The death of the land line?

My wife and I had a 25 year renewal of vows this weekend (I don't blog everything, any family wanting to see the pictures, just ask).

On Saturday night the family had the lodge at Peckforton Castle, and Sunday morning the girls were there getting ready. The whole area has really poor mobile signal, even outside, and the lodge had no wifi! It was meant to have wifi but something was not right (and no, I could not fix it).

This was something of an inconvenience. We had people arriving on the Saturday night to other hotels and people arriving all Sunday, and we were trying to keep in touch, check when people were arriving, try and get a message to someone to get some cufflinks as James forgot them, and so on. A total lack of any workable Internet was a pain. Even when I went up to the castle when the bride got ready I had no communications with the family in the lodge.

It was only when I considered writing this blog post this morning it dawned on me. There was a phone in the lodge. I just had not really occurred to any of us to use it to contact people!

To be fair, most of the communications did not want to be the type of interruption of a phone call, they suited a message which could be read later.

But this really does show how massively times have changed in just a few years. It has not been long since a time when there were no text messages or even mobile phones in popular use. Just a generation ago the phone in the lodge would have been the only communication one would expect to be able to use.

Clearly the land line is on the way out, replaced by mobiles and non voice communications.

Leaving the EU

Not a lot I can say. Started the day with something along the lines of "Holy fucking cow"!

I cannot really contribute to the analysis of what is happening today and what will happen next. There are a lot of people reporting that in a lot of detail.

Democracy is all very well, but sadly the only qualifications required to vote are that you survived to your 18th birthday, can find the polling station, and can spell "X".

P.S. Someone took this post as insulting. I was not trying to be insulting, sorry. I think that most people voting on this issue, myself included, lack the necessary experience or qualifications in politics, or economics, to have been able to make a remotely informed decision. We all went on gut feeling or propaganda. That is a problem with democracy, but it is the best we have at the moment.

Droney McDroneface: Day 4 (I passed!)

Well, day 4 is a half day, and we covered a bit on human factors, a planning exercise, and THE TEST!

This is the theory part, and I am pleased to say I passed. The questions were very easy, but a couple I was unsure of as I felt more than one answer may be valid. As it happens I got 5 wrong, and they will let me know which of these next week when the send the certificate. I can think of at least 2 I was really unsure of, but 5 is actually a lot worse than I expected, it means I only scored 91%. Pass level is 70%, so perfectly good, but I am kicking myself anyway, sorry.

The next steps are that I need to practice flying a bit, and we need to make an operational manual. Then I can book in for a practical in a few weeks. Right now I would not pass that, but in a few weeks with a few hours practice, I don't expect it to be too hard.

What I did see is at least three errors in the questions, which I noted :-) They kept referencing Kelvin metres not kilometres.

The good news is Alex passed too, same score.

P.S. Revised (audited) result, I got 94.6%

P.P.S. I now know the 3 questions I got wrong. One was bang to rights, I forgot wind is described by the direction it comes from (bloody stupid system). One question was ambiguous and I did know the answer if only I had understood what they meant by the question. One question did not list any one right answer as all answers were dependant on other factors - I picked one of the valid answers but not what was expected. I hope the improve the test.

P.P.P.S. Seems I actually got one other question wrong too, but I answered as per the course. I.e. the course was wrong, in that it asked the baseline number of satellites in US GPS system, and I answered 24. Apparently as of June 2011 it is 27.

Droney McDroneface: Day 3

Today we covered more on weather, and operational manuals, and some details of the practical flight test.

One of the key things for the PFAW (Permission for Aerial Works) is that we have to produce an operational manual. This includes a volume (1) on the company and the work we will be doing and our various procedures for operation and risk management, etc. A volume (2) on the technical details of the aircraft. And finally, optionally, a volume (3) making the operational safety case for extra permissions, if we need them, such as working closer to people and buildings in congested areas. Volume 3 is tricky to get and may require showing some operating experience, so we are not going to do that yet. Some time next year we expect rules to be relaxed in various areas anyway so may not be necessary.

I have to say that it has not been 100% clear what the course gets us, so it is worth explaining in a little more detail...

What do you get from a CAA PFAW course?

The PFAW is something the company gets, and can then engage pilots that have passed the theory and practical tests. Obviously a lone operator can get the PFAW themselves and be the pilot. Hopefully we (Alex and myself) pass the theory tomorrow, then come back in a few weeks for the practical. Once we have our operational manual we can apply for the PFAW for the company.

Without the PFAW there are rules for small unmanned surveillance aircraft (SUSA), and for a congested area these are quite strict - not over or within 150m of a congested area! Also not within 50m of a person or structure not under our control (30m during take off or landing).

Given that a congested area covers anywhere built up in a town or city or settlement (anywhere that is substantially used for residential, industrial, commercial or recreational purposes) that pretty much rules out getting close to anywhere in a town or city or settlement. Even with permission of all of the home owners near me, I could not fly up by my house as I live in a residential area!

What we get with the PFAW is a basic or standard permission: "The standard CAA permission for SUA/SUSA in the 7 kg or less category allows flight in congested areas to within 50 metres of persons, structures etc. (or within 30 metres if the persons are under the control of the person in charge of the aircraft). This category of SUA/SUSA cannot fly within 150 metres of open-air assemblies of 1,000 people or more where only a standard permission has been granted."

Update: I assume that is bad wording and they do not mean "to within 50m" as 10m is "within 50m". I assume they mean 50m or more, sort of "without 50m" :-)

This is good news as it removes the restriction for a small drone operator operating in a congested area, but leaves the 50m restriction for structures or people not in control. Oddly it also imposes a 30m restriction for those that are (a restriction which does not apply outside congested areas!).

The 50m/30m may not be an issue, assuming, as we are, that it is a straight line from aircraft, as one can take off to over 30m height, and then be close (horizontally) to my house or neighbours houses yet outside these distance limits because of height. There may be a slight issue with finding somewhere to validly take off or land. It will be interesting to see what a PFAW says about that though.

One question that came up on the course, and the answer was not 100% confident (sorry heliguy), was that these distances are 3D, i.e. "piece of string", distances. From aircraft at height to the object/person. So if allowed no closer than 50m that could be achieved by being 1m away horizontally and 50m up. Pythagoras do your worst. This is confirmed by a phrase in IN-2014/190 and CAP 722: "In any circumstances or weight category, it should be noted that flights directly overhead persons and vehicles will not be allowed at any height in a congested area unless they are under the control of the person in charge of the aircraft.". The fact they have to say this means clearly that the height is a factor in the distance calculation, i.e. we could fly 30m over our heads (if in our control). Good news, though I may need to buy some hard hats to mitigate risks.

Update: CAA have confirmed that these distance rules really do work as a direct 3D line, so height is part of that.

Getting these distances reduced is what takes a lot more work and an operational safety cases in volume 3 of the operational manual. However, the fact that the height is a factor means I should be able to fly high enough to avoid the need to get permission from my neighbours to take aerial shots of my house, and can even fly over my house (at least 30m above - though it is a structure not a person so maybe closer is actually allowed) as I control it. This is once I get the PFAW. Indeed, the documentation does say that this basic permission will be suitable for video of properties, filming, etc.

I do think heliguy should have had a slide right at the start stating clearly the rules without PFAW and the rules with PFAW - a clear indication of what you are getting by doing this course. It was not obvious to me, or others on the course, until just now that for under 7kg the basic PFAW allowed work in congested areas. I'll give them feedback on the final day tomorrow.

Somewhere to practice...

Before I do the practical I will need a bit of practice. The test involves a few basic flying manoeuvres, but as I have had exactly 20 minutes total flight time so far, I am not quite up to them yet. So where can I practice?

One possibility would be a field, with permission from the owner, and not somewhere the public are likely to access (and not near power lines or flight paths, etc, etc).

But one interesting possibility is the office car park, at a weekend!

There are two ways to do this - one is pretty clear cut and involves removing or disabling the camera so I only come under the non-surveillance rules. Then there is no issue as it is clearly "safe" on a weekend, with nobody else around.

The other is more creative, and I am trying to find a reference for this. But the idea is simple. The definition for that area to be a congested area would mean it has to be substantially used for industrial use. Well, the argument is, that, at the weekend, it is not. All of the offices and work units are all closed at the weekend and nobody is around!

The formal definition does not say! It would be an interpretation to say "right now" this is not a congested area. It was suggested by one of the trainers, so hopefully is valid. One way to be reasonably sure may be to actually ask the CAA. I am not sure I want to open that particular can of worms right now though. Some have suggested that this rule is not time specific, but ultimately it has to be - if you build a housing estate it will, at a point in time, change from non congested to congested - so time has to be a factor - so why not time of days or hours?

What I can be pretty sure of is that it would be safe, especially if I am doing it personally as a private flight, covered by MBFA membership insurance. I'll get permission of the neighbouring units within 50m so I have "control" of the buildings, and have someone watch out for vehicles or people approaching (unlikely). With any luck this will give me somewhere to practice.

Not this weekend though, as I have my wedding blessing to go to. Oooh, look, it is in a castle in the middle of nowhere (not a town or city or settlement). That could be handy :-)

Droney McDroneface: Day 2 (Air Law)

Today we covered air law, and charts and classes of air space and NOTAMs (Notice to Airmen). The charts and air space are pretty simple and there is a really cool app / website (skydemon) which allows you to point and see what restrictions and notices apply where you are. That was the easy bit. The hard bit is air law!

The reason it is hard is the vagueness, and stupidity, of the laws around this whole area.

There are general requirements to ensure flight is safe and to avoid collisions and so on, but the main two clauses of the Air Navigation Order 2009 are section 166 and 167. These two rules cover, basically, drones, and drones that are equipped for surveillance.

The drone we have is a Phantom 4 which falls in the ≤7kg weight class. What is interesting is that if it did not have a camera, only clause 166 would apply, and this has some moderately flexible rules...

• Don't drop anything from the aircraft!
• Only fly if you think it safe, duh.
• Fly only in visual line of sight (deemed to be 500m horizontally which you cannot really see the drone at, but can see other aircraft, which is what matters). In practice you need not to fly so high as to be unable to see it as well.
• Don't fly commercially without a PFAW (Permission For Aerial Works) from CAA

This is quite good - there is not even a height restriction or any need to obey controlled airspace! It is sensible as a courtesy to notify ATC (Air Traffic Control) but not a requirement. There are types of air space that prohibit any flight, but the controlled space is a big issue as that covers large areas (e.g. Bracknell is within Heathrow space) so not having that issue is huge. The requirements change once over 7kg. Basically, providing you are "safe" you can fly a ≤7kg drone most places even in towns and cities, even quite high, even if near people or vehicles or property, if it does not have surveillance equipment.

Update: It is worth pointing out that there are a load of general restrictions, such as not endangering other aircraft, which effectively place some limitations on what you do even under section 166. Even so, 166 is pretty flexible.

Section 167 is where it gets odd. Bear in mind these regulations are meant to relate to safety. This section applies to drones with surveillance equipment (e.g. a camera) which my Phantom 4 has, as do many drones. Why separate safety rules apply for drones with a camera is beyond me! The rules are much more onerous, covering those in 166 (above) plus...

• Not over, or within 150m of a congested area
• Not over, or within 150m of an organised assembly of 1,000 or more people
• Not within 50m of a vessel, vehicle, or structure not under your control (30m during take-off or landing)
• Not within 50m or a person (apart from pilot of persons directly under his control)

There are big issues with the wording - for a start the "not within 30m of a person" during take off or landing does not actually stop the "not within 50m or a person" rule. That rule should have an "except for take-off of landing" and does not have it. Really bad drafting. The other issue is the "Not within 50m of a structure not in control" does not stop the "over or within 150m of a congested area". Congested area includes anywhere used residentially, so a house is a congested area if in a city, town or settlement, so even with permission and control of the home owner you still cannot be over or within 150m!

In practice it seems to be interpreted that the 30m applies for take-off and landing not the 50m, and in practice it seems the structure you have control over is allowed within the 150m, but not within 150m of a neighbour or someone you do not control! Well, we hope, but the way the rules are interpreted is not 100% clear!

There were interesting discussion of vehicles and hence roads. Being 50m from a road could be a pain, but actually the rule is 50m from a vehicle. So we think, if the road is clear of vehicles (that are not under our control) we could take off near the road and get to 50m high. The rules do not say the 50m or 150m is horizontal, so 50m high and not actually over a vehicle would seem to be OK. But to make sure you are safe you have to have some procedures to cover checking the road is clear during take off and landing near the road somehow.

Another discussion is congested areas and the definition which is: ‘Congested area’ in relation to a city, town or settlement, means any area which is substantially used for residential, industrial, commercial or recreational purposes;

This seems to cover basically everywhere and every type of "area" or land unless not actually a city, town or settlement. So I guess a house or castle in the middle of nowhere is not a congested area. Maybe a field in the middle of nowhere is not (though fields are commercial). One interesting point though was the time frame. The idea that our office, on a Sunday morning, is not at that time being used substantially for commercial or industrial use as nobody is working in any of the offices. If that is a valid interpretation then we simply have to contend with the 50m rule for structures and vehicles not in our control. I also wonder what one has to do to justify "control" of a structure! If an adjacent office is empty can I just "take control" of it (i.e. have someone to watch out for any people approaching it and tell them we have a drone over head). So could I control all of the buildings within 50m of me as they are empty? This may mean my test flight at the office on a Sunday morning, and even over the road leading to the office, may have been 100% legit even with no PFAW. If so, cool, a place (and time) to practice.

The good news is the 150m of congested area goes down to 50m if you get a PFAW and possibly lower if you get one of the extended permissions.

Apparently, one of the other extended permissions is night flying. But I have failed to find any restriction on night flying in the legislation, so I may ask that one tomorrow. Maybe some of these restrictions are included in the basic PFAW as caveats and hence why one needs extended permission for such.

But it all makes no sense - what the hell makes a drone with a camera unsafe around people, vehicles, structures, congested areas, but a drone without a camera is not inherently unsafe around such things and so not needing of such restrictions?

One idea for practice was to put a lens cap or tape over camera on Phantom 4. I would argue that as equipped, at that point, it is not capable of surveillance and so not subject to 167. Not an argument to have with a judge maybe, but not a bad argument I feel. That would allow me to practice in my back garden then as clause 167 would not apply.

Overall it is not a good mix of pedant, techie, and the law, one way or another.

It is shitty wording and shitty legislation, clearly. The good news is that the FAA (US Federal Aviation Authority) are relaxing rules and the EU are expected to make rules that will replace the UK rules next year. Hopefully these new rules will at least be sensibly drafted and hence much clearer.

There was one other useful (and cost saving) point. The PFAW is something the company obtains, having produced an operational manual. It can then engage any pilot that has passed the theory and practical tests. This is slightly odd as part of the practical test is confirming we can follow the operational manual, when in theory we may not know who we are going to work for an what operational manual they will have! It is also the company that gets the commercial drone insurance. Given we are training two pilots, this does save some money.

Droney McDroneface: Day 1

Well, the first day of the heliguy course is over and this means Alex and I have embarked on the first steps to becoming proper drone pilots.

Personal I think today was quite slow, but I gather tomorrow will be a lot more work as tomorrow is mostly on air law. Today was covering principles of flight and aircraft knowledge, and quite a lot on Lithium Polymer battery safety (with scary videos).

So hopefully in tomorrow's post I can explain a tad more about what is allowed and what is not, and what will be allowed once we get our PFAW (Permission For Aerial Works).

The process to get there means this course and a theory test which we have to pass, then producing an operations manual, and then passing a practical test, and finally an application to the CAA (Civil Aviation Authority). This week should complete the theory test part. We will need insurance as well.

One of the things we have to decide is what sort of aerial work we want to be able to do, and if we want to try and apply for some extended permissions rather than just the basics. The basics, for example, allow working outside 50m distance of people or property we do not control, but it seems there may be ways to apply for closer distances if we can present the risk assessments and mitigation in our operations manual. Hopefully we'll know more on that tomorrow as well. Other possible extended permissions are things like night flying, and flying beyond visual line of sight. I doubt we need to go for either of those to start with.

It seems the Phantom 4 is a good choice of drone - it is very capable with an excellent camera and a lot of safety features. It fits in the lowest weight category (≤7kg). There are other drones we could get, within that category, or go for the heavy lift (≤20kg). The only real concern expressed with using a Phantom 4 on commercial work was the customer perception issue (I could get one of them from Apple/Maplin, or my kid has one of those). Obviously the fact we have done a CAA course, passed tests, and got PFAW is what really matters, but customer perception can be an issue.

What would make a difference, if we wanted to do more work, such as in London, or over people, would be a hexacopter or octocopter which can survive a rotor failure. A quadrocopter like the Phantom 4 cannot. The CAA stuff is all about safety and mitigating risk.

Should I thank Theresa May?

For some decades now the security and Internet community have tried to convince people to encrypted data.

It has taken a long time to do this - partly as computing power used to be difficult to handle secure communications even only a few years ago, but times have changed.

Now it is not just possible, but desirable, for https everywhere not http, and end to end encryption in communications.

The challenge has been convincing people of the need. After all, criminals may be smart but they had not, until more recently, been that smart.

The good news is that it seems to me that the message is finally sinking in. More and more people are assuming every web site they make should be https. Heck, even the aa.net.uk site should be soon. We are looking at ways to make this the default for our web hosting customers too (but that is quite a complex project).

The odd thing is why this is happening. Criminals are the real threat here - they could hack communications providers to access unencrypted data. They could hack DNS to impersonate a web site. They can get your data and exploit it.

But the real reason I feel worried, and I know a lot of others do, is not the criminals, it is the authorities. It is the massive invasion of privacy that the government want to have access to.

I am far more concerned that my privacy will be invaded by the government than criminals.

Why? Well, if they get the IP Bill through they will simply have the legal power to do that, and on a large scale. Criminals take a risk and have to compromise systems. Government can simple issue secret orders and warrants and do what they like. Which is more likely to happen?

The good news is more and more people are using end to end encryption like PGP, Signal, iMessage, and all sorts. More people are encrypting hard drives as standard. More operating systems are making it easy and default to do so. If they insist we disclose passwords, we make systems with hidden partitions, and steganography and secondary password protected innocent file stores. So many ways to defeat the adversary. So may ways we can prove we are complying and innocent whatever data we really hold. These are techniques to handle the criminal, even those with $5 wrench but they work just as well on the authorities if you are a criminal yourself, or not and you just want your human right to privacy.

It really seems we all fear a police state more than we fear criminals. Crazy, I agree, but end result is we are safer from criminals too. So a good thing.

Thank you Theresa May for whipping up enough paranoia for people to finally take privacy seriously. Well done.