UK Legacy Drone Transition Extension – with CAA Interview – Why this is IMPORTANT!
We will also be giving you the details on how your opinion is vital and how to get your voice heard. First up: what are the transitional and legacy periods and why should you care about it? Well, ever since the new uk drone rules came into effect where we mirrored the overall rules in place across esm member states. The uk has been working towards establishing a class marking system for drones that are sold and used in the uk, known in media terms. At least as the sea label system, drones will be classed between c02, the lower the number, the smaller the aircraft and therefore the perceived risk is lower and you can fly it closer to people and even over them, depending on the sea label. Drone you are flying and the certificate you hold from the uk caa. Then you will get more access to the three open subcategories of airspace a1 known as flying over people a2 known as flying close to people and a3 known as flying far from people. The period manufacturers are given to adopt this system and start marking their drones is known as the legacy period in terms of the drones that we already own. Well, these have allowances under the transitional period, allowing us to still fly certain drones in congested areas, etc. At the end of the transitional period, all non sea mark drones will become legacy. Drones and youll only be able to use them in the a3 open air space, which is far from people and away from congested areas, etc.
So, countryside type flights – really one important exception to this – are drones, weighing less than 250 grams that do not have a c label. Youll still be able to fly these in the a1 airspace, as you can today. Another win there for the mighty dji mini series. Both the legacy and transitional periods are due to close at the end of this year 2022. So that means that manufacturers would need to have the drones they sell in the uk marked appropriately. One major issue with this is the system itself is not ready. Although we have the guidelines available to manufacturers, the standards body who will run the classic system has not been instructed yet so a manufacturer like dji or autel simply cannot start marking their drones. Why do we need to extend a tool? Well, as it stands at the end of 2022, the existing drones we own would become legacy drones and could not be flown in towns, etc. Without a gvc and operational authorization from the caa. There would also be no new sea label drones for us to purchase. So the a1 and a2 subcategories of open airspace would become pretty much redundant to hobbyist flyers. The caa have launched a public consultation to ask the stakeholders of the drone hobby and industry how long an extension should be to both periods. There is a subtle potential within the consultation that could see something new. We could end up with different dates for the closing of the legacy and transitional periods.
This could mean you would be able to continue flying your legacy drones, so existing drones you own, within the transitional permissions beyond the time that sea label drones are available to purchase, which in itself is actually quite interesting. To put it into context, what the difference between owning a drone with and without a c label means in real terms ill. Give you a brief example: owners of the existing model of dji mavic 3, who hold an a2 certificate of competency or a2 cfc. For short. At the moment can fly their drone within congested areas, but they must keep 50 meters away from uninvolved people at all times. Take that same sub 900 gram, mavic, 3, add a c1 label, and not only will you not require an a2 cfc to fly in congested areas, but you will be able to fly without any separation to uninvolved people. You wont be able to have any intentional flights over people, but it certainly lowers the requirements for what is a powerful and capable camera drone. So this shows that there are benefits to both legacy and transitional periods. One forces the manufacturers to produce drones with sea labels, meaning we can do more with them and fly them indefinitely, of course, or until the next release catches our eye, the other. The transitional period allows us to fly our existing drones, although with restrictions for longer in towns and closer to people, so you could argue that a mix of the new dates that has a short time to the legacy period, so manufacturers adding labels to drones and a Longer period allowing us to get the most out of the existing drones, we have could be a good mix, it would mean we would have the new drones available long before we have to retire our existing drones to the a3 airspace.
Also, there is a certain amount of natural fall off, of course, as we replace our legacy drones for the latest and greatest and as technology evolves, i havent discussed the potential to retroactively label the drones we own so far today, because the more we go down the Road towards sea levels being a thing the further it seems we get away from a possible retroactive system. This mainly surrounds cost and security. It would cost you to return. The drone to the manufacturer for a labeling and a retroactive system could reduce the security of this system overall and see fake labels flooding the market. It might be possible with the more expensive drones but im, not convinced after the conversations that ive had across government regulator and industry that we will see any form of retroactive labeling system. But i will update you on this when were closer to labels actually happening before. We move on to the interview with the caa regarding this topic. Lets, take a quick look at the consultation itself and the questions it asks, and i mean a quick look because actually, thankfully, this is a very simple and to the point survey. So, as you hit that link from either the caa twitter page, the email they sent out or anywhere else, this is coming from in the description below actually as well of this video. You are presented with this page so, as it says, proposed extension to legacy and transitional uas provisions in the open category.
Now, very importantly, over here, on the right hand, side it shows that it opened on the 22nd of april, but it closes on the 13th of may so its very important that you, if youre, going to respond to this, that you do that pretty quickly. There is also a contact for the rpas policy team, which is uav inquiries at caa, dot, co d uk there, which is useful so the overview we are consulting on a proposed extension to the legacy and transitional category us provisions in the open category and would like Your opinion, unmanned aircraft systems uas operate within one of three categories: open, specific and certified. The consultation primarily impacts open category operations, so essentially the hobby flight area of drones. More details have been set out in this short consultation document. Now, when you click on that, it brings up the uh, the rpas policy team cap, two three four four: i wont go through this. It is interesting its worth having a quick look, because it does explain um some of the uh the basis of this consultation. So the next section here is why your views matter. We do not believe that the uk has in place the necessary infrastructure to move away from non class, marked uas to class marked uas by the first of january 2023, and so would like to consult on a proposal to extend the legacy and transitional period. To allow time for the necessary steps to be taken by government, some of these include establishment of the market surveillance authority, establishment of conformity assessment bodies, creation and adoption of relevant standards.
The purpose of this consultation is to gauge stakeholder support for or against an extension to the legacy and transitional uas provisions described above and for how long and to better understand the impact of making this change or not. The online survey itself is very simple, as it said again, it says 13th of may 2022 is when it closes. You do need to have cookies, enabled on the browser. So if you do have an issue and you disable cookies, thats whats happening so consultation questions whats. Your name whats your email address and whats your organization, if applicable. Now you actually dont have to give this data. The data can be given um anonymously, but one useful thing is that if you do put your email address, you actually get a pdf of your consultation. Confirmation with a unique number emailed back to you from the caa so again here you have the legacy provision. Would you be in favor of extending the provision for legacy category in the uas? Obviously i am going to say yes to that and then for how long? What period from my personal opinion, i would say around 24 months, would be good for this one, because we dont want it to be too long before uh drone companies have to actually start producing the sea label drones. I think that would be good for the marketplace. I think it would be good for the lower end commercial side of things as well.
I would even be tempted to put 12 months, but on the one i actually submitted i put 24 months. Would you be in favor of extending the provisions for the transitional category? In ues – and i would certainly say yes on that 100 and what period for that, i would say longer than 24 months, the longer we can give people to use the existing drones. That theyve already spent a lot of money on the better and then additional comments. Here you can place anything else that you want to put across so, for instance, if youve clicked longer than 24 months, you can put a specific time on there. Perhaps you know indefinite five years ten years, whatever you think that might be, but also give any information and background that you think might be pertinent. This page gives you another opportunity to place your email address in there if you havent done so, otherwise, you can submit the response anonymously to find out more about the current situation and the public consultation. I chatted with a couple of people from the ukcaa, including callum holland, an rpas policy specialist who is actually running the consultation itself and jonathan nicholson, who is the assistant director of corporate communications, yasser have chosen to extend their own legacy and transitional period recently, but chose A date without a public consultation, so they literally just said okay were extending. This is what were extending to. Why has the ukca decided to have a consultation at all regarding this yeah? Absolutely so i i cant speak and i wont speak for the asset.
I think uh there are benefits of opening this question up to consultation uh. It impacts the regulated community, so i think its only right and proper um that we communicate with the regulated community prior to forming our own official opinion and then submitting that opinion to the dft for for consideration. I i think its also, you know ushering in a a new period of stakeholder engagement. You know with the caa and the regulator community. As far as reasoning practicable, you know we we should be having these conversations with the regulated community. You know we know full well. There will be further consultations on other aspects of the regulation coming up this year, so you know we wanted the regulatory community to have a lets. Call it an easy one to start with a relatively straightforward consultation. Yes, so so were prepared moving forward, perhaps more complex consultations in the future. A bit of practice then, as well yeah yeah, one of the one of the big things that uk better regulation always said so theres a set of better regulation principles for the uk and it always says kind of if in doubt consult so you know its its Its kind of the right thing to do in most situations, especially if its like a legal or law change. If you like, yes, excellent, no, i i think its a very good idea. I have to say i i was probably only because it is what a yasser have done themselves.
I was just expecting a hey. Everyone were extending to this period, um and wed. All you know get on with it as it were, but its. So it is a welcome thing. One thing ive noticed is that, obviously, with the with the two, the legacy and the transitional periods being surveyed separately, does this mean we could see different dates for legacy and transitional period ending, or are you still looking to cap them at the same date? So no substantive decision has been made either way on that yet uh yeah theres lots of things that need to happen before we make that decision um at the top of that is review the consultation and see what the people have said and what the people have Asked for you know i can make an educated guess, an assumption that the two dates are probably going to align um in the consultation and in the cas opinion um, but were not there yet in terms of making a substantive decision um, we need to wait for The consultation to close and review the answers first, excellent, because i think that thats been the one of the hot topics in in the forums etc. So far, is that actually could we end up with a situation where the sea label drones are out on the marketplace? So lets say: the legacy is, is capped at a year, but transitional goes on for three or four years. Um and obviously then you you you do have that sort of um which which to some hobbyists would make sense and if thats, what they think you know.
If thats, what people want sure then say so, you know get them to do the consultation and get them to say that exactly exactly indeed – and i i think so far of those people that have told me that ive completed it and looking through comments and and Forums, i think a lot of people are saying that at the moment that actually they would like us as long as possible on the transitional side of things just so they can keep using their existing tech. We we do have an advantage, of course, that um with drones, the fact that dji keeps throwing them out every every couple of weeks at the moment and also just the way that tech moves on there is a natural fall off thats going to happen as people Renew into the sea labels and that type of thing, but there are there – is still a large group of people that hang on to their drones for a very long time going by the questions. Obviously, the first question on both of them is: should we extend? Is there a chance that there will not be an extension absolutely if that option exists um if there wasnt thered, be no need in the consultation um. So all options are on the table at the moment. Okay, excellent, its good to know because again everyones talking about how long, but of course we we also need to think about that thing of uh.
Should we at all on on on either of these things, absolutely um theres, a relatively short amount of time on this um uh, with with the with the closing date was? Was there a reason to keep it? That short, i mean. Was there a reason to not have it open for a little bit longer? No, not particularly um. This is when weve decided to publish the consultation, uh theres, theres, no particular more reason. We we have enough time as it stands now, for you know to push our opinion when we form it to dft and for a decision, uh dft, to be able to take a decision and make the decision uh in time either way on. On the 1st of january 23 that theres no particular reason this date was picked. Okay, excellent lots of things like this as well. We always find that the people who are going to respond respond quite quickly. Yes, people who really want their views heard have probably either already done it or just about to do it or thinking bank holiday weekend ill. Do it, then? So you know its its, not something that you know these kind of consultations really drop off the responses. Both periods have an option for longer than 24 months and again feedback from our viewers and and on the good old forums, etc. For people who are completing the survey and mentioning ticking the box and then mentioning in the comment section that they would like it.
As long as five years or maybe even possibly longer, could this be possible in terms of um, a regulatory from this from the goals of this process of obviously switching across to to see label drones? Is it possible to have a transition period that could run as long as five years or more anythings on the table? You know we need to wait for the end of the public consultation to see what the regulated community want. I i i think you know fundamentally its in the title transitional um. There needs to be a transition, its its built into the regulation. For the reason you know the the reason that we are, we want to develop the class marketing standards and bring class mark uas. Uh uh into the open cap is because of the benefits that they bring to safety and the consumers um. So i wouldnt envision a a a no end date to the transitional or or legacy category im interested to see what the regulated community think it should be and thats why we gave that i believe its plus 24 months 24 months, thats right. Yes exactly, but that thats thats a good message to put out there as well, because again, um um. You know people are sort of not excited about it, but but certainly getting sort of hot about the fact that we could have a very long transitional period. And again, as you say, it does have the word transition in there.
So we do need to to get across there, um so with within within the first page of the public consultation mini sites. There is a a brief explanation of the hurdles, the the issues that that are preventing it at the moment. So could you just explain to our audience what what are those hurdles that that are stopping us being able to go through this? This existing date, yeah, absolutely um, theres lots of idiosyncrasies in terms of the issues that weve broken down into three primary ones. That doesnt mean that theyre, the only hurdles that we need to overcome there are others, but these are the main ones: um, the the first one being the department of transport alongside bsi, need to create and adopt the relevant standards for class smart uas. Clearly, manufacturers cannot start building uas that conform to class market standards until those standards exist. Yes, that thats kind of number one and and its and and its also just a sort of job, its also worth giving the audience the separation of um. There are the guidelines so the so. What what we expect the standards to adhere to are. It is in cap 722 et cetera, and so so we know what theyre going to be, but thats still quite a distance away from being an actual label and actually being a a standard that that the manufacturers can can actually adhere to. Because of course, there are so many steps to that process to make sure their aircraft are compliant because its going to be effectively yourself, theyre going to say yes, this drone does comply so heres the label um, so it isnt just the fact that these these these Guidelines already exist its actually having to put those into being a standard, and for that we need to standards body, but i thought just thought thats worth clarifying for the audience.
Absolutely yeah could not have put it better myself. You know, and coming on to that, you know once the standards are developed and adopted and aircraft are being manufactured in line with those standards. There needs to be a what we call market surveillance authority, um, an msa, a and thats a a state based uh organization. Um, that has oversight of these uh aircraft coming these products coming onto the market uh, and in line with that we have conformity assessment bodies and all of these bodies and authorities need setting up um. You know by government by support through tft, and then you know, by support from the ca2 in order to ensure that when these aircraft are placed onto the market, first of all, what the stamp says it is on the side of the box. The aircraft actually conforms to that standards and also to ensure that we dont get fraudulent uh. You know class marked aircraft into the united kingdom as well, and i i i cant remember if its on your channel or not, but i remember reading recently i think weve actually seen appear in europe. A couple of drones with thats right. Look like class mark stamps on the side of them, so you know we need to build the authorities and the assessment bodies that are going to ensure that all of that is kept up to scratch and in line with the regulation talking again about labeling, would it Be likely in your opinion, as somebody who is a um uh im, putting on the spot as someone on the policy team here um.
Do you feel that it is likely, bearing in mind all the hurdles that are already there just to get the c label marking system into place that retroactive labeling will be possible? And – and i know you knew this question was going to come up. I im going to give an open, ended, non definitive answer as im sure you probably expected. I think you know, because we are yet to see the relevant standards and what those standards require. First of all, its impossible to answer that question um, whether or not thered be scope, because we dont know if the standards will include some form of physical stamp onto the plastic chassis of the body um, as opposed to the application of a sticker um. And if it does require some form of indent on the actual chassis of the aircraft itself, could you still retrospectively do that if you ship your aircraft back to the manufacturer, and they do that on your behalf, um we dont know yet is the answer im afraid Im, sorry, is it, is there any policy? Is there any direction to to not have that to to to to ensure that its not possible, or is it simply the case of once these standards are in place if thats, something that is possible and the manufacturers can prove, is secure and isnt a ebay, special Um that thats something that the dft obviously who i i realize you cant speak on behalf of, but the caa as well – would be open to yeah.
So what i can say on that is we havent discounted the option yet? Is there any other particular message that you guys want to to get across? All i would say, is you know these two questions or on on legacy and transitional? They might seem relatively straightforward and innocuous, but i i think its really important as the community. You know we, we are one industry together at the regulated community and and the regulator that the more we can you know further collaboration and do these consultations and have stakeholder engagement, the better it is for everybody, so i would just really promote if anybody hasnt done. The consultation, yet please do and we we do also have a fifth question. As im sure there was a scene at the beginning of your video, where you have an option to add any additional comments. So its not just a yes, no thank you and you can add additional comments and thats all id like to add to the end of that excellent cool, and i was just going to remind people where it is just in case they havent seen it so im Sure youll put a link in short, yes, theres, a link in the description you can find it on the ca twitter feed. If, if youre registered, you would have got an email by now as well, so so check your email, inbox, etc, yeah, and what actually i i do like about it is.
If you put your email address in on the um consultation itself, you actually get a pdf and a unique number to show that your your voice has been heard. Basically, there is a link to the survey in the description so head over there now and complete it with your own preferences. Certainly, it would seem that from a hobby perspective that a longer transitional period would prolong the usefulness of our existing drones also remember to place any specific comments you have within the section. At the end, we will of course keep you fully informed of any developments on this topic.