Dudes, yes Dudes
While you accuse AMAI (and it's members) of trying to protect their own interest, are you not guilty of same?
Study (not just read) the preceding posts and you will see the point I am making. Comes out pretty starkly, does it not?
Whether you guys agree to it or not, the perception (and to great extent truth) that prevails today in the community is that multi rotors and other flying machines that can be flown autonomous are threat to civil aviation and general security. And the powers that is vested in the entities and establishments that feel threatened are out to control it , and for good measure. I see where AMAI is coming from, they know the perception that multi rotor and likes are what the establishment feels threatened about and any mention of exemption for these would get turned down along with traditional form of flying. And before any one says that I am speaking for AMAI, I am not an AMAI member and speaking what I see as an independent person.
Personally I have seen (some) multi rotor and FVP guys who think they can do whatever they want and have caused issues with local authorities. Thus my opinion about this group of hobbyist is not very positive and I have no qualms about stating this. On the contrary I have seen folks who started with traditional forms of modelling have taken up these and are much better disciplined. Again at the expense of being repetitive I am not against a group or person. Just narrating my personal experience to which one is most welcome to disagree.
For benefit of others I have put my personal response to the draft, out below for all to see and if you feel there is something beneficial do feel free to pick from the same. The response has been emailed and snail mailed to the designated persona at DGCA.
And lastly I saw some one address the designated person as "Madam". And that brought me to what I have been saying please read what is there do not see things where there are none. Mr Lalit Gupta is Mr. Not Ms Lalilta Gupta. The poor guy may have a heart attack right at the beginning even before he has time to read through the remaining contents of the letter.
My response that has been sent to DGCA
SUB: AIR TRANSPORT CIRCULAR XX of 2016, Draft Guidelines for obtaining Unique Identification Number (UIN) & Operation of Civil Unmanned Aircraft System (UAS) draft dated 21.04.2016.
1. With reference to the subject draft guidelines put up in public domain for comments, I wish to bring the following points/issues/practical aspects for kind consideration by DGCA and suitable amendment where larger public interest is served. To put my comments in perspective, a bit of background would be helpful.
2. I am an ex Indian Army officer who has deep interest in aviation. I have been involved with aero modelling right from college days through National Cadet Corps and thereafter have pursued the hobby on my own. I derive pleasure in my hobby from building and flying the entire gamut, from simple hand launch chuck/catapult gliders, free flight powered/unpowered models, Control Line and Radio Controlled models. I have been safely pursuing this hobby from last 28 odd years. This has been possible due to utmost regard for safety, for others, and for self and lastly aero models. I am sure with almost 3 decades of safe experience in this field I can contribute constructively to the commendable process that DGCA has embarked upon. Since my area of interest is aero modeling purely for recreational/hobby purpose I would restrict my feedback/suggestions to the areas of draft that impact aero modelling for recreational purpose alone.
Para Wise feedback/Suggestion/Comments on the subject draft
Para 2. Defenitions - Model Aircraft - The definition states " UA without payload used for recreational purpose. Payload is further defined as " All components of equipment on board a UAV...... Its transport aims exclusively to fulfill a specific mission"
It is suggested that the definition of payload is restricted to payloads for pecuniary purposes. The reason being a recreational flyer emulating a scale aircraft may have dummy payloads on board the model to gain better points in a competition. However per the current definition the model will not be within the scope of Model aircraft. Similarly the definition restricts to "recreational use " alone. There could be occasions where the Model aircraft is also used for competitions held by various organizations like ACI, AeSI, IIT's etc. Therefore it would be prudent to also incorporate the word "sporting" along with "recreation". This would help harmonize the definition to international standards (e.g CAA (UK) CAP 658)
Para 2. Definitions - Use of word UAV instead of UA -
The acronym UAV has no definition in the draft. It is understood that the word may have crept in the draft due to oversight where UA was meant to be indicated. Since UAV is not defined it is suggested that uniform acronym is used throughout the guidelines to avoid any confusion or different interpretations
Para 2. Definitions - Remotely Piloted Aircraft (RPA) -
All Control Line and Radio controlled Model are controlled remotely (i.e some distance away from the aircraft). Since Model Aircraft has been defined separately it is assumed that the guidelines do not intend to club Model Aircraft with RPA. Hence, it is suggested that definition is made clearer so as to indicate that Model Aircraft are separate from RPA.
Para 4. Issue of Unique Identification Number (UIN)
General - In order to ensure greater adherence to this requirement it is suggested that a web based application system with facility to upload required documents is used. This is also in line with practice adopted by FAA
Sub para 4.1 It is observed that DGCA intends to issue a UIN to all UA's (including Model Aircraft). Use of identifying mark on each flying vehicle is important and helps in tracing back to the owner in case of an event. However given that many hobbyist regularly assemble, model aircrafts from wooden or composite kits, or from published designs etc and may have number of model aircraft, it may not be practical to assign a UIN to each such aircraft. Instead it is recommended that the approach taken by FAA in USA be adopted where not a model aircraft but a person operating such model aircraft is assigned a UIN and the UIN needs to be mandatorily displayed on each model aircraft intended to be operated. Being more practical this will encourage higher compliance.
Sub para 4.2 (c) It is observed that one of the documents required to be submitted is Specification of UAS. While this might be considered mandatory for Small and large UAS flown for pecuniary purposes, basic information like, wing span, weight and engine displacement may alone be considered necessary for Model Aircrafts flown for recreational purposes.
Sub para 4.2 (e) - Permission from WPC for all frequencies used in UAS operations. Given that Min Of Communications has delicensed the 2.4 GHz band and a transreceiver used for radio control model aircraft can only be imported post WPC clearance. Therefore this requirement may be considered fulfilled if the Model Aircraft is controlled using a transreceiver that already figures in Type Approval Equipment library of WPC wing.
Sub paras 4.2 (e and f) - Provision of UAFM and Manufacturers maintenance guidelines for UAS. Given that many recreational model aircraft are assembled or made by the person operating them, there may not be always a UAFM or maintenance guidelines available. Hence this requirement may be exempted for Model Aircraft up to 20 Kg weight category. This would be in line with practice in other advanced countries (for eg. CAA weight limit in UK under CAP 658)
http://publicapps.caa.co.uk/modalapplication.aspx?appid=11&mode=detail&id=5631Sub para 4.3 - Identification plate - This may be suitably modified for Model Aircraft up to 20 Kg to read, metal plate with operators UIN (as recommended in 4.1 above). As model aircraft built and flown for recreational and sporting purposes do not have any provision for RFID or SIM
Sub para 5.3 (b) Dispensation from UAOP - It is indeed commendable that DGCA understands and appreciates that aero modelling activities for recreation and sporting purpose pose no threat to air safety. However the height limit of 200 ft AGL is too restrictive and does not leave margin for safety while flying especially for novices. Hence it is suggested that this be increased to 400 ft for Model Aircrafts up to 20 Kg weight limit when flown in uncontrolled airspace. This would be in line with both FAA (US) and CAA (UK) mandates where the height limit is 400 ft AGL.
Sub para 6.7 - Import permission - The sub para figures under Para 6, that deals with UOAP. This leads to ambiguity if only UA requiring UAOP need import permission or is this applicable to Model Aircraft as well? It is suggested that model aircraft for personal and recreational/sporting use be exempt from this requirement since there is no current law/rule restricting import of Model Aircraft.
Sub para 7.1 - Sale/disposal without permission from DGCA - For Model aircrafts this may become impractical to adhere to. As recommended at preceding paras that UIN be issued to an individual intending to operate Model Aircraft and not for each Model Aircraft, keeping in view the security concerns it would suffice if the seller obtains UIN number of the buyer and keeps a record of the same. Similarly for old and aged model aircraft that are no longer safe for flight scrapping by destroying the model aircraft airframe by the aero modeller should not require DGCA approval/permission
Sub para 7.4 - Notification of incident/accidents - For Model aircraft flown for recreation and sporting purposes this may be modified to any incident/accidents involving injury or damage to property during flying of the Model aircraft will be notified to local administrative authorities
Sub para 10.1 - IN respect of Model Aircraft operation for recreational and sporting use in uncontrolled airspace limited to 400 ft AGL (as recommended to be modified) this requirement may be waived off or restricted to intimation to local jurisdictional police administration
Sub para 10.7, and 10.8 (a - f) - Flight Plan and Clearance - For operation of Model Aircraft in the height limit be modified to 400 ft AGL (as recommended to be modified at preceding paras)
Sub para 10.10 - Coordination with Authorities. This requirement may be waived off for operation of Model Aircraft operation for recreational and sporting use. It should suffice if the operator of Model Aircraft has intimated the jurisdictional police administration (as recommended at 10.1 above).
Sub para 10.11 - Call signs - For Model Aircraft operation for recreational and sporting use in uncontrolled airspace limited to 400 ft AGL (as recommended to be modified) this requirement will only add work load to the concerned ATC. Hence this may we waived off for Model Aircraft operation for recreational and sporting use in uncontrolled airspace. Or if this was not intended to be applicable for this category of UA it may be suitably clarified in the verbiage
Sub para 10.14 - Needs clarity if this applies to Model Aircraft operation for recreational and sporting use? If the intention is to apply this to UA for commercial use beyond the height limit this may be indicated clearly.
Sub para 10.15 (a -c) - Since sub para 10.12 restricts flight envelop to 500m VLOS, visibility condition of 5 Km can be reworded to fair visibility and weather conditions in so far as Model Aircraft operation for recreational and sporting use in uncontrolled airspace limited to 400 ft AGL (as recommended to be modified)
Sub para 10.17 - Means to measure actual altitude - Model Aircraft operation for recreational and sporting use may have severe difficulties in complying with this clause as many of the current WPC type approved transreceiver equipment used to control model aircraft do not have this functionality. DGCA can recommend to WPC for type approval of equipment with such capability subject to it meeting other conditions.
Sub Para 10.23 (b) - Components/Equipment for UA - SIM slot - All most all conventional model aircraft for recreational purpose that are made of wood and other composite material do not have any such capability. Similarly for model aircraft made by hobbyist themselves will not have such functionality. Hence Sub clause 10.23 (a) should suffice for Model aircrafts flown for recreational and sporting purposes.
Sub Para 10.23 (f) - Components/Equipment for UA - Return Home option - Except for ready to fly autonomous or semi autonomous UA's that are sold ready to fly or almost ready to fly, this functionality is not available on model aircrafts constructed by hobbyis. However in the interest of safety it is recommended to adopt the wordings from UK CAA CAP 658 " Any powered model aircraft fitted with a receiver capable of operating in failsafe mode should have the failsafe set, as a minimum, to reduce the engine(s) speed to idle on loss or corruption of signal."
3. In conclusion, I would like to once again thank the DGCA and other concerned who have taken the initiative to formulate these guidelines, which when suitably amended will ensure that the traditional hobbyist who flies model aircraft purely for recreational or sporting purposes is able to pursue his/her hobby and not seen as threat to air safety or home land security. At the same time the commercial users have a clear set of guidelines to follow to pursue their vocation. At last it also needs to be kept in mind that too harsh and cumbersome process will lead to decay and ultimate death of the aero modelling industry where India has already been lagging far behind some other and much smaller Asian countries that supply a fair amount of model aircraft kits the world over (e.g. Vietnam). Therefore needless to say, the guidelines should be balanced to ensure air safety while also promoting Industry, trade, commerce and hobby.
4. The more easy and convenient process or rules are, the greater is compliance. This may be readily seen in case of guidelines and registration process initiated by FAA for UA's.
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