Here is the finalized draft which I am trying to send to PM today through the link
and file it under the "Central Government (Miscellaneous)" category. There is a 4000 word limit in the submission form. But PDF files can be attached. So I am thinking of posting a short forwarding letter in the text box and attaching the complete letter as PDF attachment, since the letter exceeds the word limit.
When sending by post, the forwarding letter is not required.
Dated: ___________
To
Shri Narendra Modi
Honourable Prime Minister of India
152, South Block, Raisina Hill
New Delhi-110011Respected Sir,
Sub: (i) Request to exclude recreational users and hobbyists building and flying UAV (Unmanned Aerial Vehicles) / UAS / Quadcopters / Drones etc. from the DGCA ban and (ii) Request to take into consideration the interests of flyers in any future law or regulation being formulated in this respectAs you are aware, India has a thriving community of hobbyists who build and fly various types of Unmanned Aerial Vehicles which include planes, helicopters, gliders and Quadcopters or Quadrotors (commercially known as Drones). More recently the availability of such readymade UAVs of various sizes in the market has also given rise to a community of recreational flyers who fly such UAV/ drones for recreation or for photography. Drones are now also being used all around the world for various commercial and non-commercial civilian applications including aerial photography, agriculture, transport of goods and so on. A new kind of sports using drones called FPV Racing is also becoming popular very fast. This hobby also involves developing a lot of knowledge about electronics, aerodynamics and promotes/generates interest in science and technology amongst the youngsters.
2. The commercial availability and proliferation of UAVs in the market has given rise to the issues of national security, of inexperienced users endangering the lives of people or aircrafts and intrusion of privacy of people. Like any technology, UAVs are also dual-use. These may be used for constructive or destructive purposes, either intentionally or unintentionally.
3. While there is a requirement to control the use of UAVs in some manner, unfortunately, the blanket ban of DGCA on flying all kinds of UAVs vide Public Notice issued from File No. 05-13/2014-AED dated 7th October 2014 has at one stroke criminalized the hobbyists and amateurs. It has also forced the budding engineers and innovators who design, build and assemble such UAVs as their engineering projects to stop building and flying the same. This is no doubt harmful for the future generation in a country which already lacks innovators.
This will also effectively destroy the budding domain of FPV drone racing in India which is poised to become a new discipline in sports in the next decade. This month itself the first ever National Drone Championships were held in the USA where participants from all over the world, including people of Indian origin residing in the USA took part.
4. In the USA, the Federal Aviation Administration (FAA) has only restricted commercial use of UAV / Drones. But they have not put any control on amateurs or individuals flying these UAVs as a hobby or for recreation purposes. Nor have they made any requirement of flying licence mandatory. Instead they have issued some guidelines for recreational users flying drones, which are given at the URL
http://knowbeforeyoufly.org/for-recreational-users/ . It is to be noted that USA, unlike India, inspite of its post 9/11 security concerns and huge volume of air traffic has not banned its citizens from recreational use of UAVs.
5. Apart from recreational flying, one of the key uses of a UAV is in the domain of aerial photography. In fact a large number of tourists carry a UAV along with them these days to the countries where they visit so that they can get a different perspective of their tourist destination. Many tourists are known to produce wonderful aerial photos and videos and publish them online. Such amateur photos and videos act as an important mode of free publicity for tourism of the destination country. Unfortunately, with a blanket ban on drones in India, tourists arriving in India will never have the chance to shoot an amazing aerial video of Goa or Kerala which would have resulted in free worldwide publicity for our Incredible India.
There is a concern that aerial photography will put our national security at risk. While there is an element of truth here, usually the extent of such a risk is an over-estimation. In any case with high resolution aerial photographs of almost all of the country available through Google Maps and even higher resolution photographs available to Military Satellites of various countries, aerial photographs shot from drones (which have very limited range and battery life) can hardly add to such a security risk.
6. Drones have a huge potential in agriculture and in other civilian sectors as well. Only recently a TV news story was shown on how an Indian farmer made and used a drone to sprinkle pesticide and check for diseases in his farm. A drone has recently been used to transport blood to a hospital quickly in a difficult terrain. The potential applications are unlimited and new uses are being found everyday.
7. If this hobby, sports as well as commercial production is encouraged at this nascent stage, in future the Indian companies and startups can take a leading role in this area with effects percolating to the areas of Aviation, Electronics, Robotics, Embedded Systems and so on, leading to a success of the “Make in India” concept that you have so successfully campaigned for.
8. Sir, inspite of the above, there is a need to regulate the use of the UAVs keeping in view the security concerns of the nation as well as to maintain the safety, security and privacy of the people. However, while doing that, the necessary laws or rules should not be so restrictive that it stifles innovation and puts India and Indians at a disadvantageous position vis-à-vis other countries of the world. Regulations are definitely needed but not paranoia. The potential for its misuse or accident is no more than the potential of accident or misuse of a vehicle or an aircraft. But we don’t ban driving of a vehicle or flying of an aircraft. We have seen that in the past such restrictions have proved detrimental to the progress of the nation. Accordingly, here are a few suggestions which may kindly be kept in consideration while framing any new Rule / Law /Guidelines by DGCA or by any other agencies
Proposals for Guidelines for Recreational users of UAVs- Recreational use of UAVs by hobbyists and amateurs may be allowed subject to certain guidelines and conditions
- Commercial use of UAVs may be restricted and subjected to permission from the proper authorities
- Flying upto 400 feet in the air may be allowed
- Flying over crowded area should not be allowed
- Flying over sensitive infrastructure like power plants, water treatment plants, military areas, airports, jails, restricted zones etc. should not be allowed
- Flying within 5 km of Airport should not be allowed without permission from ATC
- The total payload carrying capacity of UAVs may be restricted upto a certain limit
- UAVs should be flown within eyesight
- UAV exclusion zones may be created and made known to flyers. Flying and aerial photography may be prohibited in such exclusion zones.
9. There have been arguments by certain quarters that licence may be issued for flying UAVs similar to that issued for vehicles or for persons who are flying. However, such a proposal in respect of recreational flyers will be counter-productive in such a big country like ours. Apart from taxing the government machinery, it will give rise to the infamous “Licence Raj” and “Inspector Raj” prevalent till 1980s, breeding corruption, red tape and harassment.
In the USA, the FAA has not proposed any licensing in respect of the recreational users. However, if at all some control needs to be exercised in respect of the UAV flying considering security aspects, a proposal is given to use e-Governance for this purpose for “self-registration” of UAVs by persons flying them.Proposal for Online Self-Registration System for recreational users of UAV using e-Governance- A web portal may be created for self-registration of UAV fliers and their UAVs
- Flyers can be citizens of India or International tourists and can self-register themselves online. This will be a one-time registration
- Domestic flyers may be identified and linked with Aadhar Card Number or Election Identity Card number
- International flyers may be identified and linked with their passport numbers
- Once the person self-registers himself/herself online, he/she can register one or more UAVs flown by him/her
- Photos, weight and other capabilities of the UAV e.g camera, FPV, telemetry etc. and similar details can be uploaded by the user himself/herself
- After entering details of UAV, a printout of UAV identification number can be generated from the system and pasted on the UAV itself
- Places where they are likely to fly can be entered online by the user himself. For example, if someone wants to fly in Goa, he/she will enter the time and dates and locations online. Flying locations can be indicated on a Google Map mashup at the site or just mentioned.
- The map can also automatically display restricted areas where flying should not be done. Time dependent restricted areas can also be shown e.g. around Red Fort area on August 15
- After the user registers the location to fly (which can be a date or a range of dates) he/she can generate a printout, which he should carry with himself at the time of flying. Authorities can also ask for the slip anytime from the flier
With the above system, no manual intervention and permission is required. No specific agency is required to deploy personnel for licensing. However, all UAVs are self-registered and have a registration number. All flyers are also identified. No harassment will be made to persons possessing self-registration printouts. Also authorities can take action against persons without self-registration documents and seize UAVs not having self-registration documents.
10. Sir, being a hobbyist, it is my earnest request to you to personally look into the matter so that the indefinite ban on flying UAVs imposed by DGCA may be lifted at the earliest and a Law, Policy or Guideline may be put into place allowing recreational users and hobbyists to fly UAVs without any problem.
Every country has its share of hobbyists in this field. Banning it will not only deprive the new generation our country from learning something interesting but India will be left behind in learning/ innovating technology, a subject we Indians pride ourselves in. This is already the most popular electronics project in engineering colleges which speaks for itself.
A continuing prohibition of a new and rapidly evolving technology with a huge potential is detrimental to our country in the long run and every day that passes with such a prohibition forces our country backwards as compared to the nations which are reaping its benefits.
Thanking You,
Yours faithfully
XYZ
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