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Author Topic: The CAA on Drones  (Read 305 times)


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The CAA on Drones
« on: August 11, 2019, 02:07:37 AM »

To the CAA

I have just received notification of the revisions to CAP 722 and am currently going through it. I notice that under Glossary of Terms you state :

Model Aircraft - Any small unmanned aircraft which is being used for sport or recreational purposes only.

However in the text you refer to both model aircraft and drones, yet offer no definition of a drone or mention it under the Glossary of Terms.

I have previously contacted you for a definition but have not received a reply. I have also contacted the DfT with similar lack of response. Contact with the Airprox Board did illicit a response to the effect that they had no definition but used the word in the commonly used sense of it. This presents a problem because there is no concensus on it's definition.

Much of your literature, both graphically and written, depicts model aircraft and drones as separate and different. I clearly understand that the regulations for Small Unmanned Aircraft apply to both but would ask you once again to provide a definition of a drone and how it differs from a model aircraft.

The purpose of asking is to clarify this for operators of both model aircraft and drones. In discussion with numerous parties flying recreationally, I have had the following responses to the Drone Registration Scheme and DroneCode :

"I don't fly drones so that doesn't apply to me"
"I know a drone when I see one"
"They are all drones"

If you are to continue using the word drone I think you ought to make it clear what you mean in order to avoid confusion, misunderstanding and misinterpretation.


Dear :-)

Thank you for your enquiry. The term ‘drone’ is only referred to in CAP722 in the context of the ‘Drone Code’ or the ‘Dronesafe website’, the term Unmanned Aircraft is used everywhere else in the document.

‘Model aircraft’ is a subset of the wider term, Unmanned Aircraft- and as such, is defined separately in CAP722. The registration scheme and pilot competency requirements apply to all small unmanned aircraft, regardless of whether they are  a model aircraft or otherwise, and the communications and publicity that surround this will reflect this.

We have not included a definition of ‘drone’ in CAP722, as this is not a term we chose to use, the correct term is Unmanned Aircraft, which includes model aircraft, multi-copters, fixed wing UAS, and any other platform that fits within the definition.


James de Beauvoir-Tupper
UAS Policy (Operations)
Unmanned Aircraft System Unit
Safety and Airspace Regulation Group

Dear Mr Beauvoir-Tupper

Thank you for the prompt response.

I would agree with your reply in the context of CAP 722. However where I have a problem is the extensive use of the word "drone" generally in the CAA's literature and the very obvious differentiation between drones and model aircraft. I find that many people regard drones to be multicopters and this is certainly reinforced graphically by the CAA's depictions in the DroneCode and Dronesafe to name but two. This is further reinforced by a document (20190219-FAQs_Drone_Flying_2019_Update.pdf) I received yesterday as part of an automated response to my query.

The section "2, What is the difference between a Drone and model aircraft?" looks promising but unfortunately has some misleading presumptions.
"A typical multi-rotor drone is capable of automatic stabilisation and navigation, in addition to being controlled from the pilot over a radio link."
 While most mulitrotor drones have automatic stabilsation, I would suggest that a significant number do not have any form of navigation. I have 7 such multirotors only one of which has navigation.

"The traditional model aircraft is usually only controlled by the pilot over a radio link, requires much greater pilot training and skill, and is flown only at specific recreational sites away from persons and property."
 While this is traditionally the case, there are increasing numbers of traditional looking (fixed wing) model aircraft with automatic stabilisation and also sophisticated navigation capabilities - waypoints, return to home, etc.

The point I am trying to make is that, lacking a clear definition of what constitutes a drone as opposed to a model aircraft, whilst continuing to use both terms, is leading to confusion, misunderstanding and misinterpretation on the part of the operators, the public and, worryingly,  those charged with reinforcing the regulations. The DroneCode and Dronesafe are very misleading and I would reiterate my earlier experience  "I don't fly drones so that doesn't apply to me". If the object of increased regulation is to make the skies safer, I would suggest that the CAA does not muddy the waters by using the term drone without offering a definition. Many documents start with definitions and a glossary of terms so I cannot see why this should not include drones. After all the point of the document will be partially defeated if there is no understanding or agreement on the terms used.

For your information my own involvement with small unmanned aircraft encompasses freeflight, control line and radio control disciplines using fixed wing, rotary wing and multicopters. Professionally I work in rotary wing aviation, in particular design and compliance verification. I am very familiar with aviation regulation and consequently have less problem understanding this. However, recreationally, I find a great deal of confusion both within clubs and the general public. It would appear that we are stuck with the word drone, which I find unsatisfactory and lacking a clear definition when it comes to trying to have a discussion or educate people. I hope I have managed to convey this without appearing to simply nit-pick.


Dear :-)

Thank you for your comments; in the context of our wider communications, the use of the term ‘drone’ is slowly being phased out, in favour of the term Unmanned Aircraft. You should start to see changes on our website, and any external communications in due course. The umbrella term ‘UAS’ is a broader term, which encompasses multirotor, fixed wing, gliders, model aircraft and any other unmanned platform. We will continue to distinguish between model aircraft, and all other UAS, and acknowledge the colloquial use of the term drone, but will not define it. Hopefully this will clear up any confusion- and our communications regarding forthcoming registration and pilot competency requirements, and the EU regulations, will be clear in the applicability to all unmanned aircraft.

Best Regards

James de Beauvoir-Tupper
UAS Policy (Operations)
Unmanned Aircraft System Unit
Safety and Airspace Regulation Group

Natibus in luto, caput inter nubila.

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