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

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

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Himadri Roy

From the post on the FB group of AMAI its clear that they have no interest in the FPV aspect of the this hobby. Also intend is quite clear that they want us to be sidelined so that hey are protected. Laxman sir says we'll talk in the future about this? But why? When the time is here why you want to wait? I have no problem with AMAI or the things they are doing, but why are they trying to safe guard their own interest by trampling over other's?
Here is the link to the draft Laxman Sir has proposed
https://www.facebook.com/groups/368147636684009/
For once you have tasted flight you will walk the earth with eyes skywards for there you have been and there you will long to return
- Leonardo Da Vinci

https://www.youtube.com/himadrifpv

santanucus

#201
Quote from: mateen270 on May 18, 2016, 07:36:24 PM
Why mention point 6 in your letter when Dgca has not mentioned anything about cameras? please don't ruin it for others when dgca is not currently concerned about it other points seem fine.

Sorry .. that was a slip of tongue...er computer keys. I shouldn't have written it. It was written in a previous letter and I copied it. Forgot to omit that part. Hope that DGCA does not give it too much notice :(

Anyway I mentioned camera in the passing. Did not write too much on it which would make it too much noticeable.

But what about the AMAI draft ! Its a total piece of sh*t. Sorry for the language but I am totally totally opposed to it and will write directly that AMAI does not serve our interest or interest of most of the recreational fliers. I am going to write another letter opposing it and will pursue it till the end to see that such points are not accepted. Those who are opposed to the AMAI stand please join hands. I have never seen a more self-centred letter than this one

mateen270

Quote from: mateen270 on May 18, 2016, 07:36:24 PM

b]But what about the AMAI draft ! Its a total piece of sh*t. Sorry for the language but I am totally totally opposed to it and will write directly that AMAI does not serve our interest or interest of most of the recreational fliers.[/b]

Totally agreed! From the looks of it AMAI is just looking to make money by getting more members to register with them!
AMAI Draft - 9. Mandatory for all recreational pilots to be registered with an Aeromodelling club or to participate as a participant from his college or institution.

This is really upsetting!

santanucus

#203
Quote from: mateen270 on May 18, 2016, 09:10:11 PM

Totally agreed! From the looks of it AMAI is just looking to make money by getting more members to register with them!
AMAI Draft - 9. Mandatory for all recreational pilots to be registered with an Aeromodelling club or to participate as a participant from his college or institution.

This is really upsetting!

Corrupt people ...just intend to make money. We should oppose this vehemently. Preparing a draft opposing AMAI. The government should not allow a corrupt private interest group to dictate flying in India. We should write a letter specifically opposing the attempt of a private group of people to control recreational flying in India.

I am also going to file and RTI to know from DGCA whether they can allow any private body to dictate recreational flying. In any case any such effort will not stand the scrutiny of law. Any attempt to do so by DGCA will attract legal actions.

mateen270

I am just gonna go ahead with your draft removing the fpv / camera part from it.

santanucus

Quote from: mateen270 on May 18, 2016, 09:18:09 PM
I am just gonna go ahead with your draft removing the fpv / camera part from it.

That would be fine. I am preparing another draft specifically opposing the AMAI points. Going to issue RTI too.

Just in case anybody needs my draft in MS Word format, here it is: https://drive.google.com/open?id=0B6UgXTZBN0sCYXJhRWhuWElOZHM

flyingboxcar

Guys May I suggest you read up and understand what is being presented?
I do not see anything wrong with registering with "An Aeromodelling Club" or "Educational institution".
Please note that they are not forcing you to join "AMAI" or "a particular club".
Once you are part of an institution/Organization you have follow the set of rules. And that is what is being recommended that instead of DGCA laying down the rules we can manage with community (read club/educational institute) based rules.  This will ensure two things
1. That we have least amount of caveats and rules laid down by DGCA
2. That the fringe elements who follow no rules do not spoil the hobby.
   
If you are really into scale you should be here. www.rcscalebuilder.com

santanucus

Why should we join an aeromodelling club and pay money to them? There is no such rule anywhere else in the world. Not even in USA from where DGCA has borrowed significant part of the rules.

There are a number of objectionable parts in their drafts.

Notifying police everytime one flies. Is this any sane recommendation?

allthatido

If they want to safeguard pure aeromodellers, they can definitely do that but not by putting others in bad light.


Santanucus, I will use your last posted comments in doc and send a mail today. Thanks for drafting the document. Very well done.

mateen270

Quote from: flyingboxcar on May 18, 2016, 09:42:03 PM
I do not see anything wrong with registering with "An Aeromodelling Club" or "Educational institution".
Please note that they are not forcing you to join "AMAI" or "a particular club".
   

Why pay AMAI? I rather pay the government to for registering since they are the ones creating the rules. The guidelines AMAI has suggested are against automated flying and fpv which personally I feel is rather irrelevant and they should not have mentioned it. They should be looking after everyones interest.

flyingboxcar

Santanu
Do research and read up, there is a requirement in US to be registered with local AMA club and fly at club's field, else you are pretty much on your own in respect to every thing else starting from insurance to ending with brush with the law. And penalties and liabilities are quite hefty if you know in US whether for damage to property or breaking the law :).

However the document AMAI has put up on FB is not a comment/suggestion on the DGCA draft. It can at best be called as an appeal for exemption. Do not know if it will be taken cognizance while finalizing the guidelines    
If you are really into scale you should be here. www.rcscalebuilder.com

flyingboxcar

Guys
That is where the problem is. Neither are you reading what is there in AMAI document, nor are you reading what the other person is writing. Do so please before making use of the omnipresent and oh! so easy to use keyboard and and a computer   
If you are really into scale you should be here. www.rcscalebuilder.com

santanucus

I checked the AMAI draft before posting and understand exactly what their intention is.

Anyway, the rule in USA is pretty simple. Register online or else. There might be provisions for clubs but as I understand from my friends who stay in US, majority of people who fly are not attached with any club. Most are casual fliers and don't have time to get attached with clubs. Insurance is available and the premiums are not too much. So "on your own" in US is not as terrible as it sounds

mateen270

Quote from: flyingboxcar on May 18, 2016, 10:05:28 PM
Guys
That is where the problem is. Neither are you reading what is there in AMAI document, nor are you reading what the other person is writing. Do so please before making use of the omnipresent and oh! so easy to use keyboard and and a computer  
tell me what this means?

Exemptions for Recreational Flying / Hobby by AMAI

6. Payload – camera and recording equipment or any other payload onboard of a Model Aircraft while conduction recreational / hobby flying is not permitted.
10. The place, date, and time of operations to be notified to local police in advance, and the notification will be responsibility of the club / institutions.
11. Autonomous flying not permitted, the model Aircraft will not have any sensors / GPS / RTL / or other equipments that lets the model fly without control inputs from the pilot. The free flights Model Aircrafts do not have any radio control. Any device to prevent the model from crashing in case of battery or RF link failure is permitted.

These are the points I am personally against. When AMAI puts something on their page and asks people to send it. People are going to do so without reading the people here who have really noticed the flaws of what they have suggested and are trying to stop people from blindly copy/pasting. and also tell me. why mention the specific use for camera when it has not even been mentioned in the DGCA draft?

santanucus

#214
From AMAI Draft... at https://www.facebook.com/groups/368147636684009/

Point 6. Payload – camera and recording equipment or any other payload onboard of a Model Aircraft while conduction recreational / hobby flying is not permitted.

Not acceptable. When the DGCA draft does not directly mention anything about this, why should anyone write this on their own? (I made the same mistake...it was not deliberate and the issue was not mentioned in details in my letter (just mentioned camera in passing) and of course, I don't ask anyone to blindly copy what I have written..unlike AMAI)

7. Hours of operation only between sunrise and sunset

Don't see any point in writing this point when the DGCA draft does not mention anything on it.

8. Met conditions for operations – min. Visibility of 3000 Meters and wind speed of 20 knots. Ceiling not lower than 500ft

Why do I need such met conditions when I want to fly for, say only 100 metres away? Also what is the point? Is this enforceable? Who is going to measure met conditions which change so often? AMAI has confused between dos and don'ts / guidelines with rules.

9. Mandatory for all recreational pilots to be registered with an Aeromodelling club or to participate as a

Discussed this already. Not at all agreed. How many such clubs are there in India? What does a person in a rural area or a small town do? Why should we mandatorily pay private clubs for flying? Will this rule  stand if challenged in court?

10. The place, date, and time of operations to be notified to local police in advance, and the notification will be responsibility of the club / institutions.

Don't want to even comment on how absurd this rule is! You want to fly in a rural area in a vast open field. You call your city club. They phone and inform the constable in your local police station. Or else, you have to fly in a field designated by your club.  :banghead:

And if something happens, police will say we don't have any letter from anyone. So clubs will need to write letters to the PS everytime you fly. This is a good joke  :bow:

11. Autonomous flying not permitted, the model Aircraft will not have any sensors / GPS / RTL / or other

The DGCA draft says GPS and RTH is required and these people say "not permitted". What to say...I am stunned.

The letter is also badly drafted and does not touch upon most of the contentious points. But I should not teach anybody on that. Still it seems to me that they had drafted what they had planned to say irrespective of whether it is there in the DGCA circular or not.

I don't know what kind of members AMAI have. If their members blindly forward such an absurd letter just because someone has drafted it, God help them. But be sure, I will write to DGCA and file RTI against any such attempt to monopolize flying rights. The letter may sound absurd to many of us but its not. Unless we take such attempts seriously, our hobby will be the fiefdom of a select group of people.

SK1701

Thank you for the detailed letter Santanu. I used it as a base for my own letter, which I have attached below. I added several points regarding FPV and also added a paragraph at the end condemning the AMAI letter. Let me know if anyone has any inputs or suggestions. If not, I will email it to the DGCA today itself.

Here is the document in Word format in case anyone needs it- https://drive.google.com/file/d/0B6XjbwXPI1coRGhfcHlmMS1JS0U/view?usp=sharing

sundaram

Why go to such length to expose the divide amongst us. Just add a line in AMAI draft to include online registration of Recreational use Model Aircraft up to 30kgs with payload like camera Autopilot GPS purely for recreational purposes and innovations intended to be flown below 500ft away from restricted and sensitive areas without infringing anyones privacy or property. On the similar lines of FAA. Modalities of content of online form is not difficult to compile.

Even you fly in a village you can't escape from registering your self with club or DGCA. No longer you will be able to follow hobby in hiding.

Sent from my GT-N7100 using Tapatalk

manojswizera

Quote from: santanucus on May 18, 2016, 10:44:54 PM
From AMAI Draft... at https://www.facebook.com/groups/368147636684009/

Point 6. Payload – camera and recording equipment or any other payload onboard of a Model Aircraft while conduction recreational / hobby flying is not permitted.

Not acceptable. When the DGCA draft does not directly mention anything about this, why should anyone write this on their own? (I made the same mistake...it was not deliberate and the issue was not mentioned in details in my letter (just mentioned camera in passing) and of course, I don't ask anyone to blindly copy what I have written..unlike AMAI)

7. Hours of operation only between sunrise and sunset

Don't see any point in writing this point when the DGCA draft does not mention anything on it.

8. Met conditions for operations – min. Visibility of 3000 Meters and wind speed of 20 knots. Ceiling not lower than 500ft

Why do I need such met conditions when I want to fly for, say only 100 metres away? Also what is the point? Is this enforceable? Who is going to measure met conditions which change so often? AMAI has confused between dos and don'ts / guidelines with rules.

9. Mandatory for all recreational pilots to be registered with an Aeromodelling club or to participate as a

Discussed this already. Not at all agreed. How many such clubs are there in India? What does a person in a rural area or a small town do? Why should we mandatorily pay private clubs for flying? Will this rule  stand if challenged in court?

10. The place, date, and time of operations to be notified to local police in advance, and the notification will be responsibility of the club / institutions.

Don't want to even comment on how absurd this rule is! You want to fly in a rural area in a vast open field. You call your city club. They phone and inform the constable in your local police station. Or else, you have to fly in a field designated by your club.  :banghead:

And if something happens, police will say we don't have any letter from anyone. So clubs will need to write letters to the PS everytime you fly. This is a good joke  :bow:

11. Autonomous flying not permitted, the model Aircraft will not have any sensors / GPS / RTL / or other

The DGCA draft says GPS and RTH is required and these people say "not permitted". What to say...I am stunned.

The letter is also badly drafted and does not touch upon most of the contentious points. But I should not teach anybody on that. Still it seems to me that they had drafted what they had planned to say irrespective of whether it is there in the DGCA circular or not.

I don't know what kind of members AMAI have. If their members blindly forward such an absurd letter just because someone has drafted it, God help them. But be sure, I will write to DGCA and file RTI against any such attempt to monopolize flying rights. The letter may sound absurd to many of us but its not. Unless we take such attempts seriously, our hobby will be the fiefdom of a select group of people.

Agreed with 'santanucus ' 
Russ-40 Trainer, Mr.moss, Pushler, Skysurfer, Mugi , F-22, Red swan, Xtra-300, redfury, flying mantaray.

pravesh736

Amai is not willing to remove 2 lines from their draft which mentions ban on camera, autopilot etc, let alone adding what you suggested (we hope for same)
We are hoping no one has to pursue this hobby in hiding in villages that is why we need to voice our needs like requesting pilot registration along the faa lines instead of having to join a non government body which has different focus so far.

satyagupta

The suggestions that have been put into by AMAI is full of bu****it and crap. They are trying to save something which they are interested into. And yes they are trying to kill multirotors, no FPV no AUTOPILOT??? aren't the main reason why we or many flyers here use multirotors??

I AM SHOUTING A BIG VERY BIG SHOUT TO AMAI and big big big thumbs down.
one stop for multirotor needs:
www.quadkopters.com

http://www.facebook.com/QuadKopters
https://www.youtube.com/user/QuadKopters
https://www.instagram.com/quadkopters

mateen270

Totally agreed. If only AMAI had paid more attention to the needs of others and not just themselves.
A very selfish move from AMAI.

sundaram

#221
Guys no need to complicate the issue at this juncture when dealing with an Govt Authority. We should not expose out weakness of divide among st us.

AMAI is not Institutionalizing AMAI as the only aeromodelling Club. Its just any aeromodelling club. As such majority among-st us are already organised under our own Regional Banner and Clubs. You will surely agree with me that pursuing this hobby as a community of Clubs always gives it more credence as a responsible activity by group of law abiding citizens. No one would like to pursue this in a hiding. its only those who have a ulterior motive would like to saddle back on under the guise of a hobby fora.

Yes AMAI has its own immediate interest of protecting just the Model flying hobby to that end they are interested in taking out a base guideline prompto. we can develop and modify from there once you get a recognition that's the thinking of AMAI.

Not withstanding the above I have modified and sent the AMAI draft as under including guidelines for Model Aircraft with Payload of a Camera purely for recreational flying. Further I have a word to word amendment of the original DGCA draft to include all the above which is still under improvement which I will be sending in due course of time.


Sub :- Guidelines for Obtaining Unique Identification Number (UIN) & Operation of Civil Unmanned    
            Aircraft System ( UAS)

Sir,
I am a Serving Army Officer who has been pursuing the passion of recreational flying in Model Aircraft Aviation along with my Son of Age 14 years for almost six years now with a hope that he will develop interest in a career in Indian Airforce or Commercial Manned Aviation Industry in future or just follow this hobby as a constructive outlet and to develop a creative passion in our personality development.

In reference to your Air Transport Circular XX of 2016 I highly appreciate the concern of DGCA not only in formulating the guidelines but to regulate this sport also. The draft contains all the regulations as required for regulating any sport, however this draft seems to have drafted with more emphasis on commercial flying and less of recreational flying. I would like to bring to your notice the presence of Large Community of Model Aircraft enthusiast in our country who has been safely practicing this beautiful hobby since ages.  Like how DGCA is interested in keeping tabs on all the UAS activity and the parties interested in pursuing this field for recreational as well as for commercial purposes, we also as part of Hobby community would like to proudly proclaim our presence to the authorities concerned and claim to fame in this hobby by loudly declaring our identity and presence and continue to pursue this hobby without being a nuisance to others and without the risk of this beautiful hobby being marginalized into the category of criminal activity.

In this modern internet age of computerization and IT networking it is very easy to compile and track credentials of the willing participant. Rather than making the entire process unfriendly for the willing common man who wish to comply to be on the right side of law,   it is urged that modern methods of online registration to be put in place on the similar lines of FAA for the common recreational flier who is equally interested in just safely pursuing this passion/hobby without being nuisance to anyone or infringing any property. I would like to take this opportunity to suggest some amendments for Model Aircraft for recreational flying.  These suggestions if accepted would help everyone, including children, new comers as well as hobbyists.

Guidelines for Model Aircraft Recreational Flying / Hobby
1. Aim – to learn aerodynamics, theory of flight, research in field of aviation and flying maneuvers to participate in competitions or to undertake as a hobby, Promote Education /Research and To inculcate air mindedness and career interest in the field of manned aviation amongst the youth of tomorrow.
2. Age – no limit. **Age under 13 to pursue Recreational Model Aircraft flying under strict Adult Supervision/ Trained Adult Model Aircraft Pilot.
3. Type of model aircraft – single / multi- rotor or fixed wing of any dimension
4. Max weight – up to 30 kilos
5. Flying envelope – within visual range of pilot flying and within the confines of the area permitted for carrying out such exercise. Vertical limit up to max 500ft AGL
6. Hours of operation only between sunrise and sunset
7. Met conditions for operations – min. Visibility of 3000 Meters and wind speed of 20 knots. Ceiling not lower than 500ft
8. Mandatory for all recreational pilots to be registered with any Aeromodelling club or to participate as a participant from his college or institution. However, no requirement of UIN or UAOP for recreational flying by DGCA. All club / institutions will be responsible for issuing registration NO to their members to be displayed on their model aircrafts. All Aeromodelling Clubs will maintain following documentation.
(a)   Monthly Summary of Registered Model Aircraft Pilots with the club to be submitted to DGCA with addition and deletion to the club memberships.
(b)   Daily Flight log of all Model Aircraft Pilots flying in the permitted space to be maintained.
(c)   Strict Radio Frequency control in the Flying field to be maintained to prevent interference and accidents.
(d)   Regular Internal Audit of Training standards of the pilots in the Club and their classifications.
(e)   Strict Audit and Control on flight safety and safe flying practices of the Model Aircraft Pilots in the permitted flying field.

9. The place, date, and time of operations to be notified to local police in advance, and the notification will be responsibility of the club / institutions.
10. Not to be conducted over restricted, prohibited, danger areas, military cantonments, security installations and protected monuments as notified from time to time.
11. International operations across the territory over water shall be strictly prohibited & 50 Kms from the international borders.
12. No flying shall be permitted so as to be in conflict of safe conduct of operations in the vicinity including approach paths and departure paths of operational airports, except when authorized. Any violations of this rule will attract severest of punishments including but not limited to imprisonment.
13. Any kind of powered or unpowered model aircrafts can be used for recreational flying.
14. Use of only de-licensed frequency band as notified by WPC from time to time.
15. Dropping of any kind while performing recreational flying is strictly prohibited.
16. Import of model aircrafts, their spares, parts and accessories, by individuals / clubs / institutions / body, should be permitted without any restrictions or conditions of approval from DGCA, in accordance to the Import Trade Control policies as existing or maybe modified time to time.
17. Autonomous flying not permitted for the model Aircraft with only registration numbers of Aeromodelling Clubs and as such will not have any Cameras/Payload/Sensors / GPS / RTL / or other equipments that lets the model fly without control inputs from the pilot. The free flights Model Aircrafts do not have any radio control. Any device to prevent the model from crashing in case of battery or RF link failure is permitted.
18.  All Model Aircraft enthusiasts who wish to pursue purely Recreational flying of Model Aircraft under 25 KGs with a payload of a camera and Command and Control Autopilot flying within the confines of the permitted flying field/ away from restricted airspace and sensitive areas without infringing privacy or property, purely for the purpose of recreational flying under 400ft AGL, within the VLOS of a Spotter, involving RC sports/hobby flying activity, innovation projects, recreational photography has to Log in DGCA Portal and register their Recreational Pilot Credentials and Details of the Model Aircraft for obtaining UIN for display on the Model Aircraft on case to case basis.
(a)   Such Model Aircraft will have flight controllers and Autopilots with Sensors for flight stabilization.
(b)   For all such Model Aircraft above 500gms, It's Mandatory to have a GPS, a RTL feature, and Virtual Fence feature enabled to perform a Command and Control Auto Pilot flight and return to home.
(c)   Under no circumstances such Model aircraft of any weight category will be flown over property, public, restricted airspace.
(d)   No such UIN requirement for such Model Aircraft for such recreational flying with camera payload under 250gms.


**Considering recreational flying I Personally request DGCA to kindly consider the suggestions, these suggestions if accepted would help the young ones to understand aviation much better and will help in developing the young RC pilots to match with International RC pilots standards.


PS : Its Mandatory for even the Last Bastion of Security of this Country when it proceeds for Training firing in its own feild firing ranges away from any civilization to give an intimation of training firing activity to the local Police before commencing the firing activity.


SK1701

Sundaram Sir, I will have to respectfully disagree with several of the points you have made. As far I as I know we do not have any organised clubs in Bangalore. If there is any, I have definitely not seen any traces of it. What about other pilots in small towns or cities where there are no clubs? Repeating what myself and others have said here earlier, why are we asking for more complicated regulations then what the DGCA wants? DGCA never mentioned anything about " Hours of operation only between sunrise and sunset", Met conditions, "Daily Flight log of all Model Aircraft Pilots flying in the permitted space to be maintained" etc. So why are we asking for further regulation?

Then there is this point - "The place, date, and time of operations to be notified to local police in advance, and the notification will be responsibility of the club / institutions." Will we have to notify the authorities every time we fly even if it is in a location far outside the city limits and away from inhabited areas? What if there is no club/ institution in charge of the flying location? Why not treat this as a courtesy for those flying near populated areas rather than a mandatory requirement? Why are we again asking for a special, extra complicated procedure for FPV/ autonomous flying when the DGCA hasn't mentioned it themselves? Also, making GPS/ geofencing/ RTL compulsory on all camera-equipped aircraft is again ignoring FPV racers who do not use such equipment.

To the AMAI, I just want to say this. This is a turning point for the hobby in India. FPV, and FPV racing is the future of this hobby. You can choose to support and accept us, remain relevant and connect with a new generation of aeromodellers. Or you can choose to ignore us and we will go on without you. FPV and FPV racing we grow whether or not you choose to support it.  All I am asking is that you do not try to hurt our cause just because you are not involved in multirotors/ FPV. I do not understand how removing those 2 lines on FPV/ autopilots from your letter hurts your cause in any way, but their presence there definitely hurts us.

aniket210696

I don't understand why can we just not have a simple flying registration setup:

No need of registration for:-
All LOS
FPV on sub 500gm models.
Recreational activity of above

Pilot Registration required for:
aircraft flying fpv and weigh fpv and weight greater than 500gm
Commercial activities such as photography.
Import license for hobby stores

And yes. Pilot license. Not model license. Simple!
As for rules :
Fly in open area, away from people etc
Don't fly near defense establishments
Altitude restriction of 400 ft

Anything else, and you will start killing the hobby. For eg: flying only during daytime kills the fun of flying with LEDS.



.

sundaram

@ SK1701

This hobby has always been flourishing safely purely on the self discipline of the individual fliers and a self imposed restraint and safe flying habits of responsible enthusiasts.

Its purely because of the so called FPV fliers and their so called reckless free for all flying habits this entire scare scenario projection has now been blown out of proportion. Model Aircraft Fliers have always had their self imposed restrictions and safe flying habits limited to their minuscule VLOS limits of just few hundred meters.  

If we are interested in not getting this hobby getting marginalized into the category of Criminal Activity, for our own good health please group together in your own regional banners and intimate the authorities of your activities. If you are not ready to abide by these and walk the extra mile no one is going to give you free hand on any kind of free for all flying. I have just thought over it four steps ahead and dictated myself self imposed restriction to be safe while being at it before its is imposed on me.

Read my draft again. Its absolutely more pertinent for the FPV fliers to be organised to a more formal and responsible in this activity. Ideally as for as authorities are concerned they would be interested in UIN and UAOP for every flight. Who cares for your sports or fooling around. Security of National Airspace takes more precedence.

Its for you to walk the extra mile to get the recognition and participate with the recognition. If not its just too dam ease to put you behind and charge under legislation's.