Petition EASA Regulations.

[Biggles' Elder Brother - Moderator]

I have no problem with you disagreeing Rich - but I'm not sure exactly what it is you are disagreeing with!

As a general point - if you have Novembers magazine can I suggest you read the piece I wrote on this in there? You will find that it is not really "all about drones" well not in the sense you, ,many others, seem to think! This proposed legislation is not primarily about solving the the renegade drone flyer problem - its about managing commercial U AV operation and integrating it into European airpace in a safe way.

So, let's look at the real reason for this legislation. In 2015 in the so-called "Riga Declaration" - which you can find here - the EU committed itself to being a "world leader" in UAV Technology and even more so in the commercial use of that technology. It sees this as a major wealth and job creation area. But there is a problem; for this to happen they need to clear the skies of possible collision obstructions below 500 feet. EASA have been tasked with solving this problem. One of the biggest users of airspace below 500feet is us model flyers! Now they can't just get rid of us - and I honestly don't think that they want to - so how to deal with this? How can models and autonomous UAVs share the same airspace? The classic solution to problems of this sort has always been segregation - separate the two. And that is what they are attempting to do.

The answer they have come up with is to corral us onto known, well documented, sites and areas. So, if all model flying takes place with registered clubs, at registered sites, then such sites could be documented on aviation maps. Then, when a commercial enterprise is planing an autonomous way-point, GPS navigated, flight they would simply steer around such sites. Simple, you can have model flying and autonomous UAVs sharing the sub 500feet airspace without collisions. Right?

Ah - but, what EASA didn't understand was that a lot of model flying goes on outside of such organised and documentable clubs and sites. That is a problem for them. You see, from their perspective, they simply cannot allow the possibility that Joe Bloggs might decide to fly his model aeroplane in a place the UAV route planner have no idea he will be. That could (eventually would) lead to a collision - at the very least loss of property, more seriously possible injury to people. That cannot be risked and so cannot be allowed to happen.

So, they are going hold out on this issue I'm afraid, they will not give in. Their position will be that all model flying must take place from documeted sites - or it will not happen at all!

In the piece I wrote for the magazine I suggested some solutions to this that might be possible - but they all revolve around registering the activity. Informal flying is dead under this development and keeping it is a battle I fear we cannot win because the whole weight of the relevant commercial interests of the EU (and the UK) and their political wing, are on the other side in the argument. Far better in my view that we put our energies into battles we can win, such as ensuring that any registration is minimal trouble, low maintenance and most of all "light touch", compatible with National Aviation Autorities being content that it is safe to operate models and commercial UAVs in the same airspace level.

Finally - please don't shout at me about this - I may be explaining it but that doesn't mean I agree with it!!! However, I am a realist in terms of protecting as much of our activity - unmolested - as possible and I'm not interested in fighting battles we cannot win or standing on principles and going down in heroic failure!

BEB

Edited By Biggles' Elder Brother - Moderator on 26/11/2016 17:22:32

[Cuban8]

When can we expect to see our airspace chocked full of commercial UAVs, to the extent that there will be a serious risk of collision with model aircraft?
No axe to grind, just wondering.

[GONZO]

BEB, this is always what I thought the reason was - 'to clear the lower (sub 500ft) airspace'. This raises a serious question of why are we being picked out for this persecution, What about hang gliders, para gliders, para motors, micro lights etc and any other forms of foot launched aircraft. I often watch the para gliders soaring the sea wall at Abergele and micro lights/para motors cruising along the North Wales coast. Then there is the not infrequent low flying helicopters. Add into this the fact that it is legal to fly an aircraft at low level as long as you observe the 'every vehicle, vessel, person and structure has a 500ft bubble over them that must not be penetrated' rule. Having flown hang gliders and GA aircraft I think the likelihood of seeing a 'drone' about its business, when you are flying, is remote. In fact on two occasions I've almost been 'taken out' by other 'traffic'. First time when flying at approx. 350ft at Corton on the Norfolk coast by a flight of four F16 jets at my altitude coming from the continent. The second time when flying a GA aircraft in open FIR South of London by another GA aircraft. So, four military pilots did not see several hang gliders all with fluorescent colouring and a pilot plus passenger did not see another GA aircraft. What chance in seeing a drone?

IMO the problem is being approached from the wrong direction. The commercial drones should have active object avoidance systems, like a much improved version on the new DJI Phantom 4 pro.

Edited By GONZO on 26/11/2016 19:55:55

[Rich too]

[Post removed for language]

 

Edited By Rich2 on 26/11/2016 20:07:36

Edited By Biggles' Elder Brother - Moderator on 26/11/2016 20:47:58

[Rich too]

Frankly BEB if that is the problem, the solution you have outlined is ridiculous. commercial use of drones, like Amazon using them for instance has far more serious hurdles to overcome than us model flyers.

 

 

 

 

 

 

Edited By Rich2 on 26/11/2016 20:13:37

Edited By Rich2 on 26/11/2016 20:14:18

Edited By Rich2 on 26/11/2016 20:14:36

Edited By Rich2 on 26/11/2016 20:15:00

[GONZO]

I hazard to say this on this forum, but, I feel such a sense of injustice over this that I would have no hesitation in deliberately bringing down (in a safe area) one of these accursed commercial drones. I doubt I am alone in this attitude.

[Martin Harris - Moderator]

I can't condone that - but I would certainly report any drone that I thought was causing a potential hazard,

[Erfolg]

I had similar thoughts to BEB, in that it is apparent that errant drones are not what this is all about.

I also can see Gonzos and others points. There are an awful lot of other objects in the sky below 500 or whatever feet,

Allowing commercial drones to occupy this presently free space as autonomous or control from significant distance, is in some ways is a general drift that seems to be towards the very way of operating, that authorities have got hot under the collar about, recently, that it is when it is modellers. That is operating out of the line of sight, or the extreme limits of sight.

I can see that autonomous drones would and will work in remote parts of the world (which are rapidly disappearing) or along specific designated routes for the specific vehicle, such as when surveying a electrical overhead power line, or a rail track, when no rail vehicles are scheduled. Yet any thing loser in operation, would be diametrically opposed to the operation of drones of modellers who have been subjected to criticism and have been prosecuted.

The designation of what constitutes a club and specifically the volume of a site could all become significant issues in the future. A real problem could well be that we will be charged to define our site and clubs, and be priced out of existence, in a similar way that ordinary people were during the implementation of the enclosure act. All so that some can become richer.

Edited By Erfolg on 26/11/2016 20:33:05

[ChrisB]

As I and others have said in the past. The likelihood of swarms of 'drones' flying in our airspace like birds will never happen.

Yes it will and does happen for limited professional filming. Yes it happens in Afghanistan. Yes it happens for limited emergency service use and for racing etc but that's as far as it will ever go.

The likes of Amazon will never succeed. Why?. Cost, range, weight/size of product, controlled airspace, weather, trees, power lines and the human factors of theft of packages dropped, vandalism and practicality of leaving packages at drop points, in back gardens, front gardens on the roof of a block of flats or the middle of the street etc.

I have spoken with several drone film makers over the years. They are only able to fly..and film for a few days each month due to weather limitations, particularly in windy conditions.

The issue that EASA is aiming to react to and resolve is the recent impact of the Christmas toy brigade causing aggravation not preparing for automated commercialisation of the sky's.

[Biggles' Elder Brother - Moderator]

Posted by Cuban8 on 26/11/2016 19:26:33:

When can we expect to see our airspace chocked full of commercial UAVs, to the extent that there will be a serious risk of collision with model aircraft?
No axe to grind, just wondering.

That is the whole point Cuban - by limiting us to only flying in set areas there will not be collisions. This is exactly what EASA are trying to achive - rightly ir wrongly.

BEB

[Rich too]

Posted by Rich2 on 26/11/2016 20:03:53:

[Post removed for language]

 

Edited By Rich2 on 26/11/2016 20:07:36

Edited By Biggles' Elder Brother - Moderator on 26/11/2016 20:47:58

Really? 

I couldn't write what I was actually thinking!

 

Edited By Rich2 on 26/11/2016 20:54:52

[Rich too]

Posted by Biggles' Elder Brother - Moderator on 26/11/2016 20:49:43:

Posted by Cuban8 on 26/11/2016 19:26:33:

When can we expect to see our airspace chocked full of commercial UAVs, to the extent that there will be a serious risk of collision with model aircraft?
No axe to grind, just wondering.

That is the whole point Cuban - by limiting us to only flying in set areas there will not be collisions. This is exactly what EASA are trying to achive - rightly ir wrongly.

BEB

Ridiculous.

[Biggles' Elder Brother - Moderator]

OK - I understand this makes you angry. But,...

1. We are not being picked on - this legislation would apply to anyone using airspace below 500feet, others are not exempt - e.g. hang gliders will have their issues with this to.

2. All those venting off please think about this,...the more we posture and threaten and suggest that we will break the law, the more irresponsible we look to the regulators. If we convince them that we are knowledgeable and responsible air-users, prepared to take on our role in using airspace safely (which I am 100% sure is the case for the vast majority of us) then it is much more likely it is that any resulting legislation will be very "light touch" on us; because they will trust us - like CAA trusts us. But the more "maverick" and cavalier we come across then the more nervous we make them and nervous airspace regulators tend to be distrustful very very conservative and the result will then be Draconian legislation, every angle covered and major sanctions - "these people need regulating"! So, I would suggest that we refrain from immoderate public comment - as it's very much not in our interest.

BEB

[Rich too]

Posted by Biggles' Elder Brother - Moderator on 26/11/2016 20:49:43:

Posted by Cuban8 on 26/11/2016 19:26:33:

When can we expect to see our airspace chocked full of commercial UAVs, to the extent that there will be a serious risk of collision with model aircraft?
No axe to grind, just wondering.

That is the whole point Cuban - by limiting us to only flying in set areas there will not be collisions. This is exactly what EASA are trying to achive - rightly ir wrongly.

BEB

You know, every time I go flying these days I pray that I don't have a collision with a drone..

[Rich too]

Will kites be exempt?

Perhaps, birds will be required to submit flight plans in future?

[Erfolg]

Yet the solution is for a non issue. We (modellers) do not have collisions, with other non club members.

I remain suspicious that this is really all about creating a commercial drone service industry and providing an environment for them to operate within.

I have been convinced for some time that much that is reported by pilots as near misses with drones, is more often and not Buzzards or Gulls. These stupid birds do not recognise that they have a duty to get out of the way of an aircraft that has invaded their airspace. It may be in their interest to get out of the way, which i think they do when possible, unlike the aircraft which trundles on.

Yet this legislation will not change their habits. They will generally try to avoid a collision, along as it is not a Crow.

[Rich too]

I agree, and control of ALL airspace below 500ft is unworkable - end of.

[Biggles' Elder Brother - Moderator]

Posted by Rich2 on 26/11/2016 20:53:25:

Posted by Biggles' Elder Brother - Moderator on 26/11/2016 20:49:43:

Posted by Cuban8 on 26/11/2016 19:26:33:

When can we expect to see our airspace chocked full of commercial UAVs, to the extent that there will be a serious risk of collision with model aircraft?
No axe to grind, just wondering.

That is the whole point Cuban - by limiting us to only flying in set areas there will not be collisions. This is exactly what EASA are trying to achive - rightly ir wrongly.

BEB

Ridiculous.

As I say - don't shoot the messenger! This doesn't fill me with glee either - and I may share your sense of exasperation - but please remember I'm only telling you what they are doing and what their reasons are.

To be fair EASA would argue to following:

"We have been asked to do this by the democratically elected representatives of the European people - ie the political leaders at the summit at Riga in 2015 (which included the UK). We have been asked to make the air safe for autonomous UAVs to operate, we are just trying to solve a problem and do our job"

If you can think of another way of doing it - well tell EASA - but given their expertise its unlikely we would come up with a radically different solution they haven't thought of!

If, alternatively, you don't want them to do it at all (and frankly its a bit late for that!) then you should tell your politicians because they are the people who commissioned this and initiated it - not EASA who are just trying to make it work.

BEB

[Rich too]

The solution is fairly obvious (kerbing my language). They must develop anti-collision technology, that is the ONLY way I can see it working at all. I don't remember being contacted by the DVLA because google want to develop and use driverless cars and are worried about where I might be driving on any given day..

[Martin Harris - Moderator]

I don't think that's a great analogy - there's no difference between millions of people travelling to work, at work, performing essential tasks and the odd weekend jolly against a few oddballs playing with toy planes then? We were probably seen as a soft target with little commitment - thankfully the powers that be have now been educated that there are hundreds of thousands of serious enthusiasts across Europe who can construct a decent case for their continued existence. I'm very much with BEB on this one - we need to continue to present a well organised and responsible front and make constructive suggestions while proposals are formalised.

Edited By Martin Harris on 26/11/2016 22:01:55

[TigerOC]

There won't be any commercial drone traffic in our area because RAF/ Navy aircraft fly a huge area around us doing training support for army/marines and most of  it is sub-500ft. We have been told to move along on a slope site by marine NCO's a couple of times.

Rob

Edited By TigerOC on 26/11/2016 22:06:25

[Rich too]

Martin, it's not just us with our toy planes, it's everything below 500 ft.

[Martin Harris - Moderator]

Quite so. We all need to act responsibly and together.

[Piers Bowlan]

BEB, thank you for explaining EASA rationale. if you can call it that. I am incredulous if that is what they truly think, that airspace below 500 ft is going to be saturated with autonomous UAVs in the future so they need to clear the airspace of obstructions. Talk about looking for a solution before there is a problem! The most common obstructions are of course aerials, church spires, chimneys, HT pylons/wires and tall buildings. The lower the UAV flies (to land/take off) the more objects that become obstructions. Clearly using GPS mapping the UAVs can be programmed to avoid these things but the data base would be truly vast and need constant updating, no mean feat and at VAST cost.

You say that they think that segregation is the answer to maintaining separation from other users to maintain safety. Certainly commercial traffic and some GA traffic are separated by operating in controlled airspace but what about the open FIR for other users? Within the open FIR, outside of controlled airspace and above 500ft AGL, the primary means of separation is see and avoid. It works! Collisions are rare fortunately and paradoxically the greatest risk lies within an Aerodrome Traffic Zone when aircraft are manoeuvring in the circuit. So business twins, light aircraft, microlights, hot air balloons, para/hang gliders and military aircraft, can all happily co- exist by virtue of keeping a good look out to avoid each other. I suggest that it is a prerequisite that UAVs be able to do the same and that this ability has a far greater priority that trying to ring fence everybody so that there is never a conflict. That is just pie in the sky in my view. Using SSRT and TCAS technology as per heavy commercial traffic, UAVs could easily avoid other UAVs if there was a common standard. However, what about separation from the rest; those that can and do operate below 500ft, and that includes us. If UAVs have an effective and dependable 'see' and avoid system then this ring fencing and segregation will cease to be an issue.

As others have alluded to, what is the probability of a mid-air between a UAV and a model aircraft? For that matter how often do you see a model aircraft unless you are at a model flying site or show? Perhaps that is why EASA didn't appreciate model flying existed as a hobby until it was brought to their attention! At the end of the day it just appears to me to be a load of bureaucracy for bureaucracy's sake.

 

 

 

 

Edited By Piers Bowlan on 27/11/2016 16:58:39

[Frank Skilbeck]

While part of the remit may be to regulate the near ground airspace for commercial UAVs, if you read the prototype regs the other drivers are geofencing and type approval of UAVs above 250g, the driver behind this is to prevent them being flown into full size airspace. Probably driven by the pilots union (and supported by the Daily Mail) seeing more and more recklessly piloted drones flying at high altitude in busy airspace.

I still can't see why they can't fit dash cams to full size aircraft to record what the pilots are seeing then they have positive evidence, I'm also surprised that they haven't caught one of these drone operators yet in view of the large number of incidences in highly populated areas such as London.