EASA NPA 2017-05

[Former Member]

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[MattyB]

Hmmm, plenty of nasties still in there - looks like registration of operators and models for the vast majority of us, 120m height limitations and the addition of technical height limiters and geofencing in certain situations.

I've not been able to get to the bit where exceptions granted by overseeing authorities are detailed. However it's obvious that (as many suspected) users of public sites are going to have major issues unless their model is below 250g. Slope soaring in particular looks difficult to do legally given the expectation (pg15) that traditional models >250g can only be flown "...in an area where it is reasonably expected that no uninvolved person will be present". In addition privately built models in without all the fancy tech can only be flown "a safe distance from the boundaries of congested areas of cities, towns or settlements, or aerodromes" . Fly anywhere near an uninvolved person with a model between 900g and 4kg and you need geofencing - how the heck does that work on an unpowered glider!

[Former Member]

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[Frank Skilbeck]

Posted by Steve J on 05/05/2017 18:26:20:

Anyway, the way things are going, is the UK going to be a member of EASA in two years? A month ago I would have said yes, now I am not too sure.

Steve

There's a few countries that aren't in the EU that are in EASA, probably depends if we want our airlines to fly in and out of Europe to a common set of rules.

[MattyB]

The requirements to be a competent authority appear significant and complex (registration of operators and UAs, audit and oversight of operators, granting and oversight of the operational authorisations etc.). That is far more than the BMFA and LMA do now to oversee their members. IMO they will need a fair bit more manpower and far more advanced IT systems to do the job. Meeting those requirements is not going to be cheap or simple for the BMFA.

Also worrying are the additional requirements on clubs to provide training and oversight of members. It is hard enough to get volunteers for committee positions as it is without all this red tape and a potential threat of being held liable if your paperwork or oversight procedures are deemed insufficient. This could really affect (legal) participation the hobby very significantly.

[Former Member]

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[ChrisB]

Having read the document I don't think it'll be as bad as originally thought. Some changes have been made to the initial publication as a result of OUR feedback.

Most clubs provide training or supervision up to 'A' standard. Oversight is done naturally by members in clubs and many clubs operate an induction and training programme. Ours consists of an induction form that takes a few minutes to go through and flight training to 'A' standard which could, in theory be documented quite easily. It'll never catch or stop all transgressions but it happens now anyway for the most part. if registration of every aircraft is required then good luck to EASA, they won't know what has hit them. The spreadsheet will be immense and the work will be unrealistic, as many models are sold, modified, crashed and re-built or disposed of. What additional resources will be given to the BMFA et.al. to address this?

MattyB

traditional models >250g can only be flown "...in an area where it is reasonably expected that no uninvolved person will be present".

What does "reasonably expected" mean?

In addition privately built models in without all the fancy tech can only be flown "a safe distance from the boundaries of congested areas of cities, towns or settlements, or aerodromes"

The above is less robust than the current regs. What is a "safe distance", "boundary of a congested area"?? At present there are defined distances and I don't think this will stack up in the long term unless more meat is added to the bones.

The consultation on the amendments commences on the 12th of this month.

I think the key issue is Slope Soaring and gliding. However, if there are regular participants at a site, then form a club and get around some of the issues. As for not flying near un-involved people, that will not be enforceable and will, in theory, affect all clubs, national associations and commercial UAV operators, hence the "reasonably expected" point.

It'll be at least another year before anything is implemented and then there will be a period of implementation and then they'll iron out the creases after that.

I work in Local Government and occasionally speak to government departments. I recently spoke to someone in a government department who has been charged with writing a new policy document. They told me informally that the idea had been developed by ministers and they, the civil servants, had been told to make it work. They suggested that they had made it work as requested but there was more work to do and they hope to issue further guidance in due course. The basic premise was, 'we'll think of something at some point, when we know, you'll know'. The people in EASA are in exactly the same position. They are trying to make work, the wishes of those higher up the chain so don't be too hard on them.

[Piers Bowlan]

I agree Chris, the key issue is slope soaring and gliding. I fly predominately gliders from the South Downs, some of the slopes I use are only a short walk from my house and are easily accessible from the South Downs Way (a 160k public footpath and bridleway). I have been doing this for the last thirty years without incident, complaint or challenged by local land owners. Forming a club would change the informal nature of this activity. Negotiations would have to be entered into with local landowners and not least, the South Downs National Parks Authority which would, I fear, have as much chance of getting a positive outcome as our forth-coming brexit negotiations!

These regulations are aimed fairly and squarely at consumer multi-rotor drones and are wholly inappropriate for RC slope soaring.

 

 

 

 

Edited By Piers Bowlan on 06/05/2017 12:14:58

[ChrisB]

Piers, If you didn't respond to the consultation last time around, I definitely would this time. Make the points about what you've been doing for the last thirty years and that there has never been incident or conflict with other users, in the air or on the ground and that this has all been done on an informal, non club environment. The other key thing to mention is heights. Sloping and gliding require height of above 400ft in order to be viable activities.

 

Several of the discussion points in the document refer to CE marks and manufacturers instructions on aircraft in a way that suggests that this whole thing is aimed at 'drones' that are ready to go, a bit like the DJI and Husban types.

 

Consultation 12th May to August 2017.

Cheers

CB

Edited By ChrisB on 06/05/2017 18:59:25

[Former Member]

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[Former Member]

[This posting has been removed]

[ChrisB]

The document clearly says that they have tried to separate model aircraft from 'drones' but they can't find a satisfactory way of doing it, so they kept model aircraft in.

All good fun!

[XK50]

I was given a good dose of general anaesthetic, a week ago, so maybe my comprehension is still affected, but have you noticed that:

• The proposed registrations and competences (we guess like our A/B tests) are to be good only for 3 (maybe 5) years? That should keep the examiners busy!
• The pilot's age is now a factor; initially for youngsters below 16 it would seem, but how long will it be before someone suggests people over 70 (like me!) should hang up their transmitters? (As has been done in the UK, recently, for drivers)
• Geofencing? Identification systems? No more receivers for me, until all this is incorporated!
• All flights to be logged

I am reminded that during the 1930s, Stalin decreed that you couldn't buy a camera in the USSR, unless you were a member of a photographic club - in which, your snaps were limited to approved subjects only. Did wonders for the photographic industry. Not!

Re my earlier thread, what price 250g, now!

John

 

[ChrisB]

Posted by XK50 on 06/05/2017 23:03:16:

I was given a good dose of general anaesthetic, a week ago, so maybe my comprehension is still affected, but have you noticed that:

 

• The proposed registrations and competences (we guess like our A/B tests) are to be good only for 3 (maybe 5) years? That should keep the examiners busy!
• The pilot's age is now a factor; initially for youngsters below 16 it would seem, but how long will it be before someone suggests people over 70 (like me!) should hang up their transmitters? (As has been done in the UK, recently, for drivers)
• Geofencing? Identification systems? No more receivers for me, until all this is incorporated!
• All flights to be logged

 

I am reminded that during the 1930s, Stalin decreed that you couldn't buy a camera in the USSR, unless you were a member of a photographic club - in which, your snaps were limited to approved subjects only. Did wonders for the photographic industry. Not!

 

Re my earlier thread, what price 250g, now!

 

John

 

John, i'm not sure you've read much of the above correctly. There has been talk of registration of aircraft to last for 5 years before they need re-registering. I've not read anything about compulsory 'testing' of pilots, other than those who fly for commercial gain or reward.There is no restriction on age of any kind. Much of the logging and geo-fencing is related to drones (it refers to hovering on several occasions and the diagrams look like quadcopters. You can't geo-fence, for example, a scale model like a Tiggie or Spitfre, its completely impossible, as although the technology is there, the aero-dynamics and propulsion system won't allow for it, unlike a multi-rota that can go to the hover very quickly.

Fear not John, all will be well.

Edited By ChrisB on 07/05/2017 21:39:59

[Former Member]

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[Piers Bowlan]

Posted by ChrisB on 06/05/2017 18:48:16:

Piers, If you didn't respond to the consultation last time around, I definitely would this time. Make the points about what you've been doing for the last thirty years and that there has never been incident or conflict with other users, in the air or on the ground and that this has all been done on an informal, non club environment. The other key thing to mention is heights. Sloping and gliding require height of above 400ft in order to be viable activities.

Several of the discussion points in the document refer to CE marks and manufacturers instructions on aircraft in a way that suggests that this whole thing is aimed at 'drones' that are ready to go, a bit like the DJI and Husban types.

Consultation 12th May to August 2017.

Cheers

CB

Edited By ChrisB on 06/05/2017 18:59:25

Yes Chris I did respond to the consultation last time round. In fact I also sent twenty emails to various Euro MPs too, for all the good it did. I didn't get a single reply despite what I thought was a calm, considered, rational argument! The email addresses were correct so I have no idea what happened there.

Regarding your comment that slope soaring and gliding require heights of above 400ft, is not strictly correct in my view. Height is elevation above ground level (unlike altitude), and I certainly don't fly 400ft above aground level when slope soaring. I rarely fly above the top of the ridge when SS so I cannot see how it could be a threat to other airspace users. Thermal soaring is a different kettle of fish and a 400ft height restriction would make this activity impossible although it seems that under the new rules different height restrictions may apply for approved clubs in certain locations. The essential thing here is 'approved clubs' operating in certain 'certain locations'. As I see it, slope soaring uses many different locations depending on conditions and I am not just talking about wind direction and speed. I won't use a slope that I find has livestock grazing. I won't use certain slopes at the weekend as nearby footpaths/bridleways are busy with leisure users, walkers, cyclists and horse riders due to nearby car parks. Most hobbies require a certain amount of common sense to be applied, the problem with legislation is that it is inflexible and heavy handed. A sledgehammer to crack a nut so to speak!

Thanks for the dates for the new consultation period Chris. I will certainly respond but I feel that the most impact will be achieved by input from bodies like the BMFA etc. I just hope that they put a word in for the special requirements of gliding (some hope!).

[ChrisB]

Thanks Piers. I think its important that the national associations respond but its equally important that individuals and clubs respond as they are able to give specific examples and anecdotal experiences that perhaps cannot be done by national associations. It's important for everyone who responds to do so in a positive manner and not shout and scream as this will only get people's backs up.
The document says that they received 1000 responses from indivuduals. Bearing in mind this is a European airspace wide consultation 1000 responses from indivuduals and clubs is very poor indeed! To be fair they are civil servants who have been tasked with a job they no nothing about. If we can provide positive responses that get them on our side then that's all we can hope for.
Cheers
CB

[XK50]

Thanks, ChrisB, for your reply. I will take no issue with your comments but let me just misquote John Prescot by saying, "We are all drones, now"!

Would that the lawmakers could understand the shear joy to be found in what we do. I'm not a religious person but the closest I've ever been to being "at one with the infinite" has been whilst slope soaring, in a beautiful location, on an ideal day.

Further, over 44 years, I've found the concentration involve in building and flying slope soarers to be so therapeutic, and so useful in overcoming work and domestic stresses, that an argument might be developed for making kits available on the NHS!

I've witnessed, too, the bonding of father and son through aeromodelling, and the acquisition of many manual and technical skills, so useful in other areas.

And yet, it seems all this is to be threatened by a mentality that says, "Everything is illegal, unless we say it's legal"? Hmm. Sadly, you can't argue with people that don't like "The Common Law" or "Habeas Corpus", either!

For me, the greatest source for ChrisB's optimism should be the ability of the Member State to implement the regulations, with regard to local circumstances. This suggests that the target for lobbying should now be our friends at the CAA. The BMFA (and please use the title "The Society of Model Aeronatical Engineers" when doing this) should give the CAA those arguments needed to help them to help us.

For instance, they might introduce "grandfathered rights" for model aircraft, as exceptions to the main purpose of controlling UAS that "are fitted with a camera and can be controlled remotely or autonomously to hover or to move instantly with 6 degrees of freedom".

Yes, it's going to be alright, I'm sure. I'll just blow the dust of my ukuleles.

John

[ChrisB]

Steve, no where can i find reference to a requirement to pocess an A cert. Or reference to the BMFA, LMA, SAA or RAFMAA.
There is no minimum or maximum age. Under 16 should be 'supervised'.

All will be well, as most of the nuts and bolts will be devolved to the CAA who will, in turn devolve to the relevant associations. As I've said before the key issues are with MR and the height restriction may limit gliding, but again,there is a long way to go yet.

[ChrisB]

Just done another key word search for model. Most of the references refer to delegation to competent authorities I.e the CAA, who will delegate to the national associations. All that will be required are desktop audits of clubs and safety records,incident reporting etc. The CAA will be able to designate certain areas that can be exempt from elements of the regs. There appear to be a lot of flexibility as is the case with high level legislation. It's clear to me that we are not the target in all of this and all the authorities know that.

[MattyB]

I am a little surprised there is nothing on the BMFA news pages regarding this latest document from EASA. Given they have been intimately involved in its creation I would have thought a communication would have been ready to go up the moment it came out? I am very interested to hear whether it will publicised as major improvement or a disappointment compared to v1 that they were not very complimentary about...

[will -0]

I wonder if there is a possiblity of an exemption for unpowered craft (ie gliders) such that they can be flown from unregulated sites more easily. It's fairly clear that in unpowered category would not include all drones that the legislation is targeting.

[Biggles' Elder Brother - Moderator]

Sadly I doubt that very much Wil-O

You have to understand what the primary motivation is here. Contary to what many think this is not about "controlling rogue drones" - that simply isn't not the agenda. It's about controlling and clearing the airspace below 500 feet.

The desire is to be able to operate commercial UAVs in that height band. These would fly beyond LOS under auto-waypoint control. This means they must know that the flight path is clear of any undocumented aircraft obstructions - ie you or me flying a model!

EASA's plan to achieve this (whilst still allowing model flying) is to concentrate all model flying at a relatively small number of well documented sites. This would allow commercial flight planners to avoid those areas when in transit.

To achieve this model flying (powered or otherwise) can only take place in a structured formal arrangement. Sadly ad-hoc flying will simply nopt be allowed under this regime; full stop.

BEB

Edited By Biggles' Elder Brother - Moderator on 09/05/2017 13:14:29

[will -0]

It sounds like in that case a fairly comprehensive exercise of documenting all sites and potential/occasional sites needs to be done including all potentially soarable hills, not just those with clubs.

It'll be a sad day when I'm not allowed to fly a glider off the dunes, particularly if someone's flying a kite on the beach with impunity

[Former Member]

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