New CAA guidance and clarifications

[Cymru]

New email to documents via Skywise which has clarifications and definitions changed.

https://publicapps.caa.co.uk/docs/33/20220621_AMC_GM_2019-947_Consultation.pdf is a useful summary.

A few changes of note, all reference to VLOS being an arbitrary 500m have been removed and its gone, more sensibly to "it depends"



This clears up something many people didn't understand - just being able to see a tiny black spec doesn't mean you're flying in VLOS. You need to determine *orientation* and maintain spacial awareness.
(To that extent, i really wish DJI would fit standard navigation lights on the drones to aid with correct orientation rather than random coloured LEDs).



Confirmed that. Which means DJI really should sell the plus battery in the UK... MTOM is assumed to be "take off weight of that particular flight" in the UK. This is a divergence from the EASA MTOM rules.

Also goes to explain what is meant by groups of people, uninvolved people and so on.

It still doesn't hide the fact we've all been utterly screwed over with the sudden decision to not recognise class markings in the future though. Really does mean sub 250g is the only useful drone in the UK unless you want to fly in the middle of nowhere after transistion.

 

[twickers14]

Caramba what a tome. Thanks so much for bringing this to our attention. Can I read through it all-possibly but perhaps someone will have a bash at summarising it. Presume the CAA exams will reflect the new clarifications etc. What section covers flying over uninvolved people? Please don’t go through it if you don’t know!

 

[scro]

I didn't spot this post here until now, and I posted separately on the same topic in the Rules&Regs section.

Geeksvana have done a couple of summary videos which I linked to in the post here:

Updates from the CAA - for UK pilots

It looks like the CAA has updated the suite of documents relating to drone rules. Some of the wording has been made clearer or more explicit and along with it some significant contradictions and inconsistencies. Key points I picked up are as follows: Removal of class marking references. VLOS is...

mavicpilots.com

 

[Felix le Chat]

New email to documents via Skywise which has clarifications and definitions changed.

https://publicapps.caa.co.uk/docs/33/20220621_AMC_GM_2019-947_Consultation.pdf is a useful summary.

A few changes of note, all reference to VLOS being an arbitrary 500m have been removed and its gone, more sensibly to "it depends"

View attachment 158066

This clears up something many people didn't understand - just being able to see a tiny black spec doesn't mean you're flying in VLOS. You need to determine *orientation* and maintain spacial awareness.
(To that extent, i really wish DJI would fit standard navigation lights on the drones to aid with correct orientation rather than random coloured LEDs).

View attachment 158067

Confirmed that. Which means DJI really should sell the plus battery in the UK... MTOM is assumed to be "take off weight of that particular flight" in the UK. This is a divergence from the EASA MTOM rules.

Also goes to explain what is meant by groups of people, uninvolved people and so on.

It still doesn't hide the fact we've all been utterly screwed over with the sudden decision to not recognise class markings in the future though. Really does mean sub 250g is the only useful drone in the UK unless you want to fly in the middle of nowhere after transistion.

Even if you have a sub-250: you're stuffed - I've just had a look through a wide cross-section of the available CAA compliant 'strobe' units and the lightest set (port/starboard/top) weighs in at 18 grams courtesy of the battery. Stick just the one set on the fuselage and you're over the 250 gram limit. The same with prop-guards... another bit of after-market kit I'll bet you a dollar we'll end up having to fly with for "Health & Safety" reasons. Makes a total joke out of the far more relaxed regulations sub-250's are currently allowed to fly in accordance with.

**corrected** original was ambiguous as I didn't state more than one strobe fitted to the drone.

 

[Cymru]

Strobe things are annoying but to this day i can't fathom why DJI don't fit compliant navigation lights to the drones in the first place.
The LEDs are there, they're just the wrong colour and angled incorrectly. A simple no-cost change there would dramatically help orientation.

 

[Jamesz]

Even if you have a sub-250: you're stuffed - I've just had a look through a wide cross-section of the available CAA compliant 'strobe' units and the lightest weighs in at 20 grams courtesy of the battery. Stick just the one on the fuselage and you're over the 250 gram limit. The same with prop-guards... another bit of after-market kit I'll bet you a dollar we'll end up having to fly with for "Health & Safety" reasons. Makes a total joke out of the far more relaxed regulations sub-250's are currently allowed to fly in accordance with.

I have fitted 2 of the Vifly strobes - really bright even at 500m- and at around 6g each, my mini 2 is still under 250g.

 

[scro]

Have a look here for very lightweight (inc battery) strobe options. They do a few that allegedly weigh 4g. I weighed my mini3p and I think I could just get 1 of these on while keeping under the 250g limit. I might have a fairly light sample at 246g. The mini2s are generally well under 250g

STROBON™ LED Lights

Navigation and Anti-collision Light Solutions for Drones

store.flytron.com

The dual LED red/green unit with a small shim of opaque plastic to act as a shield between the 2 LEDs could be made to work for orientation.

 

[Bog Down]

[New member here.]

I've been flying an old APM hex with a compact camera mounted on it for about 9 years well away from everyone - mostly on a private site which we are managing for wildlife and monitoring for vegetation. I've flown it very carefully, mostly only doing fixed point photography (fly up 50m, take a panorama, land). I never have any trouble seeing it or which way it is pointing as it is pretty large.

I thought it might be useful to have a sub 250g machine to use on other wildlife sites (with permission) as there may be people around unexpectedly, so I bought a Mini 2 last week. However, I didn't know about this new interpretation of the rules...

I haven't flown it yet so technically I could still send it back. I suspect at 100m altitude it will be pretty much impossible to see the orientation of a Mini, so it could just be an expensive paperweight, and I don't really want to fly outside the rules in the circumstances.

What I'm wondering is - is the CAA's interpretation of orientation to do with the direction the drone is flying, or the direction the camera is pointing?

If I'm only taking photographs, I don't actually care that much about the direction the camera is pointing until I take a photo (or panorama), so I could use Home Lock or Course Lock as DJI calls them.

In that sense there is no possible confusion about which way the drone will fly as long as I can see a dot in the sky. Or do I have to be prepared to fly in ATTI mode at all times in case the compass fails?

I don't really want to give up on this idea but it seems the authorities want me to.

 

[Cymru]

DEFINITION OF ‘VISUAL LINE OF SIGHT OPERATION’- ‘CONTROL THE VISUAL FLIGHT PATH’50
In order to control the visual flight path of the UA, it must be kept within a suitable distance of the51
remote pilot such that they can monitor the aircraft’s position, orientation and the surrounding airspace52
at all times.

Its the orientation of the drone - ie the direction its facing in addition to the axis its moving along.
So basically both - direction and camera.
The idea being you're always aware of which direction a specific control stick will make it move or point.

 

[Bog Down]

Its the orientation of the drone - ie the direction its facing in addition to the axis its moving along.
So basically both - direction and camera.
The idea being you're always aware of which direction a specific control stick will make it move or point.

Surely the camera is irrelevant to flight safety? You don't have to use one.

In home lock I know exactly which way the drone will move in relation to the control stick, provided I can see the drone and am facing towards it.

I know it isn't the preferred way for most people to fly, but I don't understand why the CAA would care which particular propeller is pointing north when the craft is coming towards me, stick down.

 

[Cymru]

Its more the camera is mounted on the nose so the forward axis. The fact its a camera is irrelevant.

Home lock wouldn't meet the requirement for being able to visually determine the orientation (ie which direction its facing).

Ultimately it comes down to requiring 3D spacial awareness around it.

 

[Bog Down]

Its more the camera is mounted on the nose so the forward axis. The fact its a camera is irrelevant.

Home lock wouldn't meet the requirement for being able to visually determine the orientation (ie which direction its facing).

Ultimately it comes down to requiring 3D spacial awareness around it.

If your interpretation is correct - and I suspect it is, even if it makes no sense, as a multirotor doesn't really have a natural forward direction - then I might as well send the thing back. It seems daft to require a bigger, more dangerous drone in order to fly slightly higher when a smaller one could do the same job with greater safety.

Pretty much everyone is just going to fly illegally, aren't they?

 

[Cymru]

There's still the link between what control makes it move in what direction - again its that reacting to a threat and being immediately able to issue the correct control stick to move in the direction required to avoid it.

But yes, most people are going to fly illegally. Most people already fly illegally, some knowingly, many more so unknowingly.

Education and the rules are a bloated mess. This is a drone forum and we've literally waded through several 150+ pages of documents and further summaries, amendments and amendments to amendments.
This isn't something someone that buys a drone for fun from Argos or a Christmas present is going to do.
Once you have a system as overly complex and time consuming as this, the end result is usually just non compliance as its all too hard.

 

[Felix le Chat]

There's still the link between what control makes it move in what direction - again its that reacting to a threat and being immediately able to issue the correct control stick to move in the direction required to avoid it.

But yes, most people are going to fly illegally. Most people already fly illegally, some knowingly, many more so unknowingly.

Education and the rules are a bloated mess. This is a drone forum and we've literally waded through several 150+ pages of documents and further summaries, amendments and amendments to amendments.
This isn't something someone that buys a drone for fun from Argos or a Christmas present is going to do.
Once you have a system as overly complex and time consuming as this, the end result is usually just non compliance as its all too hard.

...which inevitably leads to the Aviation Authorities and the DoT (U.K.) having the excuse they need to hit all free-range drone pilots with the big stick. Wading through all the Brussels guff published in the last two years by the E.U and the EASA as well as the post Brexit CAA R&R is enough to make you lose the will to live. For a start off, none of it will ever likely win the Award For Plain English. Then there's the fact that a lot of it is confused and contradictory - like you say: as soon as you've digested and started to comply with one set of regulations, another little codicil gets thrown into the mix and muddies the waters - a perfect example being this latest VLOS "guidance".

For the last couple of years I've thought that regardless of the variety of certificates (one of which now turns out to be a total waste of time and money) anyone owning and operating a drone is doing so on borrowed time. If you stick three mile range strobes on your sub-250grm bird a-la aircraft regs (port/starboard/top/bottom/tail) so that you CAN see your drone as well as determine which direction it's pointing in at the current VLOS limit, you now have a drone that you can't fly according to A1 sub-category because it now weighs 29 grams over the maximum 250grm MTOM.

I just get the feeling that all of us who actually use UAV's as tools instead of toys are being run around in ever decreasing circles until we're told that if we want to fly: we have to join a model aircraft club and stick within the confines of their registered flight zone. The pessimist in me reckons that the inheritors of the sub-120 metre altitude range are going to be the commercial carriers like Amazon and that this will be inevitable because... there's more money in it for the CAA and the DoT to license and regulate the autonomous carriers.

 

[Cymru]

VLOS is about your drone - its about being able to see any potential hazards in the 3d space around it. 3 mile strobes won't help that.

Ultimately you're flying a modified form of VFR so are expect to adhere to that. Its all about situational awareness all around you to detect and avoid hazards and conflicts. So depth perception is needed as well. Its also why camera-only isn't allowed.

The next obvious legislation i can see is detect and avoid systems. BVLOS and commercial wont happen without that.

 

[Felix le Chat]

VLOS is about your drone - its about being able to see any potential hazards in the 3d space around it. 3 mile strobes won't help that.

Ultimately you're flying a modified form of VFR so are expect to adhere to that. Its all about situational awareness all around you to detect and avoid hazards and conflicts. So depth perception is needed as well. Its also why camera-only isn't allowed.

The next obvious legislation i can see is detect and avoid systems. BVLOS and commercial wont happen without that.

I used the 3 mile strobe as an example because that's what the FAA and the EASA require at the moment (night flight). What I do requires total situational awareness because I work within feet of a target to produce high definition Category #2 images for study, analysis & comparison so I can only think of one occasion in the last four years where any of my drones have been anywhere near the 500m VLOS limit - and that was to get to an island in your neck of the woods. The point I'm labouring is that regulation/guidance alterations with regard to VLOS "orientation & situational awareness" seems to be the opening shot in an argument to limit the range of free-flight drones even further.

The Mavic 3 can already fly BVLOS with a dongle plugged into the controller using a signal transmitted via mobile phone repeater masts (or that's what their advertising bumf claimed) so perhaps this is the test-bed for the future design and construction of commercial BVLOS drones... interesting thought...

The DJI birds already have detect & avoid - fair enough, baseline stuff (APAS) and when they get around to it: the commercial concerns will have to have complete control over the allocated airspace with everything else human operated locked out. After reading through the E.U documents concerning 'U-Space' and 'USSP's' (U-Space Service Providers) I get the feeling that this will be the basis for determining commercial drone flight corridors and flight paths. It will also be the basis for third party businesses to charge non-commercial drone owners for drone flight on a per-flight basis in city, urban and semi-urban areas... after you have jumped through more hoops than you'd find in a can with a Heinz 57 label.

If you want a perfect example of why free-flight drones (even those with D&A) will end up being frozen out of the sub-120 metre airspace, take a look at the Google car - that was touted as being the most advanced A.I vehicle so far developed and it still managed to turn a pedestrian into a greasy smear on the tarmac because it couldn't cope with the unpredictable nature of the autonomous human. Same with 'smart motorways' they'll never work until every car that starts to go down a slip-road disengages all the human operated controls before it reaches the carriageways. Up until the time that happens - Smart Motorways will remain what they are now notorious for being - death-traps.

Whichever way it goes, I just get the feeling that after the drone equivalent of the "Wild West" between 2013 and 2018, the start of licensing, certification and legislative control from 2019 to the present, it is only a short step now to foot-on-the-neck regulation with a limited number of Green Zones for die-hard free-flight drone jocks.

The old saying "...make hay while the sun shines..." springs to mind.

 

[Cymru]

Detect and avoid means capable of detecting both actively and passively and communicating with other threats to avoid each other.
APAS is nothing like whats needed. Until the ability to detect other traffic in the air and work mutually to avoid each other BVLOS is never going to happen.

Ultimately until a suitable transponder system both in transmit and receive and capable of being utilised by manned aircraft as well things aren't going to advance on safety grounds.