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Proposed new drone legislation/registration


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Posted by David Mellor on 11/02/2018 10:00:25:

cymaz - sheer guess and hope for the best is exactly what I do too. So do we all. I think thats the point.

That's not strictly true. I fly with telemetry and set warnings - and I've experimented with automatic throttle cuts - for the current 400 foot ceiling that we have at our site for 7kg models. While not everyone has this luxury, many radios are now capable and in a club environment, it shouldn't be too hard to find someone to demonstrate the appearance of some different sized models at 120m.

I would certainly like to think that the draft regulations will be implemented in the spirit intended and due regard given to retaining the existing method of measuring slope soaring height limits above point of launch - possibly involving a defined radius of operation?

Some years ago, I took a leaf out of the Dambusters book and made a simple height measuring device - a stick with an eye hole at one end and two adjustable points at the other which could be set for a range of wingspans. Some basic trigonometry provided a scale. The model simply needed to be flown over the observer with the device for the pilot to be informed when he was reaching the desired height. Cost for this was insignificant and any club or individual could knock one up in an hour or so if some means of measurement was insisted on.

A further thought is that the A test could include a height estimate section where a candidate would demonstrate flight at an estimated 100m - not necessarily measured but just to show that they were aware of an approximation of the height limit.

Edited By Martin Harris on 11/02/2018 10:49:08

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Just in the interests of accuracy, I didn't say that I thought no one had considered this issues I said that, in my opinion, it had never occured to EASA. No citicism intended but I just wanted the record to be accurate.

To add some information, my club responded to the NPA, the response was largely written by myself with input and comments from a small working group. Being principally a powered flight FW orientated club I'm afriad we did not consider the soaring issues much, although we did make a plea for a "liberal and broad" definition of what constitutes a " flying ste" eligible for registration - that was added specifically to help the case of slope soarers. Our main concerns were about compulsary model registration, Cat A3 overflying (we fly in a public park), banning under 16's etc. I'm relived to see that on just about every issue we raised EASA have moderated their proposals to a position I think we could live with - I'm not claiming that is entirely due to our response! But hopefully we played our small part in swaying EASA along with others.

Altough this was a club response it was entered under my name IIRC. So presumably was one of the 30 cited by SteveJ above. Was that right across all Europe - just 30 individual responses? That's pretty poor for an issue as important as this. Of course the national bodies across Europe will have responded as well, and while that is vital they can't cover every issue (even they don't know every local issue!) and their contribution is added more weight to when we back it up with individual cases. It really is a bit dissapointing that so few bothered. Several of us on here (Steve, ChrisB and myself) all encouraged people to respond and provided the link to follow on numerous occassions whilst the consultation period was open - and indeed, to be fair to EASA, they even extended the deadline for contirbutions. I don't intend to be critical of any individuals here but frankly, as a group, we could and should have done better in my view. Thankfully it looks like we "got away with it" by and large - next time we might not be so lucky.

BEB

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I think the slope issue is likely to be easily resolved. The height could very easily be based on the point of launch.

In terms of EASA considering all elements of our hobby. They didn't.

They didn't because the regulations don't focus on model flying and its various disciplines, they focus purely on the use of UAS and the civil servants writing the regulations are more than likely not familiar with model aircraft and are just following the instructions of their masters, DFT will be the same.

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Posted by ChrisB on 11/02/2018 16:33:46:

In terms of EASA considering all elements of our hobby. They didn't.

They didn't because the regulations don't focus on model flying and its various disciplines, they focus purely on the use of UAS and the civil servants writing the regulations are more than likely not familiar with model aircraft and are just following the instructions of their masters, DFT will be the same.

I agree entirely, which is exactly why I said it probably never entered their minds.

However I do think our own CAA are possibly very slightly better due to their longer term dialogue with the likes of BMFA - the roots of which very much pre-date this matter. I got the impression, on the occasions I have had to talk to them, that there was genuine concern to provide a good professional service and some interest They are not necessarily "just civil servants" - I believe that some at least work for CAA because they have an interest in aviation generally.

BEBt

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However I do think our own CAA are possibly very slightly better due to their longer term dialogue with the likes of BMFA - the roots of which very much pre-date this matter. I got the impression, on the occasions I have had to talk to them, that there was genuine concern to provide a good professional service and some interest They are not necessarily "just civil servants" - I believe that some at least work for CAA because they have an interest in aviation generally.

BEBt

Thanks BEB , that’s good to know and reassurance.. Better than here in Cornwall, where the Country Councillor in charge of transport doesn’t even own a driving licence! surprise

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Posted by Biggles' Elder Brother - Moderator on 11/02/2018 19:18:52:
Posted by ChrisB on 11/02/2018 16:33:46:

In terms of EASA considering all elements of our hobby. They didn't.

They didn't because the regulations don't focus on model flying and its various disciplines, they focus purely on the use of UAS and the civil servants writing the regulations are more than likely not familiar with model aircraft and are just following the instructions of their masters, DFT will be the same.

I agree entirely, which is exactly why I said it probably never entered their minds.

However I do think our own CAA are possibly very slightly better due to their longer term dialogue with the likes of BMFA - the roots of which very much pre-date this matter. I got the impression, on the occasions I have had to talk to them, that there was genuine concern to provide a good professional service and some interest They are not necessarily "just civil servants" - I believe that some at least work for CAA because they have an interest in aviation generally.

BEBt

Certainly those in the CAA are fully aware of the details of aeromodelling. The Civil Servants at the DFT in Whitehall and many at EASA in Germany may well have little or no knowledge. Which ever way they are doing as political masters demand.

Rob Buckley from the LMA has also been in discussion with the DFT.

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Ok, So who actually made comments on the NPA as an individual flyer? - Checking this and other Posts I can find:

BEB

Steve J

Dave Bran

me

A fellow club member I bullied (one definite but I think 2)

Mike Blanford

Chris B

Piers Bowlan

So who else commented? It wasn't easy to get to the right webpage -which is why I did a 'simple guide' as to how to get into the system way back in September.

Can we get up to 30? wink

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If you are one of those who wonder what on earth the BMFA is doing about this matter, you may find the links I have posted below to many News articles published on the BMFA website on this topic as useful aide memoire. If you are a BMFA member, you can register on the BMFA website to get notification every time a News posting is made. The News section goes back several years. I've listed the dates on which the BMFA, mostly Dave Phipps the CEO, has published with links to the articles:

  • 12 Sep 2016
  • 25 Oct 2016 - where Dave states that despite passing the deadline of 15 Oct 2016 for comments, EASA were still receiving dozens of emails per day, mainly from the UK. Over 1,000 amendments were proposed, with 50-100 related to model aircraft. So, I think it will be fair to say that more than 30 UK pilots replied to the original EASA paper. For the record, I did respond.
  • 11 Nov 2016 and this links to an EAS/FAI notice
  • 24 Nov 2016
  • 18 Jan 2017
  • 31 May 2017
  • 24 Jul 2017
  • 26 Nov 2017
  • 8 Feb 2018 the latest one.

Additionally, Dave Phipps has put at least 2 updates into the BMFA News. Many contributors to this forum have stated that they just throw their copy of the BMFA News in the bin as it never covers anything of interest. Well, it clearly did in these instances.

Hope that helps.

Edited By Peter Jenkins on 12/02/2018 01:13:33

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Posted by cymaz on 11/02/2018 09:29:45:

Is there a rule of thumb/ back of envelope guesstimate on how you determine 120m/400ft. .? I don’t have any telemetry or the Rx / Tx to ever use one.

Strap a ballon ( inflated of course) to length of string?

I'm reminded of the 'guess the height competitions' held at full size displays at Old Warden. Now, bearing in mind that the audience would be mostly used to watching aeroplanes of varying type over many years, you'd have expected that the guesses would be pretty close - not so, and often wildly out when the correct height of the aeroplane's pass was given, and the range of answers was announced. I have to admit that I tended to estimate on the low side and was usually out by several hundred feet, hence no prizes ever came my way.

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Re: The subject of slope pilots bandying together to create an overarching organisation to protect the public access sites without a "tenant" club...

I brought this up in late 2016 on the BARCS forum, and reached out to the BMFA at that time. Dave Phipps responded and I placed the highlights in that thread here... (extracts from my original email in italics, Dave's responses in blue)...

Based on the proposed EASA regulations there appears to be a possibility (though by no means certain) that model flying may only be possible from registered sites tenanted by a club under the wing of a competent authority (such as the BMFA, LMA etc).

This is not the current line of thinking. The hope is that you would need to belong to a recognised organisation and would fly under a blanket authorisation issued to them by the National CAA. At the present time there is no formal plan to restrict flying only to registered sites (the UK CAA does not want to become involved in any more admin than it is at present!).

If that were to occur slope and thermal soarers who fly from publically accessible sites not tenanted by a club would be breaking the law and would not be insured.

EASA also recognises that they have to find a way to accommodate this type of activity, so our hope is that the situation will not arise.

I therefore suggested a new BMFA affiliated club might be formed to register and “own” all the currently used public access slope and thermal sites that do not have a tenant club at present... Obviously the requirement to create such an organisation is based mostly on supposition and guesswork at this point; no-one outside the BMFA team really knows how the negotiations are going or whether this is likely to be required... My question is (based on your insight as to how the negotiations with EASA are proceeding) should the soaring community setup such an organisation at this time, and if so would the BMFA want to get involved?

At this stage, there is nothing to suggest that the above course of action would be required. The next draft of the EASA rules will probably be launched for consultation towards the end of May, but at the present time they still don’t have the formal competence to produce any actual rules. It seems that the earliest that any rules would be rolled out will be 2018 and then they will take three years to implement taking us to 2021. On this basis, there is no need for urgent action.

 

Based on the latest announcement in 2018 it would appear the BMFA and the other European modelling authorities have been successful in getting the concession that any member of the BMFA/LMA/FPVUK etc. should be covered to fly at public sites without a tenant club. They will of course have to meet all other requirements set out by the class of operation they are operating under (pilot registration, height limits etc), but if that is the case (tbc) at least we should not be arbitrarily banned. I will send another email to the BMFA to get an updated opinion on this.

Edited By MattyB on 12/02/2018 14:08:36

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That is interesting Matty. Slope soaring is not one my activities - as you might have guessed! - but I'd hate to see our friends and colleagues who are interested in that area at a serious disadvantage which why I have been flagging it up as a potential problem. I'm glad to see that, hopefully, all will be well.

BEB

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Posted by Steve J on 12/02/2018 14:53:17:
Posted by MattyB on 12/02/2018 14:01:02:

It seems that the earliest that any rules would be rolled out will be 2018 and then they will take three years to implement taking us to 2021.

I think that the UK government's schedule is a lot more aggressive than this.

It's also worth noting that U-space foundation services (registration, e-identification and geofencing) are supposed to be in place next year.

Posted by MattyB on 12/02/2018 14:01:02:

Based on the latest announcement in 2018 it would appear the BMFA and the other European modelling authorities have been successful in getting the concession that any member of the BMFA/LMA/FPVUK etc. should be covered to fly at public sites without a tenant club.

What concession? If you are talking about changing "framework of" to "member of", I don't see that as a concession and anyway, the wording in the draft regulation hasn't changed.

Agreed, it remains open to interpretation hence why I put tbc in my statement and am going to ask the BMFA for an explicit statement on this matter wink 2.

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