Dear All
Please read the draft guidelines as published by DGCA for public comments;
http://dgca.nic.in/misc/draft%20circular/AT_Circular%20-%20Civil_UAS%28Draft%20April%202016%29.pdf

We can discuss here and compile our comments together.

Kumaran

Note : Thanks to Himadri for highlighting the above in the whatsapp group.

Below 200 ft, we are ok, are we?

Sir,
1. What about UIN as per Clause 4 ?
2. AS per clause 5.3.b
"Aero modelling  activities  carried out within  the  premises  of  educational  institutions will  be  considered  as
recreational purposes"

So, what if we fly out side ?

They have totally ignored Aero Modelling.

These guidelines seem aimed mostly at commercial UAS usage, withy hobby/ recreational uses added as an afterthought. I am pretty disappointed with these regulations for hobby flying. Here are my main concerns.
For the documents which need to be provided:

• 4.2.c) Specification of UAS (manufacturer name, type, model number, year of manufacture, weight and size, type of propulsion system, flying capabilities
  in terms of maximum endurance, range and height, etc. including details of equipment) - this will be rather difficult to provide for custom built multirotors/ planes
• (e)Permission for all frequencies used in UAS operations from Department of Telecommunication (Wireless Planning and Coordination Wing) - How are we supposed to get this when they won't even let a 2.4 GHz toy through customs?
• (f)Copy of Unmanned Aircraft Flight Manual (UAFM) - how are we supposed to provide this for custom builds?
• (g)Copy of Manufacturer’s maintenance guidelines for UAS;- Same as above.

Other regulations:

• The identification plate (made of fire proof material) inscribed with UIN and RF ID tag or SIM shall be affixed to the UA, and appropriate makes to identify
  ownership. - will the DGCA be providing this? They have not mentioned any registration fee so I am not sure.
• 10.12 The operator shall ensure that the UA is flown within 500m Visual Line of Sight (VLOS) during the entire period of the flight. (Applicable for micro and mini UA) - Does this mean FPV is illegal? 

Equipment to be mounted on UASs:

• GPS/ INS (with option to GPS tracking and Geo Fencing)/ Return Home option (mandatory in the event of failure) - What about 250 size racers? Foamies? Other small/ medium planes? Does that mean all our aircraft have to be fitted with autopilot systems? If the DGCA expect me to do this let them pay for the hardware.
• SIM card slot for an app based tracking (Mandatory for Micro & Mini UA); - What? Where is all this hardware going to come from?

I want to know if any of our Aeromodelling bodies were involved in the formulation of these guidelines. They really seem to be throwing hobby pilots under the bus here. A simple online registrations system like the one implemented in the USA would be far better.

Further as per 4.2.d
"Verification of character and antecedents of the operator and remote pilots from local sub-divisional police office"
Why it is required to get Identification number for the model ?

This is to be linked with UA OPERATOR PERMIT (UAOP)

At the first look it appears HORRIBLE. I'd go though it in details. Also 200 ft. is too low. It should be made 400 ft. at least

This looks stupid to me,

If someone is flying a custom made quad (250 size) it would still need a UIN?

The first question came to my mind is "Who has made this DRAFT?" does that person has ever tried to understand what aeromodelling is? or has just drafted this 

Satyaji
Did you see this clause ?
6.7 Import permission shall be obtained from DGCA based on which DGFT shall provide licence for import of UAS.

That is good, i dont mind getting an import license.

I have heard that some already have these kind of license. There are many guys in Mumbai who now buy and provide quad for the shooting purpose and they say that they have license to import these things. One of the seller got a 1200mm bit octa from Chinese supplier (RTF) and provided to one of my friend in 20 days that too without any custom hassle. So they might be talking about this only.

But the rules to regulate the use of UAS is stupid. It should make more sense or else no one buy fly or buy.

It appears that UIN will be required for all UAS...even the micros and the minis. This is stupid and we must protest. In hobby related UASs, we assemble and disassemble the items, may change specs...some may get lost or damaged etc. Is it possible to get UIN for every piece? And that too after getting character certificate from police station? That opens us to the bribery issue.

- I suggest changing the classifications:
Micro - upto 4 Kg
Mini - 4 to upto 10 Kg
Midi - 10 Kg-25 Kg
Small - 25-150 Kg
Big - Greater than 150 Kg.

- With the above classifications, requirement of UIN should be exempted for Micro or at least make them self-register online without police involvement. This will exclude most hobby class quads and planes. Fireproof ID plates will only increase weight of small aircrafts

- The height for UAOP should be increased to 400 ft. This is the standard height around the world.

There are other ridiculous requirements for UAOP. They should clearly segregate the requirements of hobbyists from commercial activities.

Quote from: satyagupta on April 25, 2016, 10:19:38 AM
That is good, i dont mind getting an import license.

This is going to be like a WPC approval.

I know WPC  and ETA i have filled last year in AUG and still there is no update on it :headbang:

But i dont think its a bad thing if they are providing a license for sellers to import these kind of things then its a good thing. The method of providing or procuring one should be made simple unlike others. Or else no one will ever get one and continue doing the same as they are doing now.

Quote from: santanucus on April 25, 2016, 10:24:06 AM
It appears that UIN will be required for all UAS...even the micros and the minis. This is stupid and we must protest. In hobby related UASs, we assemble and disassemble the items, may change specs...some may get lost or damaged etc. Is it possible to get UIN for every piece? And that too after getting character certificate from police station? That opens us to the bribery issue.

- I suggest changing the classifications:
Micro - upto 4 Kg
Mini - 4 to upto 10 Kg
Midi - 10 Kg-25 Kg
Small - 25-150 Kg
Big - Greater than 150 Kg.

- With the above classifications, requirement of UIN should be exempted for Micro or at least make them self-register online without police involvement. This will exclude most hobby class quads and planes. Fireproof ID plates will only increase weight of small aircrafts

- The height for UAOP should be increased to 400 ft. This is the standard height around the world.

There are other ridiculous requirements for UAOP. They should clearly segregate the requirements of hobbyists from commercial activities.

Exactly, just imagine the mini toy grade quads whcih are available. And they are in different name but same model. We would need UIN for that too.?? Its stupid and ridiculous.

IMO this draft is just a way to push aero modelling down and out.

Import licence will not be a blanket licence. It will be issued on case to case basis. So licensing is not going to be an easy process. First you have to approach DGCA for NOC. Then apply to DGFT for licence. How many times you are going to do that? But I think there is no licensing for parts. Only for RTF

Right and these days there are customers who need RTF. There are guys who buy parts and assemble things but then there are many customer who just want a RTF or some kind of BNF version.

I want to know how there are people who are importing RTF since a long time. That too bigger size not like smaller but the Inspire or the latest phantom how they are doing it???

I tried to get a small RTF (220 sized) but before shipping fedex advised me to not ship it since it comes in drone and customs would not release it.

Quote from: satyagupta on April 25, 2016, 10:41:04 AM
I want to know how there are people who are importing RTF since a long time. That too bigger size not like smaller but the Inspire or the latest phantom how they are doing it???

I tried to get a small RTF (220 sized) but before shipping fedex advised me to not ship it since it comes in drone and customs would not release it.

Misdeclaration with some "setting" probably. Toy is the most preferred declaration

Thats how I used to do but now they are strict and mostly open most of the packages.

Setting is for sure how they are doing it. Its technically not possible to get anything that works on any frequency since custom dont clear it without any ETA.

Hence i have stopped importing radio sets and selling the same

By the way, even after these regulations by DGFT/DGCA, the issue of WPC will still be there. So for anyone importing RTFs, I don't know how they will clear those items

True.

We FPV flyers are now illegal. UAS has to be kept under 500m LOS  Looks like all the rules where drafted without any inputs from any aeromodeller.. 

***

So what do we do? Let us read the draft notice in details and post suggestions here so that we may send comments to DGCA. Once the circular gets finalized there will be no way to change it. So whatever we do, we have to do now.

- I think we need to emphasize the fact that rules for hobbyists/recreational flyers and commercial flyers of big UAS cannot be clubbed together.  

- Micro and mini UAS (at least upto a certain weight) should be exempted from having UIN or self-registration can be suggested online. We have to mention that hobbyists with custom made quads will face problem if they have to get UIN for each piece. In fact there are some documents to be provided for UIN which are impossible to get. How can an ordinary flyer get WPC clearance ?

- The involvement of police should not come for hobbyists and recreational users flying mini or micro. This is the greatest hurdle for common flyers as police will demand money to issue character certificate

- Category of UA should be re-formulated (we need to discuss)

- The height requirement for UAOP should be increased to 400 ft. in line with the rest of the world.

- LHSs also need to formulate their opinions. Requirement of WPC should be dispensed with because running after 3 agencies - DGCA, DGFT and WPC will create enormous hurdles.

- There are many anomalies related to UAOP too. But we should first ask for making the altitude requirement to 400ft. Then most of us won't require UAOP. 200 ft is the height of a 20 storey building. And we have 60 storey or taller buildings in cities.

- I notice that there are other points which have been omitted. Its best not to raise them if not having them suits us. Why bring issues when they have failed to include it? Lets stick to the draft and comment only on that.

- There are some requirements in Para 10. I am not sure whether its applicable to everybody or to UAOP holders only.


I think if UIN requirement is dispensed with or made online without police verification upto a certain weight category then a major problem will be resolved.

Please post your views

agree with above points.