EASA. Comment Response Tool

Transcription

1 EASA Comment Response Tool You can save this page as HTML and then open it in Microsoft Word for further editing. Title Introduction of a regulatory framework for the operation of drones Unmanned aircraft system operations in the open & specific category NPA Number NPA (A) Ingemar THÖÖRN (jrfk@telia.com) has placed 27 unique comments on this NPA: CmtSegment 1233(General Comments) 0 My name is Ingemar Thörn. I am writing also on behalf of the Aeromodelling RC Club in Jönköping, Sweden with name Jönköpings Radioflygklubb My first comment is that many affected stakeholders are missing on the first page like aeromodelling clubs, model aircraft pilots and children using toy aircrafts. The regulations seems too complex and complicated to be possible to describe for the general public who use UA for recreation. It is the interest of the aeromodelling club to have the rules understandable, reasonable and proportional compared with other risks both at the dedicated model aircraft field as well as for other locations. When having too complicated rules, you will always find cases where the rules will be too strange and people will then ignore the rules and then the rules has no effect. According to health/articles/the25mostcommoncausesof Death/193?page=1 and html the odds of dying in a motor vehicle accident is about 1 in 200 for a lifetime which is much more than for air and space transport (including air taxis and private flights), the odds is about 1 in 7000 for a lifetime. It is more dangerous to cycle with an averaged risk of die of about 1 in 4000 during life Model aircraft Boundaries of the open, 9 20 I also repeat my last comment from appendix 7.1 here: Why this focus on aeromodelling? The statement for model aircrafts (e.g. aeromodelling) is valid also for balloon releases, kites, frisbees, china lights, fireworks, clay pigeon shooting etc. So it is a general problem to avoid dangerous activities close to aircrafts and for the Uspace vehicles to handle every kind of dynamic obstacle and danger. So I ask: Why should we have these complicated rules according to the NPA when there are many other dangerous activities out there? It is confusing and inconsistent to use another definition of model aircraft than used in other countries like US; Furthermore it is not as stated in extract below from regulation (EU) 2016/1185 of 20 July 2016 amending

2 specific, and certified category Thirdcountry UAS operators Link with the USpace Applicability Opencategory issues Specificcategory issues 2.4. What are the expected benefits and drawbacks Model aircraft Boundaries of the open, specific, and certified category Thirdcountry UAS operators Link with the USpace Applicability Opencategory issues Specificcategory issues 2.4. What are the expected benefits and drawbacks Model aircraft Boundaries of Implementing Regulation (EU) No 923/2012 as regards the update and completion of the common rules of the air and operational provisions regarding services and procedures in air navigation (SERA Part C) and repealing Regulation (EC) No 730/2006. Extract: 95a. model aircraft means an unmanned aircraft, other than toy aircraft, having an operating mass not exceeding limits prescribed by the competent authority, that is capable of sustained flight in the atmosphere and that is used exclusively for display or recreational activities" 9 20 It is confusing for the public to have the complicated rules for recreational use of UA proposed in the NPA. And that Europe do not have exemptions for model aircrafts like in US. I propose that organised aeromodelling shall be generally exempted from the proposed rules for drones when operated in accordance with a recognized national community based organisation s safety guidelines. That how the rules are in US, issued by FAA according to attached file (link was not accepted by CRT, please google "FAA400feet") I do not understand the idea behind UAS class C0, C1, C2, C3 and C4. It is like you have different rules if you drive a small size car, medium size car or large size car. And also FAA 400feet.pdf (432.6kb)

3 the open, specific, and certified category Thirdcountry UAS operators Link with the USpace Applicability Opencategory issues Specificcategory issues 2.4. What are the expected benefits and drawbacks like you should have the same competence requirement for driving a taxi as driving a car privately. It is also a big difference between x kg of metal or x kg of plastic foam falling on your head or crashing into something. I propose the following classes: Toy aircraft (per definition in regulation (EU) 2016/1185) Model aircraft (per definition in regulation (EU) 2016/1185) including drones used for recreation and sport Other UAS (for commercial use etc.) where you could have more complicated rules as desired necessary to perform complicated tasks with an UAS. The model aircraft definition is used in most parts of the world including US and Australia. Of course some regulation of the model aircrafts are necessary like leaflet attached with factory made UA and competence by online training with a test and a lost link management. The vendor should be responsible for the safe use by instructions (e.g. distance from people) which is delivered with each product, and when privately built, the pilot in command is trained and responsible to keep the UA at a safe distance from other aircrafts, people, boundaries of congested areas or aerodromes such that no third party is endangered Draft cover regulation Article 1 23 Many model aircrafts are flying both indoors and outdoors at sport arenas and similar places. Would be hard to understand by public why it is much more complicated rules for flying at low altitudes outdoor than indoor with no rules. It can be the same model aircrafts flying indoor and outdoor with same risk as flying at low altitudes at outdoor locations like gardens, football arenas, small remote fields and forest where fullsize aircrafts can not fly. High altitude flyaway because of technical problems is very rare. The earlier seen flyaway problems with drones was software error now mostly corrected Draft cover regulation Article Draft cover regulation Article (j) It should be allowed to control and navigate a US in FPV mode with several cameras article 3: I propose that no geofencing and electronic identification system should be required for private build model aircrafts but may be recommended when possible by the equipment used. This because a onboard geofencing will made the model aircraft more heavy and thereby more dangerous and harder to control and the risk that privately built model aircraft otherwise will be unusable when Uspace is introduced. According to

4 Death/193?page=1 and html the odds of dying in a motor vehicle accident is about 1 in 200 for a lifetime. For air and space transport (including air taxis and private flights), the odds is about 1 in 7000 for a lifetime. It is more dangerous to cycle with an averaged risk of die of about 1 in 4000 during life. It should be a world standard geofencing on cars before it needs to be fully introduced on privately built model aircrafts Draft cover regulation Article UAS.OPEN The wording operational authorisation in the proposal may cause cost for the aeromodelling clubs as many government has rules of taxes corresponding to the work required by the authority. Why shall we now pay for an already safe aeromodelling activity that has been performed in more than 80 years and by radio control in more than 50 years? Authorities should not be allowed to have weight limits like 4 kg and control every location in detail where a trained club member in an approved aeromodelling association want to fly above 120 m altitude. Instead the aeromodelling association should have rules of where it is allowed to fly. For example in Sweden, we have a lot of uncontrolled airspace which should be open for everyone without costly bureaucracy. It is also hard for the general public to understand why you in some countries need to call the airport controller when flying below 50 meter when you are 20 km away from airport or even 5 km away but in other countries you can fly when you are 1,5 km without contacting the airport. The base rules should be the same in every country with exemptions as needed for the larger airports and military airports. GM1 UAS.OPEN.20(b)&(c) Several competence levels seems complex. I propose that one level of online training with registration should be enough for flying model aircraft. I propose no registration of model aircrafts should be required. Why shall we now pay for an already safe aeromodelling activity that has been performed in more than 80 years and with radio controlled models in more than 50 years? Many government has rules of taxes corresponding to the money and work required by the authority. Display of the owners name and phone number should be enough on the model aircraft with mass above 0,25 kg. AMC1 UAS.OPEN.20(e): I propose that a display inside a model aircraft shall be allowed. Aeromodellers do not want display data on the painting of their scale models.

5 1368UAS.OPEN.35 Maximum height of UAS operations in the open category 37 I propose that privately built or modified UA should be allowed to fly by a trained pilot above 120 m altitude when allowed within the airspace in the open category. Should normally be allowed for every educated trained pilot to fly without a 120 m altitude limit in an uncontrolled airspace and when having an allowance in controlled airspace. The airspace should be open for everybody, not only manned aircrafts. 1238UAS.OPEN.40 Requirements applicable to UAS operations in Subcategory A UAS.SPEC Responsibilities of model 41 clubs and associations UAS.OPEN.40: 5 megapixels camera does not state anything about the image quality which depends on distance and lens field of view. I propose to delete electronic identification requirements for model aircraft. The regulation of privacy using any camera regardless of in air or on ground should be the same. Display of the name and phone number on or in the model should be enough. (b) It should be allowed to have trial and training flights without earlier competence of trainee when using dual command equipment (buddy box). 1243APPENDICES Appendix I I1 (g) I propose to avoid complex referring to other directives and instead use the term toy aircraft as stated in in Regulation (EU) 2016/1185 of 20 July 2016 amending Implementing Regulation (EU) No 923/2012 as regards the update and completion of the common rules of the air and operational provisions regarding services and procedures in air navigation (SERA Part C) and repealing Regulation (EC) No 730/2006: 129a. toy aircraft means an unmanned aircraft designed or intended for use, whether or not exclusively, in play by children under 14 years of age;. I1 (g) (4) The wording limit any injury that may be inflicted by blade is a vague. It seems dangerous to allow UAS flown directly above head of people when having open propellers that may causing injury. Aeromodellers has always avoid to fly close to people and directly above others head. I propose that the vendor is responsible to in the instructions write if the equipment is safe to fly above head and close to other peoples etc. It is also a big difference between 900g UAS of metal or 900g UAS of plastic foam. Should be some kind of testing requirement of factory made UAS intended to fly close to people like is present in the regulation for toys. 1763Appendix I.6 57 I.6.a. Privately built model aircrafts should not be required to handle navigation data onboard the model aircraft and furthermore not need to have a geofencing system at all when flying at a known location like a model aircraft field.

6 1765GM1 Article 14 Hobbyist flights 1838AMC1 UAS.OPEN.20 (a) form 1839GM1 UAS.OPEN.20 (b)&(c) 1840AMC1 UAS.OPEN.20 (e) Display of registration information 1841AMC1 UAS.OPEN.30 (b)(3) Ensuring that the UAS is in a safe condition to complete the intended flight 1843AMC1 UAS.OPEN.30 (c)(6) Operations in firstperson view (FPV) 1844AMC1 UAS.OPEN.40 (b)(5)(i) and UAS.OPEN.60 (e)(1) Basic competence of the remote pilot to operate in Subcategory A1 and A3 2528AMC1 UAS.OPEN.50 (b) and UAS.OPEN A hobbyist is, with this rule proposal, not allowed to fly aircraft models above 7kg and/or above 120 meters as he has been allowed for in more than 50 years when he/she want to fly in a rural area where you never see any other aircrafts and it is a long way to the activities by a club and no exemption in zones by autority. Why? My proposals is to exempt competent pilots flying model aircrafts from this rules of 7kg and 120 meters in non controlled airspaces and after allowance in controlled airspace. This is done in in many countries, e.g. United States I propose no registration of model aircraft (definition according to (EU) 2016/1185) 97 I propose no registration number is required for model aircraft (definition according to (EU) 2016/1185) 97 I propose no registration number is required for model aircraft (definition according to (EU) 2016/1185) I propose that no onboard geofencing system should be required for privately built model aircraft (definition according to (EU) 2016/1185), because it will made the model aircraft more heavy and thereby more dangerous and harder to control and the risk that privately built model aircraft otherwise will be unusable when Uspace is introduced. 99 Should be same nomenclature as in definitions: "FPV mode" (a) (2) (iv) Using an UA observer should not be mandatory. Add "in FPV mode". 103 AMC1 UAS.OPEN.50(b) I propose to have same rules for rotary wings as for other UA and not have fix distance rules. The risk level is more about not flying toward uninvolved peoples and if there are protections like a net

7 (b) Uninvolved persons or threes etc. between UA and uninvolved peoples. It is possible to fly rotary wings at high speeds where they are falling in a similar way as a fix wing. Rotary wings has sometimes a larger more dangerous rotor than the propeller of fix wing. 2543AMC AMC1 UAS.SPEC.15(c): I propose that occurrences UAS.SPEC.15 that caused an injury to any person should be defined (c) Action in more in detail. Should not include little cuts only requiring case of operations/fligh bandage or sticking plaster. exceeding the conditions and limitations defined in the operational authorisation 2548Appendix I Why generally allow to fly over people? See comment above. 2549Appendix I It is dependent on actual condition what is a safe distance to people. See also my comments above. 2550Appendix I It is dependent on actual condition what is a safe distance to people. See also my comments above Appendix Why this focus on aeromodelling? The statement for model aircrafts (e.g. aeromodelling) is valid also for balloon releases, kites, frisbees, china lights, fireworks, clay pigeon shooting etc. So it is a general problem to avoid dangerous activities close to aircrafts and for the Uspace vehicles to handle every kind of dynamic obstacle and danger. Page viewed on :34:16 GMT Copyright EASA

8 EASA Comment Response Tool You can save this page as HTML and then open it in Microsoft Word for further editing. Title Introduction of a regulatory framework for the operation of drones Unmanned aircraft system operations in the open & specific category NPA Number NPA (B) Ingemar THÖÖRN (jrfk@telia.com) has placed 4 unique comments on this NPA: CmtSegment Current EU framework EASA consultation strategy impacts Appendices : Recreational flight of UAS is currently exempted from the 120 m rule in Sweden. It is only a recomendation (no formal regulation or law) If counting flight hours, it is probably another distribution of "Main reason of UAS use" with more commercial use and less model aircraft use. Will the recreation users in general pay the fee and perform the online training when the police ability to supervise is limited, especially in rural areas? Finally I want to compare recreation UAS flying with kite flying. I am sure nobody want to be directly under a flying sport kite. A common sport kite weight is between 0,25 and 0,5 kg. Is it common sense to not be under a kite, why should you allow people to be under an UAS? People are good in common sense when it comes to kites, why should not most people have good common sense regarding UAS as well. Is it necessary to implement all the complicated regulations and rules proposed in the NPA? Page viewed on :58:03 GMT Copyright EASA