CAA Call for Input: Review of UK UAS Regulations Aug 2023

[John Stainforth]

11 hours ago, MattyB said:

 

There are huge volumes of modellers in the US who would disagree with you. The majority perception seems to be that AMA pretty much threw anyone not flying at an AMA site under the bus, presumably because they thought the fact the only way out of RID was to become a member of a community based association (e.g. the AMA) and fly from one of their sites. See some of the comments under this AMA video for a flavour.

 

Also bear in mind that there are precious few commercially available RID modules available at this point, and despite the FAAs <$50 estimate, the ones that are nearing release are at least double that, so complying on Sept 16th would appear to be pretty onerous to me unless you are one of the lucky few whose site has been designated a FRIA.

 

Practically everyone who is serious about aeromodelling in the US belongs to a club using an AMA-recognised site. You'd be a fool not to: litigation in the US against the uninsured doesn't bear thinking about.

Edited August 17, 2023 by John Stainforth

[leccyflyer]

6 hours ago, John Stainforth said:

Practically everyone who is serious about aeromodelling in the US belongs to a club using an AMA-recognised site. You'd be a fool not to: litigation in the US against the uninsured doesn't bear thinking about.

I don't believe that is the case, as there are thousands of model flyers in the USA who are not only not members of AMA clubs, they are actively anti AMA and fly from a whole variety of non-club sites. It's a big country with many non-affiliated flyers, many of whom are very serious about aeromodelling.  A few minutes reading any US-centric forum would show that to be the case.

[John Stainforth]

A few minutes reading these sites has not revealed much anti-AMA sentiment. All the serious modellers I know in the US belong to AMA-recognised clubs, and I get most of my information from them.

[Paul De Tourtoulon]

I am with Leccy on this one, there was probably 1 in 10 who bought a plane at my shop and actually came to our model club to fly it.

 

And most of them do it in the shadows, not your usual keyboard warriors.

[MattyB]

55 minutes ago, Paul De Tourtoulon said:

I am with Leccy on this one, there was probably 1 in 10 who bought a plane at my shop and actually came to our model club to fly it.

 

And most of them do it in the shadows, not your usual keyboard warriors.

 

Agreed. The numbers indicate that @John Stainforth's "serious modellers" do not include the huge raft of park flyers, non-AMA club members, slopers using public sites and those flying LOS and FPV multirotors (entirely legally) outside of AMA clubs today.

 

Given the explosion of use that occurred in FPV and multirotors in the last 10 or so years, there are now way more operators outside the AMA than within it. The registration numbers from the FAA prove this unequivocally - the AMA has ~195k members and ~2500 clubs according to their website, but there are over 1.37m(!) recreational drone owners registered with the FAA, and that number was from the end of Dec 2021 so will have increased significantly since then. That means for every one AMA member, there are around 5 non-AMA operators.

 

(Clarification - I have double checked, and this definitely s the number of Operators, NOT the number of UAS (i.e. models) registered - recreational users only have to register once, not once per model - see next post)

 

For comparison, there are currently around 36k BMFA members, but in April 2022 ~181k registered pilots in the UK, a ratio of roughly one BMFA member to every 4 non-BMFA operators. The CAA estimate recreational drone usage is actually are around the 500k mark though (presumably the delta is made up of users who only fly <250g machines + those who have not registered and are breaking the law).

 

Edited August 18, 2023 by MattyB

[MattyB]

More context from the FAA report regarding what they believe the relationship is between # operators registered and # recreational UAS:

 

 

[leccyflyer]

3 hours ago, John Stainforth said:

A few minutes reading these sites has not revealed much anti-AMA sentiment. All the serious modellers I know in the US belong to AMA-recognised clubs, and I get most of my information from them.

Aaah, right, so that's what, maybe 100 or 200 modellers that you know personally, versus the likelyhood of the number of actual modellers probably being at least in the tens or even hundred of thousands? These modellers that you actually know are presumably also sampled from the AMA sites that you have frequented, so in itself that is a self-fulfilling sampling.

[Nigel Heather]

Is there a short summary in layman’s terms describing what is being requested/proposed?

 

Appreciate all the documents are available but it is a lot to read and understand.

[MattyB]

1 hour ago, Nigel Heather said:

Is there a short summary in layman’s terms describing what is being requested/proposed?

 

Appreciate all the documents are available but it is a lot to read and understand.

It’s a white paper and request for comment, so there aren’t any formal proposals. If you read the set of posts I made on page 1 of this thread plus the summary of my concerns about half way down that page you should get the main gist.

 

Having said that, one important point… Part of how the authorities get potentially unpopular policies like this through without too much dissent is by making the docs long winded and needlessly hard to understand so people are put off reading them. If you don’t read all of it that is up to you, but so often the devil is in the details, so it it’s to read them. This particular one isn’t actually that long (~30 pages of actual content) compared to past docs on the topic from UK Gov and the CAA. 

 

Edited August 20, 2023 by MattyB

[Martin_K]

There is no short summary of the proposals, it is a broad review of the regulatory framework. I will attempt a summary of the process. The response form requires input to all the questions raised in the review. This means someone who wants to comment only on 'traditional model aircraft' cannot do so. It will be interesting to hear from the BMFA how they suggest members contribute.

[MattyB]

5 minutes ago, Martin_K said:

There is no short summary of the proposals, it is a broad review of the regulatory framework. I will attempt a summary of the process. The response form requires input to all the questions raised in the review. This means someone who wants to comment only on 'traditional model aircraft' cannot do so. It will be interesting to hear from the BMFA how they suggest members contribute.

In previous consultations of this type there has generally been the option to respond with “no response” to questions you did not have a strong opinion on. Is that not the case this time?

[Martin_K]

I only went a short way into the form because answers were required in all areas. I would have been making up answers to things about which I have no experience to get to the bit I wanted to comment on. I gave up on the form but did send my desired comments to the CAA enquires Email address, asking them to confirm if they would forward my message to the review team. That was Thursday evening. So far no reply to say whether they will or will not accept my input.

[Zflyer]

The no response option sounds fine. However you could respond putting yourself in the drone pilot/owners place or reply with ...this does not address the traditional hobbyists issues and any regulation which affects them is consrtructedon flawed data...

This response though seeming tivail would carry much weight in any potential litigation.

 

 

As an aside since when didthe CAA startung using dollars as currency or is partof their report a lift from theFAA missive

[MattyB]

56 minutes ago, Zflyer said:

The no response option sounds fine. However you could respond putting yourself in the drone pilot/owners place or reply with ...this does not address the traditional hobbyists issues and any regulation which affects them is constructed on flawed data...

This response though seeming tivail would carry much weight in any potential litigation.

Maybe, but personally I am going to wait until the BMFA provides their guidance before deciding how to respond. Hopefully that will be available early next week to give people plenty of time to do so…

 

Edited August 20, 2023 by MattyB

[steve too]

17 hours ago, Martin_K said:

I only went a short way into the form because answers were required in all areas. I would have been making up answers to things about which I have no experience to get to the bit I wanted to comment on.

 

I would advise selecting the 'Neither yes nor no' option and putting something in the comment box. I suspect that email comments will end up in the round file.

[MattyB]

42 minutes ago, steve too said:

I would advise selecting the 'Neither yes nor no' option and putting something in the comment box. I suspect that email comments will end up in the round file.

 

Completely agree!

[Martin_K]

52 minutes ago, steve too said:

 

I suspect that email comments will end up in the round file.

Which is why I asked for confirmation that my input would be accepted. If not I will go back to the form. So far not even an automated acknowledgement from the CAA.

[steve too]

On 17/08/2023 at 10:34, MattyB said:

• Remote ID (a combination of network and broadcast, which they are calling hybrid) and Geo-awareness are front and centre in this document. For those on this forum and elsewhere who have stated many times “it’ll never come here, it’s nothing to worry about”, it’s sadly time to eat those hats… 😉. As per clause 3.17, RID is required to be implemented by law by Jan 2026.

 

 

Network and Direct RID is what the FAA originally wanted and backed away from.

 

IIRC the requirement for Direct RID only applies to certain open category classes (C1, C2 & C3 ) as the DfT under Shapps removed the specific category requirement, but there have been so many amendments to the retained version of 2019/947 it is difficult to be sure.

[MattyB]

1 hour ago, steve too said:

 

Network and Direct RID is what the FAA originally wanted and backed away from.

 

IIRC the requirement for Direct RID only applies to certain open category classes (C1, C2 & C3 ) as the DfT under Shapps removed the specific category requirement, but there have been so many amendments to the retained version of 2019/947 it is difficult to be sure.

 

Agreed - I do think they make it as complicated as possible to understand and respond to these kind of things, then they can say "you see, there weren't a meaningful number of objections/negative feedback" and just push it on through.

[MattyB]

On 20/08/2023 at 15:33, MattyB said:

…personally I am going to wait until the BMFA provides their guidance before deciding how to respond. Hopefully that will be available early next week to give people plenty of time to do so…

 

@Andy Symons - BMFA, is there any update on when we can expect the guidance to be released to members? I’ve checked my email and the news section of the website, but there hasn’t been anything new since Aug 8th I don’t think. Many thanks.

[Cuban8]

On 20/08/2023 at 15:33, MattyB said:

Maybe, but personally I am going to wait until the BMFA provides their guidance before deciding how to respond. Hopefully that will be available early next week to give people plenty of time to do so…

 

Agree 100% with waiting for guidance from BMFA. The vital thing is for ALL BMFA members to engage with how we are advised to respond as a group. Hopefully most of the nonsense as it applies to us flying our models quite legally, either in a club environment or on private land or elsewhere with permission etc will be deflected away from us.

 

[Andy Symons - BMFA]

On 22/08/2023 at 08:51, MattyB said:

@Andy Symons - BMFA, is there any update on when we can expect the guidance to be released to members? I’ve checked my email and the news section of the website, but there hasn’t been anything new since Aug 8th I don’t think. Many thanks.

It is likely to be sent out tomorrow. 24th.

[Doug Campbell]

Having read the BMFA response I feel it is a complete sell out of the members. No strong objections to remote ID is probably the opposite of the membership mood. They also spend too much time wanting to keep alignment with Europe. We have gone out own way now and should do what is best for us.

 

[Andy Symons - BMFA]

24 minutes ago, Doug Campbell said:

Having read the BMFA response I feel it is a complete sell out of the members. No strong objections to remote ID is probably the opposite of the membership mood. They also spend too much time wanting to keep alignment with Europe. We have gone out own way now and should do what is best for us.

 

From the response.

However, the BMFA would be strongly opposed to any Remote ID requirements for model aircraft. Our members have a collective fleet of around 500,000 aircraft which are usually operated from fixed remote locations well away from areas likely to require Remote ID interrogation and within VLOS of the pilot (generally making it easy for them to be identified in the unlikely event of there being a requirement). The BMFA believes that Remote ID would be disproportionate and unnecessary imposition on the model flying community.

The EU regulations do not mandate any Remote ID requirements for aircraft operated under an Article 16 Authorisation within the framework of model flying associations, or for model aircraft within the Open Category (A3, C4) and the BMFA requests that this position is maintained in any amendments made to the UK regulations.

What if keeping alignment with our neighbours is best for us?

Edited August 26, 2023 by Andy Symons - BMFA

[Cuban8]

I'm having a crack at the response, but a five minute tick box or superficial customer survey type form it ain't.

I fear that the take up from the rank and file BMFA Sunday flying members will be very disapointing given past history of making our opinions known in large numbers and particularly on this task, which will take quite some time to give some thought to and answer properly. Most of us are simply too preoccupied with other things. Happy to be proved very wrong though - we might get a surprise!

All the more reason for the BMFA to really fight this for us and thank you.