authorisation is not required by the CAA for operating certain categories and classes of drone, the Overseeing Organisation's requirement is in addition to CAA requirements.

4.6 The drone operation health and safety documentation shall comply with the construction site health and safety requirements.

4.7 The drone operations plan shall be integrated and compatible with the construction programme of works.

4.8 Where dictated by the operating location and/or class of drone, drone activities must attain the relevant permission/exemption from the CAA.

NOTE Examples of locations that require permission/exemption include airspace that is unsegregated, as per CAA regulation.

4.9 Where interacting with any FRZs imposed by the CAA, drone activities must attain the relevant permission/exemption from the CAA.

NOTE Examples of FRZs include aerospace, airports, airfields, aerodromes, space sites and military facilities.

4.10 The UAS Operator shall identify any FRZs imposed by the CAA.

4.11 Evidence of all relevant permissions/exemptions shall be provided to the Activity Manager.

4.15 Drone activities shall not be conducted so as to create lone working individuals. (See INDG73 [Ref 2.I]for advice).

4.16 Where an unmanned aircraft observer is positioned in physical proximity to the remote pilot, this pairing shall fulfil the requirement to prevent lone working.

4.17 Where remote pilot(s) and unmanned aircraft observer(s) are not positioned in physical proximity, additional individuals shall accompany them to prevent lone working.

5.1 To minimise potential disruption and safety risk, drone equipment shall be selected according to the following principles:

5.2 Drones must display the UAS Operator registration number as required by the CAA.

5.3 If fitted, the ADS-B transponder shall be switched on for all drone activities.

5.4 Drone equipment for each use-case must comply with the legislative requirements defined by the CAA, specifically corresponding the drone equipment (weight, size, payload, flight type, etc.) to the limitations of the relevant CAA operational (sub)category.

NOTE 1 Selecting suitable equipment is a factor for the SRA, and ensuring that equipment is appropriate for the use-case will facilitate both health and safety requirements and ensure that the drone operation delivers its intended outcomes.

NOTE 2 Drones manufactured prior to December 2020 are classed as legacy drones by the CAA. Legacy drones can continue to operate normally until December 2023. After this date new CAA guidance will come into place.

NOTE 3 Prior to December 2022 and subject to weight and/or other variables, a drone activity can fall into the CAA operational subcategory A1, A2, A3 or Specific, and this will dictate the specific cases legacy drones operate in without an operational authorisation. From the 1st January 2023 all new drones have to meet a set of standards that dictate the open categories they can be flown in. Drones classed as C0 or C1 can be flown in the A1 sub-category, C2 can be flown in the A2 sub-category, whilst C3 and C4 can only fly in the A3 sub-category.

6.1 All accidents and serious incidents shall be reported in accordance with GG 128 [Ref 5.N].

6.2 All accidents and serious incidents shall be immediately reported to:

6.3 Accidents and serious incidents must also be reported in accordance with CAA regulations, through the ECCAIRS system (available at www.aviationreporting.eu).

6.4 'Near miss' situations between aircraft where there was a risk to life from a potential collision (an ‘Airprox’ event) shall be reported to UK Airprox Board (using the processes detailed at: http://www.airproxboard.org.uk.).

NOTE CAP 382 [Ref 1.I] provides further guidance for incident reporting to the CAA.

6.5 If any near miss or incident occurs during an operation, all flights related to the operation shall be suspended pending investigation by the Overseeing Organisation and any involved external body (as above).

This document is published by National Highways

This document supersedes CHE 471/20, which is withdrawn.

This document forms part of the works specification. It does not purport to include all the necessary provisions of a contract. Users are responsible for applying all appropriate documents applicable to their contract.

This National Application Annex gives National Highways-specific supplementary requirements for governing the use of unmanned aerial systems, commonly referred to as drones, for or on behalf of the company.

This includes additional requirements that support the implementation of National Highways governance and safety processes, and control or restrict the use of certain drone equipment, techniques, and activities to manage the risk these represent.

The assumptions made in GG 101 [Ref 2.N] apply to this document.

The assumptions made in GG 104 [Ref 4.N] apply to this document.

E/3.1 For each drone activity, a SRA shall first be undertaken, in accordance with GG 104 [Ref 4.N].

E/3.1.1 Competency assessment for those undertaking the SRA (and any associated assistance required) should be sought through the SRRT.

E/3.2 The SRA shall be completed to determine:

E/3.3 The DGH shall act as the primary point of contact regarding the completion and submission of drone activity SRAs.

E/3.4 Activity Managers shall collate and submit the SRA to the DGH.

E/3.5 The DGH shall maintain a repository of information on previous drone activities, to be used as a resource to assist in the selection of the GG 104 [Ref 4.N] categorisation type of an activity in relation to the extent of prior experience and measure of technical and/or technological novelty and/or innovation the activity involves.

E/3.5.1 Activity Managers should access the DGH repository of information on previous drone activities in support of their completion of the GG 104 [Ref 4.N] assessment for drone activity.

NOTE 1 A number of preliminary SRA's are available from the DGH, to inform a variety of drone activities and classes, to assist completion of the required GG 104 [Ref 4.N] risk assessment. These can be used as reference materials, but will require adapting to the drone operation as these do not evaluate the specific operational environment or activities to be undertaken.

NOTE 2 An exemplar GG 104 [Ref 4.N] SRA and example template is available from the DGH via an internal portal page to assist the Activity Manager in the compilation of their site-specific SRA.

NOTE 3 National Highways Activity Managers have access to an internal portal page providing pertinent reference information for drone activities.

E/3.5.2 Activity Managers should direct enquiries through the DGH (drones@nationalhighways.co.uk).

E/3.6 The Activity Manager shall maintain and update the SRA throughout the activity lifespan.

E/3.7 The Activity Manager shall engage the following groups in an escalating sequence, according to the SRA type category:

E/3.8 When informing the DGH about intent to undertake a drone activity, the Activity Manager shall provide the following information:

E/3.9 The Activity Manager shall submit the requested materials to the DGH via their contact inbox (drones@nationalhighways.co.uk).

E/3.19 Immediately before accepted drone activities are undertaken, the Activity Manager shall inform the DGH, confirming the date and time of the activity.

NOTE The SRA includes information on the dates and frequencies of flight (clause 3.8 item #4), however this typically provides a range to work within. Due to the nature of drone operations, some flexibility is required (such as to work around poor visibility or high winds).

E/3.20 Once a drone activity has been undertaken, the Activity Manager shall report back to the DGH, informing them of the completion and providing feedback documentation as requested.

E/4.1 Drone operations in the 'certified' category (as defined by CAP 722 [Ref 3.I]) shall not be undertaken for nor on behalf of National Highways.

E/4.2 Regardless of drone class, and in addition to an approved GG 104 [Ref 4.N]SRA , an approved CAA Operational Safety Case shall be submitted to the DGH and/or escalated for acceptance by the Drone SCRG/NCSRG, where the drone activity requires any of the following:

1. operation within 50 m of involved persons (that is, those under the control of the Activity Manager) or uninvolved persons;
2. operation within 50 m of National Highways property; or,
3. operation above 120 m (from ground level).

NOTE 1 Regarding list items 1 & 2 this distance can be reduced to 30 m during take-off and landing.

NOTE 2 Even though an Operational Safety Case is not required by the CAA for operating certain categories and classes of drone, the National Highways requirement E/4.2 is in addition to CAA requirements.

E/4.5 Where third parties seek permission or inform National Highways of their intention to operate within the vicinity of the network, they shall be referred to the DGH via the Drones email Inbox (drones@nationalhighways.co.uk).

E/4.6 The DGH shall collate and store records of all reported third-party flights in the vicinity of the network.

NOTE These records contribute to future agreements between National Highways and third parties to operate drones in the vicinity of the network, and can be referenced by the DGH, Drone SCRG and NSCRG during the SRA process.

E/4.7 All drone operations shall be limited to either:

E/4.8 BVLOS drone operations, that is those where direct, unaided, visual observation of the drone is not maintained by the remote pilot and/or the unmanned aircraft observer(s), shall not be undertaken.

NOTE Operating drones within confined spaces (such as the interior of a building, structure, or culvert) is not considered to be a BVLOS operation, as these operations are not within a defined airspace.

E/5.1 Drone swarms (multiple drones not controlled independently of one another) shall not be used when undertaking activity for / on behalf of National Highways.

E/6.1 The DGH shall act as the point of contact for the reporting of all accidents and serious incidents to National Highways.

E/6.2 The DGH shall maintain a log of drone-related incidents.

E/6.3 Activity Managers shall liaise with the DGH to access and update this log.

E/6.4 All incidents and near misses shall be reported to National Highways via HART in accordance with DMRB. GG 128 [Ref 3.N]. and in addition also notified directly to DGH within one day of the incident occurring.

E/6.5 Where drone operations are halted or restricted in relation to an incident, the SRA shall be reassessed to establish approval to proceed.

E/6.5.1 National Highways may implement additional restrictions on approving SRAs and/or revoke existing SRAs for drone activity, in response to an incident. This can include:

NOTE Restrictions are generally intended to be temporary, and can be lifted once any incident and subsequent investigation is resolved - e.g. when sufficient evidence is provided to assure National Highways (and the wider industry) that the cause of the incident in question does not represent an ongoing risk.

E/6.6 The Activity Manager shall be the point of contact to initiate the reassessment process.

E/7.1 All planning and undertaking of drone activities shall take account of and comply with National Highways data retention policies.

NOTE Refer to National Highways Records retention & disposal schedule NHRR [Ref 2.I] for information.