Clubs in Public Spaces and the New EASA Proposals

[Former Member]

[This posting has been removed]

[Biggles' Elder Brother - Moderator]

Steve,

1. I understand how the BMFA works, thank you.

2. My club is actually legally constituted as a society - just to complicate matters not a club, although it is affliated.

3. I have already stated that I agree BFMA would fit the description, but,...a) there is no guarentee they want to, b) so does my club/society.

4. I am aware of the extract above - as I am of all the others you so diligently post. But, as is often the caae with the extracts you select it avoids rather than answers the question. That extract still does not define what a safe distance is, it just says they recognise its dependent on the performance of the UAV in question. That begs the question, not answers it. Dependent in what manner, to what degree, what is the quantifiable link between performance criteriua and distance - after all my "reasonable view" on that may differ considerably from someone else's with a different experince base. M point here is that a guideline distance - as issued by CAA for the ANO in onnection with VLOS - is needed, but absent.

BEB

Edited By Biggles' Elder Brother - Moderator on 02/06/2017 20:08:16

Edited By Biggles' Elder Brother - Moderator on 02/06/2017 20:09:57

[Biggles' Elder Brother - Moderator]

Posted by Steve J on 02/06/2017 19:34:34:

Posted by Biggles' Elder Brother - Moderator on 02/06/2017 15:25:54:

could argue that BMFA do not "conduct sport or leisure activities" at my flying field - my club however do!

The BMFA fits the definition in the NPA and, assuming that your club is affiliated to the BMFA, everybody who flies at your club is a member of the BMFA.

Steve

Actually Steve, come to think of it, I'm not so sure! The BMFA - as I stated (at least as currently constituted) do bot in any way meaningfully conduct/regulate/control, whatever, flying at my club - affiliated or not. The BMFA Handbook only has the status of guidance - not rules. So they influence - that's all. OK a good influence, yes; but still only influence. The rules we fly under are club rules - as I suggest is the case in nearly every club around the country. To fully satisfy the conditions of the NPA I think the role of BMFA (and hence its constitution) would have to significantly change - which is what I mean when I say "BMFA may not want to". They would go from being a "representative and lobbying body" to being (at least in part) something more approaching a co-ordinating/regulatory/overseeing body. That's a very different role from their present one. Interestingly, it is closer I think to the role the LMA seem to adopt - but that's a side issue for many on here.

But OK - even if you can "shoehorn" them into the "definition" (ha! some definition!) it still doesn't answer my question - just because they could fit the bill doesn't mean that is what EASA intend - ithat would only be speculation. So where's the problem in at least trying to find out what they do actually intend the term to mean - which maybe what you suggest - and it may not.

BEB

[John Bisset]

The comment about EASA, and possibly as a result the CAA, viewing a 'club or association' as something at National level rather than at local level, strikes a chord.

In the gliding movement I believe the CAA tends to talk directly to the national association, the BGA. It does not normally discuss with individual member clubs of the BGA, to the best of my knowledge. In effect they devolve the detail of the management of sailplane flying to the BGA and discuss/agree only the broad issues. If problems arise, it will be to the national association they go first.

I will check that this weekend.

Regards,

John Bisset

[ChrisB]

BEB, you are making far more of this than you need and you're trying to split hairs that don't need splitting. Association/Club/society, its just a name. Many of the questions you have are valid and answers will be forthcoming in due course, others you may never get answers to, certainly not in the short term.

The CAA will not introduce any additional regulation until the EASA regs have been fully ratified, as until then, they are purely draft and the CAA could do work for nothing.

Secondly it is unreasonable to expect specific information like safe distances, from a high level Europe wide document, and for it to apply across the board. It all depends on the local circumstances and for want of a better word, the type of flying machine. That's where national 'bodies' come in and its too early in the process yet.

Broad principles from EASA and specific detail from whatever the CAA/BMFA/LMA/EAS determine in coming years.

I have several questions for EASA, they are contained within my 8 page representation on this specific NPA document and no other, which I'll be making to them and the one I'll be submitting on behalf of my club. In due course the answers will be forthcoming.

The CAA have been our ultimate arbiters for decades, even through some of the worst times when well publicised injuries and deaths have occurred, most of which were in club environments. The ANO, which as we know is the only legislation that governs us, hasn't been radically changed in that time, nor following those sad events. The only recent change has been the inclusion of text about drones. That tells me that the CAA are happy with model aircraft operation, either in a club or otherwise, as if they, weren't things would have changed long since.

Anyway, in the meantime I'm going to enjoy my flying and not worry about it until the document is ratified.

Cheers

CB

[Biggles' Elder Brother - Moderator]

What you have to remember Chris is that we are not all in the same boat! What these distances might turn out to be is vitally important to a club such as the one I belong to. As I have said we do not all fly in rural areas - some of us (many of us?) are in built up areas, in or near the edges of towns and cities. I don't expect a precise answer, but a guideline figure, and an outline of the factors effecting it, is I believe necessary for intelligent and meaningful feedback/consultation. You see, if the distance is of the order of 0.5 to 1km we probably don't have a problem. But if its more like 5km, then I suggest a great many clubs will have a major problem. Is it so unreasonable that, prior to providing consultation feedback, we should seek to know which end of that scale EASA are thinking in terms of? I don't believe it is.

You say club/society/association its all the same - no I don't believe so. If my club has to make an individual submission to, say CAA, and the rules are based around a default of A3 for example, we stand no chance at all of remaining in operation. But if the basis is instead simply BMFA making an assessment, then things are very different. We have been a successful, safe, club operating under BMFA affiliation for a long time - our approval under those rules might be little more than a "rubber stamp" given our track record. So, perhaps you can now see why I am so keen to know.

It could well be that all this will come out fine. Actually, I believe that is most probably the case believe it or not!.And it could be that "club or association" does indeed mean the likes of BMFA - in which case no one will be happier than me. But every one who says those thengs are so at present is only speculating - they don't actually know. But please try to understand that these things are so crucial to a club such as mine, our very existence depends on them, that we cannot leave them to such chance and speculation. If the worse case scenario is in EASA's mind then we must issue a very strong defence now, voicing our objections and evidencing our argument with our track record and current procedures. if we wait until ratification that will be too late - the die will be cast. If however, these things are not in EASA's plans and the distances/rules are fine we will not object to them! Surely it cannot be wrong to at least try to know which is the case?

I certainly don't call this splitting hairs - and if your ability to continue to pursue the hobby depended on it neither would you!

BEB

[XK50]

What is an "uninvolved person"? That seems to be pretty fundamental.

Now, a person walking down a street and encountering, suddenly, a drone (new, wide definition) can, clearly, be considered to be "uninvolved". No problem.

However, is a person, in a field or on a hill, and who is aware - or is made aware - that model aircraft activity is taking place in the vicinity, by virtue of one or more of the following:

- prior knowledge (longstanding usage),

- the sight of a model aircraft flying,

- the sound of a model aircraft flying,

- the presence of warning signs (permanent in any car park, temporary at the flying site perimeter),

- the flying of a red warning flag

- the presence of hi-vis-equipped non-flying marshal (these latter two, as at Sutton Park),

be truly "uninvolved", compare with that apocryphal bloke on the south London bus, who will know nothing?

Further, if such a person decides to wander over for a closer look, or for a chat (and they do on the hills), has such a person by virtue of his actions become "involved"?

Regards,

John

[Doug Campbell]

We also have to consider the what the competency levels will be, hopefully just an "A" cert.

I am not happy with the model registration either - I have approaching 30 models and I think registering each one is unrealistic, something like displaying you BMFA number should suffice. My only hope is that we get the exemption under 900g then I will stick to smaller models.

I think we need a bit of guidance from the BMFA on this. I know they are actively involved but after reading the explanatory notes I am still left with too many questions.

Doug

[Biggles' Elder Brother - Moderator]

An interesting point XL50. I know that, in the context of the ANO simply putting up a notice, or printing a notice on entry tickets to an event for example, or even announcing the use of drones "on stage" so the audience know, does not meet the requirements for a person to be "under your control" and hence eligible to flown within 50m of, the CAA are clear on that point and have explicitly stated so. That's the nearest concrete and definite parallel I can think of to the concept of an "involved person"?

BEB

[Erfolg]

Those who think BEB is splitting hairs, almost certainly not worked in a highly regulated, licenced industry. That is precisely what both the regulator and the licence holder both do. They are both seeking to limit their exposure to adverse comment and censure, in the case of the licence holder whilst trying to get something done.

i truly am disappointed that the BMFA have not provided any guidance of how individual members can assist all the national bodies representing modellers. I am thinking of pro former letters, petitions to be generated, then whom they should ideally be delivered to.

I can get so annoyed that more effort at least from a communications aspect is going into the NFC, than is being communicated to us ordinary members. I am not against the concept of either the LMA or BMFA, although I have reservations in what appears to arrangements nearer a "old boys club" or "trade union" in at least one case, rather than a representative of ordinary modellers, in a two way communication of equals.

Putting my bete noire to one side, all of usmodellers need guidance from our representative bodies in how to best support out cause. I do not want to hear, keep quite, and let us who know, to climb to the very pinnacles of their Ivory Towers. We cannot afford to be complacent, nor recognise we appear to be moving towards significant regulation, which always comes with a financial and time cost.