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

[Andy Symons - BMFA]

36 minutes ago, ken anderson. said:

Andy,you have more the one Fan.....count me in..

 

Ken Anderson.....ne...1....Andy's fan club dept.

🤗

[john stones 1 - Moderator]

Complaining is easy, so is giving articles you have no interest in a miss, no idea what purpose is served by highlighting people who at least contribute ?

Can you do better, or even take the time to give it a go ?

[GrumpyGnome]

Complaining whilst sitting behind a keyboard seems to be a very popular hobby nowadays.......

[Martin Dance 1]

Just a heads up. In my inbox as one of a series of emails from the CAA  Regulatory Sandbox for the development of capabilities to integrate Uncrewed Aerial Systems (UAS) in unsegregated airspace CAP 2616.  Pretty innoucous you might think.It is forum for organisations/ businesses interested in developing RPUASS systems. However worth a peruse. There is an online briefing on 10 Jan 24. Iv'e booked a slot. Notice the date? 

[MattyB]

With regards to the possible requirement for site authorisation from the CAA in order to avoid the requirement for pilots to fit RID, I decided to check the current costs for an Article 16 authorisation (it is pretty much the only item on the CAA's charge book that would appear semi-related to the activities that would be involved in the review and approval of a club site for operation without RID). This document shows the initial costs is just over £2k, based on 7 hours of work by the CAA at £290 an hour, with renewal of ~£600/year:

 

 

Key point - based on their charge book, the CAA don't do anything for free, so we shouldn't assume RID site authorisations will be. For that reason respondents to the call for consultation may wish to mention these eye-watering numbers when responding. Even if they were halved for club RID exceptions vs an Article 16 auth, they would still add a hefty chunk to the membership costs of many clubs and associations, and there is no guarantee the CAA will say yes having assessed your application.

 

That first year could certainly be a nice little money-spinner for the CAA, dwarfing the annual take-home from the DMARES scheme... 🤨😬

 

Edited December 18, 2023 by MattyB

[Andy Symons - BMFA]

As a counter to the above the site permits to fly above 400ft with over 7.5kg aircraft dont cost anything.

 

As yet we have no idea what the process will be if one is needed.

[MattyB]

33 minutes ago, Andy Symons - BMFA said:

As a counter to the above the site permits to fly above 400ft with over 7.5kg aircraft dont cost anything.

 

As yet we have no idea what the process will be if one is needed.

 

Correct, we don't, but how many of those 400ft+ for <7.5kg permits do they process a year at present? Only a small percentage of clubs hold them today, so the time and cost to the CAA will be minimal.

 

If every club/organised group affiliated to a national association were to apply for the UK equivalent of a FRIA, that will be >1000 sites, which is an awful lot of new work for the CAA. Assuming that will be done for free seems rather a large stretch, so I will definitely be commenting in my response that the costs to applicants should either be very minimal (<£10/site/annum, subsidised from DMARES if needs be), or the site authorisations should be handed off to the national associations. I severely doubt the lobbyists and UK Gov will sanction the latter though, as it's not in their interests to do so.

 

Edited December 18, 2023 by MattyB

[Zflyer]

I think the point Andy was trying to make is that permits are not required sub 400ft and 7.5kg, hence free. Whilst I accept there MAY be some cost and we need to be vigilant and pro active it would be unreasonable to assume that prohibitive pricing is to be expected. All that would do would be to drive a large number of people to criminality

With some mindful  and considered responses, which I look to the BMFA and LMA to provide and present on our behalf, reason may yet prevail. 

[Martin Harris - Moderator]

I might have misinterpreted the situation but as I think I understand it, the CAA have devolved responsibility for issuing permits to fly > 7.5 kg AUW models above 400' AGL to the BMFA - hence no charge payable to them...

 

Perhaps it's too much to hope that similar arrangements might be agreed for RID site exemptions?

[Andy Symons - BMFA]

18 minutes ago, Martin Harris - Moderator said:

I might have misinterpreted the situation but as I think I understand it, the CAA have devolved responsibility for issuing permits to fly > 7.5 kg AUW models above 400' AGL to the BMFA - hence no charge payable to them...

 

Perhaps it's too much to hope that similar arrangements might be agreed for RID site exemptions?

Precisely.

[MattyB]

1 hour ago, Martin Harris - Moderator said:

I might have misinterpreted the situation but as I think I understand it, the CAA have devolved responsibility for issuing permits to fly > 7.5 kg AUW models above 400' AGL to the BMFA - hence no charge payable to them...

 

Perhaps it's too much to hope that similar arrangements might be agreed for RID site exemptions?

 

I am sure that is what the national associations will go for, but it is not how it works in the US, where applications are via CBO to the FAA. Are the BMFA aware of another jurisdiction where they have implemented RID but devolved site authorisation to national associations? I'm not, but if there were that would be a useful precedent. Either way, whilst I'd love to believe the CAA are happy to leave site authorisation to the BMFA, LMA and FPVUK, I just don't believe their political lords and masters will sanction that - it cedes too much control in terms of their ability to clear useful areas of low level airspace for potential commercial use. 

Edited December 18, 2023 by MattyB

[Andy Symons - BMFA]

It's worth remembering that we don't live in the US.

[Peter Jenkins]

2 hours ago, MattyB said:

 

I am sure that is what the national associations will go for, but it is not how it works in the US, where applications are via CBO to the FAA. Are the BMFA aware of another jurisdiction where they have implemented RID but devolved site authorisation to national associations? I'm not, but if there were that would be a useful precedent. Either way, whilst I'd love to believe the CAA are happy to leave site authorisation to the BMFA, LMA and FPVUK, I just don't believe their political lords and masters will sanction that - it cedes too much control in terms of their ability to clear useful areas of low level airspace for potential commercial use. 

Who cares how they do it in the USA.  The CAA certainly wouldn't have outsourced the clearance of the 737 Max to the manufacturer.  Our whole political set up is completely different.  In the USA, the people distrust their government and while you could make a case for us Brits distrusting our government, on the whole we do place our trust in our elected government.  If we lose trust we vote in another lot - it's not thst simple in the USA.  In the US system you have power split between the President, Congress and the Supreme Court.  Politics is driven far more by money in the US than here.  

I think your mindset is more what I found in the USA than I find here.  

Still, each to their own.

[FlyinFlynn]

8 hours ago, Peter Jenkins said:

The CAA certainly wouldn't have outsourced the clearance of the 737 Max to the manufacturer

Errr... isn't that more or less what they actually did do?  The CAA left much of the certification to Boeing because they did not have the resources to do it themselves....or did I miss-understand the results of the 737MAX inquiry?

https://www.seattletimes.com/business/boeing-aerospace/failed-certification-faa-missed-safety-issues-in-the-737-max-system-implicated-in-the-lion-air-crash/

[GaryW]

 

 

We can do our CAA Operators & Flier ID's through the BMFA so why not the Site Authorisations as well when Remote ID comes into play or is this a case of Matty knows more than the BMFA or anyone else does again, which in all honesty thats what I'm seeing and the impression I'm getting everyday in general.... Noone truly knows how Remote ID is going to work, be implemented, paid for or governed other than the CAA,, and Andy Simmonds says above, " We do not live in the US " and things work differently here ,, All this speculation into how it will play out based on what the US and other countries do is of no useful benefit to how it will or will not play out for us in the UK ...

 

Whatever happens when Remore ID comes in all we can do is either accept it & do what is required to continue to fly legitimately and legally or not accept it , ignoring what is required risk getting caught/prosecuted , or walk away from the hobby

Edited December 19, 2023 by GaryWebb

[Peter Jenkins]

19 minutes ago, FlyinFlynn said:

Errr... isn't that more or less what they actually did do?  The CAA left much of the certification to Boeing because they did not have the resources to do it themselves....or did I miss-understand the results of the 737MAX inquiry?

https://www.seattletimes.com/business/boeing-aerospace/failed-certification-faa-missed-safety-issues-in-the-737-max-system-implicated-in-the-lion-air-crash/

The Civil Aviation Authority (CAA) is the British aviation authority.  The Federal Aviation Authority (FAA) is the USA's aviation authority.  The link you posted is clearly marked FAA.

 

So yes, you completely misunderstood the results of the 737 Max enquiry.  That related to the FAA and not the CAA.

[Ron Gray]

26 minutes ago, GaryWebb said:

or is this a case of Matty knows more than the BMFA or anyone else does again, which in all honesty thats what I'm seeing and the impression I'm getting everyday in general

With respect Gary, both Mattyb and Steve Too have done a lot, and I mean a lot of 'deep diving' into the detail of this 'thing' and I for one am pleased that they have surfaced a lot of information relating to it. What you do with that information is entirely up to you (you have already made your views known) and whilst you are correct in that we just do not know what will happen the information brought to this forum does show what could happen. IMO forewarned is forearmed but you can just ignore it as you probably will.

[Ron Gray]

9 minutes ago, Peter Jenkins said:

The Civil Aviation Authority (CAA) is the British aviation authority.  The Federal Aviation Authority (FAA) is the USA's aviation authority.  The link you posted is clearly marked FAA.

 

So yes, you completely misunderstood the results of the 737 Max enquiry.  That related to the FAA and not the CAA.

Bit harsh Peter could well have been a typo, CAA typed instead of FAA, give the guy the benefit of the doubt.

[leccyflyer]

29 minutes ago, GaryWebb said:

 

 

We can do our CAA Operators & Flier ID's through the BMFA so why not the Site Authorisations as well when Remote ID comes into play or is this a case of Matty knows more than the BMFA or anyone else does again, which in all honesty thats what I'm seeing and the impression I'm getting everyday in general.... Noone truly knows how Remote ID is going to work, be implemented, paid for or governed other than the CAA,, and Andy Simmonds says above, " We do not live in the US " and things work differently here ,, All this speculation into how it will play out based on what the US and other countries do is of no useful benefit to how it will or will not play out for us in the UK ...

 

Whatever happens when Remore ID comes in all we can do is either accept it & do what is required to continue to fly legitimately and legally or not accept it , ignoring what is required risk getting caught/prosecuted , or walk away from the hobby

You keep saying that Gary, but the whole point of this discussion is for folks to be more aware of the implications of what is down the road for us as model flyers and to make their response to this call for consultation. It may already have been decided what will happen, but that does not change the need for such a discussion, which you appear determined to stifle with that approach that we'll just have to accept what comes to pass, without at least attempting to point out the massive flaws in what is being proposed and the possible effects on our hobby.

[GaryW]

7 minutes ago, leccyflyer said:

you appear determined to stifle with that approach that we'll just have to accept what comes to pass, without at least attempting to point out the massive flaws in what is being proposed and the possible effects on our hobby.

 

Not at all 

[MattyB]

11 hours ago, Andy Symons - BMFA said:

It's worth remembering that we don't live in the US.

 

The commercial organisations lobbying UK Gov for improved access to the low level airspace are no UK corner-shops - they are huge multinationals like Google, Amazon, DHL etc., a majority of whom are headquartered in the US. These are the organisations that have been calling for globally harmonized regulations to enable their BVLOS commercial operations to take flight since way back when (Riga 2016 at least), with (probably fantastical) promises of significant regional investment, jobs and tax £££s for those countries that can get there first. That is what UK Gov are chasing, and that is why they are likely to look to places like the US where RID implementation is further along when deciding how to implement it here.

 

9 hours ago, Peter Jenkins said:

Who cares how they do it in the USA.  The CAA certainly wouldn't have outsourced the clearance of the 737 Max to the manufacturer.

 

That may well be the case, but the problem with your argument is that if the CAA is more conservative than the FAA, they will be less prepared to outsource FRIA authorisation to national associations, not more. Information on the FRIA authorisation processes in countries other than the US seems to be very hard to come by online, but other than the US (where it is definitely done by the FAA), does anyone know of any countries that have implemented RID but outsourced the authorisation of FRIAs to their national model flying associations? @steve too, do you know how they do site authorisations in Japan and France (for instance)?

 

9 hours ago, Peter Jenkins said:

...In the USA, the people distrust their government and while you could make a case for us Brits distrusting our government, on the whole we do place our trust in our elected government.  If we lose trust we vote in another lot - it's not that simple in the USA.  In the US system you have power split between the President, Congress and the Supreme Court.  Politics is driven far more by money in the US than here.  

 

I agree the two party system and the split of power across the Congress and the Senate does make it a very different system, but I doubt anyone who has watched more than 30 mins of the Covid enquiry currently places trust in this particular government, whether they voted for it or not! The last study by the ONS indicates UK trust in government is very low these days, and scandals such as Rishi's wife's non-dom status and the recent rowing back by Baroness Mone regarding PPE doesn't indicate to me that we our politics is less driven by money than anywhere else. Better shut up though, this is heading dangerously close to murky political waters now....!

 

Edited December 19, 2023 by MattyB

[leccyflyer]

9 minutes ago, GaryWebb said:

 

Not at all 

I can only go by what you have posted, which includes statements that you actively welcome the introduction of RID, that you don't forsee a problem going forward and the gross, binary, over-simplification that we will either have to accept exactly what is implemented or leave the hobby, against a long standing background of attempting to minimise and undermine legitimate discussion on the topic.

[Peter Jenkins]

20 minutes ago, Ron Gray said:

Bit harsh Peter could well have been a typo, CAA typed instead of FAA, give the guy the benefit of the doubt.

My comment was to contrast the FAA and CAA.  I was told I was wrong. I merely answered his question using his words Ron. 

[MattyB]

1 hour ago, GaryWebb said:

We can do our CAA Operators & Flier ID's through the BMFA so why not the Site Authorisations as well when Remote ID comes into play or is this a case of Matty knows more than the BMFA or anyone else does again, which in all honesty thats what I'm seeing and the impression I'm getting everyday in general.... Noone truly knows how Remote ID is going to work, be implemented, paid for or governed other than the CAA,, and Andy Simmonds says above, " We do not live in the US " and things work differently here ,, All this speculation into how it will play out based on what the US and other countries do is of no useful benefit to how it will or will not play out for us in the UK...

 

The national associations and many of us here certainly know a heck of a lot more about the likely endgame than you. That is because we have actually READ hundreds if not thousands of pages of white papers, consultations and proposals on future UAS integration and regulation from government agencies across the world since the mid 2010s.

 

By contrast you have told us that you have not read the latest CAA consultation, don't intend to respond, and will bend over and acquiesce to whatever regulation they pass regarding RID. On that basis I struggle to see why you continue to contribute in these threads - we all know your views by now, so if you don't want to hear discussion amongst modellers who actively want to challenge this ridiculous regulatory over-reach, just don't participate.

 

Edited December 19, 2023 by MattyB

[leccyflyer]

When it comes to the forthcoming need for site authorisations I'd suggest that from the most cursory examination Gary actually has much more to worry about than many people who are taking a solid look at the risks to their hobby and formulating their response accordingly.