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Petition EASA Regulations.


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I'm just going to post the reply I got from Daniel Dalton MEP, my highlighting in bold:

"Dear Mr Cotsford,

Thank you for email dated the 2nd October 2016 regarding the EASA Regulation and its impact on model aircraft flying.

We share your concerns about the over-regulation, and our position is to oppose steps which would place an unjustified burden on model aircraft. We wish to avoid a situation whereby model flying will be dragged into the scope of a regulation designed specifically to safely incorporate drones into airspace.

The negotiations on this matter are ongoing within the Transport committee (TRAN) on this file, and Parliament is unlikely to finalise its position before December, whilst negotiations with the Member States and the Commission could then take most of 2017.

It is likely the amendments they highlight will be incorporated into some sort of compromise package, however we will be doing our best to ensure a good outcome for the model aircraft community, but this will of course be contingent on the priorities of other political groups in the Parliament.

Regarding the prototype rules, we are still studying them in order to assess their impact, but our initial assessment is that they may not pass the subsidiarity test.

If we receive any further information I will be in touch. Furthermore it would useful to contact your local MEPs with your concerns about this issue.

Yours sincerely,

Dan Dalton MEP"

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If the legislation is intended to prevent any form of model aircraft, but most likely camera equipped multirotors, from being used for illegal purposes (such as carrying explosives, dropping contraband into prisons, filming major events or interfering with full size aircraft), then it will fail dismally. These activities are already illegal and prosecutions have happened (albeit not many).

Just because legal use is further regulated, won't stop these illegal activities happening. To quote Manny Williamson, "just because shotguns have to be licensed, doesn't stop people holding up post offices".

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Keith, in case you missed it I'll paste the relevant bit again

"We wish to avoid a situation whereby model flying will be dragged into the scope of a regulation designed specifically to safely incorporate drones into airspace."

It's not about drones flying into prisons, it's commercial pressure to create a framework to allow commercial drones to interact with full-size air traffic.

Edited By Bob Cotsford on 07/10/2016 13:12:15

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I may have missed other posts, so may be repeating others.

We've had a similar response from EASA. To my mind they appear to be aware and willing to listen to our concerns.

Essentially, as I see it, clubs aren't an issue, its 'lone' flyers not flying in a formal/affiliated club.

So those who fly in non club environments may be affected. There is an easy way around this. Firstly if there is a group of you, 5 of you club together, form a 'club' affiliate with the BMFA, pay a nominal subs fee £1 a year and carry on flying on the common land etc

Also an established group of country members who fly at a site that is not affiliated, why not affiliate? Its 20 minutes on the internet in the first year, then after that its easy, job done and you only need to 5 people and away you go.

I know of several clubs that fly in Aerodrome Traffic Zones and operate perfectly well and safely with no issues at all. One is within Birmingham ATZ.

My concern is the 500ft rule? Will this apply to club based flying, or only 'lone' flyers? Gliding will be severely impacted.

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Posted by Bob Cotsford on 07/10/2016 13:09:58:

Keith, in case you missed it I'll paste the relevant bit again

"We wish to avoid a situation whereby model flying will be dragged into the scope of a regulation designed specifically to safely incorporate drones into airspace."

It's not about drones flying into prisons, it's commercial pressure to create a framework to allow commercial drones to interact with full-size air traffic.

Edited By Bob Cotsford on 07/10/2016 13:12:15

I think the incorporating drones bit is about enabling the use of commercial drones for filming and S&R etc. I don't think their thoughts are Amazon etc, as we all know that'll never happen.

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So, a real life situation. A bit off track but a situation that may be experienced by others. A friend of mine lives in the bungalow that his in laws built on their hill farm in North Wales. When his mother in law died most of the farm land went to the rest of the family. Him and his wife inherited the bungalow and a large field at the bottom of the garden. He has two neighbours and many sheep in the other fields. Its a hard to find very narrow single track lane to his house. He flies electric there and I have an open invitation to join him when I choose. It's unlikely that any one else would get an invite and anyhow the drive would not accommodate that many cars. Plus everyone would have to pass his house and walk down his garden to the field, not an option. We are both BMFA members and belong to BMFA affiliated clubs.

The question to the forum is how do you think he/we would fare under the new regs? Or, should we name our wives(non BMFA members) as members of our group and get one other body to make the requisite 5, affiliate and then register the site location?

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Gonzo, I suspect that the registration of sites will not be easy. There will be hoops to jump through and many hurdles to cleanly clear.

One of my concerns it will (that is registration, will) all come at a finacial as well as time cost.

contrary to BEBs position, i suspect that we will become the target of both the commercial world and regulators as nuisances, that is unless as hefty financial cost can be extracted.

At present I am also more than a little worried that the BMFA (upper echelons) will cast us hobbyist aside, if the prize of being the administrator of the commercial operators. I sincerely hope not.

All of us hobby modellers will need to be vigilant in the coming years, to ensure that we are being represented as a single group.

Having also dealt with regulators, across the table. Perhaps more pertinently knowing many in the past as colleague and some as buddies, I know that they are similar to most groups, some are unless some are good. The biggest insight was the revelation that regulators can be Machiavellian, in targeting those who have little to loose by acquiescing, flattering the egos of those who like to feel important, to achieve the position that they desire, Only this week i have seen full scaffolding going up at the cost of approx £400 to undertake a minimal cost flashing repair on a chimney on a semi.

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Having quickly read the proposed regulations, I'm a little confused:

First, they seem to be proposing an unregulated category, and a regulated category of aircraft. Presumably the unregulated category is smaller, lighter, and less "dangerous".

When one gets to the details of the regulated category they talk, on page 15 of 32, of 250g maximum weight and 15m/s maximum speed (about 33mph) for a privately built UAS, but then further down the page they talk about 25kg maximum weight for a tethered aircraft which has no propulsion system. What are they thinking of in the tethered category (a very heavy kite?), and has someone maybe made a typo in the document regarding the weight?

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John, I really hope you are correct. It is this desire to represent model hot air balloons, the over enthusiastic embrace of Quads, that gives the impression (to me) that the whole of unmanned aerial vehicles is the ambition,is to be the representative body.

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Posted by GONZO on 07/10/2016 19:07:21:

So, a real life situation. A bit off track but a situation that may be experienced by others. A friend of mine lives in the bungalow that his in laws built on their hill farm in North Wales. When his mother in law died most of the farm land went to the rest of the family. Him and his wife inherited the bungalow and a large field at the bottom of the garden. He has two neighbours and many sheep in the other fields. Its a hard to find very narrow single track lane to his house. He flies electric there and I have an open invitation to join him when I choose. It's unlikely that any one else would get an invite and anyhow the drive would not accommodate that many cars. Plus everyone would have to pass his house and walk down his garden to the field, not an option. We are both BMFA members and belong to BMFA affiliated clubs.

The question to the forum is how do you think he/we would fare under the new regs? Or, should we name our wives(non BMFA members) as members of our group and get one other body to make the requisite 5, affiliate and then register the site location?

I'l try to answer this as best I can Gonzo - but please remember two things through out this:

1. Just because I explain it doesn't mean I agree with it, or think its right, or sensible!

2. The answer is based on the assumption that the prototype legislation, as published, becomes law (not likely given the campaigning taking place - altough what we get will probably only be a slightly modified version of what is proposed TBH)

OK - as things stand my understanding is that, in the absence of any action on your behalf, at the end of the transistional period, if you fly from your friend's field you would be breaking the law. Crazy - maybe. But that I think would be the situation. It maybe your friend's land but it is a well established legal fact that you do not own the airspace over your property - the Crown effectively does.

Can you get round this? Yes I think you could by, as you suggest, forming a club and getting yourselves registered along with your site. You mention becoming a BMFA Affiliated club - I could be wrong, but I don't think that the BMFA affiliation is essential. The prototype legislation talks of clubs - but isn't very specific about the nature of the club. My feeling is that as long as you could establish that you were a properly constituted club, with articles of association, a constitution and pukka membership list with signed up members that might be enough. Moving on from what we have concrete proposals on and speculating a little - it is very likely that the CAA would be given the task of registering clubs. In turn it could very well delegate that task to BMFA. That being the case being a BMFA affiliated club may make registration simpler even if it isn't essential. But this of course is only speculation.

One last point bear in mind club registration is very unlikely to be free! If its run by CAA be prepared for hefty fee, if by BMFA it could be more moderate - at least for affiliated clubs!

BEB

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Posted by GONZO on 07/10/2016 19:07:21:

So, a real life situation. A bit off track but a situation that may be experienced by others. A friend of mine lives in the bungalow that his in laws built on their hill farm in North Wales. When his mother in law died most of the farm land went to the rest of the family. Him and his wife inherited the bungalow and a large field at the bottom of the garden. He has two neighbours and many sheep in the other fields. Its a hard to find very narrow single track lane to his house. He flies electric there and I have an open invitation to join him when I choose. It's unlikely that any one else would get an invite and anyhow the drive would not accommodate that many cars. Plus everyone would have to pass his house and walk down his garden to the field, not an option. We are both BMFA members and belong to BMFA affiliated clubs.

The question to the forum is how do you think he/we would fare under the new regs? Or, should we name our wives(non BMFA members) as members of our group and get one other body to make the requisite 5, affiliate and then register the site location?

As the new regs are, if we take the word of the EASA representative replying to those of us who have contacted them with comments, very much a draft to provoke comment and assist them in formulating workable proposals - and their aim is not to affect hobby (sorry Mr. Dilley - their term) flyers in any meaningful way - it seems fairly pointless speculating too much at this point.

Probably best to put our faith in the people already intimately involved in fighting our corner - and support them wherever possible.

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Soo, as an infrequent flyer, BMFA country member and member of a slope soaring club that's sort of based at a landing strip on the edge of Dartmoor and does not insist on flying certificates, who is occasionally flying from a farmer's field with verbal permission granted, about 2 years back, the 'prototype' regs will have me breaking the law pretty much all the time?

I can't find a smiley that shows,"I'm old enough to know what the hell I'm doing and to do it without affecting you or anyone else so bog off and leave me to my own devices"

My bad was to sign the petition in a knee jerk before coming here to read all the sense that's all too obvious. I then realized that I knee jerked to the knee jerk petition against the knee jerk proposed regulations!

I'm hearing faint strains of Mother Brown in the background!

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Just to lighten the thread a little, the issue now seems to have been discussed in a certain bunker in Berlin....smile

Those of you who are aware of the series will know that they are invariably not for those of a sensitive disposition, so follow the link at your own risk!: **LINK**

Pete

ps Blame the other mods for encouraging me...wink 2

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Posted by Pete B - Moderator on 09/10/2016 22:14:23:

Just to lighten the thread a little, the issue now seems to have been discussed in a certain bunker in Berlin....smile

Those of you who are aware of the series will know that they are invariably not for those of a sensitive disposition, so follow the link at your own risk!: **LINK**

Pete

ps Blame the other mods for encouraging me...wink 2

I haven't laughed so much in weeks. Thats absolutely hilarious, love it!!laugh

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Has anyone sent that link to EASA? devil

More seriously, every "drone incident" report I've seen - either real or imaginary - has already involved breaches of the existing ANO. What these clowns imagine more regulation will achieve is beyond me. If its to provide yet another cash cow, then it may be effective. If its to improve safety, it simply won't happen, for all the reasons outlined in this thread. The problem is not regulation. The problem is enforcement. Any law that cannot be enforced brings the whole system into disrepute.

The CAA already delegate a lot of regulatory stuff the the BMFA, because they have more important things to worry about. Whilst I can see the CAA being involved in commercial drone operations, I can't see them wanting to get involved in the hobby / sport side of things. My hope is that they would again delegate hobby / sport registration to the BMFA et al. And if I'm reading the regulations correctly, all that the BMFA would need to do would be to keep a list of flying sites. Chuck and Gonzo would need to notify the BMFA of their existing sites, and have them added to the spreadsheet, and that would be "job done".

I just hope I'm right......

--

Pete

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