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

[Martin Dance 1]

I can think of very few occasions when remote ID would b e of any benefit to either the CAA or law enforcement (Police, Border Force). This is  because the legitimate users of drones would have already filed flight plans detailing the planned operations. For example film makers, companies carrying out survey work for example for agricultural work, pipeline surveys etc. Examples of when remote ID may be of benefit would be by a number of You tube content creators who often use camera drones to illustrate the topic of their videos. The Whitewicks and Hedley Thorne spring to mind. They operate in random locations and at unspecified times. They use their drones to show for example the route of a Roman road or abandoned canal. In this case the authorities on receiving a report of suspicious drone activity can quickly account for such legitimate operations with the minimum use of resources. Universal use of remote ID is likely to result in a considerable waste of time and resources. Of course those using drones (UAS) for nefarious purposes aren't going to fit remote ID anyway.

[Cuban8]

23 hours ago, David perry 1 said:

Absolutely.

The issue is autonomous air vehicles of the future.  There is no doubt that autonomous vehicles, flight planned on line and remotely authorised to fly, will be very commonplace.  It makes sense.  Trouble is it will effectively close all airspace below say 500ft AGL to anything and everything  not squawking an ID.  I fear a lot of light aviation, paragliding,  kite flying and of course models will either have to carry transponders or be grounded.  We are heading for a gloomy future and we brought it on ourselves with flight sims, cheap chinese foamies, quads and FPV.  Add a bit of gps and a few greedy accountants and bingo...aeronautical dystopia.

 

The CAA dont care, they dont have the manpower let alone the will power.  Anyone with half a brain can, if they want to, distinguish between a drone, a UAS and a model aeroplane and they need make no reference to 'toys' to do it.  The CAA is a profit centre and thats their bottom line.  

 

Model fliers could EASILY be excluded from all this legislation if it were about anything except an airspace grab.  The rules achieve no increase in safety because the bad guys wont comply.  The stupid wont comply. The ignorant wont comply. Only the good guys will try, and fail and be grounded or punished.  

 

Quite how my 4ft span 3 channel model with a duration of 10 minutes affects  anything  except a commercial autonomous vehicle is hard to see.  Its an airspace grab pure and simple.

Profoundly disagree with paragraph 1 What's commonplace? They're to be found quite commonly now. - A lot of truth in paragraph 2 - Ditto paragraph 3 - Ditto paragraph 4 with the addition that I doubt that the number of commercial UAVs operating will ever reach a number that has even the remotest chance of encountering your little model where it was being flown sensibly and legally under current rules.

UAVs are a reality, that's perfectly true. Effective weapons systems as we've seen from conflict zones around the world - media coverage in sport, news etc - emergency services for search and rescue, security. See series 'Drone Cops' on TV.

What is not a reality, IMHO, is this notion that is verging on becoming a religion in certain quarters, that our skies will be black with unmanned commercial vehicles following each other nose to tail in an airborne M25 style traffic flow while on their way to deposit their goods or provide some sort of service. Worse still, a free for all, based on a point to point system. Fly another device into the flow or pop your model into the airspace and 'boom', disaster will happen rather like walking across the real M25 (which is a very real danger).

We're being sold a falsehood and rather like a number of other fashionable but highly questionable ideas that are doing the rounds at the moment, I believe that eventually the truth will out.

Talk is very cheap from the 'futurists' and from those that make a living on the back of their day dreams.

 

 

Edited August 29, 2023 by Cuban8

[steve too]

3 hours ago, Ron Gray said:

Not really, the BMFA, in their detailed response, clearly shows that is not the case

 

If you don't say "Definitely no"  in response to "14. Should CAA implement Remote ID" then you are part of the problem irrespective of what you put in paragraph 4 of your comment.

[leccyflyer]

I have to agree, from my own point of view of a model flyer who also has a drone which only gets the most infrequent use - looking for lost models as it happens - the response to Question 14 should be Definitely No.  My feeling is that the BMFA is in danger of falling between two stools in trying to ensure continued support for drone flying, where that remote ID is inevitable, to the detriment of ordinary model flyers flying LOS, where there isn't a demonstrable benefit to anyone of onboard RID.

[Martin Dilly 1]

Yesterday there was a post that ended by mentioning "silly old duffers with boring toy planes" or words to that effect, to which I replied, urging people to respond to the CAA questionnaire. Both posts now seem to have vanished. As far as I am aware, neither was offensive. What happened?

[leccyflyer]

They haven't disappeared. They were posted in the thread The Big Question, not in this thread and they are still there.

[steve too]

49 minutes ago, leccyflyer said:

...  looking for lost models as it happens  ... where there isn't a demonstrable benefit to anyone of onboard RID.

 

Funnily enough, the only benefit that I can think of for direct RID for traditional modellers is finding lost models.

[MattyB]

1 minute ago, steve too said:

 

Funnily enough, the only benefit that I can think of for direct RID for traditional modellers is finding lost models.

 

Telemetry receivers with signal strength info already fulfil that need for me - no need for RID!

[MattyB]

41 minutes ago, Martin Dilly 1 said:

Yesterday there was a post that ended by mentioning "silly old duffers with boring toy planes" or words to that effect, to which I replied, urging people to respond to the CAA questionnaire. Both posts now seem to have vanished. As far as I am aware, neither was offensive. What happened?

 

18 minutes ago, leccyflyer said:

They haven't disappeared. They were posted in the thread The Big Question, not in this thread and they are still there.

 

Here is your post in that thread @Martin Dilly 1:

PS - It's easy to see all your own activity within this forum, just click on your profile, then the:

 

 

...button and Bob's your mother's brother.

 

Edited August 29, 2023 by MattyB

[MattyB]

On 28/08/2023 at 11:09, David perry 1 said:

The issue is autonomous air vehicles of the future.  There is no doubt that autonomous vehicles, flight planned on line and remotely authorised to fly, will be very commonplace.  It makes sense.  Trouble is it will effectively close all airspace below say 500ft AGL to anything and everything  not squawking an ID.  I fear a lot of light aviation, paragliding,  kite flying and of course models will either have to carry transponders or be grounded.  We are heading for a gloomy future and we brought it on ourselves with flight sims, cheap chinese foamies, quads and FPV.  Add a bit of gps and a few greedy accountants and bingo...aeronautical dystopia.

 

Whilst much of your post I agree with, the highlighted section in bold is just plain incorrect IMO. Who are the "we" you talk of - traditional line of sight model aircraft pilots, newcomers to the hobby, or both? And how does an established modeller buying and using a flight sim or foamie model cause the authorities to take the decision to legislate? I suppose the advent of affordable multirotors and FPV may have contributed a small amount, but if you read things like the Riga declaration from 2015 and listen to those who have been in the thick of this for the last 10-15 years you will realise it is really about the desire to integrate BVLOS UAS into the airspace for commercial, governmental and and military use. 

 

If you still don't believe me watch this BMFA webinar, it explains a lot. In the first section Dave Phipps directly refers to the regs being focussed on enablement of the commercial drone industry (first 10-15 mins worth). At around 57:30 Cliff Whittaker explains how we ended up here; it is an excellent explanation of the factors that led to the current regs, including the commercial drivers that led the the EASA regs on which the eventual UK ones were based (this predates the formal declaration from the CAA of the desire to implement RID, but those of us who had read the docs and understood the Operator ID includes a checksum directly designed for use in RID transceivers knew that was coming ages ago):

 

 

Edited August 29, 2023 by MattyB

[David perry 1]

The "we" is all.of us who use and fly remotely operated vehicles.  My point is that we, "we", have financed the development of the various technologies UAV need to operate.  Unintended consequences etc 

 

I am certain that the integration is what is being sought...but modellers will, IMHO, share no part innthis future.  I truly believe autonomous air taxis and personal transports are the way ahead...if not then this generation is missing a trick...but they will demand full electronic conspicuity for all air traffic...ALL airtraffic.  Since models wont have that there seems only one way to go.    Autonomous delivery vehicles, ambulances and military traffic...all are coming and all demand transponders in anything that flies between 0 and 500ft agl.

 

We will be excluded from the the airspace I fear.  

 

I know I see a dark future but i cant see a way round it.

[MattyB]

1 hour ago, David perry 1 said:

The "we" is all of us who use and fly remotely operated vehicles.  My point is that we, "we", have financed the development of the various technologies UAV need to operate.  Unintended consequences etc.

 

Please watch the pieces of the video I suggested above. Do that and you will see the idea that we as modellers somehow brought this on ourselves through purchases of flight simulators and ARTFs from China is frankly a bit silly. The tech we are talking about here was being invented by the military and in other industries anyway. Enterprising individuals and orgs worldwide (including the likes of Google, Amazon, DHL etc) realised there were opportunities to use that for commercial BVLOS SUAS in entirely new use cases that could drive profit to commercial orgs and valuable tax $$$ and jobs for governments. Unfortunately, all those new use cases have been deemed to require additional legislation to control the low level airspace these SUAS will operate in.

 

The rest of your post about the long term outlook I (sadly) do agree with, though given the  resources available for enforcement I can see a future where model flying continues, but as a much more underground and opportunistic pastime than it is today.

 

Edited August 29, 2023 by MattyB

[David perry 1]

I do accept that the technology was invented anyway and im not blaming modellers for this.  The technologies were made available and we all used them...the rise of uav and its call on airspace is just an unintended consequence of a worldwide uptake and development of the various technologies.  There was no alternative, i do understand that and im not apportioning blame.  All im saying is we are here, we as people, not just modellers but almost everyone,  brought it on ourselves.  

 

I hope the multi rotor personal transport does materialise, it ought to!  But its use will be a major challenge.  Mind you, otherwise sensible folks would also ban electric scooters so heaven knows what theyll make of air taxis!!  Pitchforks and torches i should think.

 

I was pondering the way through this...perhaps flying models from, and only from, designated sites so that other uav can be made aware of us.  Im not sure how secure that would be, but it might be one way.

 

Full size aircraft are not manadated to use transponders unless fitted,  but if they are fitted their use in compulsory.  Some airspace is already designated transponder mandatory and thus closed to none squawking traffic.  Maybe thats what will happen to us.  

 

Im sure we will find a way.  We usually  do.  Whats the alternative? No aeromodelling?  

 

 

 

 

[Martin Dilly 1]

3 hours ago, leccyflyer said:

They haven't disappeared. They were posted in the thread The Big Question, not in this thread and they are still there.

Thanks, Leccy. Brain fade strikes again. Probably time for a nice lie down...

[Andy Symons - BMFA]

2 hours ago, David perry 1 said:

We will be excluded from the the airspace I fear.  

 

I know I see a dark future but i cant see a way round it.

I really do not see any reason to be so pessimistic, model flying activity as we know it can be incorporated safely and relatively easily in to the shared airspace. The flights are all point A to point A, generally take place within 300m or so of the take off point and in full line of sight of the operator. In many respects while we are using airspace it is fixed airspace. Remote ID is simply not needed because it is generally obvious who the remote pilot of a model aircraft is because you can see them.

When flown as model aircraft always have been see and avoid works.

 

[GrumpyGnome]

32 minutes ago, David perry 1 said:

 

 

I was pondering the way through this...perhaps flying models from, and only from, designated sites so that other uav can be made aware of us.  Im not sure how secure that would be, but it might be one way.

 

I think (just think!) that the USA will require RID if flying from a non AMA-sanctioned airfield only....... 

[steve too]

9 minutes ago, GrumpyGnome said:

I think (just think!) that the USA will require RID if flying from a non AMA-sanctioned airfield only....... 

 

Not all AMA fields will be FAA Recognised Identification Areas and not all FRIAs will be AMA fields but a lot of them will.

[john stones 1 - Moderator]

Hope we're not back to a daily dose of we're doomed. Technology and business looking to make money from it brought us here as Matty B says, modellers had very little to do with it, and they could never have stopped it.

Read the E mail, I guess I could pick fault if I wished, but read as a whole I can't see where the BMFA is surrendering or accepting we give away "Our rights", it's a blinkered unrealistic view that thinks nothing will ever change for us modelflyers anyway. What about answer X,Y or Z ? I assume it fits into the overall stance they'll take on our behalf.

Similar to what Martin Harris has already said, if you've got the killer arguement that'll make this go away, fire it of to the relevant bodies.

[leccyflyer]

1 hour ago, MattyB said:

 

Please watch the pieces of the video I suggested above. Do that and you will see the idea that we as modellers somehow brought this on ourselves through purchases of flight simulators and ARTFs from China is frankly a bit silly. The tech we are talking about here was being invented by the military and in other industries anyway. Enterprising individuals and orgs worldwide (including the likes of Google, Amazon, DHL etc) realised there were opportunities to use that for commercial BVLOS SUAS in entirely new use cases that could drive profit to commercial orgs and valuable tax $$$ and jobs for governments. Unfortunately, all those new use cases have been deemed to require additional legislation to control the low level airspace these SUAS will operate in.

 

The rest of your post about the long term outlook I (sadly) do agree with, though given the  resources available for enforcement I can see a future where model flying continues, but as a much more underground and opportunistic pastime than it is today.

 

Some of us are doing our very best not to take model flying underground, but with the best will in the world sometimes that isn't possible. 😞

 

Just ask my P-51 - though only the spinner went fully underground and she's all fixed now, just awaiting a respray 🙂.

 

 

 

[Ron Gray]

6 hours ago, steve too said:

 

If you don't say "Definitely no"  in response to "14. Should CAA implement Remote ID" then you are part of the problem irrespective of what you put in paragraph 4 of your comment.

Utter tosh.

[MattyB]

2 hours ago, Ron Gray said:

Utter tosh.

I agree model aircraft pilots don’t have to newer “Definitely no”, as there are clearly some use cases where RID makes sense. However I do feel quite strongly that going right down the middle as the BMFA suggest is playing into the regulators hands by convincing them the model aircraft community are ambivalent to RID, even if the text that accompanies that response is against RID for models.

[john stones 1 - Moderator]

"Even if the text that accompanies that response is against RID for models " In a nutshell.

I'm going with the people representing us, and the ones they're engaged with in the discussion, understand a nuanced arguement.

I understand why this points being aired, but disagree with the negative slant put on it.

[MattyB]

18 minutes ago, john stones 1 - Moderator said:

"Even if the text that accompanies that response is against RID for models " In a nutshell.

I'm going with the people representing us, and the ones they're engaged with in the discussion, understand a nuanced arguement.

I understand why this points being aired, but disagree with the negative slant put on it.

That’s fair enough, we are all entitled to our view, though whilst the CAA may understand a nuanced argument, I'm less confident of their lords and masters... 😉.

 

The most important point is that people do submit their views, as a low response rate is the very worst situation for all of us - it tells the CAA and UK Gov that we don’t really care that much.

 

Edited August 29, 2023 by MattyB

[steve too]

14 minutes ago, MattyB said:

However I do feel quite strongly that going right down the middle as the BMFA suggest is playing into the regulators hands by convincing them the model aircraft community are ambivalent to RID, even if the text that accompanies that response is against RID for models.

 

Indeed. As I said above, the BMFA have been naïve at best. Whenever more regulation is proposed, our answer should be no.

[MattyB]

37 minutes ago, MattyB said:

The most important point is that people do submit their views, as a low response rate is the very worst situation for all of us - it tells the CAA and UK Gov that we don’t really care that much.

 

Reflecting on this some more, I have just submitted my own response, and have decided to post it here for others to look in the hope it stimulates some more responses to the CAA request.

 

I'm not doing this because I think you should agree with me - many will not - but that on reading the BMFA response I just didn't feel the fact it was written from the perspective of an organisation made it that easy to write a telling personal response that was aligned; by contrast this is in the first person. I also didn't feel the BMFA responses was specific enough to the type of flying I do (LOS fixed wing at club sites and public slope sites), or robust enough in its rejection of RID. Finally the fact it was in pdf format meant it could not be directly edited without conversion; this one is in docx which should work on most devices. 

 

Key point - Even if you are a LOS model aircraft pilot similar to myself, please do not reproduce this word for word; that just leads to our collective responses becoming less impactful. I'm only providing it in case it helps you to formulate your own response that reflects how these potential changes could impact your involvement in the sport.

 

Example response - CAA Call for input Aug 23.docx

Edited August 29, 2023 by MattyB