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Neil Harrison

CAA Registration - Further information for BMFA Members

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Neil Harrison

I’m sure you’ve all seen this but just in case.....

Further to the announcement earlier this week, we will be working with the CAA to clarify the detail of how we can best assist our members to comply with the Registration and Competency requirements which were introduced in the 2018 changes to the Air Navigation Order and become law on the 30th November 2019 for those operating unmanned aircraft.

The changes to the law are in part to address established issues arising from unlawful operation, but also to help facilitate the wider integration of unmanned aircraft into the airspace in the future.  The Queen’s Speech of 14th October announced the ‘Air Traffic Management and Unmanned Aircraft Bill’ which introduces mechanisms for modernising airspace and Air Traffic Services and provides the Police with new powers to deal with the unlawful use of unmanned aircraft.

It is acknowledged that Operator Registration is unlikely to address unlawful operation and that those using an unmanned aircraft for malicious purposes are unlikely to register.  However, it does provide the Police with a mechanism for enforcement if they challenge anyone they suspect of operating an unmanned aircraft illegally.  If the operator is not registered or able to confirm competency, then the Police have an immediate and clear reason for issuing a fixed penalty notice or prosecution.  Details of the punitive measures have yet to be published.

Similarly, it is acknowledged that Competency requirements will not address the issue of those using unmanned aircraft with malicious intent.  However, there is a hope that it may help reduce the significant number of unlawful operations conducted unwittingly.  The BMFA does not disagree that awareness of applicable regulations is an essential requirement for safe operation and during our campaign it has become evident to all parties (including the CAA) that there are, perhaps, a few too many model flyers who do not fully understand the existing regulations.

The measures announced earlier this week are interim ones to deal with the immediate issue of the changes to UK law which become applicable on the 30th November.  We will be working with the CAA towards the implementation of the EU regulations in June 2020, so actively encouraging members to break the law by not complying (as some have suggested) would be counterproductive and detrimental to our ongoing negotiations.

What does this mean for BMFA members?

In simple terms, if you operate an unmanned aircraft weighing more than 250g outdoors after the 30th November then it will become a legal requirement to be registered as an Operator with the CAA and be able to provide evidence that you are competent (essentially to confirm that you are aware of the applicable laws).  Those who only operate control line aircraft will be exempted from the requirements. 

The CAA have agreed to recognise our members’ Achievements as an alternative to their online test and allow us to administer registration of Operators as part of our membership process.  A few key points to note are that:

The fee for Operator registration will be £9/year.  Where members choose to register through the BMFA, we will collect the fee and pass it on to the CAA.  The BMFA does not profit from this in any way.  The CAA has to make a charge to users in order to cover the cost of the scheme which is not subsidised by the Government (unlike in some other countries).

Members will be exempted from registering as Operators on the 30th November and can register instead as part of the BMFA’s membership renewal process (ideally by the end of January 2020).

Registering as an Operator through the BMFA will be a specific ‘opt-in’ for members and the CAA will only receive information for those members who have given consent by ‘opting in’ and paid the CAA fee.  

The BMFA has never and will never share members’ data with any third parties without consent.

We are still clarifying arrangements for junior members in terms of Operator registration, but there are no age restrictions for ‘Remote Pilots’.

Members who ‘opt in’ will receive an email from the CAA with their ‘Flyer ID’ once their data is uploaded. (Should a member be asked to provide proof of registration before receiving their Flyer ID the BMFA office will provide evidence of compliance.) 

There will be no requirement to place any registration numbers on the exterior of model aircraft, but they must be carried in an easily accessible location (within a battery hatch for example).

For members with an existing Achievement, all that they will need to do to remain lawful will be to simply ‘opt in’ when they renew their membership and pay the additional CAA fee.

We will shortly introduce a Member’s Competency Certificate (a simple knowledge test which will be available online/hardcopy and/or via our clubs and examiners) as an alternative to the CAA system for those without an existing Achievement.  Members without an existing Achievement will either have to complete a Member’s Competency Certificate or the CAA’s own test before we can register them as an Operator.

Registration and/or evidence of competency will not be conditions of BMFA membership but failure to be able to produce evidence of both if challenged by the Police could result in a fixed penalty notice or prosecution. 

Compliance with the Registration/Competency requirements is largely a matter for individual members and as such we would not expect Clubs to automatically assume responsibility for policing it, though of course some may choose to do so (perhaps to assist those members wishing to comply who do not have access to the internet or in order to comply with local operating requirements such as FRZ permissions for example).

We are still working with insurers to resolve any potential insurance implications and hope to be able to clarify the situation by the end of this week.

Members will continue to benefit from the existing permissions/exemptions already granted to the CAA recognised UK Associations (such as the permission to operate above 400ft with aircraft of less than 7Kg, operate control line aircraft within an FRZ and operate FPV aircraft with a competent observer).

We appreciate that there are still likely to be many questions arising from this, but there remains a lot of detail to resolve with the CAA (and our insurers) before we can issue definitive guidance.  However, please be assured that we will provide further information and guidance as soon as it becomes available.

Kind Regards

David Phipps, CEO.

 

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Marc RC pilot

Thank you for the heads up Neil.

Regards

Marc

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BigT

Having done extensive research into the 2 major paths to UAS registration in the UK for BMFA members on behalf of the members of the  2 RC clubs I help run, my conclusion is do not bother with the BMFA deferral route! And here’s the reason why.  
 

CAA UAS/SUA/RC Operator and Flyer Registration Option 1 Operator over 18 years old Flyers over 13 years old BMFA Deferment route
Defer registration until membership renewal and then instruct the club to Opt you in and register you as an Operator and Flyer and pay the club £9. If you do not have a BPC/A/B/C certificate in any discipline then you will either have to complete the CAA Competency Test (reg document sent via email) or the BMFA RCC test (which is to be found at https://rcc.bmfa.uk/rcc ). The BMFA will then send your details to the CAA and eventually you will get your Operators number sent to you by the CAA. If you decide to go down the BMFA route you will need to have the following documents on your person when flying, either physical copy or electronic. You are now reliant on the BMFA sending your details through to the CAA.
BMFA membership card
RCC Certificate or CAA Pilots registration e mail
Exemption E4953 No 1324 until 31st January 2020
Exemption E4972 No 1331 Until 30th June 2020 unless revoked earlier If you fly control line then you will also need
Exemption E4913 Ni 1325 Until 30th June 2020
Some form of ID.
Flyers Under 18 will need to have the RCC and E4972
Please note that the BMFA say that the RCC is valid for 3 years but the exemption for that and achievements is only valid until June 2020 when the new EASA regulations come into force.
------------------------------------------------------------------------------------------------
Option 2 Operators over 18 years old Flyers over 13 years old CAA Direct Route
Go online to https://register-drones.caa.co.uk/individual/register-and-take-test-to-fly
Complete the 20 question competency test which is multi choice and is impossible to fail as it gives the correct answers to any question you may get wrong. Pass mark is 16/20 and is good for 3 years. Fill out name and address, pay £9, and get your operator and flyer number by return email. Put the number on the model. No need to carry ID or Exemptions or worry about June 2020. Just carry your Pilots ID.
Job Done
    
The Short Form
The short form is that if you go the CAA route you get both IDs within minutes, can mark your models and carry the flyer ID and don't need anything documentation. The test will last 3 years because there's no chance the CAA will embarrass itself in national press by cancelling tens of thousands of registrations
If you go BMFA you get no IDs at all until you renew and no flyer ID even then, have to carry lots of paperwork that the Police probably won't understand, and the test currently expires in June.
Just to make it a bit clearer if you go BMFA you never ever get a flyer ID as they have no way to register that with the CAA, they can only register you as an operator. You have to carry on relying on the flyer exemption indefinitely as there's no stated plan for that to change. My personal take, having some experience with police matters, is that the average copper will have been told simply to look for an OP- number on the model and a FLY- number on paper. They just don't have the time for training on all these exemptions and what a BMFA membership card looks like for example so won't listen, far too busy. Just issue a ticket and probably impound the model and let you argue all that with the magistrate. Personally I need a simple life

PS

Quick word on the Plus  400 ft exemption. Only applies to BMFA members operating outside a FRZ and  controlled airspace I E  D airspace. There is an exemption in place for slope operation that allows for over 400 ft AGL but not above the remote pilots head. 

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tonym

All my models weigh less than 250g - so do my wife's 🙂

Will the police carry scales?

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SilentPilot

I put my Operator ID on my +250g models and a sticker saying "sub 250g" on my lighter ones. 

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Mark Evans
50 minutes ago, BigT said:

Personally I need a simple life


 

Exactly why I have currently quit the hobby and at the moment have no plans on flying again. 

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BigT
32 minutes ago, tonym said:

All my models weigh less than 250g - so do my wife's 🙂

Will the police carry scales?

With my professional experience of police and police methods there is no time or budget to train every single officer on every single nuance of  every new law. The average policeman will be told to look for a reg number, proof of ID and “ to use his judgment” as to the legality of action and equipment. They won’t have knowledge or interest in exemption certs or membership cards. What they will do is use the “ suspicion of illegal action” act to seize suspect equipment for analysis by the CAA  inspectorate, inform you of your rights, take your details, issue a receipt for the equipment and let you argue your side with the Magistrates. 
 

 In obvious cases of illegal activity, such as flying an unregistered multicopter up the High Street, they will issue a Fixed Penalty Notice of  £1000.   Also worth noting that PCSO, Council officials, park wardens, traffic wardens etc do not have any powers to inspect and seize your equipment. I would also recommend that if you video any interaction with the police as they will certainly be videoing you.  I would expect that there will be a couple of high profile cases brought after December to bring publicity. 

Worth pointing out that it will probably be SO 18 that gets the budget to enforce the act when it finally goes through, it only needs one more reading. Not the a Private Members Bill but this one 

https://services.parliament.uk/Bills/2019-20/airtrafficmanagementandunmannedaircraft.html
 

 

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Steve J
7 minutes ago, BigT said:

when it finally goes through, it only needs one more reading. 

https://services.parliament.uk/Bills/2019-20/airtrafficmanagementandunmannedaircraft.html

No it doesn't. It will have to be reintroduced and go though all stages in both houses. It only had its first reading in the Lords before Parliament was dissolved.

I do agree with you about doing the CAA test and registering directly with the CAA and have been saying so on various forums. I almost fell off my chair laughing when I saw the flowchart that the BMFA have produced.

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Martin Church
59 minutes ago, Mark Evans said:

Exactly why I have currently quit the hobby and at the moment have no plans on flying again.

Me too Mark, I have no intentions on jumping through hoops for anyone these days let alone the CAA. what’s always been considered a right to fly models has in my opinion been sold down the river.

Ive packed all my rc planes into the loft & have bought fishing rods with the money I’m gradually getting for them as I’ve sold them.
Model flying isn’t going to survive this attack without serious loss in numbers.

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Mikeb52
2 hours ago, BigT said:

Having done extensive research into the 2 major paths to UAS registration in the UK for BMFA members on behalf of the members of the  2 RC clubs I help run, my conclusion is do not bother with the BMFA deferral route! And here’s the reason why.  
 

CAA UAS/SUA/RC Operator and Flyer Registration Option 1 Operator over 18 years old Flyers over 13 years old BMFA Deferment route
Defer registration until membership renewal and then instruct the club to Opt you in and register you as an Operator and Flyer and pay the club £9. If you do not have a BPC/A/B/C certificate in any discipline then you will either have to complete the CAA Competency Test (reg document sent via email) or the BMFA RCC test (which is to be found at https://rcc.bmfa.uk/rcc ). The BMFA will then send your details to the CAA and eventually you will get your Operators number sent to you by the CAA. If you decide to go down the BMFA route you will need to have the following documents on your person when flying, either physical copy or electronic. You are now reliant on the BMFA sending your details through to the CAA.
BMFA membership card
RCC Certificate or CAA Pilots registration e mail
Exemption E4953 No 1324 until 31st January 2020
Exemption E4972 No 1331 Until 30th June 2020 unless revoked earlier If you fly control line then you will also need
Exemption E4913 Ni 1325 Until 30th June 2020
Some form of ID.
Flyers Under 18 will need to have the RCC and E4972
Please note that the BMFA say that the RCC is valid for 3 years but the exemption for that and achievements is only valid until June 2020 when the new EASA regulations come into force.
------------------------------------------------------------------------------------------------
Option 2 Operators over 18 years old Flyers over 13 years old CAA Direct Route
Go online to https://register-drones.caa.co.uk/individual/register-and-take-test-to-fly
Complete the 20 question competency test which is multi choice and is impossible to fail as it gives the correct answers to any question you may get wrong. Pass mark is 16/20 and is good for 3 years. Fill out name and address, pay £9, and get your operator and flyer number by return email. Put the number on the model. No need to carry ID or Exemptions or worry about June 2020. Just carry your Pilots ID.
Job Done
    
The Short Form
The short form is that if you go the CAA route you get both IDs within minutes, can mark your models and carry the flyer ID and don't need anything documentation. The test will last 3 years because there's no chance the CAA will embarrass itself in national press by cancelling tens of thousands of registrations
If you go BMFA you get no IDs at all until you renew and no flyer ID even then, have to carry lots of paperwork that the Police probably won't understand, and the test currently expires in June.
Just to make it a bit clearer if you go BMFA you never ever get a flyer ID as they have no way to register that with the CAA, they can only register you as an operator. You have to carry on relying on the flyer exemption indefinitely as there's no stated plan for that to change. My personal take, having some experience with police matters, is that the average copper will have been told simply to look for an OP- number on the model and a FLY- number on paper. They just don't have the time for training on all these exemptions and what a BMFA membership card looks like for example so won't listen, far too busy. Just issue a ticket and probably impound the model and let you argue all that with the magistrate. Personally I need a simple life

PS

Quick word on the Plus  400 ft exemption. Only applies to BMFA members operating outside a FRZ and  controlled airspace I E  D airspace. There is an exemption in place for slope operation that allows for over 400 ft AGL but not above the remote pilots head. 

Interesting points here! I’ve taken the bmfa test, but could I still go down the CAA route, take the test, and pay the £9 direct to them? Or will that throw a spanner in the works? 

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BigT
33 minutes ago, Steve J said:

No it doesn't. It will have to be reintroduced and go though all stages in both houses. It only had its first reading in the Lords before Parliament was dissolved.

I do agree with you about doing the CAA test and registering directly with the CAA and have been saying so on various forums. I almost fell off my chair laughing when I saw the flowchart that the BMFA have produced.

I think you are confusing the bills, there are 2. I have had communications with the DfT to that effect. Whatever the case it will be rubber stamped.  
I am so disappointed with the BMFA over their actions. I speak as a member for 45 years and an Examiner.  In particular there is one BMFA officer who is determined to promote the “ glass half full, keep calm and carry on flying, forget about the future”.   Highly critical and intelligent criticism and questioning on the BMFA FB  threads was summerly delegated on Friday, I suspect behind the scenes pressure being applied but have no proof. But as if by magic they have been reinstated..

comments such as 

Here's what the BMFA test has done to the 20 CAA questions, and no I'm not spoiling it, I may be helping people:

11 questions are identical other than having the inclusivity content stripped out and the word ‘drone’ replaced by ‘model aircraft’ in some places.
1 just has a plug for their insurance added.
1 about privacy has been mucked up by someone who doesn’t understand grammar, read it carefully.
1 simple one about using a phone to control a drone has been replaced with questions on the CAA FPV exemption that most flyers probably don’t know about.
1 added a reference to dronesafe.uk which most flyers are probably unaware of so will get it wrong, yes it's a real site.
5 have extra choices added, most of which are reasonable.

Oh and for some reason it jumbles up the choices so if you redo it be careful to read the order they're presented in each time.

 

Andy Symons Well then they've shown a woeful lack of understanding of how actions are perceived in this world. As our voice they should show a lot better judgement.
Did it not occur that the CAA had been very deliberately inclusive on a test that was going to be a national news story?
Did it not occur that for a predominantly white male association to strip it all out in their duplicate test could be grasped upon by the press?

Even your answer opens you up to criticism, why does "You want to fly..." better relate to the person taking the test than "Ameen wants to fly..."

I'm just playing devil's advocate here, I'm not accusing anyone of anything other than poor judgement.  Andy Symons try this thought experiment, imagine yourself being interviewed by the press and trying to explain why removing the names Nilesh, Ameen and Kelechi  and every reference to 'she' makes it more relevant to the person taking the test, just think what the interviewer would make of it.

 

Andy Symons How you can keep saying you don't understand my issue is beyond me, so lets spell it out again:
1) There was no need  to spend BMFA money and time creating a duplicate test in the first place, they should have explained to members that they were putting the money thus saved to better use and pointed us to the CAA's test that a 5 year old can do, and gives us a flyer number, and has no need for exemptions that the plod won't understand. They could also have pointed out that the CAA was always going to insist on the same 20 questions so all that could be done was rewording them and adding an option here and there so it was pointless.
2) If they had to duplicate the test there was no rational reason to strip out all the CAA's inclusivity and thus present an anti PC  mentality to the world.
Clear enough Andy?
I'm sorry that you don't seem to believe that the members have a right to disagree with the ruling committee, and should all tow their line and shut up unless they want to praise them. Fortunately this isn't a trade union in the 70s.

Andy Symons Actually I have a third and rather important issue, that the BMFA didn't even consult it's members on how to respond to the most significant development in regulation of our hobby in living memory. It just decided on a course of action, spending money unnecessarily and setting itself up as the CAA's tax collector. Most members didn't notice what was happening until it was on the TV a month before coming into force. It could have been on the front of the magazine with an on-line/paper pole to decide what course to take.

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BigT
8 minutes ago, Mikeb52 said:

Interesting points here! I’ve taken the bmfa test, but could I still go down the CAA route, take the test, and pay the £9 direct to them? Or will that throw a spanner in the works? 

You have to Opt In when renewing your BMFA membership so taking the BMFA test is irrelevant. Just go on line and reg through the CAA put your number in a  3.1 mm font on the model or under a hatch that doesn’t require ANY tool to access, job done till 12 months have gone by. No need for any additional bits and bobs to carry around, advisable to carry photo ID for plod.  The BMFA don’t even want to know your reg number, not a condition of membership, but insurers have stated you must be lawful to be insured. FYI FPVUK insurers have said they will insurer anyone even illegal activity. 

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BigT
12 minutes ago, Martin Church said:

Me too Mark, I have no intentions on jumping through hoops for anyone these days let alone the CAA. what’s always been considered a right to fly models has in my opinion been sold down the river.

Ive packed all my rc planes into the loft & have bought fishing rods with the money I’m gradually getting for them as I’ve sold them.
Model flying isn’t going to survive this attack without serious loss in numbers.

Make sure you get your EA rod licence then, that’s one big hoop you’ll need to jump through unless it’s sea fishing.  LOL. I had mine checked 4 times last year. 

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Martin Church

I’ve fished since I was 10 I think I realise I need a rod licence.

What I’m not told by the EA or asked is my understanding of an ever evolving legal system relating to my fishing.

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BigT
5 minutes ago, Martin Church said:

I’ve fished since I was 10 I think I realise I need a rod licence.

What I’m not told by the EA or asked is my understanding of an ever evolving legal system relating to my fishing.

Glad you do, lots don’t, especially Eastern European’s around my part of the planet. I was being light hearted not critical. 
 

What models are you selling off? Might be able to pass on to club members. 

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SilentPilot
1 hour ago, Mark Evans said:

Exactly why I have currently quit the hobby and at the moment have no plans on flying again. 

You always quittin :D 

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Steve J
51 minutes ago, BigT said:

I think you are confusing the bills, there are 2. 

I am not confusing anything. If you follow the link, you will see that the DfT's Air Traffic Management and Unmanned Aircraft Bill only had its first reading in the Lords.

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Mark Evans

Yep, fished since I was 6 years old, it was actually my job once, never ever had my rod license checked, but I have bought one every year since I was 12. 
 

quick click and pay online (trip to the PO in the old days, pay and done) never the feeling anyone is trying to kill the hobby nor ever had my knowledge of fishing ‘safely’ tested. 
 

tbh I should have properly got out the flying hobby a few years ago, I’d have saved myself £££ on planes I’ve bought which if things continue they way they are will make my 2 dlg’s i packed away (one brand new) absolutely worthless to try and sell. 
 

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SilentPilot
43 minutes ago, Martin Church said:

What I’m not told by the EA or asked is my understanding of an ever evolving legal system relating to my fishing.

You could say this CAA palaver is the start of an ever evolving legal system relating to your model flying! 

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Martin Church
20 minutes ago, SilentPilot said:

You could say this CAA palaver is the start of an ever evolving legal system relating to your model flying! 

It’s been an ever evolving pain in the ass for a few years now what with CAP this & ANO that.

I have absolutely no idea of any of these new laws & that’s a fact all I have used since I started in the early 1980’s is common sense & only ever fly at recognised club fields or sites. Ive abided by rules the club sets,

 

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