Draft Car Sec. 3 Series X Requirements for Civil Remotely Piloted Aircraft System (RPAS)
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In view of the Captioned Draft Regulations on which DGCA has sought comments by 1st Dec. 2017, we wish to submit the following:
- We write on behalf of the Aeromodelling Fraternity in India, which is engaged in building and Flying of Model Aircraft for hobby/recreation and educational purposes through many decades.
- We would like to expressly state that we do not claim to represent any activity by Drones and Multicopters, which have recently entered public domain and which have become a cause for concern globally.
- We feel that the CAR Draft has been perceived primarily with reference to Drones, whose flight characteristics and envelop are grossly different from regular model aircraft flown for sports, hobby or recreational purposes.
- Our indulgence is limited to Fixed Wing Aircraft, Gliders and Helicopters in small and scale sizes. We fly exclusive for fun, without seeking any commercial benefit.
- There exists a large number of Model Aircraft (approximately 10,000) which are being flown across our country, in all sizes, by enthusiast and students of all groups and ages. Aeromodelling has been prevalent in our country through almost 60 Years. There exists no significant history of it causing any harm or damage to society except for the recent controversies regarding Drones.
- The definition of Model Aircraft, as stated in the CAR Draft, from our perspective, is grossly inadequate. It is totally suppressible of an otherwise safe and intelligent sport. The limitations of Size by weight (2 Kgs), Height (200 Ft) and other compliance of UIN and UAOP will render this great hobby and sport impossible and unsustainable. These limits may be suited for Drones, but for other types model Aircraft they are virtually impossible to observe. They would limit the sport to very small foam models which are been flown normally by kids in parks and destroy any prospects of development of this sport to any maturity both in terms of entertainment and technical levels.
- Our Rules Governing the Sport, Hobby of Aeromodelling when used for recreational and Educational purposes should be harmonized in line with regulations framed by most of the developed/developing worlds rather than a proprietary outlook.
- Inputs from The Fraternity of Indian Aeromodellers, as the real Stake Holders, should be given due cognizance, before framing rules upon such a subject, in the public interest.
Considering the compulsions with the onset of Drones may we suggest the following:
We urge for the following changes to be incorporated in the Draft Policy primarily to enable the continuity of the sport of Aeromodelling for hobby/recreational and educational purposes:
1. Separate category be created within the UAV Classification, for Model Aircraft for sports/Recreational and educational purposes
1.1. Comprising of Drones & Multi-Rotors-
1.1.1. Not exceeding the Maximum Take Off Weight of 2 Kgs.(or as may be decided by the competent authority)
1.1.2. And Flying Height of 200 Ft. AGL. (or as may be decided by the competent authority)
1.2. Comprising of other types of Aircraft like Fixed Wings, Gliders and Helicopters with or without power drives –
1.2.1. Not exceeding the Maximum Takeoff Weight of 30 Kgs.
1.2.2. And Flying Height of 400 Ft. AGL
2. Such category of Model Aircraft to be exempt from licensing requirement under UIN, UAOP and other regulatory conditions of Aircraft Maintenance etc
3. Flight envelop would be limited to line of Sight in good light conditions only
4. Model Flying prohibited within a radius of 5 Kms from all operative airports.
5. Model Flying should be prohibited in Notified, Densely Populated, Restricted, Defense and other sensitive areas including all ‘No Fly Zones’
6. Model Aircraft to accede priority to all other types of aircraft.
7. Model Aircraft flown for Recreational purposes to be prohibited from:
7.1. Carrying any payload other than those essential for enabling the flight requirements.
7.2. Flying for any purposes of Commercial Benefits, except prize considerations in competitive events.
7.3. Model Aircraft to be prohibited from undertaking any Aerial Photography, surveys, Surveillance and such other activities endangering public safety or privacy except when so authorized by competent authority.
8. Local Schools, clubs and other registered bodies whose members engage in Model Flying should be advised to maintain a record of all pilots and their identities. Such bodies should also be entrusted with the responsibility of following a disciplinary code conducive to safety and environment.
9. Model Aircraft flying should be free from any age restrictions.
10. Trade, Import, building and construction of model aircraft and its accessories, used for hobby, recreation and educational purposes, should be allowed freely and be exempt from any regulatory controls of DGCA.
11. Aeromodelling as a sport/hobby for educational or recreational purposes should be promoted and encouraged.
12. National and International conferences, trade shows, competitions events for aeromodelling should be encouraged and promoted by Government bodies to help India and it’s sportsmen gain a leading position and recognition in this arena.
13. A Model Aircraft, by itself, is not built or designed for any subversive activities. Intentional Misuse of any manner is a matter of human default. Necessary Rules should be framed to prosecute the offenders of discipline, rather than curb & stifle the activity of Model Flying as a whole.
We Request you to kindly reconsider your proposals in light of the above and incorporate the same into your Air Transport Circular. The above changes are essential for the survival of this sport, lest we lose a healthy and extremely creative sport, to overt regulatory parlance.
Federation of Indian Aeromodellers’ Associations
C/O: Wings India | Growel House | Akurli Road
Kandivili (E), Mumbai 400 101, Maharashtra
Tel: +91 22 6699 3000 | Fax: +91 22 6699 3010
For further Queries and Clarifications, please contact Mr. Wasi Ansari at firstname.lastname@example.org
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