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« Reply #25 on: April 26, 2016, 12:23:43 AM »
merin_83
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I would say UIN should be waved off for MICRO and for MINI its should be made available online..., and unrestricted airspace should not be only on education space, I should be able to fly micros in vacant land where no one is there  ... Smiley
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« Reply #26 on: April 26, 2016, 02:05:41 AM »
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and unrestricted airspace should not be only on education space, I should be able to fly micros in vacant land where no one is there  ... Smiley

They don't exactly mean that. What they mean is that UA Operator permit (UAOP) won't be required for flying below 200ft. in non-prohibited area. I don't know why they mentioned educational area here...educational area is treated similarly as non-prohibited area. 200 ft restriction is still applicable in educational area.
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« Reply #27 on: April 26, 2016, 02:23:21 AM »
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Apart from the issues on UIN discussed earlier, just see how difficult is it to get UIN by an ordinary hobbyist. People will get fed up....either they won't be able to fly or have to fly illegally. Who will take all the hassles and carry out all these procedures for every single UA? It appears that having these procedures in place is like banning the hobby. Those who fly commercially can bear the hassle because they get paid for their service. But how many hobbyists will and recreational flyers will take the hassle for doing all these things?

4.2. Following documents are required to be submitted to DGCA for issue of UIN:

a) Address of Operator along with contact details with valid identity proof. In
case of a company/organization, TIN number will be accepted;
b) Purpose of operation of UA;
c) Specification of UAS (manufacturer name, type, model number, year of
manufacture, weight and size, type of propulsion system, flying capabilities
in terms of maximum endurance, range and height, etc. including details of
equipment); ...............not always possible for custom-made UA by hobbyists.............
d) Verification of character and antecedents of the operator and remote pilots
from local sub-divisional police office; ...........almost impossible if we have to get this for each UA. Police will demand money...
e) Permission for all frequencies used in UAS operations from Department of
Telecommunication (Wireless Planning and Coordination Wing); Almost impossible clause. Those importing UAs mention that they don't get WPC clearance. Is it possible for a hobbyist to run around for permission from WPC? RTFs are supposed to be cleared by WPC during import anyway. Why again? ...................
f) Copy of Unmanned Aircraft Flight Manual (UAFM); ...Most Chinese ones don't have a decent manual. Custom UAs don't even have a manual..........
g) Copy of Manufacturer’s maintenance guidelines for UAS;......WTF? Has anyone ever seen one?.......

The identification plate (made of fire proof material) inscribed with UIN and RF ID tag or SIM shall be affixed to the UA, and appropriate makes to identify ownership. .........will increase the weight of smaller UAs............

So having these rules in place is as good as having a ban in place. Either people won't be able to fly or people would have to fly illegally.

We need to put pressure to change these silly requirements. The best thing is to completely dispense with UIN requirement for smaller UAs or do self-registration online.

Those who have access to DGCA (some of the members apparently met them earlier)...please set up a meeting and explain the points. We don't want to fly illegally. But if they law is made impossible to comply, what is the purpose of such a law?
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« Reply #28 on: April 26, 2016, 06:15:59 AM »
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...
So having these rules in place is as good as having a ban in place. Either people won't be able to fly or people would have to fly illegally.

We need to put pressure to change these silly requirements. The best thing is to completely dispense with UIN requirement for smaller UAs or do self-registration online...

Completely agree with you Santanu. But how exactly should we 'put pressure'?

Strongly worded comments from an individual aren't going to work unless he's a high ranking government official.
Seeing how not many people have replied to even this topic, how do we gather support?

We should protest most aggressively against the necessity of a UIN for micro and mini UAs (particularly self-made ones).
As for the height and LOS range restrictions, I don't think they're going to be running around with laser range finders to check if we are crossing the limits.
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« Reply #29 on: April 26, 2016, 08:18:32 AM »
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Well...we can write letters seeking amendments. That's why they have uploaded the notice in draft form. That's all we can do. The more letters they get, the more they know that there are lots of people who would be affected by the issues. Whether it works or not, we need to try.

There are so many members in this group...even if one-fourth writes letters or send email then there will be significant numbers. Also some members belonging to this forum probably met Director General DGCA earlier. They should now seek a meeting and put forth our views.

In the letter/email simply writing that "we demand XYZ things" won't probably cut ice. We have to convince them somehow that they themselves will face problems with such restrictive rules. So it is in their interest to streamline the rules.

I agree with you about the height and LOS issues. After all who is going to verify them like traffic police Wink But still, we should mention these aspects because at least on paper let the figures be reasonable. You never know ...this is a draft rule...some wise guy in DGCA may suggest 100ft in the final circular...so we should ask for higher. Its bargaining Smiley

For every demand, we need to back up the same with solid argument. For example on the height issue, we can refer to the US rules which allow 400ft. They themselves said that they would align with international rules. Also we can argue that today's buildings are getting higher like 600-800 ft. If that does not impact aviation why would a 400ft. UA height cause problems? Similarly we need to back other demands by solid arguments and implementation problems they would face. If we can point out their problems rather than ours, that would have more effect.

By the way, is there any last date to send a response? We have to hurry before the final version is published
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« Reply #30 on: April 26, 2016, 08:24:58 AM »
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Wow, you have great reasoning and bargaining skills!

But, like I mentioned before, very few people have responded here. So, maybe we ( hopefully you) can write on behalf of all RCIndians and add all our names in the 'signatures' list.
« Last Edit: April 26, 2016, 09:51:17 AM by Swapnil » Logged
 

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« Reply #31 on: April 26, 2016, 08:28:56 AM »
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We can do that. But let us decide on the points and arguments first. In the post title I noticed that comments need to be sent by 21/05/2016. We still have time.

Also, if some members of this forum have access to media, please approach them when we finalize on our views.
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« Reply #32 on: April 26, 2016, 08:31:05 AM »
santanucus
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So, maybe we ( hopefully you) can write on behalf of all RCIndians and add all our names in the 'signatures' list.

I can do that. But a letter without signatures and with lots of names cut no ice with govt agencies. Either a letter of that nature has to come from an organization representing lots of people on their "official letterhead". Or there should be lots of letters from individuals.
« Last Edit: April 26, 2016, 09:25:00 AM by santanucus » Logged
 

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« Reply #33 on: April 26, 2016, 08:33:47 AM »
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Some newspapers have printed the news about the guidelines

http://www.business-standard.com/article/current-affairs/drones-face-net-of-rules-116042600056_1.html
http://www.hindustantimes.com/mumbai/dgca-finally-brings-drones-under-safety-radar/story-IQNU6q3vYaWFyAZDtbAmiJ.html
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« Reply #34 on: April 26, 2016, 12:38:11 PM »
sundaram
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Address and last date for comments

IMG-20160425-WA0036.jpg
Re: Draft DGCA guidelines - Comments requested by 21/05/2016
* IMG-20160425-WA0036.jpg (36.26 KB, 800x233 - viewed 236 times.)
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« Reply #35 on: April 26, 2016, 01:09:15 PM »
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Ref Para 2 Definitions Its very sad that though there is definition for Model Aircraft as an UA without payload the category of fliers (aeromodelling remote pilots) and their activity of Hobby flying activities has been completely left out in the parameters and considerations while drafting guidelines and definitions and all remote pilots have been grouped under one category.

Ref Para 4.1 Its ridiculously Impractical to even think that DGCA is contemplating issue of UIN to all Hobby pilots ( Ref Para 4.2 which is a Blasphemy for all Hobbyist) and their complete hanger of Model Aircraft's all across India. I would be damned if they are at-least capable and in a position to even manage just the commercial UAS operations across India ( They just don't have the ground presence, if they are planing to depend on the local cops who has a vision capability just to see and locate MA just 100mtrs out and 100ft above, Local Cop is only going to harass the hobbist and the few unaware DJI junkies) The Real UAS fliers (The capable systems) and the real threat are still going to be way out of the reach and radar of DGCA.

If they had copied FAA or any other civil aviation auth they should have at least copied 400ft ceiling like FAA which was very much warranted.

By stipulating UIN for all and UIN only for Indians They have killed the sport of RC flying by banning all foreign RC Pilots to India for all the prestigious meets like Ambby valley and AMAI. Let alone no consideration for the upcoming drone racing FPV Sports.

Ref Para 8 and 8.4 in conjunction with definition of Remote Pilots and Definition of Model Aircraft. By only exempting Micro under 2Kgs from requirements of Pilot trainings, Simple RC flying is too killed when today every modeler of repute can put together a RC Model Aircraft up to even 7-30 Kgs with Gas engines and turbines and when they fit in category beyond even mini and you fall under the category of certified pilots one who is expected to have taken a PPL training before operating these machines. Whereas the reality is thanks to the efficiency of muddling of DGCA and the Ilks Infrastructure for PPL training and Microlight Flying Scene is next to Non existent in India. Its ridiculous to think that there has been no consideration for kids under 18 like my son and his capability to fly and develop in this beautiful hobby.

Upcoming FPV Competitions and FPV Racing sports are not part of Commercial Civil UAS operation with payload. These category of pilots and their systems too form part of Hobby fliers and UAS systems.

The guidelines will kill the open source development, student projects and participation in various international competition by students and others by having no category for them and clubbing their classification along with Commercial Civil UAS operation with payload.

The guideline reeks of pessimistic prejudice that Indian Firms and Indians just cannot fabricate their own Aircraft Models and UAS and they can only import their models. . If its all Import license and impost permits and WPC clearance for import where the Bloody hell is Make in India.

Classification parameters are largely biased towards muti-rottor models only seems they have not even considered fixed wing capabilities and parameters.
« Last Edit: April 26, 2016, 03:56:02 PM by sundaram » Logged

 

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« Reply #36 on: April 26, 2016, 01:56:05 PM »
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I agree with you sundaram sir I agree

But they arent even open to suggestions only "comments" would our comments be enough to change the guidelines? Bang Head

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« Reply #37 on: April 26, 2016, 04:28:25 PM »
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I have been following this discussion. I too feel that these guidelines will lead to harassment. I think a structured response clause by clause will catch their eye. Hence, I am attaching the format which may be used by individuals or rcindia as a whole to voice their concern. All of us can provide the inputs which can be combined or individuals can send their responses to DGCA.

They have deliberately made such guidelines to evoke/provoke response from the community. Otherwise they would have harmonized the rules as per FAA as they had said in the Oct 2014 circular.

Friends I am unable to upload the Word & Excel version of the file as it is not allowed  Huh? Any way forward?

* Comments.pdf (72.41 KB - downloaded 99 times.)
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« Reply #38 on: April 26, 2016, 04:53:27 PM »
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Goodwork
Can you please send it to me by email in word or excel format as in my profile id.
I will use it as well put in our server so that everyone can download it.
Thanks
Kumaran
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« Reply #39 on: April 26, 2016, 05:01:35 PM »
VIPIN_KUMAR
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Your mail id is hidden...
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« Reply #40 on: April 26, 2016, 06:46:19 PM »
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Nothing relating to DGCA guidelines....but just wondering....

God alone knows what's our future.....today UAVs.....tomorrow...cars....day after all geared bikes....then all mopeds (ungeared)....finally bicycle....and to close deal....kids tricycle....will be banned some day...

I cant imagine India with out toys....neither for kids nor grownups...

Basically we are forming a toy less nation without any innovation....
We are just forgetting the famous proverb ....all work no play makes jack a dull boy....  Bang Head Bang Head Bang Head

SO ARE WE GONNA BECOME A DULL NATION Huh? Huh? Huh?

I just HOPE NOT and hope DGCA thinks about finding solution to our problems ...AND NOT INCREASING OUR PROBLEMS.


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« Reply #41 on: April 26, 2016, 06:49:34 PM »
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Goodwork
Can you please send it to me by email in word or excel format as in my profile id.
I will use it as well put in our server so that everyone can download it.
Thanks
Kumaran
Check your PM.
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« Reply #42 on: April 26, 2016, 07:07:00 PM »
vibranthobbies
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Thanks. Uploaded and the File available in the below links in word / excel formats
http://www.rchyper.com/docs/Comments.docx
http://www.rchyper.com/docs/Comments.xlsx

« Last Edit: April 26, 2016, 07:20:13 PM by vibranthobbies » Logged

 

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« Reply #43 on: April 26, 2016, 07:31:06 PM »
santanucus
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Great job ! Is it possible to upload this doc to Google spreadsheet or somewhere and construct with a form which will insert data in the spreadsheet? Then members can easily fill in the form and will will have the consolidated response in a single file
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« Reply #44 on: April 26, 2016, 07:34:27 PM »
santanucus
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Upcoming FPV Competitions and FPV Racing sports are not part of Commercial Civil UAS operation with payload. These category of pilots and their systems too form part of Hobby fliers and UAS systems.

FPV racing sports is basically finished even before it starts in India. I thought about it but when the whole hobby is in danger due to UIN requirements, FPV is out of question.

I am just fed up. All these noise about India being a superpower and scientific power and so on, they have stifled everything by a single circular Sad Backward looking persons are at the helm.
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« Reply #45 on: April 26, 2016, 10:28:00 PM »
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.
.
Guys sitting here and commenting won't help. You have to actually submit a response.
Being a RC Fan myself, I would like to see a better future for this hobby in India and I think this is the right time to act and make sure the Guidelines are set right. 

Just like large number of people submitted response for Net neutrality and changed the game, you have to step up and do it. Now you will say easier said than done so,  I am going to make it easy and divide into 3 way process.


Step 1 : Finalise the standard response  

 
The senior members on forum with better knowledge on the subject, please discuss and prepare a standard response that we all will send to DGCA.

Please use This Google Doc.
https://docs.google.com/document/d/1xZclfrXCGlLSGFldKp0Xt4ALs8nVn7B4i6v1PFAE2xQ/edit?usp=sharing


Step 2 : Responding mechanism

Once we have the response, I will make it as a template and setup a system where anyone can put his email ID , name and press send (After reviewing the msg of-course), the response will be sent to DGCA as a separate email from his id.
The more number of emails they get the better it will be.
 

Step 3 : Reach-out to masses


I will make sure the msg reaches out to all the forum members / RC Activities / Photographers and other hobby guys along and will encourage them to actually send a response.  Will need help from Admin to send it out to forum members, rest I can manage myself from various means (Facebook Ads, Google Ads, emails etc).

I have even 10L email database of tech users from india whom I can reach out as well.

Time is less, act now


I am going to do it, Whether you guys come out of your comfort zone or not so better you do and make it a success.

What I need from you

1. In Next 1 week (by Next Tuesday), Please Prepare a response considering all the options and be reasonable with it.
2.  From Admin, If you can create this comment as a separate thread and pin it for few days ? We have very less time and too much to do.


I can be reached out on chandra@subhash.cc  and below is my linkedin profile for identity

https://www.linkedin.com/in/subhashchy



« Last Edit: April 26, 2016, 10:42:05 PM by wtg » Logged
 

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« Reply #46 on: April 26, 2016, 11:17:40 PM »
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We need to firstly distinguish what we modellers need.

Will list out what we think should be clarified eventually in the final rules.

Will also list out or comment on what others have mentioned.

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« Reply #47 on: April 26, 2016, 11:26:57 PM »
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Step 1 : Finalise the standard response  

 
Please use This Google Doc.
https://docs.google.com/document/d/1xZclfrXCGlLSGFldKp0Xt4ALs8nVn7B4i6v1PFAE2xQ/edit?usp=sharing



There is already a well structured Word/Excel file posted above by vibranthobbies for posting para-wise comments. These are at http://www.rchyper.com/docs/Comments.docx
http://www.rchyper.com/docs/Comments.xlsx

If you can upload it at google docs and make a form for inserting response into either of them (excel one would be better?) then it would be better.
« Last Edit: April 26, 2016, 11:38:21 PM by santanucus » Logged
 

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« Reply #48 on: April 26, 2016, 11:32:46 PM »
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Yes.....the exact response clause by clause would be very good and meaningful......DGCA would be more interested in reading response against their own guideline rather than reading an alien document....I think the document prepared by me and finally uploaded by vibranthobbies if can be uploaded as googleform will be very good....anyways I will try to find a way to upload that as googleforms by tomorrow...



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« Reply #49 on: April 26, 2016, 11:41:19 PM »
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That sounds good. Doing it.
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