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

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

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santanucus


Rathi

can we not have more complicated things and just keep it as those 3 simple points? maybe a license to differentiate us from commercial users and that set us apart for commercial pilots and we should be set... a lot of people fly slow flyers in their backyards and if u tell them to go to a flying field, it just doesn't seem sensible...
Bolt 210
QJreaper 6"
taranis 9XD+
its either FPV or nothing.

santanucus

Yes...I'd like to have that sort of differentiation and its a good proposal. But weight based exemption can make that differentiation as well because those who fly in their backyards mostly fly smaller aircrafts. Of course I am not in favour of specifically designated flying areas for everyone. That will be severely restrictive. But since it is not being agreed upon by everyone...so we may go for a "minimum common agenda" like above and then individuals can give their own proposals

sameerpawaskar

sir,
i have clearance for both never paid any chai panni
also if you have papers clear
they are very courteous.
trouble starts when some thing are missing
then they smell blood
&  hunt is on
regards
sameer

sundaram

Clearance for what Sameer 😀😀. Enlighten us too.

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santanucus

Hmm... clearance for what? I even have no problem with chai pani. But with "drones" it may easily become "whiskey soda" ;)

sameerpawaskar

hi,
you are right about things escalating to "whiskey soda"
clearance for  Character Certificate from Police and WPC clearance
sameer

flyingboxcar

1. With regard to WPC clearance for recreational use of Model Aircraft, it should be represented that WPC has already type approved many equipment, so as long as the equipment used by a hobbyist is figuring in the WPC approval library that should be sufficient proof of compliance.
2. Make registration for fliers/individuals and not aero models. Make it easy process for greater compliance. The UIN allotted should be marked on aero model during the time of flight. This is what the FAA is doing.
3. Height restrictions removed for aero models up 7 Kg (like UK) as long as these are not flown in various designated restricted/controlled/sensitive areas.
   
Also what we need is numbers to represent. We need each member to write to the designated person at DGCA apart from common ones being organized at various levels. Quote international practice, other countries rules, give evidence of the same along with your point.
It is important that the points/feed backs submitted are in the language the department understands best. Use their acronyms etc.   
I am sending an individual letter and request each one here to do so 
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roysankar

If I am reading these Guidelines right, 2 clauses in particular make me nervous.

One: "Designated Flying Fields". Are areas for these marked out in every major city? Let alone the smaller towns! Most of us fly our scratch-builts in every little safe place we can find. Will we now have to deal with a mama shoving these guidelines in our face and asking for chai-pani?

Two: the clause about "payloads". Will attaching a GoPro to our EasyStar now be illegal? Kucch bhi!
Fleet: GP Cessna 182 65", BluBaby 42" Kfm, Mini-Guinea 35"

flyingboxcar

There is no mention of designated area in the draft. Where are you reading it?
Second yes per the draft any UA with payload is considered non exempt and will require an UIN and UAOP. Flying with Payload without UIN and UAOP will be illegal per the draft.
However the point that needs to be noted is that Payload is not defined at the draft. That is what needs to be brought up with the DGCA to remove this ambiguity.  
If you are really into scale you should be here. www.rcscalebuilder.com

santanucus

#185
No. The mention of designated area is not there in the draft. Its in one of the proposals drafted by members. That's what we were discussing about. My opinion was that we should not add anything extra in our proposal which causes inconvenience to fliers but which which DGCA has not mentioned in draft.

Payload has been defined in the draft. It says "All components of equipment on board a UAV that are not needed for the flight or for its control. Its transport aims exclusively to fulfill a specific mission."

So a camera, by this definition, is a payload.

QuoteAlso what we need is numbers to represent. We need each member to write to the designated person at DGCA apart from common ones being organized at various levels. Quote international practice, other countries rules, give evidence of the same along with your point.
It is important that the points/feed backs submitted are in the language the department understands best. Use their acronyms etc.    
I am sending an individual letter and request each one here to do so

21st is the last date. I think we should discuss and start sending 15th onwards. The format in word and excel posted in this thread earlier is very convenient for making para-wise proposals. And since DGCA thinks FAA is God I'd read their rules in details before drafting my own comments.


This video describes the process of registration by FAA in USA. This gives the details of the rules and registration process for hobbyists in USA. This will help us understand the rules without going through the documents. One can see the video and note down the key points which we may include in our suggestions, if found relevant in our context

If anyone sees the part on the registration process in the video (27 minutes onward), one can see how easy it is to register. DGCA has taken many aspects from these regulations and then introduced inspector raj elements into it like police verification etc.



The salient point in USA for registering UAs are

-UA ranging from 250 gms to 25Kgs which are used for non-commercial purposes need to be registered
- UA below 250gm are exempted from registration
- Registration is simple and online. There is no "police verification" involved. Nor "WPC clearance" like us.
- Registration fee is $5 to be paid once.
- Registration is required for pilots/users and not for individual aircrafts in case of non-commercial use. Using the registration, the pilot can fly as many aircrafts as he wishes.
- The online-generated registration number is to be kept in the possession of the pilot during flying. To be affixed in ALL aircraft that the pilot flies. No need to get UIN for non-commercial operations.
- There is no requirement for affixing fire-proof ID plate.
- allowed height is 400m


Just note the difference with DGCA proposal ! There are hundreds of thousands of drone in USA. They have faced 9/11. But still they have such an easy to comply rule. And here in India, we can't think beyond introducing Inspector Raj into everything. We take parts of their rule and introduce the worst things into it. Our mentality is such that we actually support such outdated proposals in the name of security...security which can't be implemented.

USA has easy to comply registering requirements but a stiff penalty for non-compliance with penalty of $27000 at the minimum which may extend to jails for criminal cases. In India, there would be a stiff and hard-to-comply requirement for registration and people would be forced to violate such rules because it would be so difficult to comply.

It is clear that DGCA has taken elements from the US FAA rules and modified it. So the following would not be unreasonable if we propose individually

- raising height to 400m because its only 40 storey building high.

- for recreational purpose, exemption upto 2Kg. (i.e. for micro)

- for recreational purpose, for weight category >2kg. upto 20Kg. simple web-based online registration WITHOUT police verification or WPC clearance (for mini)

- rather than making registration for each UA, for recreational use, pilot registration may be done. The unique registration number of the pilot may be affixed on every UA flown by the pilot. However if DGCA thinks that every UA need to be registered, that can be done ONLY IF it is done through a simple online web-based system. The online registration system can be made AADHAR based for identifying the pilot.

- for rest of the categories online or offline registration with police verification may be required


The key aspect of registration is simple web based registration (initially it can be made paper based too). But WITHOUT police verification and WPC requirements. This will make it easy to comply with the law and people will not be tempted to not register because of fear of police harassment or WPC delay.

We have to emphasize that they have to make a law which is easy to comply. A law which is difficult to comply will prompt people to try to bypass it.

I think the above modifications will satisfy most recreational users and hobbyists.

P.S. After looking at this fpv video, I think we all should write a paragraph to DGCA to make it easier for this sport to develop. Including allowing foreigners to register.

https://www.facebook.com/quartznews/videos/1169917936375240/

shobhit17

I guess the AMAI has got involved with the entire thing..... we need to highlight the issues from the FAA policy too.... the DGCA is not made of fools.... after all it has the mandate of safe use of Indian airspace which is a very big responsibility..... The very fact that they have put the draft policy for comments by hobby and commercial aeromodellers speaks very well of them.  I am sure a easier policy meeting all demands of the DGCA will come out soon....
Well I been into aeromodelling since I was in School....  and then been in the air for over 30 years.  Now looking to be back into aeromodelling full time...

aamin172001

And what about all the packages already detained by customs and asking wpc noc, there are thousands of...? Will we hobby lovers have to loss all this? Or will there be any ways to get it cleared after the guidelines will finally announces....?

Himadri Roy

@santanu Absolutely rock solid and to the point!  :salute:  :bow: Lets have no more of same discussion that are leading to all these points santanu has stated. Let us all start flooding DGCA with our mails so that we can make these things happen. We have very few ppl into this field compared to other countries do to the fact of import problems, blown out customs duty. We could add-on this point that this is a Sport meant to grow and the government can do its part in supporting this by bringing changes to the few laws suggested and also exemption(or slight exemption)from unnecesarry documents, customs duty on import of RC items from foreign.
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

Himadri Roy

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

mateen270

Sending the email now. Hopefully they would at least consider what we are asking from them. I dont want to end up adding useless weight to my 250 sized quad and the guidelines are just silly for hobbyist to follow.

merin_83

thanks,
merin

SK1701

I don't plan on signing that petition as it is asking for a ban on autopilots- 'autonomous UAVs controlled by Artificial Intelligence'. Why is it that people feel a need to ask for even more restrictions than what the DGCA wants to impose? Especially on a technology that makes flying safer.

santanucus

I signed that petition earlier. I think its a bit outdated now, after the publication of the draft rules. Many new issues have come up. In fact in the draft rules there is a mandatory(?) provision for GPS RTH/Fencing and Tracking at para 10.23. So autonomous flight is allowed subject to VLOS. I don't think the draft rule is against artificial intelligence as such.

I plan to write the mail to DGCA after 14th and will post it here.

Kiran26

Hobbyist shouldn't be restricted but as long as safety of others is ensured. What was the person thinking while drafting such a rule, why the paranoia ? ICAO is mentioned but misinterpreted. That's for integration of the UAS with the mainstream traffic and its not required now in India. We should be allowed to continue as most of us are doing away from population and restricted airspace infact instead of the blanket restriction, the govt. should define clearly the restricted air space. the rest of the area should be free for pursuing the hobby as long as life is not risked. I suppose even in the us the 400t rule exists only near the airport beyond that there is no restriction.

santanucus

I have sent my comments to DGCA on the draft Circular today. Last date is 21st May. Comments have to be sent to

Shri Lalit Gupta,
Joint Director General,
Office of the Director General of Civil Aviation,
Opp. Safdarjung Airport,
Aurobindo Marg, New Delhi 110 003.

email:


My letter and the other enclosed documents have been linked here. There might be some errors as I am busy with other matters and did not get enough time to write. Hopefully, I have been able to communicate the main points properly.

Letter: https://drive.google.com/open?id=0B6UgXTZBN0sCLVJteDd1ZGk1WFU
Ref-1: https://drive.google.com/open?id=0B6UgXTZBN0sCaHdiX0pLMGdaUFk
Ref-2: https://drive.google.com/open?id=0B6UgXTZBN0sCdm9kbG53SUczLVU

Himadri Roy

NOT AT ALL COOL! AMAI IS CLEARLY TRYING TO PUSH ASIDE FPV FLYERS TO SAFEGUARD THEIR OWN INTEREST!  :banghead: :banghead:
And yes I am shouting, really pisses me off how grown up adults can act so childish(Looking at their own interests by crushing others)!
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

mateen270

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.

sooraj.palakkad

AMAI is in to making more trouble.

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RC Hobbyist and an Aerial Cinematographer..

VIPIN_KUMAR

Agree....we should not suggest anything from our side regarding Camera or FPV....FPV seems to be natural progression for enthusiastic flyers...