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

[MattyB]

21 hours ago, Peter Jenkins said:

My goodness, has it taken you all this time to realise that?

 

He wasn't "just realising it", he was pointing out to @leccyflyer that the CAA definition does include non-autonomous multirotors flown FPV and LOS, which is different to leccy's proposed definition.

 

21 hours ago, Peter Jenkins said:

...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?

 

Because CAA made it very clear they were not prepared to give an exception to multirotors over 400ft to association members, officially for "safety and security reason" reasons, but probably also in part because the negative optics of doing so for the lobbyists who are bending their ears. A post on this topic from 2018 when the Article 16 authorisation was granted...

 

 

"Some interesting commentary from the BMFA themselves on FB when asked about this...

"The Government was concerned that those wishing to operate multi-rotor drones unlawfully would join the associations solely to benefit from our permission/exemption in order to evade the 400ft limit. There is a lot of data to support permissions for model flyers operating 'conventional' model aircraft (which is why we were able to negotiate the permission), but unfortunately there is also a lot of data showing significant numbers of unlawful multi-rotor drone flights, many of which are at much greater heights than 'conventional' model aircraft would operate (which is why the CAA would not include multi-rotors drones)."

Edited December 6, 2023 by MattyB

[leccyflyer]

13 minutes ago, MattyB said:

 

He wasn't "just realising it", he was pointing out to @leccyflyer that the CAA definition does include non-autonomous multirotors flown FPV and LOS, which is different to leccy's proposed definition.

 

 

Because CAA made it very clear they were not prepared to give an exception to multirotors over 400ft to association members, officially for "safety and security reason" reasons, but probably also in part because the negative optics of doing so for the lobbyists who are bending their ears. A post on this topic from 2018 when the Article 16 authorisation was granted...

 

 

"Some interesting commentary from the BMFA themselves on FB when asked about this...

"The Government was concerned that those wishing to operate multi-rotor drones unlawfully would join the associations solely to benefit from our permission/exemption in order to evade the 400ft limit. There is a lot of data to support permissions for model flyers operating 'conventional' model aircraft (which is why we were able to negotiate the permission), but unfortunately there is also a lot of data showing significant numbers of unlawful multi-rotor drone flights, many of which are at much greater heights than 'conventional' model aircraft would operate (which is why the CAA would not include multi-rotors drones)."

See, that's part of the beef that I have with this. Had the BMFA concentrated on the interests of the vast majority of it's members - namely model aeroplane flyers - rather than thinking of the multirotor drone pilots, that they were actively courting, then perhaps there would have been a workable definition of what constituted a model aeroplane, allowing the exception of radio controlled model aeroplanes flown within line of sight and not equipped with cameras from the follow on regulations, involving RID etc. Our interests would have been better served IMO, rather than diluted to accommodate drone pilots. IMO it would have been far preferable had our national body left the drones to FPVUK and let those guys lobby on their behalf.

[steve too]

31 minutes ago, MattyB said:

A post on this topic from 2018 when the Article 16 authorisation was granted...

 

To be pedantic, the permission issued in '18 wasn't an article 16 authorisation. It was the start of a series of exemptions and permissions that became increasingly difficult to keep up with.

 

19 minutes ago, leccyflyer said:

Our interests would have been better served IMO, rather than diluted to accommodate drone pilots.

 

The BMFA needs members. I have long been of the opinion that the BMFA's number one priority since EASA started looking at the regulation of unmanned aircraft has been "what will increase our membership (or at least stop it dropping)".

[steve too]

Response form for CAP 2610.

 

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

 

35 days left to respond.

[MattyB]

3 minutes ago, steve too said:

Response form for CAP 2610.

 

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

 

35 days left to respond.

 

Thanks. I am waiting to see what the BMFA guidance says, though if it is similar to the last consultation I suspect will not be agree with many elements of it and respond based purely on my own views. I am certainly interested to see what they say about the hybrid (network and broadcast) RID proposal and the CAA site authorisation process.

Edited December 6, 2023 by MattyB

[steve too]

Just now, MattyB said:

I am waiting to see what the BMFA guidance says ...

 

So am I, but not to help me fill in that form...

 

The form allows you to save and go back to it, so you can do a first pass saying no to everything (except when they ask for a mass, I said 500g to that) 😀.

[David Elam]

BMFA Response

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

[Ron Gray]

Well on first look through it I am largely in agreement with the BMFA / LMA responses. The response makes a good case about the number of reported UAS incidents and how many of those were model aircraft, however I would like to know out of the reported incidents how many were actually confirmed as being UAS and then how many of those were model aircraft. I will have to read it again but I don't see why the response is 'Agree' to both 23 and 24 if in each case it is both impractical and disproportionate.

Edited December 8, 2023 by Ron Gray

[john stones 1 - Moderator]

11 minutes ago, Ron Gray said:

Well on first look through it I am largely in agreement with the BMFA / LMA responses. The response makes a good case about the number of reported UAS incidents and how many of those were model aircraft, however I would like to know out of the reported incidents how many were actually confirmed as being UAS and then how many of those were model aircraft. I will have to read it again but I don't see why the response is 'Agree' to both 23 and 24 if in each case it is both impractical and disproportionate.

 

It a typo Ron.

[Rob Buckley]

14 minutes ago, Ron Gray said:

Well on first look through it I am largely in agreement with the BMFA / LMA responses. The response makes a good case about the number of reported UAS incidents and how many of those were model aircraft, however I would like to know out of the reported incidents how many were actually confirmed as being UAS and then how many of those were model aircraft. I will have to read it again but I don't see why the response is 'Agree' to both 23 and 24 if in each case it is both impractical and disproportionate.

 

23 and 24 are the CAA proposing to not enforce Geo-awareness or geo-fencing on model aircraft, which we agree with as it is disproportionate.

[steve too]

4 hours ago, David Elam said:

BMFA Response

 

I despair of the BMFA.

 

Q21 agree, disagree, disagree and lots of words. It's a single question. One answer.

Q22 agree and lots of words including this gem "The definition of model aircraft is whatever an aeromodeller decides to try flying that day.". What? 

 

[steve too]

Just now, Rob Buckley said:

 

23 and 24 are the CAA proposing to not enforce Geo-awareness or geo-fencing on model aircraft, which we agree with as it is disproportionate.

 

Q24 is "Do you agree or disagree with our proposal to implement geo-fencing for UAS?" (not for model aircraft). How can you say agree?

[Rob Buckley]

3 minutes ago, steve too said:

 

Q24 is "Do you agree or disagree with our proposal to implement geo-fencing for UAS?" (not for model aircraft). How can you say agree?

 

If you read the consultation, at the bottom of page 27 it says about the implementation of geo-awareness and geo-fencing-

 

'We do not expect the requirements to apply to Model Aircraft (including C4 UAS), privately built UAS or C0 UAS without cameras'

 

Agree, as the proposal is not to apply geo-awareness and geo-fencing to model aircraft.

[john stones 1 - Moderator]

Pennies dropped. 😉

[Rob Buckley]

32 minutes ago, steve too said:

 

I despair of the BMFA.

 

Q21 agree, disagree, disagree and lots of words. It's a single question. One answer.

Q22 agree and lots of words including this gem "The definition of model aircraft is whatever an aeromodeller decides to try flying that day.". What? 

 

 

Q21 is four, maybe five questions in one. With explanations required. So it needs several answers and lots of words to explain.

 

Q22 is two questions in one. With explanations required.

 

Here's a video of somebody (in Australia) flying a model aircraft. Trying to write a definition of what a model aircraft is, is a hiding to nothing. It's the aeromodeller flying something that makes that 'something' a model aircraft.

 

 

[steve too]

8 hours ago, Rob Buckley said:

Q21 is four, maybe five questions in one.

 

Q21 is one question. You have to pick a single answer. Each question will end up as line in a figure in a report like the answers to the questions in the call for input ended up as figure 5 in CAP 2609. 

 

Ditto most of the other questions.

[steve too]

Quote

One of the world’s largest radio control equipment manufacturers produces RID equipment that is for the Japanese market, but does not meet any other national / international standards.

 

(BMFA/LMA response)

 

Japanese RIDs are to ASTM F3411.

 

 

(Japanese Civil Aviation Bureau, Ministry of Land, Infrastructure, Transport and Tourism)

[steve too]

10 hours ago, Rob Buckley said:

If you read the consultation, at the bottom of page 27 it says about the implementation of geo-awareness and geo-fencing-

 

I have read the consultation. Q24 says "Do you agree or disagree with our proposal to implement geo-fencing for UAS?", it doesn't say "Do you agree or disagree with the last sentence of 5.14 (i)?". And any sentence that starts with a bit of bureaucratese like "We do not expect" is pretty worthless.

[RottenRow]

Just to make things clear here, Rob Buckley, who provided some of the recent replies above, is the Secretary of the LMA.

 

This means that he was instrumental is writing the joint BMFA/LMA response above, which he hasn't made obvious here.

 

I'm not suggesting anything at all here, just making people aware, as non-LMA members would probably not know this.

 

Brian.

[Ron Gray]

I must admit that I agree with Steve too, I would much rather see the wording to be 'it is our proposal that these requirements will not apply to Model Aircraft etc. ' Putting 'we do not expect' in the document leaves the door open.

[Ron Gray]

Plus the questions 23 and 24 would be much clearer if instead of 

 

Question 23: Do you agree or disagree with our proposal to implement geo-awareness for

UAS? Please explain your answer.

 

They were

 

Question 23: Do you agree or disagree with our proposal to implement geo-awareness for

UAS excluding Model Aircraft (including C4 UAS) Please explain your answer.

[Peter Jenkins]

9 minutes ago, Ron Gray said:

Plus the questions 23 and 24 would be much clearer if instead of 

 

Question 23: Do you agree or disagree with our proposal to implement geo-awareness for

UAS? Please explain your answer.

 

They were

 

Question 23: Do you agree or disagree with our proposal to implement geo-awareness for

UAS excluding Model Aircraft (including C4 UAS) Please explain your answer.

I bet no one got an independent reviewer to read the questionaire before publishing it.  Are you volnteering Ron?😁

[Ron Gray]

Happy to do it Peter but they wouldn't allow it!

 

The trouble is that all the time you find little things like this in the document you start asking why?

Edited December 9, 2023 by Ron Gray

[Peter Jenkins]

In my experience, it usually means one of two things:

 

1.  No independent reviewer.  You know what you meant when you wrote it but will another reader think it's either ambiguous or confusing?

2. A last minute change, usually via cut and paste, that goes wrong because even the person who made the change didn't read the whole paragraph at the end of the change.

[steve too]

For the uninitiated, this is what the response form looks like.