Access to airspace closer to the ground, like below 300m (1000ft) above ground, is becoming a vaunted commodity. Private, public and commercial interests in drones, unattended aerial systems, and also our friends of long-time, aeromodelling, take up an increasing role in this airspace that has to be shared with manned aviation, in particular all kinds of general aviation using this airspace. The hazards of all players using the same airspace are obvious. Aeromodellers are now asking to use airspace up to 300m AGL in designated locations.
From our point of view an authorisation of aeromodelling up to 300m above GND in a cylinder with a diameter of some hundred meters will create conflicts and collision risks with other air traffic.
The top of these airspaces is at minimum 2000 ft MSL. All fields are located in airspace G. The top of airspace G is 2500 ft MSL except at Feulen, where it is 3500 ft MSL.
As an example, VFR aircraft leaving and entering ELLX CTR are flying at 2000 ft as required. The consequence is, that many aircraft are flying at 2000 ft in the vicinity of the CTR. Most of the model aircraft fields are located close to the CTR boundary. Aircraft flying at 2000 ft outside the CTR can collide with the upper part of the model aircraft “cylinder”. The most risky and worst situation is found at Lintgen. The model aircraft field is located between the entry route MERSA – BRAVO and the exit route to CARLI. The distance between the centre of the field and the inbound and outbound tracks is only 1770 m respective 2000 m. Taking into account accepted tolerances (+/-150ft, +/-10°) for VFR flights, these routes come very close to the aeromodelling fields.
Moreover, barring other restrictions, SERA visual flight rules allow outside congested areas for: “elsewhere at a height less than 150 m (500 ft) above the ground or water, or 150 m (500 ft) above the highest obstacle within a radius of 150 m (500 ft) from the aircraft”. This allowance is not compatible with aeromodelling flights up to 300m above ground.
We also wonder how it is assured to keep visual contact with the model aircraft at 300 m AGL and how can it be guaranteed that the model aircraft stay within the “cylinder”?
In summary, we feel that EASA requirements to operate model aircraft below 120m AGL are made to mitigate risks and stay compatible with other rules of the air and should not be modified.
We think that there are more questions which must be discussed and answered.