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


MattyB
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9 hours ago, MattyB said:

We have discussed this before Paul…

As per that thread and plenty of other resources online, RID is required in France for anything over 800g flown outside an officially registered site. Since the vast majority of slopers will weigh more than that (I think I only have one slope glider lighter than 800g) and i understand there are very few registered slope sites, then RID is pretty much mandatory, at least in theory. That thread doesn’t suggest enforcement is high on the average gendarmes list, though!

Sorry a year old and my memory isn't what it was, our local soaring sites are registered so no rid,,,

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9 hours ago, Martin Dance 1 said:

... the 'evidence ' is anecdotal and probably compiled by a Daily Mail journalist ...

 

I had to stop reading when I got to the paragraph were they milk the December '18 Gatwick incident. Whatever your opinion is on that incident is, it would not have been prevented by anything in CAP 2610.

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The report makes a big issue that there were 5000 reports to the police in 2013 about drones but nowhere does it say how many of those were actual caused by drones (and not bin bags, seagulls etc)? The report also 'bigs up' the potential revenue stream and job creation by the use of commercial drones but these figures are based on 'best case scenario' and are not shown alongside 'worse case scenario' to put them in perspective. Personally I think the figures quotes are far in excess of what will be the case but then I'm not being paid by the government to come up with these figures.

 

This one makes me laugh

 

3.6 We are proposing to extend the requirement for a remote pilot to take the Flyer

ID test for UAS operations in the ‘Open’ category, to include when flying a UAS

less than 250g with and without a camera. As is described in Chapter 2, we also

propose to remove exclusions for ‘toy’ UAS from these requirements.

 

So the CAA expect little Jonny, who has just received a drone for Christmas, to take the Flyer ID test? What absolute spherical objects.

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26 minutes ago, Ron Gray said:

 

 

So the CAA expect little Jonny, who has just received a drone for Christmas, to take the Flyer ID test? What absolute spherical objects.

Agreed Ron . Its a disgrace but doesnt little Johny have to be 18 ? The CAA I think are just empire building and making a case for increasing their remit. Those in power who know little or nothing about our hobby will of course hang on their every word while ignoring the Likes of experienced  flyers , BMFA, LMA and any opinions from polls they set up to make it look like they are listening.

The general public who buy toys for their children will just ignore it or just wont know about it anyway so its a piontless excercise thats being paid for with our flying tax (CAA annual fee) .

I had a similar discussion a few years ago with a local Park Ranger about youngsters flying at a loca park .  He told me that small children throwing a toy glider or small flying toy would be stopped at a local park! His words, although ive never heard of it actually bring enforced.

If we had a minister in office who was a devout aeromodeller it would be a tottaly different storyI'm sure ; the same as lord Young ,now deceased, who pushed for our driving rights for  heritage vehicles.

 

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3 hours ago, Rich Griff said:

As a matter of interest, what is the definition of a "toy" ?

 

If a model RC aerolplane or helicopter box says "not a toy", I assume it is not classes by the caa etc. as a toy, or is a toy based on weight/wingspan ?

 

 

 

If you read the document the intention is to remove the word ‘toy’

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It seems odd to me that the latest CAA Call for Input focuses almost exclusively on ‘safety and security’ of land-based objects. People, restricted air space etc. No where is their mention of safely integrating the new and emerging technologies with the existing airspace users, namely us and general aviation. Equally there is no mention how new UAS systems are going to be able to co-exist with each other. You can divide commercial UAS into two broad categories. 1. Surveying. And 2. Load carrying/ delivery. 1. Surveying UAS will almost certainly carry a camera. Uses could vary from surveying agricultural crops. Surveying buildings, YouTube creators using UAS to illustrate such things as Roman roads, iron age settlements etc. Film makers using UAS to capture viewpoints. The common factor here is that these uses are that they will occur at random times and random locations. 2. By and large delivery UAS will operate between fixed locations and at regular times. Such uses would be the delivery of medical supplies and equipment. Deliveries of goods from central warehouses to delivery depots. I think we can discount the trivial use of UAS delivering coffee and pizzas in the long term. Equally air taxis are likely to operate from major railway stations or airports carrying passengers to business parks. You will not be able to pick up a taxi on the street and have it drop you at your front door. The trick here is how do we make these UAS aware of each other, aware of other airspace users and FRZs.

RID as a tool to allow the Police, Border Force etc to locate most likely legitimate UAS operates seems to be missing the point entirely. Why do we need to burden our already overstretched Police with yet another responsibility and probably another bit of kit on their belts?

A version of the above will appear as an attachment to my next submission to the CAA.

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19 minutes ago, Martin Dance 1 said:

 

RID as a tool to allow the Police, Border Force etc to locate most likely legitimate UAS operates seems to be missing the point entirely. Why do we need to burden our already overstretched Police with yet another responsibility and probably another bit of kit on their belts?

Living in a county with one of the lowest population densities in England and knowing (family member in the rural crime unit) how stretched Police resources are, policing this is impossible in my area.


Liken it in my locality to wild camping, the law will be ignored.

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2 hours ago, Martin Dance 1 said:

It seems odd to me that the latest CAA Call for Input focuses almost exclusively on ‘safety and security’ of land-based objects. People, restricted air space etc. No where is their mention of safely integrating the new and emerging technologies with the existing airspace users, namely us and general aviation. Equally there is no mention how new UAS systems are going to be able to co-exist with each other. You can divide commercial UAS into two broad categories. 1. Surveying. And 2. Load carrying/ delivery. 1. Surveying UAS will almost certainly carry a camera. Uses could vary from surveying agricultural crops. Surveying buildings, YouTube creators using UAS to illustrate such things as Roman roads, iron age settlements etc. Film makers using UAS to capture viewpoints. The common factor here is that these uses are that they will occur at random times and random locations. 2. By and large delivery UAS will operate between fixed locations and at regular times. Such uses would be the delivery of medical supplies and equipment. Deliveries of goods from central warehouses to delivery depots. I think we can discount the trivial use of UAS delivering coffee and pizzas in the long term. Equally air taxis are likely to operate from major railway stations or airports carrying passengers to business parks. You will not be able to pick up a taxi on the street and have it drop you at your front door. The trick here is how do we make these UAS aware of each other, aware of other airspace users and FRZs.

RID as a tool to allow the Police, Border Force etc to locate most likely legitimate UAS operates seems to be missing the point entirely. Why do we need to burden our already overstretched Police with yet another responsibility and probably another bit of kit on their belts?

A version of the above will appear as an attachment to my next submission to the CAA.

You need to read the study (PWC) that the CAA are basing this on as that makes distinctions between the various groups.

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I’m hoping that the BMFA will have considerable influence regarding this:

 

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

As stated previously a major concern is that flying sites will need to be authorised:

 

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

 

As above, I’m hoping that the CAA will realise that the best body to determine this is the BMFA.

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5 minutes ago, Andrew Calcutt said:

Won't need bmfa when model flying is banned,I will be imprisoned in a old people's home,anyone lucky to have a job will be employed by the state.

You must be loaded if you think you'll get anywhere near an old peoples home!

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On 30/11/2023 at 13:05, MattyB said:

... can you tell us when the BMFA will be releasing guidance on how it suggests members respond to the latest consultation ...

 

I am also interested in seeing such guidance. Hopefully it won't be a bad as their response to the call for input. At least they seem to have realise that there might be a problem with remote ID.

 

Quote

However, at present, this would mean that those operating away from ‘approved’ sites would require Remote I.D. on aircraft (unless the aircraft is less than 250g and without a camera).

 

(https://bmfa.org/caa-review-of-uk-unmanned-aircraft-systems-uas-regulations)

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On 30/11/2023 at 23:33, Martin Dance 1 said:

Worth watching Geeksarnas live stream on the latest consultation. My view is the document is woolly, the 'evidence ' is anecdotal and probably compiled by a Daily Mail journalist. It's long on safety and security and remarkably short on proposals to manage the lower airspace to safely accommodate existing users alongside the expected growth in commercial UAS. A poor effort CAA could do better Must improve next term D.

 

Indeed. The fact they are even mentioning Gatwick is completely ridiculous when zero evidence has been presented to show that a UAS was ever there. Geeksvana does pick up on this too in a recent video on the consultation...

 

 

This video also gives a good view of the main elements of the consultation for anyone wanting a fairly accessible overview, though obviously he tends to talk from an FPV and multirotors perspective more than traditional aeromodellers.

 

 

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36 minutes ago, MattyB said:

The fact they are even mentioning Gatwick is completely ridiculous when zero evidence has been presented to show that a UAS was ever there.

 

The important thing about the December '18 Gatwick incident is not whether or not there was a UAS present. It is that Gatwick did not have the systems in place to give it situational awareness of its ATZ (to be fair to Gatwick, I doubt if any airport did at the time). The incident ended when the RAF Regiment turned up with their toys and gave the airport the required situational awareness. This is why CAP 2610 referring to Gatwick is so ridiculous, the fix was airports having counter UAS systems. Unfortunately, these counter UAS systems may be what is behind the the reports of UAS in FRZ referred to in 2610.

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3 hours ago, MattyB said:

 

Indeed. The fact they are even mentioning Gatwick is completely ridiculous when zero evidence has been presented to show that a UAS was ever there. Geeksvana does pick up on this too in a recent video on the consultation...

 

 

This video also gives a good view of the main elements of the consultation for anyone wanting a fairly accessible overview, though obviously he tends to talk from an FPV and multirotors perspective more than traditional aeromodellers.

 

 

Sorry Matty - if ever an illustration were needed that all of this nonsense really ought to be nothing to do with flying model aeroplanes, there it is, right there. The guy is pretty much exclusively talking about drones. The lack of differentiation in the regulations between model aeroplanes, with decades of operation across the country and these totally alien drones is coming to bite us again and again - on-board remote ID will be required even for sub 250g models and Flyer ID will also be required? It's completely outrageous imposition on model flyers - it would be better if drones had never been invented. We certainly wouldn't be having these endless consultations and new rounds of regulations if they hadn't.

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5 hours ago, leccyflyer said:

Sorry Matty - if ever an illustration were needed that all of this nonsense really ought to be nothing to do with flying model aeroplanes, there it is, right there. The guy is pretty much exclusively talking about drones. The lack of differentiation in the regulations between model aeroplanes, with decades of operation across the country and these totally alien drones is coming to bite us again and again - on-board remote ID will be required even for sub 250g models and Flyer ID will also be required? It's completely outrageous imposition on model flyers - it would be better if drones had never been invented. We certainly wouldn't be having these endless consultations and new rounds of regulations if they hadn't.

 

I don't agree that we'd be better off if multirotors had not been invented. There are lots of great uses for them from TV to crop surveys, as well as BVLOS fixed wing drones to deliver critical medical supplies etc. I have also flown a few myself, and they can be lots of fun. 

 

The problem is just that when something genuinely new is invented, initially it is can only be subject to legislation made up for a time before it existed. Of course the authorities could have chosen to separate camera carrying quadcopters from LOS model aircraft relatively simply at the outset, but they actively fought every attempt by the associations to do this because it wasn't in their interest - it's far easier to regulate and enforce if every type of craft under one umbrella. 

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3 hours ago, MattyB said:

 

I don't agree that we'd be better off if multirotors had not been invented. There are lots of great uses for them from TV to crop surveys, as well as BVLOS fixed wing drones to deliver critical medical supplies etc. I have also flown a few myself, and they can be lots of fun. 

 

The problem is just that when something genuinely new is invented, initially it is can only be subject to legislation made up for a time before it existed. Of course the authorities could have chosen to separate camera carrying quadcopters from LOS model aircraft relatively simply at the outset, but they actively fought every attempt by the associations to do this because it wasn't in their interest - it's far easier to regulate and enforce if every type of craft under one umbrella. 

 

That was all I asked for - the differentiation of this new technology from the existing model aeroplanes which had been operating perfectly fine, with no BVLOS operations, no significant conflict with other man-carrying air traffic and very little real impact on uninvolved persons. It was stated that it was just too difficult to have a definition which would allow such differentiation - yet you've just done it quite easily. There's no FPV or BVLOS flight without an on-board camera and downlink. That's the real life, simple definition which clearly separates out what we do as model aeroplane flyers and drones.

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3 hours ago, leccyflyer said:

There's no FPV or BVLOS flight without an on-board camera and downlink. That's the real life, simple definition which clearly separates out what we do as model aeroplane flyers and drones.

 

The CAA's definition of Model Aircraft focuses on autonomy.

 

Quote

An unmanned aircraft used for sporting and recreational purposes, flown by direct control inputs made by the remote pilot without any autonomous capability other than for flight stabilisation purposes.

 

(CAP 722D, the notes following this cover failsafes.)

 

Which means that my quadcopter is a model aircraft 😀.

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1 hour ago, steve too said:

 

The CAA's definition of Model Aircraft focuses on autonomy.

 

 

(CAP 722D, the notes following this cover failsafes.)

 

Which means that my quadcopter is a model aircraft 😀.

My goodness, has it taken you all this time to realise that?  Why do you think there is a specific comment in Article 16 that states that a single rotor machine can be flown above 400 ft provided its AUW does not exceed 7.5 kg but if you have more than 1 rotor you are limited to 400 ft?

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I was just surfing ebay showing ads there for drones with no reference to CAA requirements. It didn't say if they weighed less than 250g but all come with cameras. Without a public awareness campaign, there will be plenty of unwitting law-breakers. Should it be a legal requirement of the seller to advise about the regs and if so how do you legislate for the likes of Bangood and Ali express.

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20 hours ago, leccyflyer said:

Sorry Matty - if ever an illustration were needed that all of this nonsense really ought to be nothing to do with flying model aeroplanes, there it is, right there. The guy is pretty much exclusively talking about drones. The lack of differentiation in the regulations between model aeroplanes, with decades of operation across the country and these totally alien drones is coming to bite us again and again - on-board remote ID will be required even for sub 250g models and Flyer ID will also be required? It's completely outrageous imposition on model flyers - it would be better if drones had never been invented. We certainly wouldn't be having these endless consultations and new rounds of regulations if they hadn't.

Well said, totally agree 👍 

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