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

[Martin_K]

With this review the CAA have raised the possibility of changing the path we were on under European legislation. I have taken the opportunity to differentiate between self built model aircraft operated traditionally, i.e. with no onboard flight navigation, as opposed to UAVs with software based, built in, 'mitigations'.

 

How much of a possibility we have to influence the outcome I have no idea, but on this occasion my own interests in model aircraft diverges from guidance provided by the BMFA.

[aidan mcatamney]

It's a pity we just couldn't turn back the clock to the good old 1970s, 80s, and 90s when life was a lot simpler for rc airplane flyers and people were a lot happier.  Money and the power that comes with it has taken over.  

[MattyB]

26 minutes ago, Andy Stephenson said:

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.

 

Most of that info is in the accompanying document I linked from post 1 of this thread.

I don't think it includes a full list of stakeholders though (but these are pretty self explanatory - it is basically all the commercial and government players who stand to benefit form BVLOS on one side, and recreational low level airspace users on the other..

 

16 minutes ago, Martin_K said:

With this review the CAA have raised the possibility of changing the path we were on under European legislation. I have taken the opportunity to differentiate between self built model aircraft operated traditionally, i.e. with no onboard flight navigation, as opposed to UAVs with software based, built in, 'mitigations'.

 

Yes I tried to do that too when I responded - anyone who wants to use that as source material for their own response is welcome to do so, I posted it last night...

 

Edited August 30, 2023 by MattyB

[Zflyer]

The facts are this: CAA put out questionnaire

BMFA have issued response and guidance

You have the choice to use BMFA response in full

Use some of BMFA response and edit as per your view

Go your own way

 

Yes or no answers are easier to sift. Provided the reasoning is looked at and weighed, better still weighed against valid evidence.

 

NO one ever got 'somewhat pregnant'

 

There is little doubt RID will come, whether or not it will apply across the model flying hobby or is drawn up to exclude certain types of flying/flying models, may or may not depend upon how the responses are viewed and judged. 

 

 

[Martin McIntosh]

I don`t think that I have read so much gobbledy gook in my life. Do the CAA honestly think that an average club flyer (sorry, now a `stakeholder` whatever that is) with the usual electric foamie has any interest whatsoever in it? Nothing stopping somebody who has just been given a quad for their birthday from going to a nearby field and flying it, being totally oblivious to any legislation.

[Ron Gray]

32 minutes ago, Martin McIntosh said:

Nothing stopping somebody who has just been given a quad for their birthday from going to a nearby field and flying it, being totally oblivious to any legislation.

That has always been the case and as you say it will not change - RC Licence, CB Radio....................

[MattyB]

1 hour ago, Martin McIntosh said:

I don`t think that I have read so much gobbledy gook in my life. Do the CAA honestly think that an average club flyer (sorry, now a `stakeholder` whatever that is) with the usual electric foamie has any interest whatsoever in it?

 

That is the whole point. Make it 30+ pages long and wrap it up in impenetrable language, and the average model flyer probably won't have the time or will to respond. Then, when the response rate is low, they can say "We consulted with you, but you weren't that bothered". We (and the national association) are playing the game with a busted flush, and all the aces are in their hands...

[steve too]

1 hour ago, Martin McIntosh said:

Nothing stopping somebody who has just been given a quad for their birthday from going to a nearby field and flying it, being totally oblivious to any legislation.

 

That is the argument behind some of this stuff. The intention is that the birthday quad won't fly until the operator and flyer IDs are entered, will have geofencing and will transmit remote ID out of the box.

Edited August 30, 2023 by steve too

[leccyflyer]

1 hour ago, Zflyer said:

The facts are this: CAA put out questionnaire

BMFA have issued response and guidance

You have the choice to use BMFA response in full

Use some of BMFA response and edit as per your view

Go your own way

 

Yes or no answers are easier to sift. Provided the reasoning is looked at and weighed, better still weighed against valid evidence.

 

NO one ever got 'somewhat pregnant'

 

There is little doubt RID will come, whether or not it will apply across the model flying hobby or is drawn up to exclude certain types of flying/flying models, may or may not depend upon how the responses are viewed and judged. 

 

 

Indeed - I think there is a faint chance that if we respond robustly enough and make it crystal clear how unnecessary, unhelpful, disruptive and downright perverse the proposals to fit RID to model aeroplanes are, that they might just take notice. If, as model flyers, we aren't prepared to differentiate between what we do, as model flyers - namely VLOS at remote locations and  with the excellent safety record with regards to staying clear of other airspace users by See and Avoid - but allow ourselves to be grouped in with drone operators who want to operate BVLOS and outwith those remote locations, very often in close proximity to other uninvolved persons,  then we are making a rod for our own back and our chances of succeeding in that argument are diminished.

[steve too]

13 minutes ago, MattyB said:

We (and the national association) are playing the game with a busted flush, and all the aces are in their hands...

 

And we have lost the Joker. Grant Shapps was sympathetic. I have no idea what Mark Harper thinks about this stuff.

[Martin_K]

28 minutes ago, steve too said:

 

That is the argument behind some of this stuff. The intention is that the birthday quad won't fly until the operator and flyer IDs are entered, will have geofencing and will transmit remote ID out of the box.

 

Regarding "Nothing stopping somebody who has just been given a quad for their birthday from going to a nearby field and flying it, being totally oblivious to any legislation."

The "catch all" approach is listening to and decoding the radio transmissions associated with Unmanned Aircraft. How many protocols, what level of decode, how many listening stations, who is paying for it? Questions not answered in the Altitude Angel press release of 24 July 2023.

 

From the release;
Incorporating purpose-built ADS-B and Mode S receivers, as well as comprehensive SDR (Software Defined Radio) capabilities, the network is also capable of detecting existing and future ‘Remote ID’ broadcasts from transmitters on drones, as well as collecting transmission information from the common control systems used to pilot them. This means the sensor network will detect drones which are intentionally electronically broadcasting their location, as well as many which are not.  And due to the detection technologies used by Altitude Angel, low-flying crewed aviation can be detected and located using other passive sensors even when they are not broadcasting any signal.

[Peter Jenkins]

5 hours ago, MattyB said:

 

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.

 

 

5 hours ago, leccyflyer said:

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.

I was responding to your point the drones could fly BVLOS.  Try reading your post.to see that I was pointing out the drones (multi rotors) are not the only form of vehicle to be able to be equipped to fly BVLOS.  FPV also has that capability albeit.without the range.  Yes, both break the law as it is set out.  The perpetrators don't care so long as they don't get caught.

That was my point.

[steve too]

1 hour ago, Martin_K said:

How many protocols, what level of decode, how many listening stations, who is paying for it?

 

My guess as to who is paying would be the DfT as part of Airspace Modernisation. 

[leccyflyer]

35 minutes ago, Peter Jenkins said:

 

I was responding to your point the drones could fly BVLOS.  Try reading your post.to see that I was pointing out the drones (multi rotors) are not the only form of vehicle to be able to be equipped to fly BVLOS.  FPV also has that capability albeit.without the range.  Yes, both break the law as it is set out.  The perpetrators don't care so long as they don't get caught.

That was my point.

Not sure where you are getting the idea that drones just refers to multirotors - I certainly never implied that was the case. The venerable Djindvik drone is a conventional, fixed wing aircraft, but is clearly a drone. It's about the mode of control and how they are used, rather than how many propellors they might have and your description of a fixed wing model, equipped to fly BVLOS certainly fits the definition of a drone.

[RICHARD WILLS]

Logic would dictate that Andy Simmonds argument is correct . Flying model aircraft within the range of normal eyesight alone while being registered with a long established organisation should mean that insisting that we all have these units fitted, would actually tie the monitors in knots with very little gain since we are all there in plain view and documented . 

When drones came along we could all see the potential threat and when you consider that the likes of Amazon would like to replace their delivery trucks with locust swarms of them then I guess you can see one of the many issues on the way . 

This will be a test of our organisations clout and recognition  . Long established and with a sizeable membership you would think it would help . Sadly what it really needs is some TV publicity and now would be an excellent time while the public are fuming at the full size flying world and its administrators and operators . 

[Andy Symons - BMFA]

4 minutes ago, leccyflyer said:

It's about the mode of control and how they are used, rather than how many propellors they might have 

This bit is spot on! On indeed the basis of the BMFA position for many years with EASA and the CAA etc.

In fact I recall back in the days when Graham Lynn was the technical representative for model aircraft flying in Europe he was asked by EASA to provide a definition of model aircraft flying. I think they were expecting a very long definition extending to a number of pages, when in reality it is very simple.

 

"Model aircraft flying is the flying of any small unmanned aircraft, within visual line of sight of the remote pilot for the purposes of sport or recreation."

 

That is still pretty much the position, doesn't matter how many rotors or propellers, whether it's home built or purchased pre built, flown FPV with a spotter or traditional line of sight, or whether on a club field or any other suitable location. If its flown within visual line of sight for sport or recreation it is model aircraft flying.

[john stones 1 - Moderator]

Lot of good stuff among these posts, some bits I'm having problems with though. As I recall the BMFA fought on our behalf cleary stating who we are and what we do, never did I see evidence that they lumped us in with anyone, they gained us concessions because of who we are, Having an A cert brought one concession re the online test. No one, especially not the BMFA allowed us to be lumped in with others, reasoning I recall is, no satisfactory wording could be found to do otherwise. please correct me if I'm wrong. If you've got the wording sorted, get it sent in.

 

 

[Peter Jenkins]

1 hour ago, leccyflyer said:

Not sure where you are getting the idea that drones just refers to multirotors - I certainly never implied that was the case. The venerable Djindvik drone is a conventional, fixed wing aircraft, but is clearly a drone. It's about the mode of control and how they are used, rather than how many propellors they might have and your description of a fixed wing model, equipped to fly BVLOS certainly fits the definition of a drone.

I worked for 8 years in a company at the fore front of introducing UAVs into UK airspace so I am well aware that drones cover both rotary and fixed wing vehicles.  It was unclear from your post whether you were also of the same view - many are not.

[Zflyer]

I was under the impression they struggled to get a definition. Altitude Angel wow every military in the world must get their kit, they can detect stuff even when its not transmitting. 

Just fell in they have 'sniffer pidgeons'

[leccyflyer]

That's the general assertion - that they struggled to get a definition, but we've just seen perfectly workable definitions and the references to drones and model aircraft in the documents mentioned in this thread show that such a distinction is possible.

 

As for evidence of lumping us in with other disciplines -it's right there in the BMFA response to the question on whether to review the regulations applying to model aircraft, by the explicit inclusion of drone operations in that response.

[john stones 1 - Moderator]

You've seen definitions on here some claim are acceptable, CAA are not one of those agreeing with that.

Second one Leccy, I disagree, and I'll leave it coz it's going round in circles.

[GrumpyGnome]

The entire debate is going round in circles! 

 

My personal view is that if we fundamentally disagree with the BMFA standpoint and responses, the various authorities will not see the BMFA as a representative body, and anything they say in any meetings/negotiations will have less credibility.

 

"Just say no" is not a viable negotiating stance.

 

This will need compromise on both sides. Unfortunately, we have less power than those we (BMFA) are negotiating with.

[Futura57]

I've been following this topic, though not always staying engaged with some of the nuances and technicalities of the proposed leglisation. Call me a grunt, but when cheap drones became available years ago, requiring no skill or safety discipline to operate, all the crankies would show them selves. Personally I think they are an abomination. Bussing airfields and aircraft landing or taking off has brought nothing but bad press to model flying in the eyes of the public, who don't differentiate. Use as a weapon of war and in the MSM nearly every day doesn't help. I for one would vote for the BMFA tomorrow to have nothing to do with drones or basically anything not being flown Line-Of-Sight. A case of too much diversity being a bad thing in my view. But I doubt it will make a jot of difference now. The genie is well and truly out of the bottle.

Grunt signing off.

[leccyflyer]

Playing devil's advocate here -and let me stress that I do not consider this a valid viewpoint - it could be argued that some flights by free flight models are launched with the possibility that they will result in BVLOS flight and we have all either experienced, witnessed or heard of fly-aways of free flight models committed to the air. Does that put free flight in the same potentially BVLOS category as drones? Personally I don't believe it does, as the key differentiator is the under control aspect of the drone, whether it be by FPV or by autonomous flight path programming, it is under control of the remote pilot.

[Cuban8]

44 minutes ago, leccyflyer said:

Playing devil's advocate here -and let me stress that I do not consider this a valid viewpoint - it could be argued that some flights by free flight models are launched with the possibility that they will result in BVLOS flight and we have all either experienced, witnessed or heard of fly-aways of free flight models committed to the air. Does that put free flight in the same potentially BVLOS category as drones? Personally I don't believe it does, as the key differentiator is the under control aspect of the drone, whether it be by FPV or by autonomous flight path programming, it is under control of the remote pilot.

Intent must play a part. Launching a device that is then flown deliberately BVLOS either to follow a pre-programmed course or steered remotely by a headset is, I suggest, somewhat different to a free flight model  that is pre-trimmed, and in case of a powered model, carrying a very limited amount of fuel/energy with the express desire and intention that said model remains in close proximity (within sight) so that it can be viewed (and enjoyed) directly by the launcher and subsequently recovered from very nearby.

Although a  sudden change of wind strength or direction, or unexpected thermal activity can affect the free flighter's original intent as I'm sure many of us have found out - the original intent remains unchanged.