General: The safety issue claims in the consultation are based on suspect data (uncorroborated airprox reports). So most of the proposals are about tackling a problem that doesn’t exist.
Proposal A: Test Sites: No views
Proposal B. Pilot Competency: We are against compulsory training and licensing – there is no reliable evidence that these are needed.
Proposal C. Insurance: We are against messing about with insurance. The Insurance world are showing no enthusiasm for risking their funds on drones, so the likelihood is that the Government would produce an insurance requirement that is unavailable at any price.
Proposal D. Awareness of the Law: We are generally in favour of improving leisure drone user awareness of the law – but as the CAA has just released the new Dronecode and publicised it, and is working on a further (DfT funded) programme of education and awareness, the Government should wait for the results before making further changes.
Proposal E. Improving deterrents: We are against ‘improving’ deterrents. Dedicated law breakers pay no attention, and the penalties are already draconian for accidental law breakers.
Proposal F. No Fly Zones: We support the development of apps to alert drone users to nearby restricted flying zones.
Proposal G. Registration: We are against registration as it will simply be a bureaucratic hurdle and a tax on law abiding members of society, with no method of policing. If there are people out there who want to operate outside the law, then they will not register their drones. There shouldn’t be a register for drones less than 150kg.
Proposal H. Electronic identification: As this technology is not yet available, and has not yet even become available to sports aviation manned aircraft, no firm decisions can be made. If and when it is available, then sensible discussions could be had on which aircraft should carry it, taking due account of their ability to lift and power it. The App based pilot scheme is interesting – and seems worth encouraging. (Even small model aircraft that would be incapable of carrying an electronic conspicuity device will have a pilot operating it, who will almost certainly have his smartphone in his pocket.)
Proposal I. Drone Traffic Management: We support this general concept and plan. But this needs to be quite separate to leisure drone and model aircraft flying.
Annex A is for Manufacturer and Vendors
Annex B is for Commercial Users.