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

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

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SK1701

As I have already said here, there have been a grand total of ZERO verifiable incidents of drones (the media's blanket term for all multirotors) hitting airplanes. Here is an interesting little statistic for those who think drones are a major threat to civil aviation:


The recent 'drone strike' at Heathrow, hailed as 'a sign of things to come' was most probably a "a plastic bag or something".


flyingboxcar

Baba
Apna ke  :bow:  :bow: :bow:

Raghupati Ragahav Raja Ram, saab ko sanmati de bhagawan

And as Bapu had said, an eye for an eye will soon turn the whole world blind.

If you still do not get my drift, file an RTI please
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flyingboxcar

I am going to stop spending lesser on this hobby and starting to save monies to visit US of A. I may get to see flying Turtles.
Any one want to come along?   
If you are really into scale you should be here. www.rcscalebuilder.com

Himadri Roy

Quote from: flyingboxcar on May 20, 2016, 04:10:41 PM
And you do believe that what you say will be taken as gospel truth and carved in stone there after? Don't you?
A simple search on www will tell one that far more cases of multi-rotors and fpv have been on the wrong side of the law than traditional models.
By the way when you send that representation, do include, kites, balloons, flying debris, and oh the birds please as they are the biggest reason for aerial incidents especially the debris and birds. Therefore they must be banned from Indian airspace (on second thoughts may be indoor use would be
Sorry just cant agree with this! Just do a google search you will find more no of accident and deaths due to rc planes than multirotors. That's how "harmless" the fixed wings are. And also the fact SK posted!

Quote from: flyingboxcar on May 20, 2016, 04:10:41 PM
On a serious note,
I can not understand what is making you feel so incensed and threatened?  Do you think DGCA will take the AMAI representation promulgate that in to a law?         
Why not? AMAI's suggestion may out weigh our individual suggestions as it is the national body for "so called aeromodelling". That's why we are worried. Had it been some ABC individual we wouldn't have worried much. The government will surely give more ear to what they say won't they?
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

flyingboxcar

Himadri
Who gave AMAI the national status?
And if they are then so be it. I am all for a national body representing me.

   
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flyingboxcar

"And also the fact SK posted"
So you want to see flying turtles??
If you are really into scale you should be here. www.rcscalebuilder.com

sundaram

@santanucus. On what basis did you presume AMAI is asking for a ban on multirotor or a model aircraft with payload.

Please read the original draft of AMAI.

It has just taken it upon itself to mediate on the issue of registration numbers for its members flying recreational model aircraft without payload and with a room for other club members to do so on the similar lines for its members with a self imposed restriction of not to fly with payload for all those model aircraft issued with registration numbers of clubs.

You are free to follow your own path.

How did you presume that AMAI is asking for a ban on others with payload or multirotors.

Why this emotional outbusts and personal attacks.

By the way DJI Junkie attitude was a reference to the free spirited unrestricted flying choice we all have and was not directly aimed at you.

PS : You seem to be having a problem with official positions of representations too. That's childish if I put it bluntly. Please hope to influence only that which is within your control.


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flyingboxcar

Sundaram sir
"free spirited unrestricted flying choice we all have"  :giggle:
Not for long, how I wish people see the ominous writing on the wall.


And folks
Just noticed another thing, there are quite a members on the forum who proudly mention the radio equipment they use under their signature blocks. From a cursory research appears that, not all such radios may be legal within India. 

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SK1701

Quote from: flyingboxcar on May 20, 2016, 05:51:51 PM
I am going to stop spending lesser on this hobby and starting to save monies to visit US of A. I may get to see flying Turtles.
Any one want to come along?   
Quote from: flyingboxcar on May 20, 2016, 06:00:05 PM
"And also the fact SK posted"
So you want to see flying turtles??

I would have thought someone so dead against spoon-feeding would have done some searching of their own before claiming the statistics I am presenting are false. Go ahead, try a quick Google search and you might be surprised. You can also start with popular media outlets and work your way all the way back to the FAA database of wildlife strikes.

Sundaram Sir, you make a very fair point. I have partially missed that interpretation and have got pretty salty over here. However, since it is mostly multirotor pilots using autopilots/ FPV, as per the AMAI suggestions we would have to apply under the commercial category, which I am against. I am in favour of a simple online registration process and centralised database.

flyingboxcar

And hey if that Official position barb was directed towards I,  to be very rude (if you will excuse me for that ) "go stuff up dude".
I and Col Sundaram have earned that and are proudl about it. Whether you like it or not is your problem.

And may I suggest?  grow a funny bone please, will help you navigate through this thing called life    
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sundaram

@SK1701 Its purely your assumption that only multirotor pilots use Auto Pilot or fly FPV.  

I would proclaim multirotor pilots are just new kids in the block of FPV clan.  ;)

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flyingboxcar

SK
Did I say your post or data was false?
All I said was I wanted to go to US to flying turtles
But pray tell me, unless those are flying turtles what is the use of using data that has no relevance to the threat we are discussing?  I am still under impression that we were discussing about flying incidents, not wildlife strike. That is unless the topic veered off to wildlife and likes somewhere and I completely missed the bend in the path.
If you are really into scale you should be here. www.rcscalebuilder.com

flyingboxcar

If you are really into scale you should be here. www.rcscalebuilder.com

Himadri Roy

Quote from: flyingboxcar on May 20, 2016, 06:27:06 PM
SK
Did I say your post or data was false?
All I said was I wanted to go to US to flying turtles
But pray tell me, unless those are flying turtles what is the use of using data that has no relevance to the threat we are discussing?  I am still under impression that we were discussing about flying incidents, not wildlife strike. That is unless the topic veered off to wildlife and likes somewhere and I completely missed the bend in the path.

Qoute from the website PLEASE READ
"To investigate the risk that small drones pose to the airspace," Dourado said over email, "my collaborator Sam Hammond and I downloaded the full dataset to run some analysis on it. We found not only reports of bird strikes, but strikes of all kinds of mammals and reptiles as well. We thought this evidence was very revealing—planes hit objects all the time. Meanwhile, there still have been no confirmed collisions with drones in the United States.
So why turtles? "I picked turtles because turtles are funny," Dourado said, "You don't think of turtles as posing much of a threat to planes, and they don't. If we've hit turtles 198 times and drones 0 times, then maybe we are worrying too much about collisions with drones."
Earlier studies have shown that drones under three pounds show no more risk to airplanes than small birds, especially if flown below 400 feet and more than 5 miles away from airports, as the law already requires. Registering drones smaller than that means flying toys are now more controlled than ducks, but no deadlier.
This fits into a larger portrait of how bad people are at assessing risk, whether that of plane crashes, cyberterrorist attacks, or even the liklihood of rain. Drones are new and easy to fear, while turtles are ancient and an accepted part of life. If a turtle on a runway isn't that scary, maybe a drone flown five miles away from an airport shouldn't be, either
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

sundaram

On the funnier side. We all are missing on one important Suggestions for add to DGCA.  ;)

We all should  be allowed to fly within the terms of guidelines with an AF UIN board along with name and mobile number till such time DGCA issues a registration number for the online application or otherwise. Problem solved   :giggle: :giggle:

flyingboxcar

Thanks for setting the perspective regarding turtles right. So the turtles have no relevance in our discussion here.
But again there are lot of unknowns there, in that extract. But does the same article also give out the number of aerial collisions with conventional model aircraft's without FPV or autonomous gear?
Prima facie the article (from which extract is taken) appears to be done by an interested group or people and hence needs to be taken with pinch of salt ( I prefer a bag full please).

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santanucus

#291
So far as official positions are concerned, some people like to flaunt it, some don't. I have earned mine too..but official positions are meant for official purposes so far I am concerned. So far as the hobby is concerned, I am just another individual here and even a 13 year old who knows more than me and is into this hobby longer than me is my senior.  ;)

Ok folks...let's do the draft response on AMAI letter and finalize it by tomorrow. Why I think that AMAI is surreptitiously pushing fixed wing over multi-rotor will be clear from the draft letter itself.

Kindly suggest amendments and additions.




Quote
Dated: 20.05.2016
To
THE DIRECTOR GENERAL OF CIVIL AVIATION
TECHNICAL CENTRE, OPP. SAFDARJUNG AIRPORT,
NEW DELHI.

Madam.

Sub:  Draft Guidelines for obtaining Unique Identification Number (UIN) & Operation of Civil Unmanned Aircraft System (UAS) – additional comments reg.

Kindly refer to my letter dated 18.05.2016 on the draft guidelines of DGCA for obtaining UIN and operation of Civil UAS in which detailed comments and suggestions had been sent.

It is understood that representations from a number of organizations and individuals have been sent on the draft guidelines, some of which reflect the views of entities like AMAI which claim to be aeromodelling clubs representing the interests of all aeromodellers but are actually organizations having specific interests including commercial interests.

It may be noted that a vast majority of the recreational users of UAs in India are not attached with any such club and their opinions and views are not appropriately reflected by these clubs, contrary to any such claims made by them.

It has come to my notice that AMAI has made following representations on the DGCA draft circular which are based on points either not in the circular or are against the interest of vast majority of recreational users and hobbyists of UAs and favours specific groups.

   They have demanded that it may be made mandatory for recreational pilots to be registered with aeromodelling clubs and that the clubs should be made responsible for issuing registration number for the UAs. It would be obvious that there is a vested commercial interest behind such demand. Moreover, these entities have no presence across India and it is neither practical not legal to hand over matters of national security to such private clubs. In the USA, FAA has made no such requirement and it is suggested that such demands may not be acceded to.

   They have further demanded that before flying, local police be notified of place, date and time and that should be done by the club. This is a clever ploy to force recreational users and hobbyists to register with these clubs because it would be impossible for individual users to approach police on a regular basis. Moreover, people with no access to such clubs such as in remote or rural areas would be debarred from flying.

   They have also demanded that autonomous flying be banned and model aircrafts should not have any sensors, GPS, RTL etc. This is a strange demand and is contrary to that proposed in the draft circular that GPS/RTH should be mandatorily available in the UA. It is well known that GPS and RTH facility helps maintain the orientation, height and direction of UA. It also enables UAs to "Return to Home" in case it goes out of control. In fact it would be dangerous to have a UA without these faculties as it could endanger peoples' lives without such failsafe mechanism.

   AMAI also demanded that flying envelope be confined in the area permitted for such exercise and asked for vertical limit to be 500ft. Both of these proposals are contrary to the international norms. US FAA has fixed the height to 400ft. as per international norms and all areas except prohibited areas and populated areas are allowed for flying. In fact this is a surreptitious attempt to control the hobby and recreational flying. There is no reason why someone cannot legally fly in a rural area away from populated places just because it is not designated.

   Further, Demand for met conditions is absurd and not enforceable. What may be construed as "favourable" met condition can only be a guideline. It is not enforceable or measurable. It appears that they have confused guidelines with rules. Moreover, the term Model Aircraft has already been defined in draft circular as one without payload. There is no need to separately prohibit payload in respect of model aircrafts.

While they don't specifically mention it, from the set of suggestions it appears that AMAI is biased only towards a certain type of UA, which is fixed wing aircrafts. It would not be proper to introduce certain new clauses (in the guise of general clauses) in the DGCA circular which would surreptitiously favour one kind of UA over another.

It is suggested that a common set of rules be made for all kinds of UA irrespective of its nature. A fixed wing UA is not "safer" than other types of aircrafts from the national security point of view, although some quarters may try to portray as such. On the contrary, as the wing provides the lift, it is possible for a fixed wing UA to go further with the same amount of battery/fuel and carry more payload than multirotors and other kind of UAs. In fact the real-life drones which are used in military warfare are all fixed wing aircrafts (and not multirotors) for this reason.

Further, the demand of AMAI that aeromodelling clubs be made the authority to control the hobby by the above means (either directly or indirectly) may not be acceded to, as it may not stand the scrutiny of law to grant private commercially motivated organizations such leeway.

Thanking You                     
Yours faithfully

Downloadable .docx version is available here for modification: https://drive.google.com/open?id=0B6UgXTZBN0sCZnI0TFpiaWlNelk

allthatido

Quote from: flyingboxcar on May 20, 2016, 05:50:29 PM
And as Bapu had said, an eye for an eye will soon turn the whole world blind.

Fun fact : There is a conspiracy theory that Gandhi actually never said any such quote (No recorded usage of this quote). It was popularized by Ben Kinsley in the movie Gandhi.

flyingboxcar

Ok then if you wish, do read it as "Bapu in movie Gandhi said" 
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sundaram

@santanucus to  clear the misunderstanding and to set the record straight here. The proposed guidelines for civilian use of UAS in indian airspace has no effect on the flying activities of mine, Gusty or our sons for next 10-12 years till the time we hang our boots. We have our own wide open cleared controlled airspace to fly.

Its just that we are part of this beautiful community of hobby enthusiasts so we choose to waste our hard earned money on memberships of AMAI to be part of the community formally.

While being part of this community we are just trying to contribute to the draft guidelines for the community as a whole with common mans perspective in mind.

PS : please read defenition of controlled airspace from DGCA draft.

PPS : Please do not subject us to such awkward position of justifying to some kids in the block on our positions official or personal.

To put it Arrogantly blunt, You have no business in the representation of my official capacity.

flyingboxcar

Whether you wish to or actually use your official, demi official or unofficial position anywhere or not is your choice, but no one gives you the right to question how and why I or others use it, as long as it is not harming your interests in any way (and I am only hoping that by using my previous rank etc in a letter addressed to DGCA your multi rotor and FPV flying interests are not impinged). So take the advice and chill buddy.
The take away I have after all this Angreji is that I will send one more e-mail and snail mail to DGCA asking them to include a clause in the proposed guidelines that all recreational and non recreational purpose/s flying of UA/UAS in India be regulated by Santa Claus .  

Now for this yeomen service to Santa Claus will he bring a me a nice not ARTF shiny scale fixed wing this Christmas?? ;D ;D

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sundaram

@santanucus further since you claim to have been associated with DGCA. Let me make it clear here, if you go through my ammendments suggested as an improvement to AMAI's draft which will actually go a long way in making DGCA's life easier if they have any intention at all of implementing guidelines for recreational use with even an iota of sense of control

santanucus

#297
@sundaram...I have no business or interest in your controlled space. I am just bothered with flying my multirotors in whichever airspace law permits.

I have no interest in AMAI either, formal or informal, as long as they don't step on our interests

You are welcome to try to contribute in whatever manner you deem fit. But be assured, that we are as free to respond if something hurts our interest.

PS: No need to read it again. I am not going to suggest changing the definition of controlled airspace.

PPS: No I am not suggesting the DGCA that letter written by someone mentioning official positions be ignored.
That frankly, I agree, is not my business. All I said was that I, personally, won't do it to influence somebody by stating my position in a non-official matter. I would like to try to convince them on the merits of the points written in my letter. What others do is their own business.

By the way, I have not read your draft. My comments are based on the points in the AMAI draft. If that is now the "official" line of AMAI, I will surely go through it. And just to add, I don't need to bother about the jargon on the commercial aspects of the rules. I believe AMAI does not bother about the commercial aspects of the circular either. (correct me if I am wrong). My concern is only about the recreational, non-commercial part of it. Most members in this forum, I believe, are concerned only about those aspects.

saikat

- You guys should listen to flyingboxcar and sundaram .... they know officialdom more than most
   and their collective experience is something you cannot even come close.

   as for FPV - sundaram was flying it >6 years ago with ranges in the 10's of kms

   don't be too quick to brand ....

sundaram

Re:
#299
@santanucus For all the storm kicked up, I am really surprised to know that you have not even read my suggestion for amendment.

I am begining to wonder weather  you have even read the latest DGCA draft completely. I sincerely hope that you are not in the 2015 perspective still.

I would insist that you read the definition of controlled airspace and  DGCA draft completly to make sure you understand all my post correctly.

If you are asking me if my suggestions for ammendments are the new official lines of AMAI. You are being rediculously stupid.

To answer to your query IMHO AMAI is allergic to commercial interest of operation of UAS.

To repeat my perspective on AMAI draft again here AMAI has just taken it upon itself to mediate on the issue of registration numbers for its members flying recreational model aircraft without payload and with a room for other club members to do so on the similar lines for its members with a self imposed restriction of not to fly with payload for all those model aircraft issued with registration numbers of clubs members. Model Aircraft being defined as any type of UAS without payload.

You are free to follow your Path.

PS : why am I getting a feeling that I am wasting my time with someone who is just jabbing away on the keyboard without even going into the previous contents on the entire Subject.

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