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From the latest CAA CHIRP publication - an outlet for anonymous reports to help enhance safety - I’m very concerned if the report reflects the attitudes of the club concerned accurately:

 

Initial Report

I was planning a flight from [Airfield 1] to [Airfield 2]. As part of my planning I saw a NOTAM raised in the [Town] area, 4nm diameter, surface to 3200ft amsl, 24/7, for the flying of drones and model aircraft. It’s a very congested piece of airspace constrained laterally by [Airfield 3] MATZ and [Airfield 4] ATZ. Vertically it is adjacent to the London TMA.

I always try and follow the GASCo advice of take 2 miles laterally and 200ft vertically, so I was pretty interested in what might be out there to bump into. As a courtesy, I elected to call the number given to see if they were operating. The person’s tone at the other end was demeaning, became insulting and finally threatening by demanding my details because they were going to immediately contact the CAA. As the conversation had become threatening, I advised I would not continue and terminated my call. I’m glad I was operating as a rear-seat pilot not as P1 because by this point I was thoroughly irritated and distracted.

Their understanding of NOTAM use and the rights they give is different to mine. They considered that: the NOTAM had been raised by the CAA to protect my life (if in error I apologise but I thought NOTAMs were raised by the originator); I was not permitted to fly through that airspace; there is no requirement for the drone operator to maintain lookout; the drones are not required to be kept in line of sight; they had no concept that they were also responsible for separation and avoidance action; in no uncertain terms they advised that I should hold outside their airspace and climb above before proceeding; they could fly their large heavy drones 24/7 with no consideration of other airspace users; and they had no requirement to manoeuvre away should they sight an aircraft.

I remain certain much of the above is not true. I believe the size and use of this NOTAM’ed airspace is inappropriate and have raised that direct with the CAA.

CHIRP Comment

This report highlights misunderstandings that might exist about NOTAMs versus restricted areas and TRAs.  Although published by NATS on behalf of the CAA, NOTAMs are compiled by the requestor of the activity. In this particular case, the NOTAM was a navigation hazard warning with no requirement to avoid it although sensible to do so given the activity likely to be conducted within with small models/drones. For their part, those operating drones/UAS within such NOTAM’ed areas still have a duty to avoid collisions with other aircraft and so they must maintain visual contact with their drone/model at all times – all airspace users have a duty to avoid collisions and must give way to aircraft to the right of their own. Given the often small size of drones/models, there is extra importance in drone/UAS operators avoiding aircraft that they see given that their drone/model will likely be very difficult to detect by an aircraft pilot. In short, unless specific arrangements have been made to operate BVLOS[1] (which requires a TRA at present), a model/drone operator is required to maintain lookout (either themselves or by an observer if using FPV[2]) and must keep any model/drone within their line-of-sight.

[1] BVLOS – Beyond Visual Line of Sight.

[2] FPV – First-Person-View, i.e. using heads-down video or virtual reality goggles.

The NOTAM itself was poorly drafted with a number of errors in heights. The upper limit was erroneously described as the surface altitude in one part and 2500ft agl in another (implying a top height of 3200ft amsl). The intended top-height was 1500ft agl (2200ft amsl) and this was corrected in a subsequent issue of the NOTAM. Whilst we’re all prone to mistakes and errors at times, it shows the importance of understanding the NOTAM compilation process and double-checking any entries to make sure they are correct. NATS have produced NOTAM Guidance Material (see also QR code), wherein Paras 3.2 and 3.3 (reproduced below) give an explanation of how to decode NOTAMs. Although many electronic navigation and planning aids do this automatically for users, those compiling NOTAMs need to understand the various entries and what they mean.

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I do hope this wasn't a BMFA Club or originated by a BMFA member.  I hope that Manny or Dave will take this further and if it turns out to be a BMFA Club/member, then put them in the right as regards the rules of the air.  One has to wonder who this person is that they think a NOTAM about an activity means that absolves them of the usual rules of the air!

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2 minutes ago, Martin Harris - Moderator said:

It’s not clear whether this was a club or a commercial drone concern but of course the reporting system is anonymous.  However, there are clues in the report which would certainly narrow down the location as it seems to be located at around 700 feet altitude. 

And close to a MATZ and the London TMA.  Narrows it down a bit more.

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I noted the comments regarding the mistakes etc made in the NOTAM. Given they are published by NATS  i have to ask who checked it and ehy the errors were notpointed out to the author.

If i accept the reporting of the incident is indeed accurate i allude to errors obvious on both parties.

Given safety is paramount the attention afforded too it seems lacking on behalf of those paid to police it, whilst ignorance is apparent on the author.

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As a EASA/UK PPL SEP pilot, the lack of understanding of each others responsibilities for safety, and in particular belligerent disregard of the consequence of one's actions must be verging on more than a breach of CAA regulations.

 

As an aside the increasing use of the term 'pilots' within the FPV community is mildly irritating, where the training including both theoretical and practical skills together with exams , written and skills tests of competencies, including regular currency ratings checks required is not reflected, but by adopting that mantle seems to imbibe some misplaced authority. 

 

 

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10 minutes ago, Robin Mosedale 1 said:

... As an aside the increasing use of the term 'pilots' within the FPV community is mildly irritating ...

 

The CAA etc refer to us all (traditional modelers and FPV) as remote pilots.

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One of the problems with UAV operations, is that often the person manning the radio or answering the phone isn't as experienced or as knowledgeable of the regulations as they really need to be. 
The fact that this NOTAM was 24 hours a day, seven days a week, suggests it wasn't a model flying operation but some sort of trial.  It doesn't surprise me that it specifies model aircraft as well as UAVs , as its not unusual for pilots on UAV operations to fly a low value aircraft at the site , i.e. a model, to get some site awareness before operating the larger, more expensive and more complex UAV.  

Edited by Robin Colbourne
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