CAA Review of UK UAS Regulations

[Steve J]

Comments close on this review next week. If you can't be bothered to respond, please don't moan when remote ID comes in.

[Graham Woods]

If anyone believes they can influence the CAA with some comment or other, they probably live in Cloud Cuckoo Land (Aristophanes' City in the sky from 'The Birds')

We know, and the CAA know, that bad actors do not obey laws and rules. The latest NATS fiasco is a perfect example of quangocrat incompetence.

 

[satinet]

50 minutes ago, Steve J said:

Comments close on this review next week. If you can't be bothered to respond, please don't moan when remote ID comes in.

You can't be naive enough to believe that the caa is actually looking for input to shape it's policies.  

 

[satinet]

1 hour ago, Steve J said:

Comments close on this review next week. If you can't be bothered to respond, please don't moan when remote ID comes in.

They might get more responses if there was actually a feedback form that they say there is in the policy document. 

[Steve J]

47 minutes ago, Graham Woods said:

If anyone believes they can influence the CAA with some comment or other, they probably live in Cloud Cuckoo Land (Aristophanes' City in the sky from 'The Birds')

That may or may not be the case, but I know precisely what the effect of not commenting will be.

 

47 minutes ago, Graham Woods said:

The latest NATS fiasco is a perfect example of quangocrat incompetence.

NATS are 51% privately owned.

[PaulR]

22 minutes ago, satinet said:

They might get more responses if there was actually a feedback form that they say there is in the policy document. 

The form is mentioned in the email detailing the general BMFA response that all BMFA members should have received recently (I got mine on Friday).

https://consultations.caa.co.uk/rpas/call-for-input-review-of-uk-uas-regulations/

1 hour ago, Graham Woods said:

If anyone believes they can influence the CAA with some comment or other, they probably live in Cloud Cuckoo Land (Aristophanes' City in the sky from 'The Birds')

From the two communications around this from the BMFA it would appear that it would be to our benefit to respond, not to put forward a specific, individual viewpoint but to add to what we hope will be a massive volume of replies that generally align with the now published BMFA response. By acting as a group the hope is that we can indeed influence the CAA.

[Steve J]

37 minutes ago, PaulR said:

From the two communications around this from the BMFA it would appear that it would be to our benefit to respond, not to put forward a specific, individual viewpoint but to add to what we hope will be a massive volume of replies that generally align with the now published BMFA response. 

I strongly disagree with the BMFA response to some of the questions, most notably the remote ID one where they say "Neither yes nor no".

[satinet]

1 minute ago, Steve J said:

I strongly disagree with the BMFA response to some of the questions, most notably the remote ID one where they say "Neither yes nor no".

Remote ID is a potential disaster for RC flying but the BMFA seem happy to go along with it.  The idea that people are going to want to setup a device with their ID number, model details etc on each and every model in bananas. Half the people in my club are probably 70 plus, flying wooden models.  It's a ridiculous response from the BMFA and extremely disappointing. No just downright stupid, let's not use euphemisms.

The other thing in the proposed rules is all this stuff and type approval for UAS. Not sure how that's going to fit in to kit built models.  Or basically any rc model.

 

[PaulR]

1 hour ago, Steve J said:

I strongly disagree with the BMFA response to some of the questions, most notably the remote ID one where they say "Neither yes nor no".

1 hour ago, satinet said:

Remote ID is a potential disaster for RC flying but the BMFA seem happy to go along with it.  The idea that people are going to want to setup a device with their ID number, model details etc on each and every model in bananas. Half the people in my club are probably 70 plus, flying wooden models.  It's a ridiculous response from the BMFA and extremely disappointing. No just downright stupid, let's not use euphemisms.

To quote from their 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."

I'm not sure how that makes them "happy to go along with it" or how this is "ridiculous". 

[Steve J]

1 hour ago, PaulR said:

I'm not sure how that makes them "happy to go along with it" or how this is "ridiculous". 

Try reading and quoting the entire answer to Q14 including the bit that says "A. Neither yes nor no" (which is the most important bit). The same applies to Q15.

[MikeE]

Currently we can drive in Europe on a UK driving licence. 

Regulations  just need to be aligned, and accepted by each as appropriate. 

[Dave Elam]

Just completed the survey. Hope it helps, although I have a nagging doubt that it is just a process of tick boxing that the CAA feels it has to go through and that the outcome may already be pre-determined. I hope I'm wrong.

From a technicality point of view, how on earth could a remote ID transponder be fitted into a moulded glider fuselage that is already packed with receiver, servos and battery?

[hpihl]

19 hours ago, Steve J said:

EASA is an EU agency. The UK is not a member of the EU or EFTA. The UK cannot be a member of EASA.

There is no such requirement (see EU 2018/1139 article 129), the EFTA countries just use EFTA trade agreement as a legal framework for their EASA deal. Had the UK pursued staying inside EASA, the legal framework would probably have been the EU/UK trade agreement or a separate agreement covering just the needed areas. However, the UK never wanted to continue inside EASA for the reasons stated by the Department for Transport.

Regarding your original claim about some kind decision by EU/EASA; there is no such thing. All the decisions here are by the UK.

[PaulR]

21 minutes ago, Steve J said:

Try reading and quoting the entire answer to Q14 including the bit that says "A. Neither yes nor no" (which is the most important bit). The same applies to Q15.

I quoted the bit that you appeared to not have read, or at least ignored - that explicitly states the stance on remote ID in model aircraft. Suggesting that the BMFA doesn't want to stop remote ID being required in "wooden models" seems to be incorrect in my interpretation of the document they have provided.

Making it a yes/no question is a simplification that is not very useful in the wider discussion of the consultation. I'd suggest that subsequent description of where it might and might not make sense is actually the "most important bit".
The proposed BMFA response seems to me to be roughly in line with my thoughts that although it may become a de facto standard in some drones etc that are commercially produced it has no relevance to "model flying" as most of us know it. The consultation is not (just) about model flying though, so some mention of the scenarios where it does make sense doesn't seem "ridiculous" and is probably a response more likely to be listened to than a blanket "NO" to remote ID.

The same applies to Q15:
"15. Should CAA implement geo-awareness (Opportunity 12) and why?
A. Neither yes nor no
On-board automated Geo-fencing and Geo-awareness are features increasingly incorporated into
UAS/drones but would not be appropriate for model aircraft as they are manually piloted.
The BMFA supports the concept of Geo-Awareness, provided that model aircraft are excluded from
any such requirements."

Lets agree to disagree on the approach the BMFA is suggesting here, but we can just agree that remote ID in model aircraft is not something we want to see.

[satinet]

1 hour ago, PaulR said:

I quoted the bit that you appeared to not have read, or at least ignored - that explicitly states the stance on remote ID in model aircraft. Suggesting that the BMFA doesn't want to stop remote ID being required in "wooden models" seems to be incorrect in my interpretation of the document they have provided.

Making it a yes/no question is a simplification that is not very useful in the wider discussion of the consultation. I'd suggest that subsequent description of where it might and might not make sense is actually the "most important bit".
The proposed BMFA response seems to me to be roughly in line with my thoughts that although it may become a de facto standard in some drones etc that are commercially produced it has no relevance to "model flying" as most of us know it. The consultation is not (just) about model flying though, so some mention of the scenarios where it does make sense doesn't seem "ridiculous" and is probably a response more likely to be listened to than a blanket "NO" to remote ID.

The same applies to Q15:
"15. Should CAA implement geo-awareness (Opportunity 12) and why?
A. Neither yes nor no
On-board automated Geo-fencing and Geo-awareness are features increasingly incorporated into
UAS/drones but would not be appropriate for model aircraft as they are manually piloted.
The BMFA supports the concept of Geo-Awareness, provided that model aircraft are excluded from
any such requirements."

Lets agree to disagree on the approach the BMFA is suggesting here, but we can just agree that remote ID in model aircraft is not something we want to see.

The problem with the BMFA's stance on remote ID and geo-fencing is there isn't such a thing as a model aeroplane such.  Much simpler to put "no" as clearly it's a can of worms that doesn't need to be opened.  What they're saying is we want the CAA to create a new class of UAV that the CAA/EASA etc etc have previously been unable or unwilling to do.  If you look at the document it alludes to creating a classification for RC aircraft (in my view unlikely.). 

Most of the exiting regulations that came in to force around the competence test etc don't have any relevance or proportionality to RC flying, in the traditional sense, either, but that didn't stop it being brought in.  We're all still doing this silly test every few years that's done absolutely nothing to increase flying standards or reduce (virtually non existent) safety incidents.

Everyone knows that you can just build a drone from parts and send the gear over a prison wall or whatever other fanciful idea is being put forward. If the CAA don't acknowledge that their either incompetent or dishonest, or both, which doesn't bode well for the future.  Bad actors don't play by the rules as stated above.  Most the the hobby drone pilots I've met since the database came live haven't got a the slightest clue that it exists and/or don't care anyway. 

The whole "call for input" is asking for input on a totally open question - i.e future expansion of UAV use. I mean how are you supposed to make a meaningful contribution to that question if the CAA doesn't or can't even provide a projection of the number of "drones" we're talking about. In my view the great drone usage explosion is a load of bunkem - I think there's less around than there was a few years ago. (Hardly ever see one). The need for stuff like geo-fencing and IDs is completely different if the sky is going to be darkened with drone swarms than if we are talking about a few tens of thousands of people flying drones in open fields. 

 

 

Edited September 1, 2023 by satinet

[Steve J]

1 hour ago, PaulR said:

I quoted the bit that you appeared to not have read 

Making it a yes/no question is a simplification that is not very useful in the wider discussion of the consultation.

I read it all. In my opinion the BMFA are, at best, naïve.

1 hour ago, PaulR said:

Making it a yes/no question is a simplification that is not very useful in the wider discussion of the consultation.

The CAA will produce a bar graph of the responses. If the majority are yes or don't care, they will see no reason not to proceed. If you don't want remote ID, geo-awareness/fencing, having to get permission before take-off, say "no" not "I don't care".

[swarrans]

Whilst I don’t suppose my response will make any difference whatsoever I decided to plow through it and have submitted it.

I strongly objected to the potential of remote ID and tried to make the comment that model aircraft should be exempt from all the new rules. 
 

It won’t make any difference to their conclusions no doubt but hey ho!…

[Steve J]

12 hours ago, Dave Elam said:

From a technicality point of view, how on earth could a remote ID transponder be fitted into a moulded glider fuselage that is already packed with receiver, servos and battery?

Dronetag BS

[Dave Elam]

1 hour ago, Steve J said:

Dronetag BS

And Spektrum's SkyID. Which is quite a big larger. 

https://www.spektrumrc.com/product/skyid-remote-id-module/SPMA9500.html

[satinet]

4 hours ago, Steve J said:

I read it all. In my opinion the BMFA are, at best, naïve.

The CAA will produce a bar graph of the responses. If the majority are yes or don't care, they will see no reason not to proceed. If you don't want remote ID, geo-awareness/fencing, having to get permission before take-off, say "no" not "I don't care".

Exactly.  I don't want to see remote id for other people even if rc models were exempt in bmfa dream world.