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

[Learner]

10 hours ago, Martin Dance 1 said:

I supect the latest news from Amazon about upcoming drone delivery drones is yet another example of a 'mania'. Started with canals in the 18th century, continued with railways in the 19th century. The next mania was flying in the first third of the 20th century. Then we had the .com bubble |(mania) in the 1980-90's. Now its drone delivery mania. The only common denominators that link all the previous manias were that some people thought it was a way to untold wealth most were disapponted. The other thing that links those earlier manias is that they have provided a leisure activity for groups of enthusiasts. So hang on in there we will become the next popular leisure acitvity. Oh wait a moment..... 

 

You forgot the electric car😅

[Cuban8]

3 hours ago, Learner said:

You forgot the electric car😅

Some interesting historical comparisons. The point I'd make is that the canals were constructed for a need that couldn't be fulfilled at the time by the terrible roads of the era.  i.e to move coal, material and goods etc efficiently and cheaply between towns and to ports for export as the industrial revolution and factory system took hold. Further amplified by the railways in the 19th century and the inevitable running down of canals.

Commercial drones have their uses and may, in some specialist areas, have an advantage over conventional road and air transport and for emergency services - don't hold your breath over a widespread revolution where the skies will be black with them delivering everything under the sun - I don't believe the market is there or is ever likely to exist  in a size that will push road delivery out of business. We really don't need them and  Its simply going to take a while for that fact to sink in especially when investors don't see the promised returns or indeed lose money.

On the other hand, look at how successful the likes of Deliveroo and others have been and how quickly they've developed -  how on earth can drone delivery compete commercially with the likes of the hoardes of scooterists and cyclists circulating around all of our towns and cities 24 hrs a day? All centrally controlled via an app for maximum efficiency for the customer and riders - even in the worst weather conditions, actually doing a good job for an increasing user base.  I take my hat off to them it must be very hard work.

Breakfast, lunchtime and dinner being a busy time for the riders and even very late at night. Where would drone delivery better that?

 

 

Edited October 20, 2023 by Cuban8

[MattyB]

Update from this months BMFA News - sounds like no feedback or new proposals on this til 2024...

 

Edited October 25, 2023 by MattyB

[Cuban8]

I smell a registration/licencing scheme (££s) for 'approved model flying sites' coming down the pipeline in the not too distant future.

[leccyflyer]

I receive the NOTAMS every morning from the CAA mailing list and it's notable that several of the local clubs in the wider area have long standing NOTAMS covering their activities for a few months at a time. My clubs do not currently avail ourselves of this facility for our club sites, but I can see it being useful in the immediate term and likely essential in the event that the plans for RID go ahead.

[MattyB]

20 hours ago, MattyB said:

Update from this months BMFA News - sounds like no feedback or new proposals on this til 2024...

 

One additional point...  In general I thought it was a good issue of BMFA News, but I wasn't impressed by Andy's somewhat snarky remarks about members who have discussions on this forum and other social media platforms regarding regulatory matters:

 

"...When you read some of the comments from a small number of people on social media and internet forums you would think the hurdles in front of us were almost insurmountable and take a huge amount of time to get past, then you get the internet 'know it alls' who quote chapter and verse from obscure sections of various bits of legislation, usually out of context and that do nothing but feed in to the incorrect perception of a massively overbearing regulatory framework affecting us. I often find myself thinking that some of these people, rather than spending time damaging our sport online with their negativity, should get away from their keyboards and find a hobby to take up instead. Model flying for example, a great social activity with great benefits for mental health and general wellbeing, great value for money and really easy to get involved with. "

 

Being grumpy at members who actively engage by reading, understanding and discussing the various whitepapers and proposals from the CAA, UK Gov, EASA et al. would seem to be completely counter-productive. Yes, the regs we have today are not too onerous thanks to the work of the national associations and their members, but our rights have still been eroded (and are significantly more fragile) than in pre-registration/Article 16 days. If we do not act collectively against regulatory over-reach those rights could undoubtedly be eroded further in the coming years (see what has happened with RID in the US for example). With that in mind the BMFA would be far better looking to work with those who are already engaged to help spread the word about responding to consultations like this; the more engaged members we have, the better our long term prospects. 

 

PS - One of the reasons there was so much discussion on social platforms like this was the lengthy period (>2 weeks) between the CAA's launch of the RFI and guidance from the BMFA on how we should respond. That time period represents more than 50% of the available response time for the RFI. Yes, the CAA probably gave them little warning of the RFI's release, and yes the BMFA only have a relatively small full time staff available to respond, but it was entirely predictable the CAA would launch a consultation or set of proposals along these lines given the global regulatory landscape. This was one of those times when dropping other things in order to move at pace (as one would in a commercial organisation) and get guidance out within a day or two would have been extremely worthwhile, giving the BMFA far more time to publicise the guidance and mobilise members to respond.

[GrumpyGnome]

The complete rubbish often found on FB, often posted by people who happily state they are not BMFA members, is certainly far more negative than this forum........ I'm pretty sure Andy will see some of that, and in all likelihood posts on other forums......

[MattyB]

33 minutes ago, GrumpyGnome said:

The complete rubbish often found on FB, often posted by people who happily state they are not BMFA members, is certainly far more negative than this forum........ I'm pretty sure Andy will see some of that, and in all likelihood posts on other forums......

 

Maybe, but exchanges like this one in this very thread make meinclined to believe he's also including this forum and it's members too. Whether that's the case or not, I can't see any point point is in calling people out like this in BMFA News - it is only likely to get peoples backs up more and increase the volume of the posts that he is describing. 

Edited October 26, 2023 by MattyB

[leccyflyer]

The bottom line here, much as I agree with a lot of what Andy says and feel that he is often the voice of reason, in this particular case no small number of people did not completely agree with the BMFA's guidance on certain key topics in that feedback to CAA. It was discussed at length in this thread and not being in lockstep agreement with BMFA on every single point is most certainly not intended to damage our hobby and many of those expressing concerned put a lot of time and effort into attempting to understand and work through the constantly changing regulations in an entirely appropriate manner. Those people do have a hobby - aeromodelling - and they are at their keyboards discussing these topics in order to be able to make an appropriate representation to the CAA, as requested.

[john stones 1 - Moderator]

Wouldn't dream of trying to speak for someone else, my take is, some links provided helped me, trawling through the legal guff ain't my forte by a long shot.

Don't think not being in lockstep was an issue either, I reckon most who replied used their own words after reading opinions/info on here and elsewhere.

BMFAs guidance was just that, guidance.

Andy had a grumble ? He's a way to go. to match the grumbling he gets heaped on his plate. No biggie for me.

 

[Bob Bertram]

It looks like another review came out yesterday from the CAA with input by the 10th January. Remote ID has reared its ugly head. I only had a quick read, lots of reading to digest.

[Martin_K]

Thanks Bob. As you say, the result of the previous consultation is - another consultation. The new Consultation Review of UK Unmanned Aircraft Systems (UAS) Regulations can be downloaded as CAP2610.

 

The reference to model aircraft and remote ID is in Section 5.8.viii
Model Aircraft: We recognise the good safety record of Model Aircraft flying in the
UK, and the importance of Model Aircraft to many hobbyists. However, our view is
that a blanket, unconstrained Remote ID exemption for all Model Aircraft flying
would make UAS regulations challenging to enforce and create inconsistent
security outcomes, due to the wide range of locations and aircraft currently used
for Model Aircraft flying. Our aim is therefore to find a proportionate approach that
supports the Model Aircraft community to fly safely and securely, without
undermining the security benefits we aim to achieve through Remote ID.
We are proposing for safe and secure Model Aircraft flights to be exempt from
Remote ID requirements. Under our proposed approach, Model Aircraft flights
would be exempt from Remote ID requirements, if:

 

a. The aircraft meets the CAA’s definition and specification for exempt Model
Aircraft;

 

b. The pilot and UAS remain within the bounds of a designated Model Aircraft
flying site, authorised by the CAA based on proximity to urban, sensitive or
restricted sites; and

 

c. The flight takes place within a Model Aircraft club, with an authorisation
granted under Article 16 of UK Regulation(EU) 2019/947.

 

This approach is similar to that taken by the Federal Aviation Authority (FAA) in
the USA. In practice, the detailed definition of Model Aircraft and criteria for
designated flying zones would need to be established in parallel to this
consultation, in collaboration with Model Aircraft stakeholders. These would be
developed to ensure that flights taking place without Remote ID are limited to
locations and aircraft that pose a sufficiently low security risk.
Where these conditions are not met, Model Aircraft flights would be expected to
meet the same regulatory requirements as legacy UAS – i.e. to have active
Remote ID, delivered via a Remote ID add-on module (unless the aircraft is less
than 250g without a camera).
Under these proposals, Model Aircraft that fly at low-risk club or association sites
and meet the definition of an exempt Model Aircraft would not be impacted by
Remote ID. We expect for this approach to be implemented from 1st January 2028
onwards, aligning to our proposals for legacy UAS.

[Paul De Tourtoulon]

2 minutes ago, Martin_K said:

The pilot and UAS remain within the bounds of a designated Model Aircraft
flying site, authorised by the CAA based on proximity to urban, sensitive or
restricted sites;

Like over here in France no more flying in your back garden, and anywhere else, forcing you to pay for a club and association adhesion ! 😨

[GaryW]

55 minutes ago, Martin_K said:

Thanks Bob. As you say, the result of the previous consultation is - another consultation. The new Consultation Review of UK Unmanned Aircraft Systems (UAS) Regulations can be downloaded as CAP2610.

 

The reference to model aircraft and remote ID is in Section 5.8.viii
Model Aircraft: We recognise the good safety record of Model Aircraft flying in the
UK, and the importance of Model Aircraft to many hobbyists. However, our view is
that a blanket, unconstrained Remote ID exemption for all Model Aircraft flying
would make UAS regulations challenging to enforce and create inconsistent
security outcomes, due to the wide range of locations and aircraft currently used
for Model Aircraft flying. Our aim is therefore to find a proportionate approach that
supports the Model Aircraft community to fly safely and securely, without
undermining the security benefits we aim to achieve through Remote ID.
We are proposing for safe and secure Model Aircraft flights to be exempt from
Remote ID requirements. Under our proposed approach, Model Aircraft flights
would be exempt from Remote ID requirements, if:

 

a. The aircraft meets the CAA’s definition and specification for exempt Model
Aircraft;

 

b. The pilot and UAS remain within the bounds of a designated Model Aircraft
flying site, authorised by the CAA based on proximity to urban, sensitive or
restricted sites; and

 

c. The flight takes place within a Model Aircraft club, with an authorisation
granted under Article 16 of UK Regulation(EU) 2019/947.

 

This approach is similar to that taken by the Federal Aviation Authority (FAA) in
the USA. In practice, the detailed definition of Model Aircraft and criteria for
designated flying zones would need to be established in parallel to this
consultation, in collaboration with Model Aircraft stakeholders. These would be
developed to ensure that flights taking place without Remote ID are limited to
locations and aircraft that pose a sufficiently low security risk.
Where these conditions are not met, Model Aircraft flights would be expected to
meet the same regulatory requirements as legacy UAS – i.e. to have active
Remote ID, delivered via a Remote ID add-on module (unless the aircraft is less
than 250g without a camera).
Under these proposals, Model Aircraft that fly at low-risk club or association sites
and meet the definition of an exempt Model Aircraft would not be impacted by
Remote ID. We expect for this approach to be implemented from 1st January 2028
onwards, aligning to our proposals for legacy UAS.

 

 

So if i read this right ..... The need for Remote ID is expected to be implemented ( bought into force/law ) making it a legal requirement from Jan 2028.....

 

Question: Why Jan 2028...?

Question: Why wait 5 years to bring this in....?

Question: If this is going to be a legal requirement, Why not introduce/implement it within the next year to 18 months

 

As to the conditions on exemption to Remote ID as listed in A,B,C, Making Remote ID legally required for all models being flown/operated outside the club/ CAA approve flying site.... Ie: Local Park / Private Land or in your Back Garden like Paul mentions above I think thats very fair and to be totally honest,,, Since this first started to be talked about on here I was expecting whats be proposed to go along similar lines to how Rc fliers in the US & the FAA will be going with Remote ID

 

So basically we will have 2 choices,,,, Join/Stay with the club you are with ( those that are members of a flying club or looking to join a club ) therefore Remote ID wont be an issue, Or fit Remote ID if you choose to leave the club and/or choose to fly outside a club environment

 

Looking at the potential financial costs,, It will be far cheaper to join a CAA recongnised Club where Remote ID will not be needed than to fit Remote ID to various models/Drones to Fly outside a CAA approved club/flying site.... I know what my choice will be,,, Stay with the club im with

Edited November 23, 2023 by GaryWebb

[steve too]

Figure 5 from CAP 2609 (Call for Input Response Summary).

 

My apologies to anybody who said that there was no point responding to the call for input. It is pretty clear that the CAA, Home Office, Department for Transport and Police don't care what we think. 

 

(CAP 2610)

 

[Martin Dance 1]

OK I've just read this latest CAA consultation document. On the positive side at least they are now recognising that Model Aircraft represent a small safety and security risk.  As for the rest which bit of cloud cuckoo land do the people who write these documents live in? Are going to see a doubling of our Police forces to cope with the additional demands being placed on them at the moment? Let alone those placed on them by these proposed changes. Interesting too citing the FAA implementation of FRIA's and remote ID in the USA where in practice little uptake of remote ID has happened and relatively few FRIAs have been approved. So effectively no evidence. UAS s observed at between 6,000-10.000 ft really? Also no reference to any sort of rigorous risk assessment. The asseration that new regulation will reduce crime commited by UAS is simplyn unbelievable. Since when did new laws and stiffer sentences reduce crime? 

[steve too]

This is the sort of thing that will be required to meet 5.8 of CAP 2610.

 

https://dronetag.cz/products/mini/

 

€299

[Graham Bowers]

4 minutes ago, steve too said:

This is the sort of thing that will be required to meet 5.8 of CAP 2610.

 

https://dronetag.cz/products/mini/

 

€299

Perhaps this aptly named device ?-) https://dronetag.cz/products/bs/

[steve too]

Just now, Graham Bowers said:

Perhaps this aptly named device ?-) https://dronetag.cz/products/bs/

 

The BS doesn't do network.

[steve too]

11 minutes ago, Martin Dance 1 said:

... relatively few FRIAs have been approved ...

 

I understand that over 1200 AMA sites have FRIA status.

[Rich Griff]

Bob said "

It looks like another review came out yesterday from the CAA with input by the 10th January. Remote ID has reared its ugly head. I only had a quick read, lots of reading to digest."

 

Thanks Bob.

 

May I ask, bmfa, as a matter of interest, when did the bmfa first know of this new "response request" please ?

 

Over to you Andy/bmfa...

 

 

[Graham Bowers]

10 minutes ago, steve too said:

 

The BS doesn't do network.

Well, I wordsearched CAP2609 for "network" and no match, so they must be using a different terminology. I suppose all will become clear in the fullness of time. 

[steve too]

Just now, Graham Bowers said:

Well, I word searched CAP2609 for "network" and no match

 

Try CAP 2610.

[EGB 953]

Make it even harder to fly in a local park or field is just going to make it less likely a young kid, given a model for a birthday or Xmas gift is ever going to start in the hobby. This regulates us into decline. 
 

is there a legal challenge around proportionality of the regulations?

[Futura57]

Almost every day, out walking or driving, I see cars with illegal number plates. Letter/number spacings deliberately manipulated! Black fixing bolts deliberately placed to alter a letter/number, fancy or 3D typeface. I could go on. I got so fed up one day waiting in the Sainsburys carpark for my wife I went online to try to report three clear transgressions with photographic evidence. Firstly it was a pain in the behind to find the right website, and when I eventually did I got no acknowledgement. More than two years later I see the same vehicles with the same illegal number plates. The police have better things to do with their time and remote ID will be the same. I'm not stressing about it unless my club mandates it to remain member. Even then I will ...