Hi everyone,
I see that
1. Several senior members are trying to make a response that will be meaningful to DGCA
2. DGCA will probably only pay attention to responses in their format, and ignore freestyle comments.
3. So the most effective way may be to make a standard response, which can be copied and emailed to DGCA from at least a few hundred RCI members.

(Remember last time Santanucus' efforts actually elicited a response)

My 2cents worth is to separate hobbyists from commercial operators, like private and commercial driving licences.

Can we suggest to DGCA that hobbyists are different from commercial operators?
And that hobbyists can easily be monitored as suggested by me to DGCA in my email of 12th Oct 2014

1. DGCA could set up a website for flyers of remote controlled aircraft models to register on
2. Flyers of RC aircraft models can register by providing their name, ID, address, phone number, transmitter frequency and location of usual flying site, and get a registration number.
3. Flyers of non remote controlled models need not register.
4. Main restrictions can be:
- weight not to exceed 5kg
- no flight above 400 ft
- no flight within 5km of an ATC airport
- no flight over public or vehicles or houses. Rules for permission can be worked out.

The DGCA registration can be like a car numberplate. Flyers can proudly display on their models.

Anyone caught in suspicious circumstances can easily be identified as a bonafide hobbyist or not.

For many decades we were not allowed to photograph airports, something that is now allowed.
All aeromodellers are not necessarily enemies of the State!

Since I'm retired, I dont have any importance in the Govt.
May I suggest that a member who has the most 'paua' or credibility with DGCA/PMO lead the charge from RCI?

Agree with you Sir. As per the posts in this thread, most of us are thinking in the same line. There are very few points of disagreement. Hopefully we'd be able to decide on a response soon.

I feel a bit sad that many of the members seem unaware of the significance of this issue.
One would have thought that doubts like which wire goes where could have waited awhile...

True sir.
At this crucial moment people are busy in logo making too.

Sir, can this topic be made as a sticky thread? It might be noticed more. Just a suggestion.

1- RTF and prebuild models may get licencee, but what about customs made quads or hexas or Aeroplanes.  Where we use different           
    parts from different manufacturers.
2- If we get UIN for a custom made plane, if the plane crashes and we need to replace its parts with different motors and esc, then 
     do we need to again get UIN

Dear All,
We need to come to a common base points and all of us can shoot emails with the similar points.

I am putting here a compiled version of Comments to DGCA;

The current draft guidelines is applicable only to Commercial UAs and a new section shall be introduced for Model Air craft with the following points;
Applicable to :
- Model Aircraft weighing more than 250 gram and less than 20kg.
- Shall be operated below 500 feet AGL in uncontrolled airspace and clear of notified prohibited, restricted and danger areas as well as Temporary Segregated Areas (TSA) and Temporary Reserved Areas (TRA)

Rules
- Registration of Model Aircraft Pilot on DGCA Website and issue of Unique Identification Number for Pilot. This number will be affixed in the Model Aircraft.
- Allowing FPV flying.
- Allowing 14 years above under guidance of other pilot.
- Allowing other nationals pilot registration with supporting document by the event organiser.

----
If we ask more then only they give something. If we ask 500 feet they may give 400feet. If we ask 20kg they may give 10kg.

Please review add/suggest on the above points.

Please let us unite and come to a common ground on the points to be raised.

Different opinions and different suggestions will not yield a benificial result.
Similar suggestions in different words will give a better result.

Kumaran

The above points look good and solid.

My area of concern was the draft does not includes the model air craft (multi,planes or heli) it was more for like the RTF or the commercial UA like the DJI or the WALKERA or any other.

The points said above my Kumaran ji solves the issue for the Custom Models which is good. Also for the Commercial UA i think they should increase the height to 500 ft AGL atleast.

I have a question,
If i am a model pilot and registered also have a UIN. But do i have to also register or inform to DGCA about the models that i have or i build in future?

Actually I guess that they have two intentions;
1. They want to know the model capabilities.
2. They want to trace the person who flown the model in case of mishap.

With regard to model aircraft we suggest the model capabilities & flying areas by ourself.
1. We limit the capabilities by our self, say Maximum 20kg (we ask this, they may reduce it), 500 feet, uncontrolled space etc.
2. For tracing, We will suggest onetime Model aircraft pilot registration and this will be affixed to the model.

ok so for model aircraft no need to get UIN for aircrafts?

Yes.
All of us should suggest for Model Air craft Pilot Registration
and NO to Model Aircraft Registration

That is just for custom builds or for all? (like the commercial UA DJI and others?

satyaji
I believe that the term recreational or commercial is with respect to use and not based on model.
A DJI RTF can be used for recreational purpose too.
Edit: However, we will restrict model aircraft upto 20 kg as recreational use. Even, If they limit to 5kg most of us will be free of trouble.

Further, I believe that Model Aircraft Pilot is more concerned on safety of himself and others.
Whereas people doing it for money will be ready to fly over crowd. So, commercial use to be governed much.

However, there are areas to be commented on guidelines for commercial use.
We can't limit ourselves only to model aircraft. UAs can be used for many productive purposes and as we know the subject, we have to comment to make it right.

I believe only Model Pilot Registration is prone to abuse. What if somebody else flies with somebody else's registration no?

Best way is to include a separate micro class without GPS/Cameras and then exempt that class from UIN registration. That will make everybody happy.

We can put the Pilot ID inside Model.
A onetime registration will save us from harassment from local police.

I believe DGCA will neither have the manpower nor inclination to issue a Pilot ID to anyone. It's a very responsible task.

The best way to check harassment from local police is to form a local group and then handover the list of all registered fliers to them with ID proof, etc. They'll be more than happy to oblige. The group is not responsible for any other flier who is not registered with them.

The group can also insist that all registered members register themselves with amai.in That way, it'll add to more credibility.

Dear Vishal,
We are suggesting for an online Portal for registering with facility to upload supporting documents.
If they are planning to approve all Models they can definetly approve the Model pilot.

Dear Kumaran, why I'm suggesting to include a separate micro class without GPS/Camera system and no UIN for that class is because we can do away with the whole registration thing. We all know how efficient our system is.

Approving a model pilot is more demanding than approving a model. The former is like giving a license to fly anything. They certainly will not have the setup to checkup the credibility and skills of the pilot nor there is any certifying body here to issue a RC Pilot license.

Yes they are planning to issue UINs for models but within what time frame are they going to issue one?

This whole security thing came up only after the advent of multirotors with GPS/Cameras. Model aircraft flying was there lot earlier without any security concerns. One certainly cannot drop a bomb at a precise location without the help of GPS and cameras. Also, having altitude restriction puts a barrier on accidents with commercial/civilian aircrafts. These were and are the two main concerns of DGCA as understood by their Ban letter dated Oct 2014.

Quote from: vishalrao on April 29, 2016, 04:57:05 PM
This whole security thing came up only after the advent of multirotors with GPS/Cameras. Model aircraft flying was there lot earlier without any security concerns. One certainly cannot drop a bomb at a precise location without the help of GPS and cameras. Also, having altitude restriction puts a barrier on accidents with commercial/civilian aircrafts. These were and are the two main concerns of DGCA as understood by their Ban letter dated Oct 2014.

1. I strongly feel that we should not mention in any of our letter or proposal about camera or photography and dig our own holes. Why raise an issue which DGCA has itself not raised in the draft? Their categories are weight-based. Let's discuss on classification based on weight.

2. DGCA in their draft have themselves suggested inclusion of GPS and RTH. Why then suggest anything about not including GPS?

We have enough problems on the points against hobbyists which they have included in the draft. Let's stick to those points. Why raise issues on points which they haven't mentioned? Do not make this thing any more complicated by assuming things.

I appeal to everybody to only discuss the points in the draft which goes against our interest. Please do not give them ideas about things which they have not included in the draft. That is not in our interest. Else it would be suicidal

You can only comment once you take the whole draft into consideration, what i mean is including ICAO, FAA etc..., Also FPV is largely now regulated/banned in many countries.

I believe there are two categories of hobbyists here. Those that are old style traditional aeromodellers and have nothing to do with multirotors and complicated stuff and others who are the new generation type, who are into multirotors. Clubbing these two and making a general rule is not possible as the interests and risks associated with both of them are entirely different. Doing so is bound to make life of either of them miserable. I belong to the former type and I don't want to be entangled in this complicated stuff. That's the reason I want a separate class of aircraft without GPS/Camera. There is no point in ignorant about that as that is the reality. The DGCA is well aware of that and that's the reason their entire draft is based on that.

I'm not trying to make things complicated here. Things are already complicated. I'm just trying to simplify things for traditional aeromodellers here.

True,Vishal

But a UIN for each model? Supported by a manufacturer's manual? What happens to scratch builders?

That's what Sanjay sir. Create a new class for models that fly without GPS/Cameras and exempt them from procuring UIN. It's as simple as that. We Aeromodellers have been completely ignored by the draft. It really doesn't make any sense in getting UIN for scratch builds and also simple fixed wings or for that matter simple multi-rotors as well, as they are no real threats.

I'm sorry but I can't ignore the fact that that our life has been made miserable after the advent of these advanced multirotors. Our life was simple and we would like to keep it that way. The hole has already been dug and we don't want to be buried for no fault of us.

Aeromodellers, it would be suicidal if we kept mum on this. This is not a please everybody plan. Either get out or sink together.

And regarding weight based classification, it really can't get dumber than this. How can one club together a 1kg fixed wing aircraft and 1 kg DJI Phantom? I would curse myself for the rest of my life I kept mum on this. Wake up guys.

I don't get why there should be this differentiation between fixed wing pilots ('traditional aeromodellers') and multirotor pilots. Why should you receive preferential treatment? A fuel powered plane as well as medium-large electrics have greater endurance and equal scope to cause damage as most multirotors. Honestly, if it wasn't for the surge in multirotor tech, this hobby would have a fraction of the people it currently does. Also, it is no less impractical to add GPS, RTH and a SIM based tracker on an FPV racer than on a small foamie.

I say we should have a common weight class (say 250-500g below which no registration is required (similar to the FAA's 'two sticks of butter'). This should exempt toy quads, the smallest FPV racers, and small foamies (I guess). Another weight class (say up to 2kg), for which simple online self registration is sufficient. As others have said, a unique ID can be granted to each pilot, which he can then display on all his models. This will be much more practical than a UIN for each model (especially for builders). The requirement for VLOS should be waived as long as there is a trained spotter (I am not particularly bothered about this since I seriously doubt this will be enforced. It's not like they could stop us from flying even when it was 'banned'). The max altitude without UAOP should be raised to 400 feet, comparable to international standards (though again, it's not like cops are going to be chasing us with altimeters). The main thing should be differentiation between 'commercial' and 'recreational use' rather than trying to segregate multirotor and fixed wing pilots.

As santanucus has said, let us not bring cameras into this matter. Why inflict extra trouble upon ourselves?