I am surprised at apparently no comment

[Erfolg]

I noted an update a few days ago on the proposed Proposals for the safe operation of drones.

Initially the title suggested to me there was little interest to me. Further reading did not seem to make a distinction between what i think of as Drone (a quad) and my model aircraft.

If my interpretation is correct the way many modellers pursue the hobby will be changed substantially. As written in the bulletin the regulations for unmanned aircraft will be more restrictive than those currently in place with additional requirements for training, registration and a 400ft/120m height limit.

Far more is unsaid, which suggests that inevitably there will be additional boundaries and requirements which will be put in place.

The reassuring word of so nothing will happen instantly. Is as reassuring as the words of "Don't Panic" at the beginning of the Hitch Hikers Guide to the Galaxy.

I personally just think that when these regs come to pass, it will signal the further decline of my hobby of flying fixed wings models. Basically as the obstacles will discourage many potential modellers. I am also guessing that the sale and operation of many of the present day flying toys as played with by children will cease. Which I see as a great pity. Not only for the fun, also the feedstock potentially into my hobby.

It is not clear to me that very much as been improved on from the initial EASA proposals.

[Rich too]

Yes, it is absurd that there is no definition - we all know what "drones" are. However, this has already been done to death.

Btw - drones are not (just) quads..

[Jonathan W]

I was chatting a couple of weeks ago to a BMFA instructor visiting us from another club. He said that there is currently a difference of opinion between the CAA and Dept for Transport. The CAA is happy to allow fixed wing model flying to continue much as it has been, due to proven safety record. The DfT wants to legislate more heavily, I suppose for the usual reasons why governments like to. So we will see what happens sooner or later.

I commented, standing on our remote patch down a pot-holed single track lane, "So are the Police going to come along that lane and stop us doing what we are doing?" We both had to agree that this is unlikely.

[john stones 1 - Moderator]

What's to say that's not been said already ? wot does training/ registration mean ?

P.S I stopped reading stuff, there's nowt i can do, other than deal with it when it happens.

Edited By john stones 1 on 29/08/2017 11:51:30

[Former Member]

[This posting has been removed]

[Erfolg]

Steve , the published date, and lack of reaction is what has surprised me.

Particularly, in that a drone does seem to include my fixed wing models.

When the legislation is introduced, that vast majority of us will comply or cease flying. That is the difference between us and many present day environmental protesters.

I am totally in agreement that there is nothing I personally can do

[kevin b]

The problem Erfolg lies in the word Drone.

The first radio controlled target aircraft used by the RAF was called "Queen Bee" as far as I can gather and was a full size aeroplane. After that they used model aircraft (all be it large !) which they then called Drones. So in fact all our models could be referred to as "Drones", including gliders as they are radio controlled.

Maybe we should all go back to free flight, or control line.

[Adrian Smith 1]

I guess Kevin, if free flight and control line were the only options left I would take up knitting instead!!

[Frank Skilbeck]

How would they differentiate between this Drone and a conventional fixed wing RC aircraft.

The issue isn't fixed wing vs multi-rotor as far as the authorities are concerned but unmanned aircraft which are capable of operating in controlled airspace. If you go on U tube and look at FPVers posting videos of long range flights, you'll see most of these are fixed wing aircraft, often the same as we fly LOS. One of the reasons they couldn't agree on separating conventional model aircraft was that somebody flying one of these could claim it as falling in the model aircraft category.

[Erfolg]

Adrian

There is an implication that FF is not an option without some form of positive height limiter, that 400 foot component.

If there were a requirement for FF models to have some means of height control, I could not imagine that other types of models would need their own method?

My fear is what is not written or said where the fundamental issues could be hiding. I suspect that some have started to manage our expectations.

[Peter Jenkins]

Erfolg, why do you quote selectively from Dave Phipps' news flash? The detail you omit to quote from I reproduce below, again from the very same article that Steve J referred to above, namely:

• The DfT proposals generally align with those developed by the European Aviation Safety Agency (EASA). The general principle is that (for those operating outside the framework of an established model flying association) the regulations for unmanned aircraft will be more restrictive than those currently in place with additional requirements for training, registration and a 400ft/120m height limit. This is comparable with the ‘Open Category’ requirements proposed by EASA.
• Within the EASA proposals, established model flying associations would operate within the ‘Specific Category’ under an authorisation granted by the Civil Aviation Authority (CAA) which would essentially allow us to operate as we do today. The DfT’s proposals do not change this. Essentially, the CAA would issue us with an authorisation (or exemption) defining our agreed operating parameters which would reflect how we operate today (including operations above 400ft/120m).

I hardly think that your claim that no one is doing anything holds water but no doubt you will seek to split a few more hairs to explain to us why this is the case.

Peter

[Braddock, VC]

Posted by Peter Jenkins on 29/08/2017 17:03:58:

Erfolg, why do you quote selectively from Dave Phipps' news flash? The detail you omit to quote from I reproduce below, again from the very same article that Steve J referred to above, namely:

• The DfT proposals generally align with those developed by the European Aviation Safety Agency (EASA). The general principle is that (for those operating outside the framework of an established model flying association) the regulations for unmanned aircraft will be more restrictive than those currently in place with additional requirements for training, registration and a 400ft/120m height limit. This is comparable with the ‘Open Category’ requirements proposed by EASA.
• Within the EASA proposals, established model flying associations would operate within the ‘Specific Category’ under an authorisation granted by the Civil Aviation Authority (CAA) which would essentially allow us to operate as we do today. The DfT’s proposals do not change this. Essentially, the CAA would issue us with an authorisation (or exemption) defining our agreed operating parameters which would reflect how we operate today (including operations above 400ft/120m).

I hardly think that your claim that no one is doing anything holds water but no doubt you will seek to split a few more hairs to explain to us why this is the case.

Peter

Well said that man.

[John Bisset]

I broadly agree with your Peter (Jenkins) , however I think what may be concerning Erflog is that the wording of some of the comments from sources in authority are less than clear and can easily be interpreted as allowing for later additional restrictions. Sadly government bodies have a fair bit of previous history showing they cannot be trusted without very precise rules being set.

I for one am not convinced by the involvement of the CAA being beneficial; nowadays they are very heavily driven by political will, not logic or fairness. Oh, and by cost - they must at least break even in what they do, and they are civil servants. Not cheap. They also have many fewer old style flying enthusiasts than they used to. Our hobby is a small matter to them overall; we will have little clout, so our only hope is to ensure NOW that we get what clarity we can.

They mean well but their 'delivery' is poor at present- as an example have a look at the current rules and regulations for private pilot licencing. It is a shambles, largely of the CAA's own making. (No doubt EASA will be blamed, but the CAA have input to that body, so...! )

I have some current experience of the Authority's own internal confusion on this and other issues, sadly. Unintentional - but the consequences of major confusion in our area could affect many clubs and r/c pilots badly.However, I'd 'trust' the CAA before the DfT any day. Different agendas.

I still don't see what is wrong with the simple LoS as definition of radio control machines versus drone. Sure LoS can be many things but a limit of say 1/2 mile maximum, worst case, would be hard to argue with. Can any of us see orientation of a model at that range? Guess maybe, but...

 

Edited By John Bisset on 29/08/2017 17:57:40

Edited By John Bisset on 29/08/2017 17:57:57

[Biggles' Elder Brother - Moderator]

Hi Peter,

whilst I would generally agree with your position I must point out one major concern that, in my view, is being rather glossed over here!

It is all well and good for David P to say

"Within the EASA proposals, established model flying associations would operate within the ‘Specific Category’ under an authorisation granted by the Civil Aviation Authority (CAA) which would essentially allow us to operate as we do today."

This is true. But, as always, the devil is in the detail. While it is quite true that EASA have indicated that model flying associations will be granted some exemptions from the new regulations, they have not (as far as I can see) indicated what those exemption might be and how far they might extend. So, we are not out of the woods yet.

I would also take slight issue with those who say "there is nothing I can do" - I do not belive this is so. The consultation period for this proposed legislation (as laid out by EASA in NPA 2017-05) has been extended until 15th Sept and every European citizen has the right to comment on its content to EASA. I have exercised that right and added extensive comments to the NPA indicating what areas I believe model flying, within a club environment, should be granted excemption under the regulations based on our excellent existing safety record.. The more of us that do that the better - as it strengthens the case. So you can contribute - I urge you to do so. There will be little point in whining afterwards if you have not made any contribution now! Oh, and posting here doesn't count - I don't believe EASA read the forum - so save your energy on this issue and send it to them instead via their formal response mechanism. Just google NPS 2017-05 for details of how to comment.

BEB

[john stones 1 - Moderator]

Yep fair enough "nowt i can do" is a negative attitude n there's nothing to lose in trying, now which one of the very numerous threads gives to email address to send to. ?

John

[Olly P]

Posted by Biggles' Elder Brother - Moderator on 29/08/2017 19:52:43:

Hi Peter,

This is true. But, as always, the devil is in the detail. While it is quite true that EASA have indicated that model flying associations will be granted some exemptions from the new regulations, they have not (as far as I can see) indicated what those exemption might be and how far they might extend. So, we are not out of the woods yet.

BEB

I have snipped your excellent post for ease BEB.

The only part i have an issue is the limitation to 'flying in a club environment.' I am no longer a member of a club - I don't fly enough to make club membership worthwhile, and do most of my flying with the PSSA crowd these days. Would this type of flying be classed as a 'club' even though there is no formal membership methodology, but BMFA insurance is required....

This is the sort of hole that causes people who have experience of government making useless laws that only limit the law abiding feel very nervous about the first steps down the road....

[John Stainforth]

These restrictions are becoming almost a necessity in today's world. I think the CAA is bound to follow the FAA with their planned restrictions. During emergencies and special events, restrictions are placed on all aviation. The FAA have just issued a NOTAM with a TFR for all non-essential aircraft including UaS (of which model aircraft are a part) for the Houston area, Tx.

This doesn't bother me at all, and I don't think it deters from the hobby.

[Biggles' Elder Brother - Moderator]

That is a very good point Olly. I am afraid that as things stand they do not look good for those of us outside of the club system. The proposals do not mean they will be "banned" from flying, but it seems very unlikely that they will be able to benefit from any exemptions on offer. In short they will likely have ti comply with the full diet of regulation as would be applied to a commercial operator. And that looks very onerous.

I fear those who fly gliders are vulnerable here as well. As we all know glider flying tends to be a much more informal and "non-club orientated" activity - having said that many glider sites of course have been in use by the same group of flyers for many many years - constituting what in essence is a club. But will EASA see it that way? As things stand I fear not.

Basically the reason I believe EASA like clubs is that through them (and their affiliation to BMFA etc) it is possible to establish a clear record of safe operation, the existence of a set of rules and procedures for operation and a channel of communication. Now regardless of what effectiveness and value we ascribe to these features - EASA seem to like them!

I believe that for their own good glider pilots will need to get themselves organised on some basis. I'm not sure what, but it should be able to register sites, draw up local operational procedures and somehow "represent" the flyers - as distasteful as this may seem I believe it may be necessary.

For the pure "loner" who flies from a local farmer's field though I see no solution - regretably.

BEB

[Peter Jenkins]

BEB, having re-read NPA 2017-05 (B), it is quite clear that the lobbying from the model aircraft world has been recognised. Section 1.2.4.7.3. deals specifically with model aircraft. The introduction to the section states:

In some MSs (Member States), model aircraft operations are clearly defined and regulated by established model clubs and associations, in accordance with the regulatory framework of their NAA (CAA in the UK). These national regulations are mostly considered to be fit for purpose by both the remote pilots and their NAA. Based on the replies provided by model aircraft associations, a total number of 1.5 million model aircraft across the EU could be estimated.

The text continues under the Consequences heading as follows:

The main consequence of this issue is the barrier to the market. If model aircraft would be required to comply with the same requirements mandated for UAS, they could be even prohibited or at least a disproportionate burden could be imposed on them. For this reason, some special alleviations need to be identified for this aircraft category. (My emphasis)

The document continues with the view that if there is no EU-wide legislation on this topic then National Aviation Authorities (NAAs) would continue to implement rules that would be different and, in some cases, overly restrictive. In our case this is referring to the status quo with which both we and the CAA appear to be quite content.

Please explain why a further response to EASA is likely to result in any further relaxation in the proposed rule making at this stage?

[Rich too]

Posted by Frank Skilbeck on 29/08/2017 13:20:05:

How would they differentiate between this Drone and a conventional fixed wing RC aircraft.

The issue isn't fixed wing vs multi-rotor as far as the authorities are concerned but unmanned aircraft which are capable of operating in controlled airspace. If you go on U tube and look at FPVers posting videos of long range flights, you'll see most of these are fixed wing aircraft, often the same as we fly LOS. One of the reasons they couldn't agree on separating conventional model aircraft was that somebody flying one of these could claim it as falling in the model aircraft category.

Simple - capable of flying outside LOS? Equals a drone.

[Paul Smith 223 Sqn]

Agreed - and the offence is created when the pilot flies his aircraft outside LOS. In that way, putting a camera that is not being used to control the aircraft and operating the craft within LOS would not be in violation of the rules.

Edited By Paul Smith 223 on 30/08/2017 10:09:11

[Erfolg]

Peter asks why did I selectively quote from the BMFA communication.

The reason is quite simple, i wanted to keep things simple.

Although it is suggested that within clubs we will operate as today. Again a selective quote The DfT’s proposals do not change this. Essentially, the CAA would issue us with an authorisation (or exemption) defining our agreed operating parameters which would reflect how we operate today (including operations above 400ft/120m). Even the phrasing suggests that each site will be treated on an individual basis. On that basis the excemption from the height limit, may such an issue, particularly for those operating in the general vicinity of airfields. Significant areas of the country ranging from London, the major cities of the UK, areas such as the Fylde coast, Cumbria, also other areas where typically low flying aircraft, such as the military, fly occasionally.

I have been accused of splitting hairs, I guess this is meant to be proactive enough to elicite a reaction. Yet often reflects tat some can be intolerant of views that do not fit with their own.

I have been been and steadfastly been resistant to just accepting regulation in this area, with emphasis on the established RC air vehicles that we operate. The reason being our operating history has been in general exemplary.

I do however recognise that change is coming, I personally see the communication as being far from reassuring. The areas of ambiguity and lack of specifics being the basis of this view. This is not intended to be a criticism of Dave Phillips. More a recognition of there is a lot of work still to be done, to limit as far as possible the impact on all areas and groups in what we all call our hobby.

I also urge the BMFA via its achievements schemes examiners to consider, if necessary how can these used or amended as vehicle to demonstrate, the CAA requirements when known. A bottom up, rather than a top down, approach to our hobby. The objective not only compliance, also involvement of the grass roots of both the BMFA and others.

Yet I fear for those who operate outside both clubs and club sites. Again with particular concerns of (one of ) our feed stock, children and parents who go onto become modellers.

Essentially, the CAA would issue us with an authorisation (or exemption) defining our agreed

operating parameters which would reflect how we operate today (including operations above

400ft/120m).

Essentially, the CAA would issue us with an authorisation (or exemption) defining our agreed

operating parameters which would reflect how we operate today (including operations above

400ft/120m).

[Rich too]

I agree with you Erfolg, and I gave up on this consultation process when I discovered that they cannot even agree a definition for a drone - which is frankly ridiculous.

There is absolutely no way that this can be policed - especially outside of a club - and a simple registration process (similar to joining the BMFA) is the only way it will have any chance of working. How many modellers currently operate outside of clubs? How many of those outside the BMFA or LMA? And they will be expected to conform? Not a chance.

 

Edited By Rich too on 30/08/2017 13:23:08

[Biggles' Elder Brother - Moderator]

Peter, you beg the question I'm afraid. Simply stating (again) that EASA recognise that some excemptions will be be forthcoming is not telling us what those exemptions will be - and that is critical information!

For example (note this is just one example - I could pick very many). The new regs state that Cat A aircraft will not be allowed to over fly any people - none at all! Will we have an exemption to that - or not? If not, then my club (and many others based in public parks) are "dead" - as is pretty well all slope soaring on public land.

I stress - I'm not looking for you to answer this particular point - its the general. principal I am refering to, the fact that we are told there will be exemtions - but have no indication of the detail! That is still worrying and that is why I still urge people to respond to the consultation - and thus "lay claim" to what exemptions we want and need.

BEB

[kc]

It was mentioned yesterday that clubs might get exemptions. Those people who are NOT in any club would probably lose out so surely the answer for them is to make sure you form yourselves into a club BEFORE the regulations apply. Even if you are a lone flier then form your own club! Just a name and a website with some stated flying site might be enough. Maybe co-opt a non flying family member along too to ensure it counts as a club. But the fact that the club exists before the regulation might be critical so make sure it's documented in some way. ( on this forum perhaps)

Having said that I still reckon flying with others in a club is so much more enjoyable than a lone flying session!