Draft DGCA guidelines - Comments requested by 21/05/2016

Started by vibranthobbies, April 24, 2016, 07:55:24 PM

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sundaram

Its a prooven concept that all wings no rottor is capable of unmanned aviation hover, like wise single rotor and no wings too is capable of unmanned flight hover. No wings and no rottor too is capable of unmanned aviation hover. We should not waste our time in such discussions. Agencies are well aware of such capabilities of tech.

sundaram


santanucus

What about the requirements for Character Certificate from Police in cases where UIN would be required. And also WPC clearance Shouldn't we propose to do away with these? The first one will definitely involve bribery issue. In respect of the second, it would be almost impossible to get one.

If these requirements remain, it would be impossible to fly anything because almost surely one won't get these things.

Also, in my opinion 250gm. is a far too low weight for seeking exemption. Some batteries weigh more than 250 gms.

Moreover, in those cases UIN is required, we should insist upon simple online registration. There are no DGCA office in every town. For every item, should a person travel to the DGCA office in a metro city to get a UA registered?

vibranthobbies

We have not specified any requirement for Model Aircraft Pilot Registration. If they want to include we have to get it one time.
Exemption upto 250gram is reasonable and in line with FAA Rules. So, there is a possibility to exempt.
This is just to allow to small quads like CX10 and Toy Helis. etc. 
We are asking for Online registration of pilot upto 20 kg. Is it not enough ?


sujju

There needs to be a lot more responsibility from our community to monitor newbie's on getting a FPV quad or plane and fly into restricted and public areas (of course we cannot stop this unless we are aware of this, also during sales of a RTF-FPV unit to newbie's all LHS's including us need to make a buyer aware of the basic ethics in recreation flying)..

We wanted to launch a new hi-end transmitter and had approached the WPC the couple of months back for ETA (keeping the background of ALL OUR transmitter are approved from the WPC), however this time the WPC refused to give us the ETA which we think is definitely due to a internal circular from the DGCA. So if you are looking to get a ETA from the WPC at this juncture i would only say.........forget it.......(hence you will not get a UIN)

We get a "once in 3 week" regular visit from the local police authorities in our stores (especially after the event with the gentle man from Russian embassy flying his quad around the parliament with his kid). Believe me the authorities are only bothered about the safety of the general public and our country and not interested in curtailing our hobby. An if our hobby seems to be interfering with the security then definitely the later will prevail. During our many discussion with the police authorities it mostly points to the lack of coordination between our community and a LHS "including us" not doing enough to educate a new comer...(we get 10 year old kids asking for a quad with camera and goggles and lift capability of 5 plus kgs for which is refuted obviously).

As much as we are in line with Sundaram's comments on the fixed wing and rotary wings fpv capabilities we are also in line with what Vishal commented that this fiasco was born with the advent of multicopters in the hands a few amateur stupid flyers. We have also been part of this fiasco by NOT educating the consumer properly on the "rules of flying". And Yes multicopters are here to stay and are poised to grow larger then before and WILL enter our daily lives soon...

Coming to the point of DGCA... we need a proper LOUD voice which will be heard by the DGCA before they formulate and publish the circular as it will next to impossible to draft amends later.

I have seen the petition on change.org by a gentle man here from rcindia
https://www.change.org/p/directorate-general-of-civil-aviation-form-rules-for-uav-flying-as-a-recreational-hobby?recruiter=135098595&utm_source=share_petition&utm_medium=copylink
1.   Would this help if we get around 10,000 plus comments on this link?
2.   Do we need to generate some PR / Media agency help in getting a slot to voice our concern?
3.   Would the DGCA be ready to meet with a committee and discuss (again who will decide who is a part of this committee and how?)
4.   Would a simple letter with lots of signatures help
5.   All of the above?
6.   Any more suggestion are open and welcome...
Also the large question is... even with the above would DGCA listen to us..

We are ready to invest time, effort and money on this if we get some good executable solutions.

In the meantime we can discuss our points here plus other points which are in discussions with a few seniors from this fraternity on the way forward.

Remember, we can only overcome this situation as "ONE".. if not it will be status quo.

Regards
Sujju

On a lighter note:... someone visited our Bangalore store last week..pehchan Kaun??..   :)
CEO
RcBazaar

Darshan for multirotors

@sujju sir, you could have atleast named the image something else.. The name of the pic itself is "anwar at RCB".  :giggle:
put your heart in flying and flying will never leave your heart

sujju

CEO
RcBazaar

sundaram

There is fixed govt rate for police verification for a passport by local cop he gives a proper receipt for that 100 odd rupees. Its done at your declared address proof automatically. You don't have to knock any police door. Certain category of people of known social repute, their passport is printed even before they walk out of seva kendra and dispatched same day. Everything is possible as long as leagality of the activity established.

santanucus

Quote from: sundaram on May 01, 2016, 03:41:45 PM
There is fixed govt rate for police verification for a passport by local cop he gives a proper receipt for that 100 odd rupees. Its done at your declared address proof automatically. You don't have to knock any police door. Certain category of people of known social repute, their passport is printed even before they walk out of seva kendra and dispatched same day. Everything is possible as long as leagality of the activity established.

PVR for passport is a regular process initiated by the government. Character certificate for registering each and every UA (assuming no exemption is given) would be an impossible task. It would have to be initiated by the person concerned. And when police learn that someone has applied for character certificate for "flying a drone" it would attract extra scrutiny and demand for more money than usual. After all, thousands apply for a passport. How many would apply for registering a drone? With this requirement in place, one may as well give up flying these things.

We should write against mandatory PVR upto a certain weight category. Otherwise people will stop buying or making UAs because of police verification.

Also ...no talk about WPC clearance. When LHSs are facing difficulties getting WPC approval, how can individuals manage to get one?


santanucus

Quote from: vibranthobbies on May 01, 2016, 01:43:33 PM
We have not specified any requirement for Model Aircraft Pilot Registration. If they want to include we have to get it one time.
Exemption upto 250gram is reasonable and in line with FAA Rules. So, there is a possibility to exempt.
This is just to allow to small quads like CX10 and Toy Helis. etc.  
We are asking for Online registration of pilot upto 20 kg. Is it not enough ?

I have no problem with exemption upto 250 gms if for higher weight categories (say upto 4 Kg.) they make an easy process of online self-registration without police verification and WPC clearance. But there is no certainty that such online registration will happen at all.

The issue is not about RTF only. If a modeller makes a UA weighing more than 250gm. he will face the same problem of registration, police verification and WPC clearance. So unless we address this issue, only people who fly toys will face no problem.

laritiewsoh

Hello everyone. I am currently in Europe (Czech/Austria) and these are the laws followed here.
http://www.caa.cz/letadla-bez-pilota-na-palube/provoz-ostatnich-letadel-bez-pilota-na-palube (Czech)
http://www.austrocontrol.at/luftfahrtbehoerde/formulare__serviceinfo/allg_informationen/faq/ulfz (Austria)

I'm sure most of us know already the laws from the FAA. I just want to give a different perspective. Over here there is a clear distinction between a "drone" and a "model airplane". This distinction mostly comes up when there is FPV involved. In case of a drone, there needs to be some sort of registration/clearance otherwise if flown for recreational use then there is no need for any such registration (provided everything is within limits eg. weights, heights, flyzones, etc)

sanjayrai55

UIN to be affixed by the importer/seller/manufacturer? Read LHS

Sent from my Mi 4i using Tapatalk

Dharmik

It's better than nothing but in my opinion 250grams is too low. nowadays only frame weight will reach to 250.

santanucus

Quote from: sanjayrai55 on May 02, 2016, 07:13:27 PM
UIN to be affixed by the importer/seller/manufacturer? Read LHS

That's not mentioned. It simply says "All unmanned aircraft intended to be operated in India will require an Unique
Identification Number (UIN) issued from DGCA"

It is operator specific as clearly seen from 4.2. So end users and not importer/seller is required to apply for UIN. Also if manufacturer is same as operator, like hobbyists, then he is required to apply for UIN.

The requirements in section 4.2 is sure to cause difficulties for end users. This will make it impossible to fly if these requirements stay in the final version.

- applying to DGCA office
- getting police verification / character certificate report from police for each UA
- getting WPC clearance

sundaram


vibranthobbies

#165
Dear All,
Is this is acceptable to all ?

- Please exempt registration requirement for Model Aircraft weighing less than 2kg (Micro Category) for recreational purpose without payload and flying in uncontrolled airspace and clear of notified prohibited, restricted and danger areas as well as Temporary Segregated Areas (TSA) and Temporary Reserved Areas (TRA).
- Please modify the rule to permit online registration of Model Aircraft Pilot above 15 years and assign Unique Identification Number to them. The registered Model Aircraft Pilot shall be permitted to fly under the following conditions;
   - Model Aircraft weighing less than 20 kg (Mini Category) and for recreational purpose and without payload;
   - Flying shall be always under ceiling height of 400 Feet and 500 Meters of perimeter of radius 500mtrs VLOS (Edited as per Sundaram Sir)
   - Flying location shall be only in uncontrolled airspace and clear of notified prohibited, restricted and danger areas as well as Temporary Segregated Areas (TSA) and Temporary Reserved Areas (TRA). The flying location is confined to the premises of a local administration and ATS permitted field/clubs.
   - Model Aircraft Pilot Unique Identification Number shall be affixed on the model on Fire Proof material.
   - Model Aircraft not complying to the above conditions shall follow UIN Registration and other requirements as per the guidelines.

Let us not decide ourselves that they won't exempt 2kg.

@santanucus
- We are suggesting for Online Registration. If they are unable to make a online system, one time registration of pilot through offline system is also acceptable. Is it OK ?
- We have not given any documentation requirements for pilot registration. If they include police clearance requirement, we have to comply. Again, it is one time. Is it OK ?
- You have already permission from WPC for using 2.4 GHz TX/RX. You have to check for ETA from where you have bought the transmitter.


santanucus

@vibranthobbies...I'd check in details when I get back home. For now just one comment....is there any difference between the term "model aircraft" and UA? If these are the same, shouldn't we use their term? Otherwise another layer of confusion would be added.

sundaram

Model Aircraft is a UA without Payload used for Recreational Purposes. Refer Definitions.

laritiewsoh

In the Czech Republic, they use the following definition (roughly translated into English):

Unmanned aircraft (UA) aircraft is designed to operate without a pilot on board (which may be and usually is part of an unmanned system). In the context of the legislative framework of the Czech Republic for unmanned aircraft drones consider all models except for aircraft with a maximum take-off weight not exceeding 20 kg.

Unmanned Aerial System (UAS) is a system consisting of an unmanned aircraft, control station and any other elements necessary to enable the flight, such as communication links and devices for draining and return. Unmanned aircraft, control stations or devices for launch and return can be within the unmanned system more.

Model aircraft aircraft which is not capable of carrying humans on board, is used for competition, sport or recreational purposes, not equipped with any device allowing automatic flight to the desired point, and that, in the case of the free model is not remotely controlled otherwise than for the purpose of ending flight or, in the case of remote controlled model, for the duration of the flight via the transmitter directly controlled by the pilot in the visual sight.

While in Austria:

If the aircraft
- in a radius of more than 500 m or
- paid or business or
- for purposes other than for the sole purpose of the flight itself operated,

an operating license by Austro Control GmbH is necessary for it.

For the classification as unmanned aircraft, it is sufficient that one of these alternatives present. Therefore, once a camera is turned on to an aircraft and this is not the purpose of the flight itself serves (when images are saved / photos, videos, etc. are made) is an operating license required. This is regardless of whether the recordings private or commercial nature.

santanucus

@vibranthobbies....that's quite reasonable I guess.

Regarding the registration of pilot, I think it would be proper if the pilot applies to DGCA first and then DGCA itself forwards documents for police verification. This is similar to passport application. Person applies to passport dept. who forwards to police for verification.

But if the pilot concerned has to get a certificate from police first and then apply to DGCA, that would make it tough. So I think the whole process has to be made clear to DGCA.

Regarding WPC clearance, it is ok in respect of aircraft constructed by hobbyist. But what about RTFs? I think henceforth, every seller of RTF and Tx/Rx parts should mandatorily provide copy of WPC clearance to the end user/buyer and that should be incorporated in the rules. But what about aircrafts purchased earlier?

I did not understand this line: "The flying location is confined to the premises of a local administration and ATS permitted field/clubs." Do you mean that we cannot fly in places other than ones designated by the government? If its is meant so, then it is restrictive. We should be allowed to fly in any place except certain pre-designated locations and populated areas.

vibranthobbies

Hi,
I don't find anything regarding police verification in our comments.
Repeatedly, I am telling that let DGCA decides what is required for Pilot Registration.
How can we equate Police verification for passport to your hobby flying registration and ask DGCA to do the police verification ?

Regarding WPC, if they exempt UIN registration upto 2kg our problem is solved.

Regarding flying location, initially my suggestions was to establish "No fly Zones". But, based on suggestion by sundaram sir, i adopted the  the proposal for flying at nominated locations.

Alternatively, we have to also provide comments line by line to DGCA guidelines.

Kumaran

SK1701

Right now they haven't said anything about having to fly only at certain locations. We just need to remain clear of populated/ sensitive areas and airports. Why ask for more restriction then? I don't want to have to travel to a flying field outside the city every time I want to fly. And also, all these proposals are asking for 500m VLOS. What happens to FPV/ long range flying then?

santanucus

#172
Exactly. We shouldn't suggest more restrictions than DGCA already has done. Why suggest that flying may be done in specified locations when there are thousands of locations with no people, away from airports, away from any sensitive area. Safety precautions may be suggested ... but specified areas? India is a big country and we can fly only in a limited number of areas? Not agreed ! I don't think any other country has got such rules. If someone in a village want to fly there, will he be forced to violate the rules? We should be practical.

DGCA will of course decide what it takes for pilot registration. That does not mean that they are not open to suggestion. Else they would not have sought comments.  Whether they would accept our suggestions is their prerogative. But if we don't suggest, they won't understand the issues.

So, regarding police verification, I am sure DGCA will definitely have a registration cell for handling these things. DGCA will simply forward the letter to police to request police verification. On getting reply from police they will grant licence. That's all. We will pay application fee to DGCA and all expenses will be covered by that. Not having anything in our reply on the process of police verification will be a blunder.



santanucus

Regarding FPV, I think we need to pay special attention to this upcoming sport. FPV in India will be destroyed in the bud if they make it too restrictive. FPV will give a quantum boost to this hobby. So we should give special attention to this issue and suggest accordingly.

vibranthobbies

Noted.
Hope you all agree to some common points;
1. Exemption upto 2 kg for recreational purpose
2. Pilot registration upto 20 kg for recreational purpose
3. Height upto 400 feet.

You can include additional suggestions to DGCA as you wish.

Kumaran