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

[john stones 1 - Moderator]

Do mine later, stuff like this I find difficult, so a chance to read what others have written is helpful.

[Ron Gray]

1 hour ago, MattyB said:

that just leads to our collective responses becoming less impactful

I don't think that it can as each returned response is, in effect, signed (email) by the individual so it is the individual's response even though it may say the same as someone else's.

[MattyB]

11 minutes ago, Ron Gray said:

I don't think that it can as each returned response is, in effect, signed (email) by the individual so it is the individual's response even though it may say the same as someone else's.

 

In terms of influencing the stats for a given question then yes I agree. However, if every answer was a copy and paste of the BMFA response I'm sure the CAA would quickly spot that, and may even discount some of those responses if they thought automation was being used to skew the result (it's really simple to do these days).

[steve too]

15. Should CAA implement geo-awareness

 

Geo-awareness requires a huge, high integrity database. I wonder how this will be financed?

 

The U-Space roadmap breaks geo-awareness/fencing down into three stages.
 

Quote

Pre-tactical geofencing

The service provides the operator with geo-information about predefined restricted areas (prisons, etc.) and available aeronautical information (NOTAM, AIRAC cycle) used during the flight preparation. This service requires the identification of accredited sources and the availability of qualified geoinformation related to restricted areas. This service provides information that allows the drone operator to make use of the geofencing capability of the drone.

 

Tactical geofencing

Compared to U1 pre-tactical geofencing, tactical geofencing brings the possibility to update the operator with geofencing information even during the flight.

 

Dynamic geofencing

Compared to tactical geofencing in U2, the dynamic geofencing targets the drone itself and then this service requires data-link connectivity to a geofencing system that allows the data to be updated during the flight.

 

(European ATM Master Plan: Roadmap for the safe integration of drones into all classes of airspace)

 

Just say no.

[steve too]

17 hours ago, MattyB said:

... but those of us who had read the docs and understood the Operator ID includes a checksum directly designed for use in RID transceivers knew that was coming ages ago

 

EASA style operator IDs include a secret part and a check character to detect miskeying when entering the ID into a RID etc. As far as I am aware there is no check character in UK IDs. If you want to see an over the top RID, have a look at the Japanese requirements (link in one of my previous posts).

[MattyB]

2 hours ago, steve too said:

EASA style operator IDs include a secret part and a check character to detect miskeying when entering the ID into a RID etc. As far as I am aware there is no check character in UK IDs. If you want to see an over the top RID, have a look at the Japanese requirements (link in one of my previous posts).

 

Ah yes, I remember now, there was a previous conversation on here that the EASA format may not have been followed correctly in the UK in the end...

 

 

 

TBH it sounds like the CAA made a bit of a horlicks of it when they re-issued the Op-IDs following Brexit...

 

Edited August 30, 2023 by MattyB

[steve too]

1 hour ago, MattyB said:

... the EASA format ...

 

ASD-STAN's Introduction to the European UAS Digital Remote ID Technical Standard describes the EASA ID format and isn't a bad primer on RID in general.

[MattyB]

18 hours ago, Andy Symons - BMFA said:

I really do not see any reason to be so pessimistic, model flying activity as we know it can be incorporated safely and relatively easily in to the shared airspace. The flights are all point A to point A, generally take place within 300m or so of the take off point and in full line of sight of the operator. In many respects while we are using airspace it is fixed airspace. Remote ID is simply not needed because it is generally obvious who the remote pilot of a model aircraft is because you can see them.

When flown as model aircraft always have been see and avoid works.

 

For some reason I missed this when it was first posted... See and avoid may work fine today, but (like it or not) the authorities don't believe it will be enough in a world where BVLOS automated operations are commonplace.

 

Yes, we all know that is almost certainly a long way off, but politicians want those jobs and tax £££s promised by the big corporations to make them more electable in future. As a result they are going to legislate well in advance to make that possible; mandating RID as widely as they possibly can is clearly a key part of that.

 

I know that the national associations need to maintain good working relationships with the CAA and UK Gov, but I really hope the BMFA have learnt from what has happened in the US and will not make similar errors. There the AMA pretty much sat on their hands and went along with the government proposals because they believed RID would drive up their membership (because pilots then need to be in a community based organisation to operate from a FRIA). Now pilots are realising how restrictive the new legislation is, that they are unlikely to get all the FRIAs they thought would exist, and that the CBOs can be forced to change their rules by the FAA at almost any point or face losing their CBO status. Article 16 authorisations are nice to have, but we all need to fight against the erosion of rights for the rights of current and future model aircraft users, not just those in the national associations today.

[steve too]

16. Should CAA introduce requirements for manufacturers to provide user guidance during product set-up or pre-flight, via the controller or other interface (Opportunity 13) and why?

 

Sounds reasonable doesn't it. The BMFA gave one of their "yes, but" answers. The problem is that it potentially leads to controllers linked to traffic management systems and things like this -

 

Quote

Flight planning management

This service covers the receipt of a flight notification or a flight plan and provides the appropriate
answer according to the characteristics of the mission and applicable regulations
This service will be available for any drone operator/user with different levels of requirements.

 

Just say no.

[john stones 1 - Moderator]

Just say No ?

Unless you've the clout to enforce that position, is it wise ? Is a refusal to see any given situation and how it affects others, or how it impacts the goal of those we're are talking to wise ? Sometimes "Yes, but" is your best answer to start from, it leaves the door open to discussion and concessions may be given.

 

The AMA keeps being used as an example, please show me evidence that "just say no" would have improved their outcome ?

[john stones 1 - Moderator]

1 hour ago, MattyB said:

 

For some reason I missed this when it was first posted... See and avoid may work fine today, but (like it or not) the authorities don't believe it will be enough in a world where BVLOS automated operations are commonplace.

 

Yes, we all know that is almost certainly a long way off, but politicians want those jobs and tax £££s promised by the big corporations to make them more electable in future. As a result they are going to legislate well in advance to make that possible; mandating RID as widely as they possibly can is clearly a key part of that.

 

I know that the national associations need to maintain good working relationships with the CAA and UK Gov, but I really hope the BMFA have learnt from what has happened in the US and will not make similar errors. There the AMA pretty much sat on their hands and went along with the government proposals because they believed RID would drive up their membership (because pilots then need to be in a community based organisation to operate from a FRIA). Now pilots are realising how restrictive the new legislation is, that they are unlikely to get all the FRIAs they thought would exist, and that the CBOs can be forced to change their rules by the FAA at almost any point or face losing their CBO status. Article 16 authorisations are nice to have, but we all need to fight against the erosion of rights for the rights of current and future model aircraft users, not just those in the national associations today.

 

I don't fly from slopes, wish I could but that's another story, my flyings done only within a club, this thing no doubt brings concerns that are not obvious to me, so what is it that you feel is a danger to those not within clubs Matty ?

[leccyflyer]

It's one thing if the imposition of RID is inevitable, to give a middle of the road answer, accepting that, expecting that what you try to put forward as a nuanced argument has some weight, but, when push comes to shove and that RID becomes mandatory for all flying models it would be very annoying for the authorities to then reply " Ah, but you were consulted and didn't have a problem with RID - too late to object now".  The question is being asked of individuals, from their perspective and my perspective is that RID is unnecessary, will have a significant impact on how I operate my models - which all operate LOS at remote locations and will involve considerable hassle and cost.   Whilst I agree that we should take guidance from BMFA, I believe it is not effective to cut and paste our responses and, if we feel strongly that our position on particular issues is not in lockstep with the answer given, then it's really up to the individual how to answer a particular question.

 

To thine own self be true.

[john stones 1 - Moderator]

Can't argue with much of that Leccy, your Email your choice how you respond.

I'm still struggling to see when the BMFA have not opposed RID though, looks to me they state it's not appropriate to us, but accept it's there on some purchases already and may well be going forwards.

 

Cut n Paste, yep agree with you, prefer to write my own.

[steve too]

45 minutes ago, john stones 1 - Moderator said:

... The AMA keeps being used as an example, please show me evidence that "just say no" would have improved their outcome ?

 

You need to compare the FAA's original proposal with what they ended up doing. The FAA backed off when 50k people said no. Which is not to say that what they ended up with in the US is good, but it could have been a lot worse.

 

Just now, john stones 1 - Moderator said:

... I'm still struggling to see when the BMFA have not opposed RID though ...

 

"Neither yes nor no" is not opposing RID.

[leccyflyer]

It speaks to what I believe to be a fundamental part of this topic. The BMFA made the decision long ago that it would embrace drone flying and encourage drone flyers. As such, their position in a topic such as this is compromised by the need to include drone operations within their replies. Since drones are totally capable of Beyond Visual Line of Sight Operation but are not equipped to adequately incorporate the See and Avoid techniques that model flyers have successfully used for a hundred years to avoid other air traffic then some form of electronic conspicuity device does make sense for those drones. From direct personal experience I can confirm that it's not possible for someone with average eyesight to see a drone at 200m distance and 140m altitude, in order to orientate oneself with the drone and fly it successfully. Flying the drone FPV well beyond that range is a trivial matter -as demonstrated by countless You Tube videos - but is not possible under the Drone code that we currently operate under , where a spotter needs to be able to see the drone and keep a look out.

 

My opinion is, that if BMFA were solely concerned with model flyers and drone opertors just had their own association, that the BMFA response could be much clearer and less ambiguous in their opposition to RID in particular.

[john stones 1 - Moderator]

Posting comments in Isolation is easy, and done to suit an agenda imo, very clear what the BMFA thinks to RID and written for all to see.

 

Likewise the first comment "Original proposal" before discussion took place, pretty common place for start point not being final outcome. Evidence that Just say No won the less worse position please.

[Peter Jenkins]

3 minutes ago, leccyflyer said:

It speaks to what I believe to be a fundamental part of this topic. The BMFA made the decision long ago that it would embrace drone flying and encourage drone flyers. As such, their position in a topic such as this is compromised by the need to include drone operations within their replies. Since drones are totally capable of Beyond Visual Line of Sight Operation but are not equipped to adequately incorporate the See and Avoid techniques that model flyers have successfully used for a hundred years to avoid other air traffic then some form of electronic conspicuity device does make sense for those drones. From direct personal experience I can confirm that it's not possible for someone with average eyesight to see a drone at 200m distance and 140m altitude, in order to orientate oneself with the drone and fly it successfully. Flying the drone FPV well beyond that range is a trivial matter -as demonstrated by countless You Tube videos - but is not possible under the Drone code that we currently operate under , where a spotter needs to be able to see the drone and keep a look out.

 

My opinion is, that if BMFA were solely concerned with model flyers and drone opertors just had their own association, that the BMFA response could be much clearer and less ambiguous in their opposition to RID in particular.

You seem to forget that any RC powered fixed wing model aircraft can be fitted with an autopilot that can be programmed to fly BVLOS.  Given that, your argument is holed below the waterline.

[MattyB]

45 minutes ago, john stones 1 - Moderator said:

I don't fly from slopes, wish I could but that's another story, my flyings done only within a club, this thing no doubt brings concerns that are not obvious to me, so what is it that you feel is a danger to those not within clubs Matty ?

 

That anyone who flies legally outside of a club environment, be that on a public slope, in a private field they own or in a public space that allows flying today will be required to purchase and use RID. As posted eloquently by leccy above, for all these individuals RID is unnecessary, will have a significant impact on how they operate my models, and will add considerable hassle and cost that will definitely put off a percentage of participants. In reality the regs will just mean these pilots go off grid, as the chance of enforcement (particularly for slope flyers operating off a random hill or coastal cliff) are minimal. Is that really what the authorities are looking to achieve?

Edited August 30, 2023 by MattyB

[john stones 1 - Moderator]

1 minute ago, leccyflyer said:

It speaks to what I believe to be a fundamental part of this topic. The BMFA made the decision long ago that it would embrace drone flying and encourage drone flyers. As such, their position in a topic such as this is compromised by the need to include drone operations within their replies. Since drones are totally capable of Beyond Visual Line of Sight Operation but are not equipped to adequately incorporate the See and Avoid techniques that model flyers have successfully used for a hundred years to avoid other air traffic then some form of electronic conspicuity device does make sense for those drones. From direct personal experience I can confirm that it's not possible for someone with average eyesight to see a drone at 200m distance and 140m altitude, in order to orientate oneself with the drone and fly it successfully. Flying the drone FPV well beyond that range is a trivial matter -as demonstrated by countless You Tube videos - but is not possible under the Drone code that we currently operate under , where a spotter needs to be able to see the drone and keep a look out.

 

My opinion is, that if BMFA were solely concerned with model flyers and drone opertors just had their own association, that the BMFA response could be much clearer and less ambiguous in their opposition to RID in particular.

 

Ours and many other clubs embraced drones, they're flying out the way and safely and they contribute to our running cost, these folk didn't bring all this down on us, it just isn't true, business and opportunity did it. BMFA took a lead amid lots of garbage written in the media, we were at risk from bad publicity personally I applaud what the BMFA did.

[MattyB]

8 minutes ago, Peter Jenkins said:

You seem to forget that any RC powered fixed wing model aircraft can be fitted with an autopilot that can be programmed to fly BVLOS.  Given that, your argument is holed below the waterline.

 

Fitting those systems is the operators decision and responsibility. If they choose to do so and those autonomous systems allowed it to fly BVLOS, it isn't a model aircraft any more and (assuming they implement it) the operator would need to ensure it complies with all RID requirements at that point in order to fly legally.

 

Edited August 30, 2023 by MattyB

[leccyflyer]

15 minutes ago, Peter Jenkins said:

You seem to forget that any RC powered fixed wing model aircraft can be fitted with an autopilot that can be programmed to fly BVLOS.  Given that, your argument is holed below the waterline.

No  it isn't - clearly that is flying BVLOS and would not be permitted under the existing regulations for normal model flying - it's a drone, not a model aeroplane.

[leccyflyer]

12 minutes ago, john stones 1 - Moderator said:

 

Ours and many other clubs embraced drones, they're flying out the way and safely and they contribute to our running cost, these folk didn't bring all this down on us, it just isn't true, business and opportunity did it. BMFA took a lead amid lots of garbage written in the media, we were at risk from bad publicity personally I applaud what the BMFA did.

I used to be in a club which also embraced model boats, but nobody would suggest for a moment that the BMFA has it within it's remit to promote model boating.

[john stones 1 - Moderator]

4 minutes ago, leccyflyer said:

I used to be in a club which also embraced model boats, but nobody would suggest for a moment that the BMFA has it within it's remit to promote model boating.

 

Flying boats ? 😉

[steve too]

13 minutes ago, MattyB said:

If they choose to do so and those autonomous systems allowed it to fly BVLOS, it isn't a model aircraft any more and (assuming they implement it) the operator would need to ensure it complies with all RID requirements at that point in order to fly legally.

 

The moment you go BVLOS you are outside the open category and the BMFA's Article 16 authorisation. You would need a specific authorisation from the CAA. IIRC last year the CAA were talking UAT on 978MHz for such operations.

[Andy Stephenson]

I've been reading through the questionnaire and more explanation of what they are after in some of the questions would be helpful without having to look up some obscure CAA documentation.

For instance...

 1. Do you agree with the challenges with operational requirements identified by stakeholders, and why?

What are these challenges and a list of stakeholders would be useful, I think I know what some of them might be but are they listed anywhere. The same goes for many of the other questions.

 

I think some neutral common-sense guidance by someone other than the BMFA would help, failing that some biased guidance.