South Cotswold Soaring Association:

Photo: Phoenix 1600 on Minch Hi, I do not normally write letters of complaint, but I feel that in this case I have to express my disappointment and disgust at the CAA’s consultation document (CAP1775) re. the registration scheme for model aircraft fliers in the UK. I, like many other responsible people in the UK, have been flying radio controlled model aircraft for over 40 years, without any problems or safety concerns. However due to the alleged recent actions of a few irresponsible drone operators, we are being “tarred with the same brush” and are being forced into a registration scheme, even though we have caused no problems. I think this is grossly unfair. The EASA Basic Regulation (EU) 2018/1139 states model aircraft operators must be registered. However it also acknowledges that model aircraft have had a good safety record, especially for the members of model aircraft associations who have developed codes of conduct for safe and responsible flying. In the UK this association is the BMFA (British Model Flying Association), of which I have been a member for many years. The BMFA has been negotiating on behalf of all its members with the CAA to agree on a sensible, practical and reasonable solution to the EASA regulations. However recently the DfT/CAA have issued their “consultation” (CAP1775) and have imposed a registration scheme which will be charged at £16.50 per annum. This is grossly unfair for a number of reasons. 1. EASA regulations permit the BMFA to register its members on the registration scheme, without having those individual members having to register themselves. The CAA consultation does not permit this, despite the EASA saying this is acceptable. 2. The CAA consultation has imposed key policy decisions (such as age limits & competency requirements) without either consultation or discussions with the BMFA. This is inconsistent with the EASA regulations for flying model associations 3. In France, the equivalent registration scheme is free and valid for 5 years. Why should we as an EU country be treated differently? 4. The CAA state they “drive to be a transparent, fair and effective regulator”, however they have imposed these regulations without consulting the relevant association (BMFA). Imposing the registration scheme without consultation goes against their own aims. In addition the CAA operates within the governments Better Regulation Framework and its regulator code, to which all UK regulators must comply. In this case the CAA failed to comply with government regulations for the following reasons~: Proportionality – regulators should only intervene when necessary, remedies should be appropriate and cost minimised. EASA and CAA have long recognised that model flying has always had a very good safety record, even for the majority of drone operators. However recent alleged “rogue drone operators” have led to the CAA imposing draconian regulations on all model aircraft operators. This is disproportionate to the real problem, especially as it’s hasn’t actually been proved that drones were actually use in the Gatwick incident. Consistency – Government rules & standards should be applied fairly. The proposed regulations are not consistent with the rules applied to other forms of aviation in the UK, even those with far worse safety records. No other recreational aviation activity requires the pilot to register annually or repeat theory tests every 3 years. This is inconsistent and unfair to model aircraft pilots Transparency – regulators should be open and keep regulations simple and user friendly. The CAA has not been open with the BMFA with the development of these regulations. In CAP1123 (response to the “red tape challenge”) the CAA say emphasised the “values that we place on an open and meaningful dialogue with the aviation community”. However in this case, they have imposed registrations fees and changed flight restriction zones, without consultation. This goes against their own values. In order to keep the registration scheme simple, it would be a lot easier to allow the BMFA to register its members on their behalf, rather than individuals having to do it themselves. Targeting – regulation should be focussed on the problem and minimise side effects The proposal is not targeting the problem. The “problem” is acknowledged to be with “rogue” multi-rotor drones, not with the long established model flying community. The CAA proposal targets all model fliers, despite the EASA concessions granted to model fliers and ignoring the widely recognised good safety record of traditional model fliers. Accountability – regulators should be able to justify decisions and be open to public scrutiny As the CAA has not consulted with the BMFA on this proposal, they cannot justified their decision to impose a regulation, which is inconsistent, disproportionate and incorrectly targeted.