Rather than safety, could it be for security? That is to say, at 50mtrs, a drone could get a clearer picture through a window. At 150, not so much.
I for one fail to see what âsecurityâ concerns the CAA keep harping on about in this consultation. Security is not part of the CAAâs remit. Personally I think the CAA is trying to secure airspace for the likes of Amazon etc in this utopian future they apparently foresee ( much like the FAA in the USA with that ridiculous video they released last year) Although it could be an attempt to shutdown these Frauditors 
I had to chuckle the other day, while researching a video camera Iâve seen a lot of people harping on about their 360 cameras being an alternative to drones as they swing their 150ft long selfie sticks around.
I only chuckle, as thatâs got to be more of a hazard to people than a responsibly flown drone.
I did wonder about the security thing⌠In the call for input, I think I made mention of the fact that the CAA role was safety⌠security if for others to worry about.
I did as well Peter. Security is the domain of other services in this country
Except CAP722 says for residential, commercial, industrial or recreational purposes that they are âareas that are densely populated or likely to be occupied by large numbers of personsâ
Is a single building likely to meet their own description?
Guess it would depend on what the building is used for âŚ
Iâm pretty sure that was one of the questions - âshould a single building be includedâ or at least it makes reference to changing the description I think to include them
I notice that there is a email address associated with the CAA Consultation, so am going to email this to them:
I have been completing the âCAP 2610 - Consultation: Review of UK Unmanned Aircraft Systems (UAS) Regulationsâ and felt compelled to respond separately about the total lack of transparency and legitimacy of the document.
In a document that has such far reaching implications, it can be assumed that the best, most compelling evidence for change will be included. The document is supposedly about improving the safety and security of UK airspace, in relation to UAS (Unmanned Aircraft Systems) better know as drones, but the entire premise of the document and therefore the process is undermined by the total lack of evidence that there is a problem that needs to be resolved.
In the opening section of the document, you state that:
âData provided by the police and government demonstrate that these risks have already materialised and are growing. Since November 2020, police have received 18,290 reports of drone flights involving a legal, nuisance, criminal or safety concern. In the first 9 months of 2023, police received 5,005 reports - a 10% increase over the same period in 2022. In the 6 weeks following 23rd September 2023, the CAA received 558 reports of UAS operating within a Flight Restriction Zone (FRZ) or outside a FRZ but over 400ft. Between January and October 20238, 9 UAS have been reported operating between 6,000 and 13,000 feet.â
You also provide information that the figure of 18,290 reports are based on data collated by the NPCC Counter Drone team from police forces and other agencies. Up to 6th October 2023.
Following a Freedom of Information Information request (F0006594) that asked:
- How many of the 18,290 reports were followed up and fully investigated
- Of reports fully investigated, how many were found to be valid complaints with drone operation being at fault
- Of reports fully investigated, how many were found to NOT be the fault of drone operation.
The CAA responded that:
Your request has been considered in line with the provisions of the Freedom of Information Act 2000 (FOIA). I can confirm that following a review of held information it has been reasonably determined that the CAA holds no information within scope of the request.
The CAA was supplied with the grand figure of 18,290, as annotated in the consultation document (Review of UK Unmanned Aircraft Systems (UAS) Regulations), by National Police Chiefs Councilâs Counter Drone team from police forces and other agencies; therefore a further breakdown of the figure is not held by the CAA.
In a separate FOI request to the NPCC Counter Drone team, it was asked:
- I would like confirmation if each and every incident log was requested and all 18,290 checked to ensure the searches performed didnât retrieve incidents that werenât drone incidents. If not, were any hand checked and if so what was the sample size?
The answer:
The NPCC does not hold a record which provides an answer to your question at part 3, however, in wishing to assist you, having consulted with NPCC Counter Drone colleagues, I can confirm that the figure referenced were all suspected drone sightings, incidents and/or incursions.
From the above, it is therefore clear that the CAA have no valid evidence that there are any real safety issues with the current regulations. The CAA does not know how many (if any) of the 18,290 reports were actually valid complaints. It is even unclear how many (if any) resulted in prosecutions. It is likely that some of the âreportedâ drone issues may even have been about drone users reporting lost or stolen drones!
Incredibly, in the document, as a way of proving how big the issue is, the CAA go on to discuss the alleged incident at Gatwick in 2018:
The impacts of these risks go beyond just safety and security â they also require significant public resources to manage, cause disruption to lives and businesses, and compromise the viability of the commercial UAS sector. The closure of Gatwick airport in 2018 was estimated to cost the police ÂŁ459,000, the airport between ÂŁ1.4m and ÂŁ15m, and the airlines over ÂŁ35m
The CAA know that there has never been any successful prosecutions relating to this event, and indeed there is a a lot of doubt about whether a drone was ever actually involved (The mystery of the Gatwick drone | Gatwick airport | The Guardian). Again, a total lack of evidence being presented.
This consultation, and the legislative changes that are likely to follow, will impose a huge burden on UAS manufacturers and drone flyers in an effort to prevent what?
There is no evidence that any changes are required.
Is it too much to ask that before huge costs are incurred, and ill conceived regulation changes are proposed, that real evidence is collected and analysed?
Taking all of the above into account, I would suggest that the entire consultation is aborted, and not re-introduced unless credible, factual and transparent evidence is presented as part of the document.
The current plan to introduce complex, expensive and draconian measures to address a non-existent problem must be stopped.
I have copied this to my MP as I feel that whole process needs to be reviewed urgently.
I look forward to your response to my concerns.
Too much?
Too heavy?
Iâd appreciate feedback from all you good folk 
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Worrks for me, mind if we all use it?
Nope!
Nope!
Feel free⌠the more the merrier.
The further I got into writing my response, the more frustrated I got that there wasnât anything to âfixâ
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Many thanks, done and MP ccâd inâŚ
Done and ccâd to my bloody useless MP
There is nothing to fix!!! The rules and regs that are in force now just need to be used and enforced. The reason they want to implement this, IMHO, is because they donât have the resources (police boots on ground) so lets think of an automatic way of dealing with it and issue fines through software, let the computers do the work. There are however some things I agree with what they are trying to do. I am all up for geofencing sensitive areas, but accurately and not like the shite DJI have come up with. According to the CAA I am not allowed to fly in my garden, but DJI allows it? Others in here try to fly near airfields that havenât existed since the 2nd world war, but canât. Geofencing accurately IMHO would solve so many issues. Second is clear instructions on the outside packaging, inside the packaging, in the manual, and in the software on first start-up. Let people know there are rules and regs to be adhered to. No it wont stop the criminals, but that doesnât appear to be what the CAA are trying to stop. The crims will still get round all of this stuff, while the rest of us who, in the main, act lawfuly get punnished and fucked up the ass because some twat flies over a football match. Use geofencing, give people clear guidance, and if they fuck up? Hit them hard!!! But people have to know what the rules are in the first place. Personaly I would also ban flying over police stations without permission, but thatâs just because I hate wee fucktard auditors that are going to cost me my hobby.
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I agree, but I wonder how many people who were gifted/bought drones this Xmas actually realise there are rules in place? Personally speaking, I bought my drone from Curryâs online, but only after doing a lot of research and obtaining Operator and Flyer licences. Itâs probably fair to say that retailers will shift boxes and rely on the customer to know what theyâre doing.
Last year I approached a guy on the park who was flying a Mini 3 at low altitude, for a chat. He was there with his lively kids and dog who were all trying to chase the drone. Insured? Almost certainly not. Looking back, I doubt if heâd even heard of the drone code let alone read it, and the likelihood of him causing an accident/incident looked to be high. These are the sort of flyer weâll be penalised for!
Thatâs why there should be clear info on the outside packaging. Something as simple as
âThis drone must legally be registered with the Civil Aviation Authority before flightâ
I think it would put quite a few casual buyers off. If they do get themselves into trouble then they have no excuse. They can then have massive fines imposed and kit confiscated. But more importantly, it might lead them to the drone code so they can learn where and when they canât fly.
Well my MP Paul Maynard has surprised me - here is his reply:
CAP 2610
Dear Mr Goldsack,
Thank you for the email, and I am glad to see such regulation being robustly challenged. As a former aviation minister, I was more than aware of the concern over how drones could be misused, and that their use around airports can be particularly problematic. Nonetheless, regulation should always be necessary and proportionate to resolve any problem that may exist, not just a kneejerk desire to exercise greater control.
I know the consultation originates from an original call for evidence from the drone community, so I wonder what aspects you regard as especially problematic? As new-ish technology emerges (drones are hardly new), I accept that regulation may need to be refreshed to keep up to date, and that some of what the CAA seeks may assist the drone community, but I just want to understand a bit more about the problems the proposals may cause someone such as yourself? I can then ensure I make suitable representation to my successor as aviation minister.
I look forward to hearing from you.
Kind rgds,
Paul.
Suggestions for a reply to him ?
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I would thank him for a start and then no more than 5 bullet points. Emphasis on the spurious and incorrect data on which the consultation was based.
âFixing a problem that does not existâ.
And no amount of regulation will prevent those wishing to break the law from doing so.
Good luck.
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I agree that those cases (negligently unaware individuals) are the ones most likely to cause problems, alongside those malicious.
But the majority of the proposals made by the CAA will do nothing to prevent that from happening.
In your example, the guy in the park was not doing anything wrong (other than not being registered).
He wasnât flying anywhere he shouldnât with a mini 3. RID wouldnât prevent that.
And had he bought a bigger drone which shouldâve been >150m from a residential or recreational area, he still wouldâve flown there regardless.
Making the regulations more stringent also wouldnât prevent that individual flying there, serves only as a tool to ensure that we PUNISH people more easily.
Punishment is not the solution. Better education is.
And as always, I go back to my point that those who maliciously break the rules, will do so regardless by finding ways to circumvent them.
I think a stepped qualification framework is the way to go.
I.e. Flyer ID entitles you to fly <250g drones >150m from residential or recreational areas.
A CofC (paid for training) entitles you to fly anywhere, but >250g drones only >50m from people
And a GVC or similar exempts you from the 50m rule.
The exact specifics might not be that exactly, but that sort of principal.
That way, those who have proven they have a healthy attitude towards training and safety get to benefit from flying wherever they want, and those who just want to âfly a cool new toyâ must do so further from people and property.
And then Iâd even go so far as to say, that it should be part of the setup process when you buy a drone, that you must link it to your Flyer or Operator ID to prove that youâve done at least the most basic level of training before it will fly. I also agree that there should be large warning labels on the packaging and on the retailers websites. Self-builds could reasonably be exempt, as itâs a pretty fair assumption that anyone willing to put in sufficient research on how to build a drone will be aware of the regulations.
Combine that with geofencing and I think thatâs about as much as you can reasonably do to control drones without penalising those who use them responsibly.