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Old 16th Dec 2016, 11:24
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TelsBoy
 
Join Date: Feb 2016
Location: Hadley's Hope, LV426
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Speaking both as a pilot and as an engineer I have major concerns about the development and seemingly uncontrollable exponential prolifigation of UAVs. Aside from my strongly-held beliefs/bias that humans should always remain in executive control of machines, preferably not remotely, and that people should not be shafted out of jobs by technology, I strongly suspect the Amazon scheme is a gimmick which will quickly die off once the realities and practicalities to make it happen are finally understood, which clearly at the moment aren't.

In my view the current regulation and training (what training?) is wholly inadequate for the present. The purchase of UAVs is not controlled, Johnny Bloggs can buy one from Argos and fly it around his local international airport theirby causing chaos. Yes he may be prosecuted under the ANO for its breach (if he's caught) but what is stopping him in the first place and why are these things freely available without any need for licensing, understanding of principles of flight, air law etc.?

I have held a PPL for 7 years and have been gliding for the past 2. In both cases I had to prove I had a sound understanding of principles of flight, air law, meteorology, navigation etc. before I was entrusted with the command of an aircraft. Why should this be any different for the operator of any UAV? Most RC clubs have training/awareness and are sensible about the operation of their machines, UAV operators should require the same as a minimum. NATS run awareness courses for UAV operators, however attendance is completely voluntary.

Serious questions require to be answered both in respect to the Amazon Drone Delivery and in regard to wider UAV ops, specifically:-

-What safeguards are in place to cover loss of control of the UAV? Have eventualities been covered in any pre-flight plan, e.g. landing sites, recovery procedures, risk of damage to property/life, and what are the mitigations?

-With respect to the above, is there a pre-flight plan made by the operator and sent to any agencies as required (emergency services, ATSUs if required etc.), covering the task, route and any eventualities as described above?

-What are the contingencies in place dealing with uncommanded release of payload, where is the risk assessment and what is the mitigation?

-If flight is made within the boundary of an ATSU and/or inside CAS, bearing in mind all airspace is within the control of the parent ATSU down to 0' AGL, what are the methods of gaining legal and safe access to the airspace, ensuring the legal requirement (where required) of two-way RT contact at all times with the ATSU, and ensuring safe separation with other aircraft in the vicinity/airspace?

-How are these aircraft (as that is what they are) safeguarded from infringing ILS approaches, other navaids and Radar systems? Granted most UAVs' construction will give a very negligible (if any) radar return; which leads to a further question:-

-If the aircraft is to be operated within a Transponder Mandatory Zone/any other zone where Primary, Secondary or both contact is essential, how will the aircraft be tracked in order for the ATSU to be fully aware of its position at all times, and therefore how will the aircraft be able to be legally and safely operated in such airspace?

-If the aircraft is to be operated in IMC/at night, what separation limits apply, and how is a UAV separated in IMC from other aircraft?

-If operated in IMC, what navigation aids will the aircraft use to navigate, what instruments are available to the operator/pilot in order to conduct save IMC flight, and will an IFR flight plan be required in CAS?

I can think of many more questions but my brain is starting to hurt.

There are a few major worries I have; firstly, clattering in to one of these things when I'm in a glider working a ridge; secondly, some idiot terrorist using one to cause all sorts of mayhem using certain payloads; thirdly, Mrs Miggins at 31 Acacia Avenue getting their Bergerac DVD box set delivered by Amazon Drone (because they "need it now" ), the machinery develops a fault, there's an uncommanded payload release or the UAV stops flying as well as it was and then some poor sod or his house/car gets clouted by said box or UAV falling from a couple of hundred feet.

For me, until these questions are all fully answered, UAVs remain a significant flight safety risk and should be treated as such.

There are many sensible UAV operators out there who do understand the ANO, who stay away from airports and who know and follow the rules and have a safe operation, I take my hat off to them. It's worrying that not everybody has such a professional attitude. Only suitable education and robust legislation will ensure that safety is upheld. Otherwise the worrying trend in airproxes will worsen and will end in an accident...

TelsBoy
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