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

[Andy Symons - BMFA]

4 minutes ago, steve too said:

 

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.

I'm not the one playing silly games, of course we will only be exempt if the CAA put an exemption in our authorisation, that's not new to anyone, just like getting exemptions to certain aspects of the ANO isn't new, nor the fact that the CAA could have opted not to issue exemptions.

However, due to the hard work the BMFA has put in over the years in Europe the facility remains for the CAA to continue to issue exemptions to us as the provision for Article 16 was carried into UK regulation from the EU regulation. That facility recognises that model aircraft flying as an activity is very different to drone flying and builds in to the regulation the option to exclude us from regulations that are simply not fit for purpose when it comes to model aircraft flying but could be fit for purpose for drone flying.  

I really cannot see why you think having Article 16 is not a good thing. We will still  need to stay engaged with the CAA and respond to consultations in a realistic and constructive way and continue to operate safely, lawfully and with consideration, just as we always have.

Regulations can change, this has always been the case, the BMFA will keep fighting to minimise their effects on our activities though, so far it has been with some success.

You do seem determined to try and find a stick to beat the BMFA with, even trying to suggest the BMFA is supportive of remote ID for model aircraft flying when clearly they are not. So far your search for a stick hasn't even yielded a twig.

 

[Andy Symons - BMFA]

23 minutes ago, David perry 1 said:

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.  

This is exactly why having the facility for an Article 16 authorisation is so valuable, it gives the facility for the CAA to not apply many of those solutions to what you do. Remote ID and Geo-awareness are not appropriate for what we do so we need to ensure we let the CAA know that and then there is every possibility they won't be included in our authorisation so the future can be pretty much carrying on as we always have.

[Alan Gorham_]

32 minutes ago, David perry 1 said:

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.  

FYI remote ID does not rely on mobile phone cells. It is a short range link intended to allow either broadcast or serve the ID upon enquiry. The Spektrum SkyID referenced earlier in this thread uses Bluetooth, while some of the devices sold in France use a flavour of WiFi. 

[FlyinFlynn]

4 minutes ago, Alan Gorham_ said:

FYI remote ID does not rely on mobile phone cells. It is a short range link intended to allow either broadcast or serve the ID upon enquiry. The Spektrum SkyID referenced earlier in this thread uses Bluetooth, while some of the devices sold in France use a flavour of WiFi. 

At the moment that is true, however, mission creep will all but guarantee this is the thin end of the wedge. I can foresee a future requirement for pilots to be on-line in real time to allow the authorities to monitor (and fine transgressors) from a comfy chair in a data centre instead of having to get plod out on patrol.......  as it will be a more efficient fund raising procedure. Lets not kid ourselves this is about safety.

 

19 minutes ago, Andy Symons - BMFA said:

it gives the facility for the CAA to not apply many of those solutions to what you do

Is this the best we can hope for?.... having the good graces of a government body allow you an exemption to fly?  Should it not be something that is a 'God given right' unless you misbehave .....whatever happened to 'innocent until proved guilty'

[Ron Gray]

4 minutes ago, FlyinFlynn said:

'God given right' unless you misbehave .....whatever happened to 'innocent until proved guilty'

Those died out years ago.

[Andy Symons - BMFA]

7 minutes ago, FlyinFlynn said:

Is this the best we can hope for?.... having the good graces of a government body allow you an exemption to fly?  

It's how it has always been. 

[Cuban8]

13 hours ago, leccyflyer said:

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.

Trouble is, we're damned if we do and damned if we don't. It's a tedious task, but if we can find the time and energy to make a reply then at least it'll appear that we're 'engaging' with the authorities and taking their consultation seriously. I actually feel quite upbeat about our chances and if we continue to put our case forward in a logical and thoughful way, I can see us coming out with a satisfactory result.

[leccyflyer]

22 minutes ago, Cuban8 said:

Trouble is, we're damned if we do and damned if we don't. It's a tedious task, but if we can find the time and energy to make a reply then at least it'll appear that we're 'engaging' with the authorities and taking their consultation seriously. I actually feel quite upbeat about our chances and if we continue to put our case forward in a logical and thoughful way, I can see us coming out with a satisfactory result.

I know, I know and, of course, I'll put the effort in one evening this week to formulate my response. That doesn't mean I can't get a bit fed up with it all though - it seems to be never ending, they are like a dog with a bone and just cannot even let the dust settle before embarking on the next ill thought out implementation of unwanted and un-needed legislation.

[Glenn Philbrick]

 I have sent my form in. I must admit to it being a bit difficult to reply to some of the points as it seems to be very much pointing to drone flyers which I'm not. Wether we like it or not the BMFA are our representatives so I don't think it helpful that this thread becomes the usual bash the BMFA session.

[Ron Gray]

18 minutes ago, leccyflyer said:

That doesn't mean I can't get a bit fed up with it all though - it seems to be never ending, they are like a dog with a bone and just cannot even let the dust settle before embarking on the next ill thought out implementation of unwanted and un-needed legislation.

That is what they want, people to get fed up and not do anything about it as they can't be bothered!

[Cuban8]

10 minutes ago, Glenn Philbrick said:

 I have sent my form in. I must admit to it being a bit difficult to reply to some of the points as it seems to be very much pointing to drone flyers which I'm not. Wether we like it or not the BMFA are our representatives so I don't think it helpful that this thread becomes the usual bash the BMFA session.

I'm more than happy for our national body to represent us in this matter and I don't see the need for or any point in 'bashing' - if indeed that's occured. We pay our dues year in and year out and go about our business of enjoying the hobby, and BMFA get on with their stuff in the background as it might simply appear  to the majority of members.

Now.....we really need them to earn their corn, so let's give them the chance to do so - they've had a pretty good track record up to now.

[David perry 1]

7 minutes ago, Ron Gray said:

That is what they want, people to get fed up and not do anything about it as they can't be bothered!

Absolutely.

The issue is autonomous air vehicles of the future.  There is no doubt that autonomous vehicles, flight planned on line and remotely authorised to fly, will be very commonplace.  It makes sense.  Trouble is it will effectively close all airspace below say 500ft AGL to anything and everything  not squawking an ID.  I fear a lot of light aviation, paragliding,  kite flying and of course models will either have to carry transponders or be grounded.  We are heading for a gloomy future and we brought it on ourselves with flight sims, cheap chinese foamies, quads and FPV.  Add a bit of gps and a few greedy accountants and bingo...aeronautical dystopia.

 

The CAA dont care, they dont have the manpower let alone the will power.  Anyone with half a brain can, if they want to, distinguish between a drone, a UAS and a model aeroplane and they need make no reference to 'toys' to do it.  The CAA is a profit centre and thats their bottom line.  

 

Model fliers could EASILY be excluded from all this legislation if it were about anything except an airspace grab.  The rules achieve no increase in safety because the bad guys wont comply.  The stupid wont comply. The ignorant wont comply. Only the good guys will try, and fail and be grounded or punished.  

 

Quite how my 4ft span 3 channel model with a duration of 10 minutes affects  anything  except a commercial autonomous vehicle is hard to see.  Its an airspace grab pure and simple.

[leccyflyer]

Good post, but then you have to go and spoil it by reference to things that you just don't happen to like, such as cheap Chinese foamies. The existence of cheap Chinese foamies has zero impact on the bringing of this legislation, any more than the existence of Keil Kraft Flying Scale rubber powered models - well other than the definition of the latter as flying models was hugely optimistic.

[steve too]

3 hours ago, Alan Gorham_ said:

FYI remote ID does not rely on mobile phone cells. It is a short range link intended to allow either broadcast or serve the ID upon enquiry. The Spektrum SkyID referenced earlier in this thread uses Bluetooth, while some of the devices sold in France use a flavour of WiFi. 

 

Indeed. ASTM F3411/ASD-STAN 4709-001 direct remote ID's are Bluetooth 5 long range coded advertising (and BT 4) or WiFi beacon or WiFi Aware (the later may have been dropped). France went off and did their own thing before the ASTM / ASD-STAN standards where published, their "Arrêté du 27 décembre 2019" IDs use WiFi beacon frames. There are national/regional variations on top of F3411/4709-002 with US IDs being the simplest and the Japanese being the most complex that I am aware of.

[steve too]

2 hours ago, leccyflyer said:

That doesn't mean I can't get a bit fed up with it all though - it seems to be never ending, they are like a dog with a bone and just cannot even let the dust settle before embarking on the next ill thought out implementation of unwanted and un-needed legislation.

 

There was a roadmap published in 2016 or '17. They are working through it. Eurocontrol published a report as to how various European aviation authorities (the ones who are part of the Single European Sky) are getting on last year.

[Mike Chantler]

Thanks all for raising this. I've submitted my input. Took me 30 minutes I think. Back to building.

[Cuban8]

"An airspace grab"? More like the road to nowhere IMHO. 

[aidan mcatamney]

7 hours ago, David perry 1 said:

Absolutely.

The issue is autonomous air vehicles of the future.  There is no doubt that autonomous vehicles, flight planned on line and remotely authorised to fly, will be very commonplace.  It makes sense.  Trouble is it will effectively close all airspace below say 500ft AGL to anything and everything  not squawking an ID.  I fear a lot of light aviation, paragliding,  kite flying and of course models will either have to carry transponders or be grounded.  We are heading for a gloomy future and we brought it on ourselves with flight sims, cheap chinese foamies, quads and FPV.  Add a bit of gps and a few greedy accountants and bingo...aeronautical dystopia.

 

The CAA dont care, they dont have the manpower let alone the will power.  Anyone with half a brain can, if they want to, distinguish between a drone, a UAS and a model aeroplane and they need make no reference to 'toys' to do it.  The CAA is a profit centre and thats their bottom line.  

 

Model fliers could EASILY be excluded from all this legislation if it were about anything except an airspace grab.  The rules achieve no increase in safety because the bad guys wont comply.  The stupid wont comply. The ignorant wont comply. Only the good guys will try, and fail and be grounded or punished.  

 

Quite how my 4ft span 3 channel model with a duration of 10 minutes affects  anything  except a commercial autonomous vehicle is hard to see.  Its an airspace grab pure and simple.

These are the truest words I have read.   Well done sir and thanks for posting.  What you have said is absolutely to the point and spot on.  I agree one hundred percent.   

[David perry 1]

6 hours ago, leccyflyer said:

Good post, but then you have to go and spoil it by reference to things that you just don't happen to like, such as cheap Chinese foamies. The existence of cheap Chinese foamies has zero impact on the bringing of this legislation, any more than the existence of Keil Kraft Flying Scale rubber powered models - well other than the definition of the latter as flying models was hugely optimistic.

Ah, you see, you infer what you should not.  I NEVER said I dislike cheap chinese foamies -  I have them here and have had many more!  I also have drunk a lot of diet coke...and that is also not really in my best long term interests!  I like the foamies, my B24 is way better than I could ever build...but it has brought with it a plethora of issues!  I think one of the issues is that now (well not now, but since they became available) anyone could grab a model and fly it anywhere...and they did / have/ do.  When we built them, cared for them and flew on private land or at a club (or indeed as a club on common land), things were more controlled - it took effort and rather self regulated.  The foamie changed everything.  I am not knocking what I dont like (I like the foamies) -  you might do that, feel free - but I am critiquing what we, and *I* - have done...it has not all been in our best long term interests.  However, at the time we didn't know and even if we had known, would we have changed anything?  I doubt it.

Edited August 28, 2023 by David perry 1

[john stones 1 - Moderator]

Not read BMFAs guidance yet been busy, I expect as last time my best route is supporting the BMFA. Throwing my toys out pram, calling others wimps,surrender Monkeys will achieve zero, some did it for years last time it achieved nothing, the BMFA did.

Will RID come one day ? Hope not, but we've few cards to play tbh.

[Zflyer]

The issue arose with drones/quads, call them what you will. We MAY get some leeway in the short term with less onerous regulation for LOS fixed wing and possibly heli's.

Whilst I accept the premise of "air grab" one has to consider the absolute safety parameters that will be required for autonomous flying vehicles. Many streets can readily or just about cope with cars, landing an air taxi in my road would be difficult, one would expect the car to have priority. 

In addition most, not all, flying sites are in the country side, having unmanned or even manned vehicles contaminating, sorry, using that airspace seems a little unlikely. Granted they operators would seek to minimise populated, built up, industrial, major road and rail areas by using the country side, but this fraught as well due to farming, construction and the wayward gun club!.

I imaging as we speak insurance company actuaries are drawing up policies, as any business looking to utilise this air space will have to be insured ,and I would expect the policies to be quite detailed in their exclusions. 

Further given the CAA's responsibility the job they will have policing the space and the conditions they will have to bring to bare will be mammoth I suggest. Starting with us I think is just putting a toe in the water, and we are after all 'low hanging fruit'

Just my tu'penny worth.

[Martin Harris - Moderator]

My recollection is that governments perceived an opportunity for businesses to take advantage of the emerging technology enabled by the development of drones. 
 

This was concurrent with mass availability of hobby drones and sensationalist reporting of drone sightings in mostly unlikely scenarios. 
 

Whether these factors were a driver for, or seen as an enabler for implementation of more stringent legislation or controls on our hobby is neither here nor there.  The genie is not only out of the bottle but is now in full control.  Complaining about the need for these regulations is futile and we need to concentrate on providing constructive input to limit or, thinking wishfully, reverse some of the more restrictive aspects. 
 

A major step would be to formulate an acceptable definition for bona fide model flying as we know it.  There are signs that the CAA recognise the difference - witness reference to drones in some recent publications - but I can’t imagine them complicating their own lives by attempting to produce watertight legislation to accommodate us.   If anyone can help here, I suspect the BMFA would love to hear from them…

[MattyB]

On 26/08/2023 at 11:22, Andy Symons - BMFA said:

From the response.

However, the BMFA would be strongly opposed to any Remote ID requirements for model aircraft. Our members have a collective fleet of around 500,000 aircraft which are usually operated from fixed remote locations well away from areas likely to require Remote ID interrogation and within VLOS of the pilot (generally making it easy for them to be identified in the unlikely event of there being a requirement). The BMFA believes that Remote ID would be disproportionate and unnecessary imposition on the model flying community.
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.

What if keeping alignment with our neighbours is best for us?

There are a few problems for me here, one with the original question, the others with the BMFA response. Here is the question and the full BMFA guidance::

 

“14. Should CAA implement Remote ID (Opportunity 11) and why?

A. Neither yes nor no

 

Many drones being introduced onto the marked already incorporate the facility for Remote I.D. and this is probably appropriate due to the locations they can be operated from and the increased potential for security/privacy concerns due to them being equipped with cameras.
Interrogation of the Remote I.D. should be limited to enforcement agencies and the BMFA would be opposed to the information being accessible by the general public.

Existing/Legacy UAS under 250gm should be excluded from the Remote ID requirements and there should be a suitable transition period for existing/legacy UAS over 250gm before they must comply.

However, the BMFA would be strongly opposed to any Remote ID requirements for model aircraft. Our members have a collective fleet of around 500,000 aircraft which are usually operated from fixed remote locations well away from areas likely to require Remote ID interrogation and within VLOS of the pilot (generally making it easy for them to be identified in the unlikely event of there being a requirement). The BMFA believes that Remote ID would be disproportionate and unnecessary imposition on the model flying community.

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.”

 

Most of the response I am ok with, but there are some fairly significant issues I can see:

• This whole question is somewhat moot given earlier in the doc they confirm they are effectively obligated to bring legislation implementing RID. If that is the case, why are they asking for opinions? Probably just so they can implement whatever they have already decided having “formally consulted” the public 🙄 
• By answering “neither yes nor no” we will not make any statistical impact on the responses to that question (e.g we are just putting a large weighting on the middle “not particularly bothered” answer). Even though I agree there are RTF consumer craft that probably should have RID, I will certainly not be answering with the middle answer, as that statistically undermines the fact I believe RID is completely unnecessary and disproportionate for LOS model aircraft at this stage. Sure, if clouds of delivery and survey drones were to become widespread then perhaps electronic conspicuous could become a requirement we have to meet, but we all know that is not going to happen for at least a decade, maybe longer, maybe never.
• The last bit of the BMFA response is very focussed on protecting members operating under Article 16 specifically. I suppose this may play well with some of us, but personally I’d rather see them arguing that RID is unnecessary and disproportionate for ALL recreational model flyers at this stage, not just national association members. We have given up enough rights already, this is the time to actively point out that there is no evidence that BVLOS commercial drone services are ready to start operating at any kind of scale yet. There are also plenty of other air users in the 500ft band don’t have to have RID today, so why should model flyers?

Edited August 28, 2023 by MattyB

[steve too]

5 hours ago, MattyB said:

• By answering “neither yes nor no” we will not make any statistical impact on the responses to that question

 

Indeed. Saying "neither yes nor no" to that question is, at best, naïve.

[Ron Gray]

2 hours ago, steve too said:

 

Indeed. Saying "neither yes nor no" to that question is, at best, naïve.

Not really, the BMFA, in their detailed response, clearly shows that is not the case, but then you do like to find any excuse for kicking the BMFA!