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

[steve too]

2 hours ago, Andy Symons - BMFA said:

The EU regulations do not mandate any Remote ID requirements for aircraft operated under an Article 16 Authorisation within the framework of model flying associations, or for model aircraft within the Open Category (A3, C4) and the BMFA requests that this position is maintained in any amendments made to the UK regulations.

 

Actually the original version of 2019/947 (of which the BMFA said "We believe that the recently finalised European proposals are pragmatic and fit for
purpose.") does require remote identification for unmanned aircraft operating in the specific category and Article 16 itself is silent on the subject.

[Andy Symons - BMFA]

30 minutes ago, steve too said:

 

Actually the original version of 2019/947 (of which the BMFA said "We believe that the recently finalised European proposals are pragmatic and fit for
purpose.") does require remote identification for unmanned aircraft operating in the specific category and Article 16 itself is silent on the subject.

Not sure what your point is. The statement in the reponse is entirely correct.

[Martin_K]

I finished filling in the response form yesterday, saved, but did not submit it, waiting to see what guidance would be forthcoming. My focus was on self built, fixed wing, model aircraft and the mis-match between the traditional operation of these and regulation of manufactured UAVs and commercial drone operations.

 

Interesting to see that the BMFA guidance makes only one reference to self build, instead focusing on the activity of flying. I will go over my submission again in a couple of days, having had time to digest the complexities.

[GrumpyGnome]

Filled mine in and submitted it. Largely followed the BMFA 'template' but with my own words...... not too onerous.

[John Lee]

17 hours ago, Martin_K said:

My focus was on self built, fixed wing, model aircraft and the mis-match between the traditional operation of these and regulation of manufactured UAVs and commercial drone operations.

 

 

I have also responded on these lines.

 

I've had cries for help from several (all professional qualified in other spheres) Club Members this morning confused with the BMFA's response, describing it as 'daunting'. As a retired regulatory Compliance Officer & full size Flying Instructor the consultation is bread & butter for me and hopefully I've been able to help. But I fear in it's present form the BMFA's response as a template is, let's just say, 'sub-optimal' for the likes of my Club mates.

[PeterF]

I recognise that BMFA is covering a broad church with the BDF but for the traditional model flier that existed prior to drones self building or fitting out ARTFs and who has continued in the same vein, we have not followed or absorbed all the different drone type criteria from CAA and within the Article 16 authorisation we have not had to absorb all the different categories. A response for this type of traditional modeller making up the bulk of the membership where concerns are high about further intrusive legislation may have been useful.

[Andy Stephenson]

Is it correct that the completed questionnaire can be saved and edited before submitting it. I would always like to revise my answers to earlier questions based on the later ones.

[steve too]

2 hours ago, John Lee said:

But I fear in it's present form the BMFA's response as a template is, let's just say, 'sub-optimal' for the likes of my Club mates.

 

Part of the BMFA's response surprised me. There are some yeses where I said no.

[steve too]

22 hours ago, Andy Symons - BMFA said:

Not sure what your point is.

 

The BMFA supported the EU regulations (this is clear from their submission to the Commons Science and Technology enquiry on drone use).

 

The EU regulations include remote ID in the open and specific categories (UAS.SPEC.050 (l)).

[Martin_K]

1 hour ago, Andy Stephenson said:

Is it correct that the completed questionnaire can be saved and edited before submitting it. I would always like to revise my answers to earlier questions based on the later ones.

Andy,

 

Yes, you can save your work, go back and revise. Browser cookies must be enabled for this to work. When saving you will get a link by Email from the CAA. This takes you back to the start of the form, not where you left it.

 

Easier to keep your head clear in a number of sessions rather than one long session, I think.

Edited August 27, 2023 by Martin_K

[Andy Symons - BMFA]

2 hours ago, steve too said:

 

The BMFA supported the EU regulations (this is clear from their submission to the Commons Science and Technology enquiry on drone use).

 

The EU regulations include remote ID in the open and specific categories (UAS.SPEC.050 (l)).

Still not sure what your point is. They EU regulations were a pragmatic solution for model flying as they enabled, thanks to the work of the BMFA CEO, the facility of the CAA to issue Article 16 authorisations, which means that at the moment barely nothing has changed for model flying as BMFA members. 

Nowhere does Article 16 or the provisions for it include remote ID. 

 

The BMFA is strongly against remote ID for model aircraft flying as the BMFA response clearly states. However if you aren't happy with the BMFA response you have the opportunity to submit your thoughts to the consultation.

[Dickw]

Another form completed and submitted, and I found the BMFA's responses very helpful in formulating my own answers.

I did it in several goes using the "close and come back later" option offered, so had plenty of chances to reconsider and edit my replies before final submission.

 

Dick

[PeterF]

Completed mine from the POV of self build model flying using the BMFA prompts but my own words. As others have noted answering "no" to some questions where BMFA have a more neutral stance.

[Martin Dilly 1]

Peter F and others make a very important point. Many of us have never bought a model aircraft in our lives, but the tenor of the CAA proposals is that they are regulating a commercial product, ("product requirements", "manufacturer standards", "product labelling"); there seems a serious risk that unless we stress that many members of Britain's largest airsports organisation, the BMFA, have been designing and building the aircraft they fly and compete with safely for over a century (sometimeas it feels like that personally...) then they risk being legislated out of existence. The BMFA bumper sticker sums it up well, - Model Flying - Sport with Built-in Satisfaction.

 

Many of the aircraft we fly weigh under 250grams, - F1B Wakefields for example and a lot of other free flight competition and recreational types, - and the imposition of any sort of remote ID device would be a serious weight and possibly safety penalty.

 

The STEM benefits of what we do - designing, building and trimming an aircraft for the best possible performance -  are too valuable to allow legislation primarily aimed at commercial products to swamp them.

[steve too]

4 hours ago, Andy Symons - BMFA said:

Nowhere does Article 16 or the provisions for it include remote ID. 

 

You do realise the Article 16 authorisations are in the specific category and that the CAA can change such authorisations don't you?

[steve too]

1 hour ago, Martin Dilly 1 said:

Many of the aircraft we fly weigh under 250grams, - F1B Wakefields for example and a lot of other free flight competition and recreational types, - and the imposition of any sort of remote ID device would be a serious weight and possibly safety penalty.

 

The Spektrum SkyID is 14g (with a case) and there are lighter offerings, e.g. Dronetag's BS.

[Cuban8]

4 minutes ago, steve too said:

 

The Spektrum SkyID is 14g (with a case) and there are lighter offerings, e.g. Dronetag's BS.

I'd love to hear a good reason why a model aeroplane that is flown quite legally and safely under radio control by a pilot standing on the ground, and within unaided view (no see it, no fly it - including first person view regulations with a spotter, naturally, as well as  common sense free flight operations) would possibly need to be transmitting a remote ID. Who on earth would be interested  - and up to now without remote ID,  what difference has it made?

Very happy to be enlightened.

 

[leccyflyer]

Getting a bit fed up with hearing that fitting RID to our models is no big deal, because lightweight units will be available, so where's the harm? 

 

Also getting a bit fed up with having to wade through multiple pages of complex documents in order to formulate an opinion and communicate it back, for the authorities to just do what they were going to do anyway.  I don't think everyone just regurgitating the BMFA's position, by cutting and pasting is going to make any difference, so it will need to be responded to as individuals, in our own words, which will make just as little difference.

[Andy Symons - BMFA]

40 minutes ago, steve too said:

 

You do realise the Article 16 authorisations are in the specific category and that the CAA can change such authorisations don't you?

Any of the regulations can be changed going forward, but that has always been the case since model aircraft flying came in to existence.  You do seem to think it's something new for some reason.

 

It is why it's important that we engage in a constructive  way when there are consultations and as many of us as possible submit responses.

 

So far, we have done a very good job of minimising the effects of regulatory changes.

[Andy Symons - BMFA]

26 minutes ago, Cuban8 said:

I'd love to hear a good reason why a model aeroplane that is flown quite legally and safely under radio control by a pilot standing on the ground, and within unaided view (no see it, no fly it - including first person view regulations with a spotter, naturally, as well as  common sense free flight operations) would possibly need to be transmitting a remote ID. Who on earth would be interested  - and up to now without remote ID,  what difference has it made?

Very happy to be enlightened.

 

Exactly the BMFA position.

Edited August 27, 2023 by Andy Symons - BMFA

[steve too]

11 hours ago, Cuban8 said:

I'd love to hear a good reason why a model aeroplane that is flown quite legally and safely under radio control by a pilot standing on the ground, and within unaided view (no see it, no fly it - including first person view regulations with a spotter, naturally, as well as  common sense free flight operations) would possibly need to be transmitting a remote ID.

 

Ask the BMFA. They are the ones who support the EU regulations, not me.

 

 

[Andy Symons - BMFA]

18 minutes ago, steve too said:

 

Ask the BMFA. They are the ones who support the EU regulations, not me.

 

 

That would be the regulations that have a specific facility to exempt model aircraft flying from remote ID and pretty much everything else that is being considered, that was also carried in to the UK regulations. Sounds like you want that facility removed. Which is odd.

Edited August 28, 2023 by Andy Symons - BMFA

[leccyflyer]

Sorry, but I'm really not happy with the BMFA recommended response to this, the most critical question in the document.

 

Quote

6. Should CAA update how model aircraft operations are regulated (Opportunity 3) and why? A. Neither yes or no In terms of model flying, the Call for Input is focussed entirely on the Open Category. The EU accommodated model flying in the Open Category with the A3, C4 classification but could have made it clearer. There is perhaps a danger in defining model aircraft and this is something which EASA considered at length, instead considering model flying (including FPV Drone Racing) as an activity and this approach remains our preference. The model flying community’s preference from the outset was for model flying to be excluded entirely from the drone regulations and this was achieved to some extent for those operating within the framework of an Association with the provision of Article 16, which (so far) has minimised the regulatory burden on members. Our hope is that in the worst case, the current status quo will be retained with Article 16. Ultimately, we would like to see model flying (in its entirety) returned to the pre-EU regulatory position, being regulated in the proportionate way it used to be, along the lines of how Hang Gliding and Paragliding is still dealt with.

 

FPV Drone racing is NOT model flying and IMO the BMFA's adoption of that position is at the heart of the failure to produce a definition of model aircraft which would enable exclusion of traditional model aircraft operation of a hundred years good standing from the operation of drones. It is ridiculous to claim that such a definition is not possible, as it is clearly being used in this very document.

 

BMFA should not have touched FPV drone racing with a greasy barge pole, it's not model flying by any stretch of the imagination. As a sport it should have just had it's own national body and BMFA should have stuck to model flying.

 

The Neither Yes or No answer to this question is clearly aimed at keeping FPV Drone flying under BMFA control and does a disservice to actual model flying.

Edited August 28, 2023 by leccyflyer

[steve too]

23 minutes ago, Andy Symons - BMFA said:

That would be the regulations that have a specific facility to exempt model aircraft flying from remote ID and pretty much everything else that is being considered, that was also carried in to the UK regulations. Sounds like you want that facility removed.

 

Stop playing silly games. Article 16 is silent on the subject of remote ID. We will only be exempt if the CAA put an exemption in our authorisation.

[David perry 1]

I filled it and sent it.  But like others,  from the pov of a balsa basher.  Many of the solutions just dont apply to what I do.  As for remote ID...absolutely NOT.  What if theres no cell link nearby?  It becomes pointless.  Its pointless anyway because naughty people wont obey.  As for geoawareness, i pointed out that as a manual LOS flier I am always geo aware.  I know where i am.

 

Its all rubbish of course, the genie is out of the bag now.  I see a future where the only model flying will be furtive home built small stuff.. all else banned.  I remember reading about certain Arab states where this was the case in the 80s and thinking "how?".  Now i know.