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Summary of advice about the "drone" enquiry of EASA

Summary of Europe Air Sports and its members position on A-NPA 2015-10 Prepared by René Meier Europe Air Sports, Programme Manager European Powered Flying Union, President Aero-Club of Switzerland, Member of the Committee, head International Affairs

Europe Air Sports (EAS), on behalf of all its member organisations and members, thanked the Agency for preparing this A-NPA dealing with a subject of utmost importance to all of us. The
organisations count some 680’000 members, a very high percentage started aviation activities by building their own model aircraft for sports and recreational purposes.
Today, EAS is concerned because aeromodelists forms the largest member group within the organisation. From this perspective, it would be dramatic for aeromodels to be included in a future “Basic Regulation” Model flying has been performed safely for many decades in a club environment, which provides dedicated training and ensures the responsible operation of aeromodels. For the sake of the future of aeromodelling it is the unanimous opinion of our members that model flying performed safely in a club environment must remain inside “Annex II” of the Basic Regulation in force and thus continue to be regulated nationally, in accordance with the principle of subsidiarity.
EAS is concerned because the future regulation would jeopardise the protection of our members flying powered aircraft, sailplanes and balloons or the hang-gliding and parachuting activities. As regards our members engaged in manned aviation we stress that drones must not undermine the safety of any other airspace user.
As most of our operations are performed according to the visual flight rules we insist that drones must be fitted with reliable see and avoid technology, able to see and avoid non-cooperative aircraft. We do not accept any attempts to bring about new equipment requirements for existing airspace users, as they do not generate any benefits for recreational aviation, while having the potential to generate significant costs, not to mention technological challenges when it comes to fitting advanced electronic equipment to a non-powered aircraft, such as a hang glider, or a sailplane. We do not want to install new and costly equipment on-board our aircraft. We do not want to fly according to revised visual flight rules, being obliged to look inside instead of outside our aircraft which would reduce our safety. This would also lead to a sharing of responsibility that we do not accept.
We at EAS have our doubts that this A-NPA really follows the intention of the "Riga Declaration". We think what we got here is a product prepared by those who think “drone” operations are not to be limited and that the other airspace users have to take measures to guarantee collision-free “drone” operations.
Education is the solution, this is more effective than enforcement. We do not see how "police" could deal with the "open category" proposed. We oppose to the risk level assigned to these operations: The risk to the public is not "low", it just is different from the "certified" category.
According to art. 100.2 of the Treaty of the Functioning of the European Union solely air transport falls within the Unions competence. Attention should be paid to this fact when dealing with all other forms of aeronautical activities.
Finally, we do not accept the idea of putting all “drones” of all weights under the European rules framework. This measure is not risk-based, not appropriate and does not increase safety. Furthermore, using weight limits is, in our view, an outdated approach.