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« on: November 18, 2017, 05:28:13 PM »
sravan
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Hello RCindia members,

As most of us are aware about the new DGCA CAR regarding UAS and how it requires anything above 2 kg and anything that flies above 200 ft to require a lot of permits etc/hardware.  Some petitions have been initiated in this regard for the hobby sector. But i am not aware about anyone talking about the Civilian UAV sector.

Let me introduce myself here. I am a figter pilot in IAF flying frontline fighter jets. I am also a flying instructor and i have also done the UAV operator s course of IAF. I am also a aeromodelling enthusiast and fly turbine jets now. So i understand the operations of civil airspace, frontline UAV operations and the hobby segment.

 I went over the DGCA car and it says anything above 2 kg or flying above 200 feet needs to have ADSB/ SSR(transponder). Sim and gps based tracking, FRTOL(flight radio telephony operator s licence- it is required for the commercial full size  pilots to fly in Indian airspace )for the operator. Also flight plan will be required.The govt agencies are exempt from these. Now ADSB/SSB are used in full size aircraft and they are heavy equipment and require a lot of power. Even the full size UAV s in Armed forces( which cost upwards of 100 s of crores) as of now dont have SSR leave alone ADSB. Though the UAV operated by NTRO has SSR.

So these requirements will make it impossible for civil UAV developers/enthusiasts to test their equipment/products. Though for some time we may get away with it but with time it willl not be possible to import/test/fly anything.

In the USA airspace it self it is not mandatory for the full size aircraft to have ADSB till 2020. So how can it be mandatory for the UAS in india to have ADSB/SSR and sim and GPS based tracking. I understand that filing of flight plan and information to police is still a genuine to be asked for. I checked online and found some really small ADSB units/SSR available for sale in USA. But the power which they operate on will not give them enough range to be detected by ATC further than 10 odd kilometers. Though the price was not mentioned i am sure they must be expensive.

These requirements will kill the civilian UAV market in India and the Govt/ civil operators will be dependent on getting the equipment from outside rather than benefiting from the domestic market. And then the govt talks about Make In India campagin.

I was working on a letter to DGCA addressing the issue and asking them to amend certain requirements like no requirement for UAV  s upto 25 kg flown within line of sight, upto 400 ft  to have any permit( as followed in USA as per part 107 regulations). Dropping the requirement of ADSB/SSR/ Sim based tracking etc.

So in this thread everyone is open to suggest me their opinions and i will consider them. Especially i am looking for inputs from commercial UAV developers.
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« Reply #1 on: November 18, 2017, 06:11:21 PM »
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Hello Sravan sir,
I completely agree with everything you said. In our country, almost everything hobby related is imported with almost zero manufacturing done. If the draft rules are implemented it would kill the market with zero innovation and manufacturing being done in our Indian market. All the hobbyist will suffer.

The government should follow the international standards which it has been doing blindly till now in almost everything else. With the age restrictions, it would become impossible for young minds to be able to open up to the world of technology and aviation. It would prevent them from getting exposure to this field and will largely remove the career option in the development of UAVs from their heads which will hurt the nation in the long run for drones are the future with unlimited opportunities. I can keep going on and on how the implementation of the current draft is going to be a disaster for the nation but there's no point.

So in this thread everyone is open to suggest me their opinions and i will consider them. Especially i am looking for inputs from commercial UAV developers.
My suggestion would be to register the pilot instead of the drone/multi/plane/heli. It is impossible to register each and every aircraft since a lot of users make their own models. It is possible to register the pilot and also the airfield. There should be a provision to register a certain flying field where users can fly without any restrictions. Every city should have a few flying clubs and should have a registered flying field where the members of the club can fly. It should be illegal to fly at public parks/playgrounds with a lot of human footprints.

When your draft is done please share it with us. I am working on my own version. We should get our voice heard. All the LHS should unite and share their own draft with the higher authorities but I guess it's too late.

Regards,
Nitesh
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« Reply #2 on: November 18, 2017, 06:18:05 PM »
sravan
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Thanks Nitesh. Suggestions are noted. I will share the draft once its ready. No its not late to take up anything. As per DGCA you can send your comments till 01 dec 17.
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« Reply #3 on: November 18, 2017, 07:58:46 PM »
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Hello Sravan sir,
I completely agree with everything you said. In our country, almost everything hobby related is imported with almost zero manufacturing done. If the draft rules are implemented it would kill the market with zero innovation and manufacturing being done in our Indian market. All the hobbyist will suffer.

The government should follow the international standards which it has been doing blindly till now in almost everything else. With the age restrictions, it would become impossible for young minds to be able to open up to the world of technology and aviation. It would prevent them from getting exposure to this field and will largely remove the career option in the development of UAVs from their heads which will hurt the nation in the long run for drones are the future with unlimited opportunities. I can keep going on and on how the implementation of the current draft is going to be a disaster for the nation but there's no point.

So in this thread everyone is open to suggest me their opinions and i will consider them. Especially i am looking for inputs from commercial UAV developers.
My suggestion would be to register the pilot instead of the drone/multi/plane/heli. It is impossible to register each and every aircraft since a lot of users make their own models. It is possible to register the pilot and also the airfield. There should be a provision to register a certain flying field where users can fly without any restrictions. Every city should have a few flying clubs and should have a registered flying field where the members of the club can fly. It should be illegal to fly at public parks/playgrounds with a lot of human footprints.

When your draft is done please share it with us. I am working on my own version. We should get our voice heard. All the LHS should unite and share their own draft with the higher authorities but I guess it's too late.

Regards,
Nitesh
Well said Nitesh. Push the ideas through

Sent from my Moto G (4) using Tapatalk
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« Reply #4 on: November 18, 2017, 09:20:00 PM »
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Well said Sravan. Registering just pilot through online portal or may be age restriction and not the each and every drone would be fine as many of us make them from parts either new or used.
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« Reply #5 on: November 18, 2017, 09:37:44 PM »
sravan
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Here are some comments by a expert as uploaded on this website https://www.suasnews.com/

https://www.youtube.com/watch?v=g4v44ADjP-4#action=share

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« Reply #6 on: November 19, 2017, 09:15:30 AM »
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Dear All

Here is what I think should be included in new rules.

While they are working on tagging every UAS with UIN, it should be mandatory to attach the BOE (bill of entry #) to UIN application.
This would cut the illegal import, cash transactions and would also boost Govt. income. The law makers have not focused at the existing problems. As of now, import of UAS is made virtually impossible. While the Govt I focusing on imposing new rules, what would happen to the existing rules is still a GREY AREA.

Below are few problems.

1. The RC equipment require WPC "Type Approval". The regional WPC is unable to process the applications. If this is not changed/addressed even with new rules, we are heading to dead end.
2. The import of any UAV/UAS/Drone require DGFT approval as these items are under restricted categories of DGFT. This needs attention and should be changed. If not, this is another dead end.
3. All battery charges and lipo batteries require BIS. This is again a very long process and all manufacturers are not interested in applying for BIS. Due to BIS, we are limited to few items ( which has BIS). The law should focus on safety and not impose import restriction.
 
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« Reply #7 on: November 19, 2017, 01:54:26 PM »
sravan
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Hello Sphere Hobbies,

Regarding--- While they are working on tagging every UAS with UIN, it should be mandatory to attach the BOE (bill of entry #) to UIN application.

Now why should we introduce more hassles to the already complicated process proposed by DGCA. I do not know if u get a bill of entry(BOE) if the item is received by courier. I understand it is definitely given when the item comes through cargo. Multicopters are coming illegal way into India because there is no legal way to get them inside India. So what should the hobbyists do? Accept them to be banned or somehow get it.

Regarding-what would happen to the existing rules is still a GREY AREA.

The fire right now is just to make the DGCA procedure logical . Rather than everything coming to a  end.

Regarding- The RC equipment require WPC "Type Approval". The regional WPC is unable to process the applications. If this is not changed/addressed even with new rules, we are heading to dead end.

Right now we are just dealing with DGCA. I doubt if DGCA can give any clarification/ new policy in this regard.

Regarding - . The import of any UAV/UAS/Drone require DGFT approval as these items are under restricted categories of DGFT. This needs attention and should be changed. If not, this is another dead end.


If the UAS are legalized then i guess DGFT permission can be obtained officially


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« Reply #8 on: November 19, 2017, 02:08:10 PM »
sravan
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Hello Guys ,

If anyone can clarify the below aspect in the DGCA CAR

11. EQUIPMENT REQUIREMENTS
11.1 All RPA except Nano shall be equipped with the following serviceable components/
equipment:
a) Identification Plate
b) GPS for horizontal and vertical position fixing
c) Autonomous Flight Termination System or Return to Home (RH) option
d) Flashing anti-collision strobe lights
e) RFID and GSM SIM Card Slot for APP based tracking

What will the RFID do in a UAS? Also GSM Sim card slot for APP based tracking. Is any such feature available right now for multicopters for fixed wing UAS? I do see some online. But i dont see if they are used commonly . What do they do. I am not into FPV/ Multirotors or AP based flying so those who are into it could clarify so that i can address this issue in my letter to DGCA.

Also the CAR mentions

14. INSURANCE
14.1 All civil RPAS operators shall have insurance with the liability that they might incur
for any damage to third party resulting from the accident/incident.


Is there any agency providing insurance to model aircraft or UAS. I understand in USA the pilots registered with AMA have a third party coverage nd the AMA fees is also hardly anything. Because if there are none in India then the process will get stuck for the want of insurance. So if anyone who is aware about this is requested to throw some light. Else i will mention that a non availability certificate from a leading general insurance provider be attached while submitting documents to DGCA mentioning that insurance service is not available in India.
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« Reply #9 on: November 19, 2017, 02:32:50 PM »
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I found this while searching online.

https://trackimo.com/

It says it can track worldwide where ever gsm network providers are available

Worldwide Coverage

Trackimo devices can be tracked via web or smartphone app anywhere GSM cellular reception exist.


I dont know how that will work. So are we supposed to put a Indian  sim with data enabled in it or does it come with a sim.
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« Reply #10 on: November 19, 2017, 03:25:41 PM »
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A GSM based tracker is used to find the drone when it's had a fly away issue or when it's lost I guess. GSM based trackers aren't really that commonly used. I don't know anyone who uses this. Although they're commonly available for a cheap price but I wouldn't trust them and the more expensive ones are well expensive but trustable. The trackimo devices are available for 200$ which is super expensive and impractical for new users. I don't understand how the RFID system is supposed to work.

The insurance is a big problem although it should be made mandatory in my opinion. A central body like the AMAI should be handling this. I think insurance is available as a lot of aerial photographers must be opting for it. This is just an assumption and we should clarify with the insurance companies first.
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« Reply #11 on: November 19, 2017, 04:49:13 PM »
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Detect and avoid capability as listed in CAR

The RPA intending to operate at or above 200 ft AGL shall carry the following
equipment/capabilities in addition to those specified in Para 11.1 of this CAR:
a) SSR transponder (Mode ‘C’ or ‘S’) or ADS-B OUT equipment
b) Barometric equipment with capability for remote subscale setting
c) Geo Fencing capability
d) Detect and Avoid capability

Is this technology or facility available as of now?
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« Reply #12 on: November 19, 2017, 05:47:47 PM »
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This technology is available in very few models and is not fully developed. As of now only a few DJI drones and a few Yuneec drones offer this. This technology is not completely reliable and is very expensive. It would be ludicrous to expect all aircrafts to have this technology. In fact, nothing listed above can be possible.

Nitesh
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« Reply #13 on: November 23, 2017, 08:49:14 PM »
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Ok guys here is the update. I finished my detailed document for comments on DGCA CAR.

Also met Mr Hillol Biswas at  DGCA office in safdarjung,Delhi. I told him about the hardware requirement for UAS to be too demanding and such technologies like detect and avoid and ADSB/SSR is not available yet. He said the CAR was made after taking inputs from various agencies like MHA, IAF , DGCA and other agencies. The RFID requirement was coined by MHA, he said. Basically everyone coined their opinion of what they felt the RPA should have. They had no clue whether such technology existed. Crux of the matter is they guys wanted all the fantasy technology they had heard about in the RPA.

I was giving him the printed copy of my Comments on CAR. He told me he could not accept by hand and asked me to mail it. So i will do that.

I want to upload my pdf but the pdf size is more than 200 kb. I split the document but still its more than 200 kb .
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« Reply #14 on: November 23, 2017, 09:02:44 PM »
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...
I want to upload my pdf but the pdf size is more than 200 kb. I split the document but still its more than 200 kb .

Sir, please upload the pdf to a free document hosting site (or google drive) and then share the generated link with us.
Few hosting sites:
https://www.pdf-archive.com/
www.filehosting.org
https://sabercathost.com/
https://mega.co.nz/
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« Reply #15 on: November 23, 2017, 09:09:51 PM »
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Ok i tried and i get this

https://www.pdf-archive.com/2017/11/23/comments-of-dgca-car-pdf/

Swapnil could you try if get the document
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« Reply #16 on: November 23, 2017, 09:16:03 PM »
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Otherwise here are the broken down pdf

* comments to DGCA CAR part1.pdf (131.29 KB - downloaded 134 times.)
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« Reply #17 on: November 23, 2017, 09:18:14 PM »
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here is the second part

15. The shortcomings in the Draft CAR that needs to be
addressed are discussed in succeeding paragraphs.
ISSUES IN CAR THAT NEEDS TO BE ADDRESSED AND AMMENDED

16. Section 6.3 of the CAR requires all RPAs with flying weight of more than 2 kg(Mini Category) and above and those which fly above 200 ft AGL irrespective of weight to have RF ID tag. A RFID tag is used to identify a tagged item within in a limited distance. The range is usually within a few metres. So practically a RPA cannot be tracked using a RF ID Tag. No other country in the world as of now has such requirement listed in the RPA rules. Section 12.6 of the CAR clears operation of RPA in Visual Line Of Sight(VLOS) only. Hence having a RFID tag will not be of any consequence, since the RPA is flying within a limited distance from the pilot. So this requirement must be deleted.

17. Section 9.1 of the CAR states the Remote Pilot should have attained a age of 18 Years. Unless the RPA is being flown for commercial purposes the age limit does not make sense. India, with over 380 universities, 11,200 colleges and 1,500 research institutions , has the second largest pool of scientists and engineers in the world. These engineers do very well when they study abroad, where they get practical training in colleges as well as by working with leading aerospace aviation giants. It is many of these college students who invent new technology as part of their study and research, which is often adopted by aviation giants abroad. There is a need to provide the same environment to the students of IITs and engineering colleges in India. Students from many Engineering Colleges/Schools these days participate in designing and building RPA as part of competitions, conducted nationally and internationally and this age limit will restrict them. There should be no age limit unless the RPA is flown for commercial purpose. Age limit of 16 Years should be imposed for commercial operation of RPA as is the standard in USA as per Part 107 of FAA rules.

18. Section 9.1 of the CAR also mentions the RPA pilot to undergo ground training and have FRTOL. The ground training for a full size aircraft and RPA will vary, though they will definitely have some common areas. FRTOL is required by commercial pilots of manned
2
aircraft. It needs in depth study of RT phraseology and passing a exam. Such exhaustive knowledge is not required for a RPA pilot. Also when flown within VLOS, communication with ATC is not necessary. Such knowledge will be required by RPA pilots when flown in non Segregated Airspace where manned aircraft would fly as well. In future when RPA get all the technology to operate together with manned aircraft, in common airspace then the rules maybe revised. Even United States and other western countries do not have such requirement. Since the present scope of the RPA operation will either be within VLOS or in Segregated Airspace( through Flight Plan to ATC) so this requirement should be deleted. As and when other western countries incorporate RT rules for RPA pilots, DGCA RPA regulations should be suitably amended as per Indian context. As of now we can have a similar Remote Pilot Airman Exam for Commercial RPA pilots as conducted by FAA in USA. We can follow the study material as prescribed by the FAA in their website for this. The details of this are mentioned in paragraph 11 of this article. DGCA should device a similar exam in India. So section 9.1 should be amended to read- All commercial RPA Operator need to pass a Remote Pilot Airman Exam to Obtain a UAOP certificate. The syllabus and model question papers for the Exam are being worked out and will be available made available in DGCA website once finalised.

19. Section 11.1(e) of the CAR requires all RPA except nano category to have GSM SIM Card Slot for APP based tracking. Micro category RPA(<2 Kg) are too small to have have this additional equipment and it will add additional weight penalty to the RPA. Also if the RPA is being flown VLOS and the pilot is keeping it in view all the time and is aware about its position, a GSM SIM based tracking should be done away for VLOS flying of RPA. When the RPA is flown BVLOS then the RPA’s IN/GPS navigation units transmit back the position of RPA to the Operator. Hence a additional GPS GSM Sim card APP based tracking is not necessary. However if still considered necessary it should be made mandatory in Small(>25 Kg) and above weight Category RPA when flown Beyond Visual Line Of Sight(BVLOS). So 11.1(e) should be amended to read GPS GSM Sim based tracking equipment necessary in Small(>25 Kg) and above weight category RPA when flown BVLOS.

20. Section 11.2 (a) of the CAR states that RPA intending to Operate above 200 ft AGL to carry SSR Transponder( Mode ‘C’ or ‘S’)
3
or ADSB OUT equipment. None of the RPA operated by Indian Defence Force which costs upwards of hundreds of crores as of now have SSR or ADSB Out facility. Only the RPA operated by National Technical Research Organisation(NTRO) have SSR facility as of now. SSR equipment is very heavy, expensive and requires a lot of power for its operation. It is not even mandatory for full size Aircraft in India to have SSR as of now. Also as of now there are no equipment available, that is compact and light enough to be placed in Nano, Micro, Mini RPA. ADSB is a emerging technology. It is not mandatory for full size aircraft in Indian Airspace to have ADSB facility as of now. ADSB is not even mandatory in US Airspace for full size Aircraft as of now. Neither it is mandatory for RPA in US Airspace as per Part 107 of FAA rules. There are no approved ADSB equipment available to be installed in RPA as of now, though some prototype equipment is being tried out in this field. SSR and ADSB inform the ATC and other Aircraft about the position of a aircraft. If a RPA is flown within VLOS the Pilot will inform the ATC about the place of conduct of RPA operation and hence it is not a unnecessary equipment. SSR and ADSB Out should be made mandatory in case of BVLOS RPA flying in controlled airspace for Small and Large RPA once such certified equipment is made available for RPA. In the interim, BVLOS flights of RPA should operate under exclusive Flight Plan and Clearance Of Concerned ATS provider in the region. For this the RPA Operator shall file a Flight Plan which shall mention the details of Area Of Operation and Time Of Operation. The ATC shall give clearance for Operation of RPA in the Specific Time Slot and Height Band. ATC should not allow simultaneous operation of manned aircraft and RPA in the same dimensions(same area and height banned) of Airspace at a given time. For example if manned aircraft are operating in a specific area above 1500 feet where RPA operator wants to operate then RPA operations should be cleared below 1000 feet only. Hence it is suggested that Section 11.2(a) should be amended to read – SSR(Mode C or S) or ADSB Out equipment mandatory when RPA is flown beyond visual line of sight and above 400 feet for Small and Large RPA as and when the Credible SSR/ADSB Technology becomes available for use in RPA. In the interim BVLOS flights above 400 feet should operate under exclusive Flight Plan and Clearance Of Concerned ATS Provider in the region. ATC shall not allow simultaneous operation of manned aircraft and RPA in the same dimensions of Airspace at a given time unless it has been mutually agreed to between the pilot of manned aircraft and RPA
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« Reply #18 on: November 23, 2017, 09:18:42 PM »
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part 3
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« Reply #19 on: November 23, 2017, 09:19:10 PM »
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Sravan sir,
the link you've posted is working fine. The download link for the pdf is given halfway down that page.
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« Reply #20 on: November 23, 2017, 09:19:45 PM »
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PArt 3

* Comments of DGCA CAR for pdf part3.pdf (112.1 KB - downloaded 34 times.)
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« Reply #21 on: November 23, 2017, 09:21:04 PM »
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part 4

sorry for this mess. I could not get to convert the part 2 to less than 200 kb . Su u read part1 pdf, then part 2 typed in post, then part 3 and part 4 pdf.
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« Reply #22 on: November 23, 2017, 09:22:03 PM »
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part4

* comments to DGCA CAR part4.pdf (124.7 KB - downloaded 25 times.)
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« Reply #23 on: November 23, 2017, 09:23:00 PM »
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City: Pune, Tezpur,Hyderabad
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Got it swapnil. Any one having any issues you can pm me ur mail id/watsapp nos. i can send u the full pdf version
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« Reply #24 on: November 23, 2017, 09:24:33 PM »
Swapnil
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City: Pune
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Retreat, Hell!



I just uploaded to another host that shows original pdf.

https://sabercathost.com/9h7y/Comments_of_DGCA_CAR_pdf.pdf
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