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

[john stones 1 - Moderator]

Mine done, the language on some questions baffles me, so it was back n forth to BMFA guidelines to get gist of question. Chin up. 😉

 

[MattyB]

3 hours ago, john stones 1 - Moderator said:

https://dronetag.cz/news/2023/05/15/dronetag-bs-basic-remote-id-solution/

You have to laugh, it’s easier than crying…!

“Please welcome Dronetag BS, the ultimate cost-effective solution designed to help aeromodelers, FPV pilots, and hobbyists comply with the latest FAA standards. With its affordable price of $49, this device is a game-changer. We call it Dronetag BS – a basic solution to prove that Remote ID is no BS.”

[Nick Cripps]

Also finished my submission and sent it off.

Many thanks to MattyB for highlighting this to us all and sharing his thoughts, and also thanks to the BMFA for their input.

[GrumpyGnome]

3 hours ago, steve too said:

 

If they go network ID it's a lot worse.

Jeez

 

always look on the bright si-ide of life, phew-ew, phre-ew, phre-ew, prew-eh....

 

It's not going to be armageddon.

[RottenRow]

Mine is done too; like many on here, I have answered the questions purely from the position of a builder and flier of model aircraft.

 

Thanks to all for your comments, which have been very helpful.

 

Brian.

[john stones 1 - Moderator]

Similar, in my own words but as a member of a group of modelflyers, those outside clubs are just as vital to the hobby, doubt we all answered much differently myself.

[MattyB]

1 hour ago, GrumpyGnome said:

Jeez

 

always look on the bright si-ide of life, phew-ew, phre-ew, phre-ew, prew-eh....

 

It's not going to be armageddon.

 

Maybe not, but I do think there is a major difference between the two in terms of likely compliance rates.

 

If the CAA and UK Gov stop at broadcast remote ID for model aircraft with exceptions for recognised flying sites, I'm pretty sure the vast the majority of current pilots will continue to participate. If they go to broadcast remote ID (which is far higher cost and pretty invasive IMO in terms of the data being provided and the potential for remote monitoring and enforcement) I can see large numbers of modellers exiting, and another chunk choosing to operate off grid in defiance of the new rules. A decent percentage of traditional aeromodellers may also choose to leave the BMFA if they perceive they have been unsuccessful in protecting the hobby from regulators.

[steve too]

6 hours ago, MattyB said:

With its affordable price of $49, this device is a game-changer. We call it Dronetag BS – a basic solution to prove that Remote ID is no BS.”

 

The $49 was a one day introductory price. They are 89€. 

[steve too]

3 hours ago, MattyB said:

... If they go to broadcast remote ID (which is far higher cost and pretty invasive IMO in terms of the data being provided and the potential for remote monitoring and enforcement) I can see large numbers of modellers exiting, and another chunk choosing to operate off grid in defiance of the new rules. ...

 

I assume that you mean network RID here. I doubt if they will go NRID outside of designated areas, but if they do I will probably be walking away.

[steve too]

6 hours ago, GrumpyGnome said:

always look on the bright si-ide of life, phew-ew, phre-ew, phre-ew, prew-eh....

 

I really can't see the bright side of paying 299€ for an ID that livestreams my flight to a server somewhere.

[Wookman]

Does somebody have a link to the doc you have to fill in?

 

5.4 Feedback can be provided by 7th September 2023, using the feedback form on
the CAA website

 

But only if you can find it.

 

[steve too]

Just now, Wookman said:

Does somebody have a link to the doc you have to fill in?

 

https://consultations.caa.co.uk/rpas/call-for-input-review-of-uk-uas-regulations/consultation/intro/

[GrumpyGnome]

Do you seriously think there is going to be millions of pounds spent harvesting and analysing data from a limited number of models, putting in place the necessary legislation for enforcement, setting aside the budget for legal challenges etc, etc.? 

 

If someone wanted to remotely monitor and prosecute people, they'd just need to obtain GPS data from mobile phones and rake in the cash from 'speeding' motorists.

 

The hobby will adapt and evolve, the same as it always has (remember CB radio, and noise sensitive sites).  

 

Yes, some people may walk away - in the same was as die-hard ic lovers may have done. But the hobby will survive.

[Ron Gray]

2 hours ago, steve too said:

 

I assume that you mean network RID here. I doubt if they will go NRID outside of designated areas, but if they do I will probably be walking away.

If NRID happens then some will walk away but I do believe the majority will stick 2 fingers up at it and continue to fly. Not wishing to encourage such rogue behaviour but I would be one of those and would welcome the publicity surrounding any resultant prosecution. 

[steve too]

On 31/08/2023 at 16:48, MattyB said:

Based on that table, the ICO pages on UK GDPR indicate a fair bit of that would be considered personal information

 

I found something on this which I read as saying that they are prioritising the people on the ground over the UAS operator, i.e. the UAS might be collecting data so it should transmit the operator ID and location.

[MattyB]

3 hours ago, steve too said:

 

I assume that you mean network RID here. I doubt if they will go NRID outside of designated areas, but if they do I will probably be walking away.

Sorry, yes, was a typo.

[Andy Stephenson]

Someone earlier mentioned switching it on and leaving it on the ground. This should be enough to warn of any conflict in the area around the flying site. One would imagine, once detected, any conflicting flight would be advised to give that site a wide enough berth for it not to matter whether the RID was in the air or not.

[leccyflyer]

Done.

 

Have been putting it off and enjoying my flying this week, but knuckled down and got it done this morning. Three hours solid and I come away with two main impressions - the unnecessary repetition of the same question being asked multiple times in the document was annoying. Secondly, the more I went through it, the more I became convinced that this impenetrable screed was actually designed to make folks just give up and not submit anything.

 

Speaking to various clubmates in the past week, I'm struck that almost everyone has said that they won't be answering this questionnaire.  British people in general, tend to be followers of the rules and I'm really starting to think that RID, if implemented, could be the straw that breaks the camel's back and causes no small number of flyers to either pack it in altogether, or just fly models <250g.

 

My responses largely followed the BMFA's but with the strong exception of RID where I had, in all conscience, to deliver my response from the POV of a traditional model flyer, rather than trying to embrace the drones. Don't get me wrong, I have a drone, used it only the other day, but I'd willingly throw it under the bus if by a miracle CAA do recognise that different regulations should apply to conventional model aircraft, flown LOS, and drones which are capable of operating BVLOS and all that entails. I requested a much lighter touch be applied to model aeroplanes, given our long history of safe flying and well though out modes of operation that are confined to a hemisphere at most a few hundred metres in diameter, centred on the model flyer themselves.

[FlyinFlynn]

14 hours ago, steve too said:

Arrêté du 27 décembre 2019

"Arrêté du 27 décembre 2019 relatif aux mesures de protection des personnes lors de l'utilisation de produits phytopharmaceutiques et modifiant l'arrêté du 4 mai 2017 relatif à la mise sur le marché et à l'utilisation des produits phytopharmaceutiques et de leurs adjuvants visés à l'article L. 253-1 du code rural et de la pêche maritime"

 

That Arrêté ?

 

The EU does allow homebuilt RiD's, at least at the moment they do. They have their own unique reporting ID category.

 

15 hours ago, steve too said:

"Arrêté du 27 décembre 2019" IDs would require different firmware to comply with the ASTM/ASD-STAN regulations.

 

I doubt if the government will allow homebuilt IDs. The FAA don't appear to be doing so.

 

PS prEN 4709-002 says "The Direct Remote Identification system shall reduce the ability of tampering the functionality of the
direct remote identification system."

Edited 14 hours ago by steve too

 

They can always change the goal posts.

 

Different firmware from what? 

 

The FAA isn't allowing homebuilt gear....but the FAA isn't going for NetworkID either - there will be statutory differences between the US and the EU position (and even different national positions within the EU). 

 

That statement about reducing the ability of tampering could mean anything.  I'm not going to pay €262 to read exactly what ASD-STAN prEN 4709-002 Corrigendum 1 has to specifically say but note:

 

  Such functionality, based on an open and documented transmission protocol (described in this document) contributes to address security threats and to support drones’ operators’ obligations with respect to citizens’ fundamental rights to privacy and protection of personal data.

 

'Open and documented'  does not sound to me like they are wanting to close this subject down. The firmware used in the self built RiD's I made do conform to the CURRENT normes in France, however, it appears that the E in RCM&E has pretty much fallen out of favour these days and no one is interested in this conversation.

 

 

[steve too]

34 minutes ago, FlyinFlynn said:

That Arrêté ?

 

No, this one.

 

https://www.finesseplus.org/wp-content/uploads/2020/01/joe_20191229_0302_0039.pdf 

(Which at some point should be superseded, if it hasn't been superseded already, to bring France into line with the rest of the EU.)

 

Which is why it says "The Zéphyr Beacon AM remote identification beacon allows any model to comply with the decree of December 27, 2019." on the Drovavia Beacon AM page.

 

41 minutes ago, FlyinFlynn said:

The firmware used in the self built RiD's I made do conform to the CURRENT normes in France, however, it appears that the E in RCM&E has pretty much fallen out of favour these days and no one is interested in this conversation.

 

The norm in France is not the norm anywhere else. So yes you can build a French RID for for 20€ and I can build a non-FAA approved F3411 RID for £20, but those two facts are not particularly useful in the context of this topic.

[MattyB]

2 hours ago, FlyinFlynn said:

‘Open and documented'  does not sound to me like they are wanting to close this subject down. The firmware used in the self built RiD's I made do conform to the CURRENT normes in France, however, it appears that the E in RCM&E has pretty much fallen out of favour these days and no one is interested in this conversation.

I don’t think that is true; it’s just more people are focussed on trying to prevent RID being implement for LOS models aircraft in the first place at this point, rather than working out how we would comply if it is. If it does move forward I’m certain we’ll have lots of time to chew the fat over the devices that can be used to comply with whatever finally gets passed by UK Gov. 

[Rich Griff]

Duty done in my own words...

 

No confirmation email/PDF copy yet....

 

You guys got an email/pdf confirmation ?

[GaryW]

6 hours ago, Ron Gray said:

If NRID happens then some will walk away but I do believe the majority will stick 2 fingers up at it and continue to fly. Not wishing to encourage such rogue behaviour but I would be one of those and would welcome the publicity surrounding any resultant prosecution. 

 

I'm very sorry but anyone openly saying they will stick 2 fingers up to whatever rules/laws are passed regarding what we are legally required to do to continue flying legally and legitimately shouldn't be in the hobby and anyone that refused to follow the laws & rules that ensure we do things above board i truly hope get caught and prosecuted in the same way you would for driving without a license, insurance, tax ,mot or worse still drink driving

 

And I'm gonna order a couple of Spektrum Sky ID units asap so i'm prepared for if and when remote id does come in to force

Edited September 6, 2023 by GaryWebb

[steve too]

28 minutes ago, GaryWebb said:

And I'm gonna order a couple of Spektrum Sky ID units asap so i'm prepared for if and when remote id does come in to force

 

I would advise against that for two reasons. Firstly, modellers in the US need them now and, secondly, there are national/regional variations on top of the standards so if you buy something now it may not be compatible with whatever the CAA decide.

[GaryW]

9 minutes ago, steve too said:

 

I would advise against that for two reasons. Firstly, modellers in the US need them now and, secondly, there are national/regional variations on top of the standards so if you buy something now it may not be compatible with whatever the CAA decide.

Where I say I will order a couple asap... it translates into as soon as available in the uk

Edited September 6, 2023 by GaryWebb