CAA Consultation - Review of UK UAS Regulations

Just submitted my response… :crossed_fingers:t2:

Hello @ben-s

No, we are not, simply because CAA do not weight the response of an organisation any differently to the response of an individual, and most of our team have already responded personally.

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I’ve been reading posts on FaceAche today in the drone groups. Oh dear some of the posts are unbelievable. One person is flying his drone (£12.50p off Aliexpress) 1200m away and wondering why he couldn’t see it. Another has got a Mini4Pro and is asking about range, “ It starts losing signal once it’s 500m away” FFS :roll_eyes::roll_eyes::roll_eyes: No wonder the CAA are ( seemingly ) wanting more regulation.

And there is part of the problem. We already have laws to deal with these situations, but they’re not used or enforced. More regulation won’t do jack shit, enforcement of the current regs WILL.
I keep asking myself “why do they want or need more regulations when what we have is good enough”
The only reason I can think of is because they want us hobbyists out of the sky? And as always it will have something to do with money.
In a way I’m not concerned, just yet. The police at present know pretty much fuck all and really don’t have the resources to respond to every ken and karen when they have a complaint. The big problem, for me, will start when RID is rolled out for all drones in UK, new, legacy, self build will all come into the picture. The only places we will be able to fly is the CAA’s designated areas, if we pay a fee of course.

Maybe we should petition for CAA to be renamed to CBA :smiley:

the problem with “designated areas” will be the same as asylum seekers housing , and new homes, and homes of multiple occupation, new and larger prisons, new nuclear power , etc etc … Not In My Back Yard! (nimby’ism)

the best one I heard was when a politician was being interviewed a while ago over new housing and his response was along the lines of “yes we do need more houses to be built” followed by being given the question “do you therefore accept them to be built in you constituency?”, and gave the response "well yes but we would like them spread out so that those areas that don’t have much housing or have an acute need can have their needs for filled! {first}

but… you get an extra response if you form a group and submit one together…

technically… if you are a politician… you just use your dogs name … and set up your dog with an email address and they get a response too… along with your wife, ex wifes, previous acquaintances, plus each of the kids … now if my name was Boris I’d be on to a winner with close names one could use

(during the expenses scandal didn’t one have a bank account set up in his dogs name in error… if it’s good enough for them it’s good enough for the peasants too)

Yep and reading between the lines, he meant to say, “ Yes, but not within 3 miles of my house.” :wink::wink:

I have completed my response, I have included below my response to the controversial Remote ID question which I think is the one most people are most interested in. Feel free to use any of my answer in your responses.

  1. Ineffectiveness Against Malicious Use:

The Remote ID system’s fundamental flaw is its ineffectiveness against malicious drone use. Malicious individuals can easily bypass the system by hacking or disabling the Remote ID functionality. This vulnerability significantly undermines the primary goal of the proposal.
Expecting compliance from those with intent to misuse drones is unrealistic. Malicious operators are likely to either modify existing drones or build new ones without Remote ID capabilities, rendering the system ineffective.

  1. Redundancy Due to Existing Technologies:

Existing police and CAA technologies effectively track and trace criminal drone usage. These systems have been capable of identifying unlawful drone operations without the additional burdens imposed by Remote ID.
Implementing Remote ID seems redundant, adding unnecessary complexity and expense given the efficacy of current detection technologies.

  1. Potential for Spoofing and Misuse:

Remote ID is susceptible to spoofing, where drone identities are falsified, negating security benefits and increasing law enforcement and CAA workloads.
Spoofing risks leading to false accusations against innocent operators, complicating legal and administrative processes.

  1. Privacy and Security Concerns:

Instances in the USA demonstrate that similar systems lead to privacy violations and security threats, such as harassment or muggings of drone operators.
Making operator location data publicly available, even in a limited capacity, poses significant personal safety and privacy risks.

  1. Disproportionate Burden on Operators and Manufacturers:

Remote ID requires substantial investment from drone manufacturers and operators, likely resulting in higher costs for consumers.
Retrofitting Remote ID on legacy drones and model aircraft is particularly burdensome and may not be feasible or cost-effective.

  1. Overkill for Negligent Misuse:

Addressing negligence-related drone misuse through education and awareness is more effective and less invasive than a technological measure like Remote ID.
The proposal seems excessive for the issue at hand, requiring nuanced solutions rather than a broad, technological approach.

  1. Excessive Reporting Requirements Compared to Manned Aviation:

The level of surveillance and reporting required for drones exceeds that of most manned aviation, raising questions about the necessity and proportionality of such measures.
The continuous, real-time transmission of extensive data by drones is excessive compared to the relatively lower risk profile of smaller, unmanned aircraft.
This approach creates a regulatory imbalance between unmanned and manned aviation, placing undue pressure on drone operators.

Conclusion:
While the intention to enhance safety and security in airspace is commendable, the proposed Remote ID system is an overreach. It fails to effectively address the issue of malicious drone use and imposes significant burdens on law-abiding drone operators and manufacturers. It also raises privacy concerns and duplicates existing law enforcement capabilities, without sufficiently mitigating the risks of spoofing and hacking. A more balanced approach, emphasizing education and targeted use of existing technologies, is a more effective and less intrusive way to regulate drone use. The focus should be on aligning drone regulations more closely with those for manned aviation, ensuring fairness and proportionality.

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That’s a great summary of all of my concerns. I will copy your approach of grouping any concerns under headings and will try to write as constructively and succinctly as you have.
Thanks

WOW, 3 hours that just took. What a pile of steaming shite, who the fuck came up with that and actually got paid for it? That’s what you call justifying your job ffs

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no, that is democracy at work… if you can’t be bothered to reply or object then don’t be surprised when something passes as an accepted change.

it’s like the “vote for me”… and if you don’t vote for me, then don’t vote at all because your vote won’t count against me adage… everyone should vote and everyone should take the time to respond.

it’s not made to be easy as if you don’t reply it will just be a given that everyone thought that the caa’s proposals were acceptable

people who have YouTube channels should encourage everyone to respond

I’m sure you could probably ask chat gpt to draft some detailed responses to simple yes and no responses…

I was watching one of @ianinlondon YouTube clips on the m4p extended battery and RID and whilst not surprised of the acceptance that RID is coming and is inevitable it is rather defeatist (but pragmatic and realistic) but with these consultation documents one must not accept it as a given or it will be just that. and then there is no difference between an autocracy, oligarchy, plutocracy or democracy…


please everyone just reply… something… anything… even if you think it’s bs and your response won’t be very good or change anything or be accepted… it’s about being counted!

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Is there anything that @Committee can do to raise awareness of the approaching deadline, and to encourage others to respond?
Would it be appropriate to add something to the banner at the top of the page (where the insurance options are highlighted)?

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whist it may be a done deal (rid, more restrictions, more rules, more confusion and less places to fly) let’s all give it just 1 shot and each us that fly drones or have an interest in drones please please reply.

a little over 10 days to go, spare a few hours in this carp weather that you may have otherwise been out flying to just have YOUR say.

you can even start it and come back to it later and finish it off later when time permits (before the deadline)

We have made that change for you.

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Thanks …. Let’s hope we generate hundreds of additional responses :blush:

From @xjet:

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correct and well said… time to stand up and be counted… or do we just cave and accept any old carp that the CAA wish to shovel without ANY evidence.

have you known ANY government software or hardware project that has ever been delivered on time and on cost (please tell me as I’m not aware of ONE!)

given that Amazon/ DHL / FedEx etc drone deliveries are not here now or ready for implementation and VTOL taxis are presently pie in the sky… (we can’t get driverless cars sorted!). by the time these things become real and sharing airspace the software will be out of date, not fit for purpose and guess what… need updating with something new!!!

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I’ve watched the xjet video (great as always), will assist with my response too. I wish those at the CAA would watch things like this…

Pay per flight? What do people think of his suggestion of declaring to ignore this. There is NO justification for RID at all, none nada. Just insane.

Anyways, anyone want, 1 avata (never crashed, though once hit by a clink of a dink), 1 DJI FPV (never crashed), a number of wings/drones (crashed loads, but fly fine). inbox me!

After watching lots of videos, and reading lots of information here, I am in the process of trying to complete the Consultation response.

I have read the following two clauses:

(iii) The current operational requirements for flights in the A3 sub-category do not specifically define a minimum distance a UAS must fly from an uninvolved person. However, guidance material (e.g. CAP2012 and AMC/GM) sets out that a minimum distance of 50m should be maintained from uninvolved persons. We are proposing to introduce a regulatory requirement in the A3 sub-category for UAS to fly a minimum of 50m from uninvolved persons. This aims to avoid confusion for users by aligning regulation with current guidance.
(iv) At present, the operational requirements for flights in the A3 sub-category limit distances to residential, commercial, industrial or recreational areas to 150m. The CAA interpretation of this requirement, published within guidance material, sets out that this also includes distance to individual buildings. The difference between the guidance material and the regulatory requirements may create confusion for operators flying near individual buildings. We are proposing to change the regulatory requirement for flights in the A3 sub-category to be at least 150m away from residential, commercial, industrial, recreational areas and buildings. Flights taking place closer than 150m to individual buildings in the Open category will continue to be subject to A1 or A2 sub-category requirements.

Are they really saying that flights in the A3 sub-category must stay 50m away from uninvolved people, but 150m away from a building :exploding_head:
So it’s safer if an uninvolved person is outside, than if they are inside a building???
I keep re-reading this, and cannot understand what they are saying… can anyone please explain ???