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

[Ron Gray]

I sent an email to the CAA about the 'facts' within the document:

 

Sirs

 

As a regular UAS operator I am going through the process of understanding the above document so that I can provide my responses by the 10th January. However I have some concerns about some of the ‘facts’ listed or referred to in the document.

 

On page 5 and page 7 you make the following statements:

 

There is clear evidence that some of these risks have already materialised.

Between November 2020 and October 2023, police received 18,290 reports of drone flights

involving a legal, nuisance, criminal or safety concern. Police received 5,005 such reports

between 1st January and 6th October 2023 - a 10% increase over the same period in 2022.

 

Data provided by the police and government demonstrate that these risks have already

materialised and are growing. Since November 2020, police have received 18,290

reports of drone flights involving a legal, nuisance, criminal or safety concern. In the

first 9 months of 2023, police received 5,005 reports - a 10% increase over the same

period in 20226 . In the 6 weeks following 23rd September 2023, the CAA received 558

reports7 of UAS operating within a Flight Restriction Zone (FRZ) or outside a FRZ but

over 400ft. Between January and October 20238 , 9 UAS have been reported operating

between 6,000 and 13,000 feet9

 

What you fail to list are the numbers of the reported incidents that turned out to be not UAS related. Which leads to the next statement, Page 8 1.5

 

The impacts of these risks go beyond just safety and security – they also require

significant public resources to manage, cause disruption to lives and businesses, and

compromise the viability of the commercial UAS sector. The closure of Gatwick airport

in 2018 was estimated to cost the police £459,000, the airport between £1.4m and

£15m, and the airlines over £35m.

 

Whilst the cost of the disruption cannot be argued, the facts can be. Despite all of the investigations carried out it has not be proven that an unauthorised UAS was the culprit, it could easily have been a black bin liner blowing in the breeze (not the first time that has ’spooked’ authorities)

 

On page 7 1.2 you state:

 

Over the coming years, we expect the UAS sector to grow as even more individuals

and businesses harness their benefits. This will support our economy to grow and

create new jobs, benefitting us all. External analysis predicts that drones could save

businesses up to £22bn a year and contribute up to £45bn to the UK economy by

2030. UAS could enable up to 270,000 jobs

 

 This refers to the consolation document ‘Skies without Limits’ commissioned from PWC which paints a rather nice rosy view of the future of commercial type UAS. I notice in that document it only refers to ‘best case scenarios’ yet to be a properly balanced report it should also, in my opinion give the ‘worst case scenario’ too. As it stands it is a largely biased viewpoint.

 

I welcome a response to my concerns detailed above.

 

 

And this was the CAA's response:

 

Hi Ron,

 

Thanks for your email. Feedback will be considered as part of the consultation process, and we expect to publish a full response in Spring next year.

 

Kind regards,

 

The Review of UAS Regulations team

 

 

Edited December 22, 2023 by Ron Gray

[Peter Jenkins]

So, don't confuse me with facts my mind is made up.  Well,we really must all submit our responses now!

[Arthur Harris]

1 hour ago, Zflyer said:

If anyone cares to look its recorded as a 'malicious Incident' by the Police and there is no positive evidence of it being a drone, to my mind a somewhat disingenuous use of information on behalf of the CAA.

There has been no evidence of a drone. An air traffic expert and a drone instructor quoted by the BBC speculated that the "drone" had in fact been a bird, a plastic bag, a balloon, a paper lantern or a distant manned aircraft.[32] In 2020, the Guardian journalist Samira Shackle published an investigation into the incident. Shackle suggested it was an instance of mass panic, in which "people attribute a sinister cause to something that had been there, unnoticed, all along. "Gatwick Airport drone incident - Wikipedia or even a drone sent up by the police to look for it once the initial "sighting" had been made.

Edited December 22, 2023 by Arthur Harris

[kevin b]

I just submitted mine. it took an hour to complete !!!

I feel sorry for the people who have to process them all. I don't think they will be using AI.

I bet they aren't unpaid volunteers like the BMFA.

[Arthur Harris]

2 minutes ago, kevin b said:

I just submitted mine. it took an hour to complete !!!

I feel sorry for the people who have to process them all. I don't think they will be using AI.

I bet they aren't unpaid volunteers like the BMFA.

Do you think anyone will read them? I don't. The consultation is a paper exercise - the decisions will have already been made, (like Rishi saying he will be weighing up the pros and cons of HS2 when the government had already decided to cancel it).

I think FRZs will be increased in area, and clubs that fly within them will be forced to abandon operations.  

I also think that like a lot of government decisions, the unintended consequence will be that there will be an increase in unregulated flying. If our current police can't deal with real crime, they won't be able to spare manpower to stop individuals flying discreetly in parks and common land.

[kevin b]

The BMFA have put the request out for us to respond to the information request.

This is our association requesting us to support them in their efforts to minimise any further restrictions on our hobby.

If you can all spend time and effort moaning a bucket load on this thread, then you should have time to fill in the questionnaire.

That would be a little more constructive, don't you think ?

 

 

 

[Arthur Harris]

8 hours ago, kevin b said:

The BMFA have put the request out for us to respond to the information request.

This is our association requesting us to support them in their efforts to minimise any further restrictions on our hobby.

If you can all spend time and effort moaning a bucket load on this thread, then you should have time to fill in the questionnaire.

That would be a little more constructive, don't you think ?

 

The BMFA already knows our views. If they haven't yet cottoned on to model fliers wanting to be exempt from further UAV regulations, they are in the wrong job. We have complied enough, flying model planes within line of sight a few hundred metres around a known model airfield is harmless.

[Ron Gray]

8 hours ago, kevin b said:

If you can all spend time and effort moaning a bucket load on this thread

If that’s a generalisation then you clearly haven’t read through all of the thread, sure there is some moaning and FUD but there are some really useful and informative posts on here too that can help people make better decisions. IMO it’s no good just blindly following the BMFA/LMA suggestions if you don’t understand why they’ve made them, like a lot of others on here I’ve used that to assist me but do not agree with all of their responses.

Edited December 23, 2023 by Ron Gray

[GrumpyGnome]

47 minutes ago, Arthur Harris said:

The BMFA already knows our views. If they haven't yet cottoned on to model fliers wanting to be exempt from further UAV regulations, they are in the wrong job. We have complied enough, flying model planes within line of sight a few hundred metres around a known model airfield is harmless.

 

The BMFA aren't asking for our views. They are asking us to tell our views to the CAA by getting involved in the process.

 

And, again, this doesn't just affect people flying within a few hundred metres of a known model airfield......

[Zflyer]

I will have to check but im sure there is a sentence in the CAA document about registaring tethered models!!!!

[Simon Burch 1]

1 hour ago, Arthur Harris said:

The BMFA already knows our views. If they haven't yet cottoned on to model fliers wanting to be exempt from further UAV regulations, they are in the wrong job. We have complied enough, flying model planes within line of sight a few hundred metres around a known model airfield is harmless.

 

Simply saying 'we want to be exempt from UAS regulation' would, I'm sure, reflect the the views of most model flyers but, sadly, 
taking that line in isolation won't do us any favours.

 

As you said in an earlier post, the CAA has almost certainly already made up its mind.  The new regulations, including RID and geo-fencing, are coming whether we like it or not.  

 

For the continued future existence of this hobby, it is surely essential for us all to highlight the many flaws in the CAA's UAS proposals, and thus, hopefully, help to minimise their impact upon model flying.  I think the BMFA's response does a pretty good job in this respect, and it deserves our support.

[Paul De Tourtoulon]

42 minutes ago, Simon Burch 1 said:

Simply saying 'we want to be exempt from UAS regulation' would, I'm sure, reflect the the views of most model flyers but, sadly, 
taking that line in isolation won't do us any favours

Sitting on a railway line with your eyes closed expecting the train not to come,,

[Wookman]

11 hours ago, Arthur Harris said:

I think FRZs will be increased in area, and clubs that fly within them will be forced to abandon operations.  

To give an idea of things to come this is exactly what has happened in France. Large swathes of land have been swept up into restricted zones.

The Presque Isle de Crozon is now a red zone effectively stopping the use of many good coastal slope soaring sites to the west of the Menez Hom.

Edited December 23, 2023 by Wookman

[Arthur Harris]

9 minutes ago, Wookman said:

To give an idea of things to come this is exactly what has happened in France. Large swathes of land have been swept up into restricted zones.

The Presque Isle de Crozon is now a red zone effectively stopping the use of many good coastal slope soaring sites to the west of the Menez Hom.

This is why I think we (model plane flyers) should disassociate ourselves from drones, large models, jet turbines and other models that draw attention to our hobby. Us electric flyers can keep our heads down and off the radar.

[GrumpyGnome]

3 minutes ago, Arthur Harris said:

This is why I think we (model plane flyers) should disassociate ourselves from drones, large models, jet turbines and other models that draw attention to our hobby. Us electric flyers can keep our heads down and off the radar.

That really doesn't deserve a response........

[FlyinFlynn]

15 minutes ago, Wookman said:

To give an idea of things to come this is exactly what has happened in France. Large swathes of land have been swept up into restricted zones.

The Presque Isle de Crozon is now a red zone effectively stopping the use of many good coastal slope soaring sites to the west of the Menez Hom.

This site shows the extent of the restrictions in France. There are some interesting locations included for some reason..large swathes of the Bay of Biscay and the Med.

The red parts are 'vol interdite' (no flying) and the orange flights limited to 30 metres max height.

[Zflyer]

Perhaps our French counterparts should be demanding reasons for the restrictions. I suspect its just laziness.

[Arthur Harris]

1 hour ago, GrumpyGnome said:

That really doesn't deserve a response........

I don't think it unreasonable. Business will win in any battle with aeromodelling if we tackle them head on. After all, ours is a niche hobby.

A case could be made for small EP models (say, under 2 kg) operating in a defined area. That would preserve aeromodelling as a pastime and might be acceptable to the CAA.

[Martin_K]

There is already international consensus among law makers on the mass of allowable small models, derived from the kinetic energy carried. That is 250 grams.

[Paul De Tourtoulon]

47 minutes ago, Zflyer said:

Perhaps our French counterparts should be demanding reasons for the restrictions. I suspect its just laziness.

I asked the government 6+ month ago, who and why decided on the new restrictions,still no answer, I also asked our club president an acting Gendarme and still no answer from him,  my garden went from 150 m to 0 last year including ALL of the countryside around me, go onto FlyinFlynn geoportail and put down, saint-privat-des-vieux, 30340 that's where I live.

[GrumpyGnome]

38 minutes ago, Arthur Harris said:

I don't think it unreasonable. Business will win in any battle with aeromodelling if we tackle them head on. After all, ours is a niche hobby.

A case could be made for small EP models (say, under 2 kg) operating in a defined area. That would preserve aeromodelling as a pastime and might be acceptable 

 

I'd suggest it's unreasonable to anyone that:

 

Flies a jet turbine

Flies a 'large' model - whatever you think that is

Flies any ic powered aircraft

Does not fly at a 'club' site - e.g. country members, many slope soarers

Etc. Etc.

 

As a niche hobby, we need to stick together and not exhibit an "I'm alright Jack" attitude.

[RottenRow]

I have just completed my response; took about an hour and a half in total.

 

I used the BMFA's response for some guidance, but as I am a model aircraft builder and flier only, not drones, I did try to make my answers specific to my own interest. I didn't feel that I was qualified to provide answers to some of the drone-specific questions. As I fly both from both clubs and other locations I have answered accordingly (with the prospect of requiring RID in mind).

 

1 hour ago, FlyinFlynn said:

This site shows the extent of the restrictions in France. There are some interesting locations included for some reason..large swathes of the Bay of Biscay and the Med.

The red parts are 'vol interdite' (no flying) and the orange flights limited to 30 metres max height.

 

That French site is interesting, and concerning. I don't know for how long that has been in force but it would be interesting to know how well it is being adhered to (by model aircraft fliers and drone fliers).

 

Of the three clubs of which I am a member, only one has made contact with its membership about the consultation (this was before the BMFA's e-mail to members on Thursday). I have brought the subject up at both of the other clubs but have since heard nothing, which is disappointing but not really unexpected. As I mentioned in a previous post, apathy will certainly not help us.

 

Brian.

[Martin Harris - Moderator]

I'd want to know a lot more about the regulations before commenting on the site e.g. is there a mechanism to authorise flight in the red blanket areas?

 

However, I do consider the area covering 100 miles or so out into the Bay of Biscay to be a bit of a red herring!

[Shaun Walsh]

4 hours ago, FlyinFlynn said:

This site shows the extent of the restrictions in France. There are some interesting locations included for some reason..large swathes of the Bay of Biscay and the Med.

The red parts are 'vol interdite' (no flying) and the orange flights limited to 30 metres max height.

The other interesting bit is a height restriction of 50 metres over the Channel Islands.

Since when did the French government get to decide matters in a British Crown Dependency?

[FlyinFlynn]

 

 

1 hour ago, Martin Harris - Moderator said:

I'd want to know a lot more about the regulations before commenting on the site e.g. is there a mechanism to authorise flight in the red blanket areas?

 

However, I do consider the area covering 100 miles or so out into the Bay of Biscay to be a bit of a red herring!

 

I don't know the answer to that one, however my old flying club site has a big red splodge over all of it but they still fly from there and the site is registered with the FFAM as a RID free authorised site..... Maybe it is marked as a no fly zone BECAUSE it is registered and non-members are prohibited from flying on it? That might explain the areas around Biscay and the Med if, say, the navy has claimed the use of it for gunnery practice.

 

/straw_grabbing

Edited December 23, 2023 by FlyinFlynn