I would also like to know if AMAI is doing anything in this regard. We should prepare a response and would be more than willing to sign and send.

My wish
1. Exempt UA less than 250 gram from Registration. This is similar to FAA Rules. Imagine registering Cx10 and small toy helis with DGCA.
2. Provide a simple online registration form for UAs less than 20kg (Mini & Micro) and used for recreational purpose in uncontrolled airspace. Registration number along with basic information of model with photo of the person and model can be printed and carried in hand while flying. Of course we will install Registration number on the model.

It is to be noted that a person who intend to cause damage is not going to get UIN or pilot license which is not realised by DGCA. Instead they are simply harassing common man who is either going to quit the hobby or going to try religiously to comply to these rules without success.

DGCA shall establish No fly Zones in cooperation with State Govt. and local security agencies and local govt agencies shall install suitable warning symbols in these areas. Public shall be made aware about these No fly Zones and to report any flying activities in these no fly zones. This way there is a possibility to stop a  malicious attempt by local police when they receive message from public.

I am preparing my comments line by line will share.

Kumaran

Guys as far as commercial use of UAS is concerned the guidelines are almost perfect by the book drafting with one exception, aspect that there has been no consideration for those who have assembled their own platforms and using it today. I am highlighting this because when it comes to the question of  flight worthiness it is a big merry go around when dealing with any  Civil Aviation Authority.

I am too drafting para by para inclusions required in the draft to include hobby/recreational/Sports RC pilots interest too. This I am too forwarding in personal capacity in Demi Official Position. Give me time till monday. Will post para by para amendment required to guard our interest and will be sharing in all Fora of Hobby Community.

Someone can start a Change.org petition too on that to express our consolidation on those aspects. Similarly all can send similar recommendation from all quarter's.

Kumaran you jumpèd the gun buddy while I was typing. Yours are valid points already in mind to be included. Yes lets work on it. Compare notes by weekend and consolidate response.

Quote from: vibranthobbies on April 27, 2016, 12:08:41 AM
My wish
1. Exempt UA less than 250 gram from Registration. This is similar to FAA Rules. Imagine registering Cx10 and small toy helis with DGCA.
2. Provide a simple online registration form for UAs less than 20kg (Mini & Micro) and used for recreational purpose in uncontrolled airspace. Registration number along with basic information of model with photo of the person and model can be printed and carried in hand while flying. Of course we will install Registration number on the model.

I think we should demand upto 1 Kg/2Kg for exemption. If you ask for 2 Kg. they'd probably give exemption upto 500 gms

If there is option for online self-registration (say AADHAR based, which will identify the person) then there is no problem in registering. The main thorny issue in respect of registration are

- police verification / character certificate
- WPC certification

If these two clauses remain, then flying legally would be virtually impossible.

- Also this fireproof number plate is likely to increase weight in mini quads e.g. for FPV
- The issue of 200ft altitude also has to be taken up. It should be made 400ft

If these issues are taken care of then we'd be able to fly legally.

When I sent a letter to DGCA earlier, I included a proposal for online self registration. Unfortunately there is nothing of that sort in this draft circular. If they had considered AADHAR based online registration then police verification would not have been required. Here's a quote from that part of the letter

Quote
Proposal for Online Self-Registration System for recreational users of UAV using e-Governance

-   A web portal may be created for self-registration of UAV fliers and their UAVs
-   Flyers can be citizens of India or International tourists and can self-register themselves online. This will be a one-time registration
-   Domestic flyers may be identified and linked with Aadhar Card Number or Election Identity Card number
-   International flyers may be identified and linked with their passport numbers
-   Once the person self-registers himself/herself online, he/she can register one or more UAVs flown by him/her
-   Photos, weight and other capabilities of the UAV e.g camera, FPV, telemetry etc. and similar details can be uploaded by the user himself/herself
-   After entering details of UAV, a printout of UAV identification number can be generated from the system and pasted on the UAV itself
-   Places where they are likely to fly can be entered online by the user himself. For example, if someone wants to fly in Goa, he/she will enter the time and dates and locations online. Flying locations can be indicated out on a Google Map mashup at the site or just mentioned.
-   The map can also automatically display restricted areas where flying should not be done. Time based restricted areas can also be shown e.g. around Red Fort area on August 15
-   After the user registers the location to fly (which can be a date or a range of dates) he/she can generate a printout, which he should carry with himself at the time of flying. Authorities can also ask for the slip anytime from the flier

Agree.

Dear All,
It is preferable that we all create unique responses instead of duplicating.
However, we will discuss and agree to some common points to be highlighted using our own words.

Some of the common points in my mind;
Sundaram sir rightly said that the draft is perfect for Commercial drones. Hence, I use the term Model Aircraft hereafter instead of UA.

1. Exempt Model Aircraft less than 1 KG from Registration.
2. Provide a simple online registration form for Model Aircraft less than 20kg (Mini & Micro).
3. Revise Height limit upto 400feet.
4. No WPC involvement since frequencies like 2.4ghz/5.8Ghz used by us are already exempted by WPC from licensing requirement. Further, ETA and Import license for TX/RX are already obtained by the Seller and it is not possible to obtain by Modeller.
5. Exemption for RTH, SIM, GPS etc.
6. No police verification. However, while flying police can verify for availability of registration.
7. Allow FPV Flying with standby spotter.

Deleted. Wrong post.

Agree to all the points. I too think that sending separate letters broadly covering all the points will be helpful. Those who send letters can post their drafts here for others to see.

Before using the term "model aircraft" we need to clarify what exactly we mean by that. There are drones, helis and all sorts of things. How they differ from UA should be explained clearly else babus who deal with the matter will again raise issues with that.

The term "recreational use", "hobby" and "non-commercial" use should be emphasized.

The definition in the guideline says
Model Aircraft - Unmanned  Aircraft  (UA)  without  payload  used  for recreational purposes only.

Google search on aircraft results
"an airplane, helicopter, or other machine capable of flight."

This was the first thing i verified when i started reading the guidelines.
So, I think no more confusion.

Edit : If required, we can suggest to include the same under definitions.

That's good. So in the letter the terminology should be clarified to them at the beginning and request then to clearly differentiate between the two.

But one point...what about a camera? Camera is also a payload but its used in FPV and recreational flying too. Won't mentioning the issue of payload bring into focus the issue of camera?

By the way, I am not suggesting any reference be made in our letters on camera and photography. I think they have not included any reference on aerial photography in this draft. So we should not raise this matter at all. Otherwise yet another troublesome issue will crop up

Hi,

Definition in the guildlines is clearly mentioned. These definition have been largely taken from RPAS Regulations that have been ratified in 2015.

Lets not suggest to lower weight to DGCA as all over the world its 55LBS or 20KGS (note that even a 46 size trainer goes above 2 kgs or a 50size heli goes over 2 kgs). That is too mentioned by DGCA by categorising under Micro & Mini.

We need to ensure that DGCA clarifies in clear terms that these two catagories do not need any regulation when flown for recreational purpose, when flown below a particular height (400ft in the US/Europe), when flown away from buildings,people,stratergic locations etc and when flown within line of site.

As per the international body ratification UAS systems will not be exempted largely, so think dgca will go forward in that direction.

All definitions are already mentioned in different regulations in many countries.

Please do not use the word Drone - thats the problem creator.

Please lets emphasis on recreational or hobby purpose.

We have enough trouble with clearance from WPC we don't need another 2 licencing agencies. So we need to impress upon them to leave out our hobby from the gambit of it by clearly mentioning that.

Lets not suggest to them that the height or weight needs to be monitored if they do then we are doomed.

Quote from: sundaram on April 26, 2016, 01:09:15 PM
Ref Para 2 Definitions Its very sad that though there is definition for Model Aircraft as an UA without payload the category of fliers (aeromodelling remote pilots) and their activity of Hobby flying activities has been completely left out in the parameters and considerations while drafting guidelines and definitions and all remote pilots have been grouped under one category.

Ref Para 4.1 Its ridiculously Impractical to even think that DGCA is contemplating issue of UIN to all Hobby pilots ( Ref Para 4.2 which is a Blasphemy for all Hobbyist) and their complete hanger of Model Aircraft's all across India. I would be damned if they are at-least capable and in a position to even manage just the commercial UAS operations across India ( They just don't have the ground presence, if they are planing to depend on the local cops who has a vision capability just to see and locate MA just 100mtrs out and 100ft above, Local Cop is only going to harass the hobbist and the few unaware DJI junkies) The Real UAS fliers (The capable systems) and the real threat are still going to be way out of the reach and radar of DGCA.

Agree UIN no for recreational flying is a total no no......

Quote from: sundaram on April 26, 2016, 01:09:15 PM
If they had copied FAA or any other civil aviation auth they should have at least copied 400ft ceiling like FAA which was very much warranted.

Totally agree 400ft should be allowed

Quote from: sundaram on April 26, 2016, 01:09:15 PM
By stipulating UIN for all and UIN only for Indians They have killed the sport of RC flying by banning all foreign RC Pilots to India for all the prestigious meets like Ambby valley and AMAI. Let alone no consideration for the upcoming drone racing FPV Sports.

Agree, We need to clarify that if one is from a member country and flying Model Aircrafts for recreational purpose/sport or hobby then they are allowed.

Quote from: sundaram on April 26, 2016, 01:09:15 PM
Ref Para 8 and 8.4 in conjunction with definition of Remote Pilots and Definition of Model Aircraft. By only exempting Micro under 2Kgs from requirements of Pilot trainings, Simple RC flying is too killed when today every modeler of repute can put together a RC Model Aircraft up to even 7-30 Kgs with Gas engines and turbines and when they fit in category beyond even mini and you fall under the category of certified pilots one who is expected to have taken a PPL training before operating these machines. Whereas the reality is thanks to the efficiency of muddling of DGCA and the Ilks Infrastructure for PPL training and Microlight Flying Scene is next to Non existent in India. Its ridiculous to think that there has been no consideration for kids under 18 like my son and his capability to fly and develop in this beautiful hobby.

We need them to clarify all models upto 20kgs should be exempted when flown with LOS and below say 400ft this very important.

Now 8.4. The above training requirements for remote pilots are not applicable for micro category UA & recreational flying. There by they mention that recreational flying does not need training requiremnts and also for UA

Quote from: sundaram on April 26, 2016, 01:09:15 PM
Upcoming FPV Competitions and FPV Racing sports are not part of Commercial Civil UAS operation with payload. These category of pilots and their systems too form part of Hobby fliers and UAS systems.

The guidelines will kill the open source development, student projects and participation in various international competition by students and others by having no category for them and clubbing their classification along with Commercial Civil UAS operation with payload.

let them permit FPV racing in a closed or limited space enviroment, anything else will not be permited.

Quote from: sundaram on April 26, 2016, 01:09:15 PM
The guideline reeks of pessimistic prejudice that Indian Firms and Indians just cannot fabricate their own Aircraft Models and UAS and they can only import their models. . If its all Import license and impost permits and WPC clearance for import where the Bloody hell is Make in India.

Classification parameters are largely biased towards muti-rottor models only seems they have not even considered fixed wing capabilities and parameters.

We donot have manufacturing largely that we need to agree, mostly its making a few air frames, so we need to ensure that any models or their parts/accessories are not restricted, otherwise we are doomed for sure.

One Very important thing DO NOT suggest them for lower weight classification then if the allow say 1kg then we can only fly small foamies even for an Easystar with a larger battery it tips close to 1kg.

Please note that they mention "Education Institutes and all flying within their premises also constitutes to recreational flying", so we need them to clarify that for recreational flying there is no age barrier and if below or under 14 year then under parential guidance or guidance under adult supervision is suggested.

Will list out more points soon.

Also kindly note that even industry bodies (like FICCI, ASSOCHAM etc) have given their inputs to DGCA, so we need to find out and write to the relevant people in FICCI etc too.

Quote from: vibranthobbies on April 27, 2016, 01:15:09 AM
1. Exempt Model Aircraft less than 1 KG from Registration.

I think its too less, there are few custom build models which easily goes more than 1KG what about them? get UIN?? and then if modeller decides to upgrade the model then? get new UIN?

We have to act fast on this

It has appeared in news paper today: http://www.mumbaimirror.com/mumbai/others/If-its-a-drone-you-need-a-permit-for-it/articleshow/52002360.cms

I want to know, who is going to take this suggestions ( that we are putting down here) to DGCA?
Do we have AMAI? if we do then what's their stand on this?
I am sure we have many other modeller association's can this thread brought to their notice? It would be a lot better to have more opinions than few?
If any RCI member can spread the news among fellow modeller it would really help.

This draft is non-sense and it would kill the hobby for sure. (multi,plane and heli) 

@ satyagupta,

Largely most of the serious aeromodellers have read the draft and discussing amongst their groups.

Many points are acceptable or been followed already.

Even TV channels have carried the news with interviews.....



Please note that mostly the multi is shown as Drones in all news channels.

Even AMAI has already given their inputs earlier is what i heard.... more will need to be done.

The guidelines is good for RTF models like DJI, since they come with manuals and specs from manufacturers. What about the custom builds? How would those be regulated?

I dont know whether if what i am going to say will be right or not, but what if <b>ALL The  LHS</b> provide a dedicated page for this particular thing.

What right points we should look out for.  (At this point of time we have no idea about whether if  groups like AMAI etc are working on this or not. But most of us follow LHS or RCIndia so spreading a word from these sources can be helpful and useful )

This will spread the awareness. Because not every body is familiar with all the terms. That Pdf may be too long for newbies like me(Really sorry for this fact). Who have just entered into this hobby . Who really want to participate like you all because of the love/passion for this hobby. But they may have no idea(or may be little idea).

(EXAMPLE as of now newbies like me may think 61m/200ft is enough. But it may not be. So if we get idea, THE REAL IDEA from the experienced people, Then it would greatly help in maintaining the comments/unity in comments)

I read a few points from the pdf draft, Then i read your conversation(and beleive me or not your conversation was much more easier to get into mind ) Hope you all understand....!!

And sorry if I said any thing wrong.

Regards
Sukhpreet Singh

I think Kumaran ji did mentioned about doing this and i would too on my store. But i think all the LHS should make modellers aware of the rules and how to fly safe and legally.

If getting a UIN is made easy process i think LHS might also guide users to get one to make it easy for them.

Quote from: vibranthobbies on April 27, 2016, 01:15:09 AM
Agree.

Dear All,
It is preferable that we all create unique responses instead of duplicating.
However, we will discuss and agree to some common points to be highlighted using our own words.

Some of the common points in my mind;
Sundaram sir rightly said that the draft is perfect for Commercial drones. Hence, I use the term Model Aircraft hereafter instead of UA.

1. Exempt Model Aircraft less than 1 KG from Registration.
2. Provide a simple online registration form for Model Aircraft less than 20kg (Mini & Micro).
3. Revise Height limit upto 400feet.
4. No WPC involvement since frequencies like 2.4ghz/5.8Ghz used by us are already exempted by WPC from licensing requirement. Further, ETA and Import license for TX/RX are already obtained by the Seller and it is not possible to obtain by Modeller.
5. Exemption for RTH, SIM, GPS etc.
6. No police verification. However, while flying police can verify for availability of registration.
7. Allow FPV Flying with standby spotter.

Adding to this
8. Exemption of giving license to fly to only Indians. This closes the door for international competitions(miniquad and flying wing fpv racing)
9.To have all the registrations online rather than indulging in paperwork. This would prevent hassles. Registration of pilots would be better(each pilot would be given a unique number that he/she could carry all the time while flying) than registering UAS.
10. Removing the age limit(everyone is equally capable of flying..)

Quote from: Himadri Roy on April 27, 2016, 11:59:11 AM
10. Removing the age limit(everyone is equally capable of flying..)

I dont agree to this, everyon is capable of driving still no drivers license for less than 18 yrs.

I think less than 18yrs old can fly but should have a licensed pilot along with them to supervise/guide

Quote from: satyagupta on April 27, 2016, 12:01:30 PM

Quote from: Himadri Roy on April 27, 2016, 11:59:11 AM
10. Removing the age limit(everyone is equally capable of flying..)

I dont agree to this, everyon is capable of driving still no drivers license for less than 18 yrs.

I think less than 18yrs old can fly but should have a licensed pilot along with them to supervise/guide

Completely agreed..but sir we we are trying to refer to the FAA model of registering then why should we ignore this? I don't think FAA has made any clause debarring ppl under the age of 18 from flying. Supervise/guidance is a good point.. There are many great young pilots out there..

People in India is not responsible hence they we have more road accidents.

You have to understand that, flying these are dangerous what if some one screws it? and it just destroys everything for others too. Then?

@Satya and Vibranthobbies,

Off late customs have been very strict with import of drone or quadcopter (however you want to call it)  parts. I have been regularly importing stuffs without any issues but now they impose restriction even for parts. Recently one of my parcel was held in Bangalore customs which had all 2212/13 - 1000kv, 1400kv and some emax motors  around 100 numbers in total and they said that it has been detained because it has parts of drone/quadcopter. I totally understand that import of UAV is restricted but are the parts too ?  Please advice.

Parts are not i am doing it, and one recently too.

@satyaji
We face problems with Bangalore & Chennai Air Customs for parts too and they say that these are for ---

Errr then it would start with others too...

I don't know what will happen to this hobby in India or this will propel indigenous manufacturing