Dear NPCC UAS Lead,
Following recent reporting of a police-operated UAS incident (serious injury to a child) and separate references to DFR/BVLOS trials within TDAs, I would be grateful for responses to the following points in the public interest. Please answer for NPCC policy and, where possible, provide force-level data or references to current guidance.
A. Safety governance, State-aircraft status, and “just culture”
- Framework: Under your State-aircraft arrangements, what documented Safety Management System (SMS) and occurrence reporting standards apply to police UAS operations nationwide? Please share the current NPCC UAS safety governance policy (or confirm document titles and locations if public).
- Equivalence: How do you ensure equivalent safety outcomes to the civil regime (had operations fallen under UK-retained Reg. 2019/947/CAP 722)?
- Just culture: What formal just-culture policy protects candid safety reporting while ensuring accountability? How is this implemented and audited across forces?
B. Occurrence reporting & accident investigation
- Mandatory notifications: For public-injury events, which body is notified (AAIB or other competent State-aircraft investigation authority)? What is the trigger threshold and timescale?
- Statistics: In the last 36 months, how many UAS occurrences involving injury or significant property damage were recorded by police forces? Please provide counts by severity, force, and whether a public report/learning bulletin was issued.
- Learning dissemination: What is the process and cadence for publishing anonymised safety lessons to the wider UAS community?
C. The Isle of Sheppey incident (2 August 2025)
- Notifications & preservation: Was the incident notified to the competent accident investigation body? Were raw flight logs, controller logs, and video preserved using a tamper-evident process?
- Causation factors: Did your internal analysis identify technical factors (e.g., geofencing, return-to-home logic, obstacle sensing), human factors (workload, visibility, training), or procedural gaps (site survey, overhead line identification) as causal or contributory?
- Public update: When will you publish a redacted lessons-learned summary covering risk mitigations implemented post-incident?
D. Data integrity, evidence, and misconduct prevention
- Deletion controls: What technical controls prevent operational personnel from deleting or altering mission footage/telemetry (e.g., write-once storage, automatic cloud offload, audit logs)?
- Audit & sanctions: How are audit trails reviewed, and what are the sanction pathways where evidence tampering is suspected?
E. Training, competence, and currency
- Standards: What are the minimum training/competency standards for police UAS pilots/observers, including BVLOS/DFR roles? Please provide the syllabus outline (air law, airspace, HF, emergency procedures, obstacle/power-line hazards).
- Currency checks: What recency and proficiency checks apply (e.g., periodic check rides, scenario-based training, simulator time)?
- Human factors: How is HF/CRM embedded and assessed in line with best practice from NPAS or civil aviation?
F. BVLOS/DFR trials and Temporary Danger Areas (TDAs)
- Legal basis & proportionality: What is the legal basis for the BVLOS/DFR surveillance concept over built-up areas, and how is necessity and proportionality assessed (incl. DPIA and retention periods for collected imagery)?
- Airspace impact: Prior to establishing TDAs (e.g., London, Coventry), what stakeholder consultations were undertaken with other UAS operators and how was economic impact (lost commercial operations) considered and mitigated?
- Deconfliction: What strategic and tactical deconfliction measures (procedural and technical) are used with other airspace users (manned and unmanned) inside/near TDAs?
- Public transparency: Will NPCC publish a public summary of each TDA trial’s safety case, mitigations, performance outcomes, and lessons learned?
G. Equipment, technical mitigations, and insurance
- Technical mitigations: What minimum equipment/automation standards apply (obstacle sensing, power-line awareness tools, geofencing parameters, lost-link logic, conspicuity, remote ID where applicable)?
- Insurance & redress: What public-liability arrangements cover injuries/damages arising from police UAS operations, and how is redress communicated to affected members of the public?
I would welcome a written response within 30 days. If any answers turn on documents not publicly available, please indicate whether they can be shared in redacted form or summarised.
Yours faithfully,
Richard Ryan
Barrister, Mediator & International Arbitrator
+447867807008
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