Atypical Air Environment Consultation Response.
https://www.caa.co.uk/our-work/publications/documents/content/cap2968/
The Scottish Hang Gliding and Paragliding Federation (SHPF) is the national membership body that represents participants of these sports in Scotland. It is a member of Sport Scotland and an affiliate of the British Hang Gliding and Paragliding Association which is the CAA-recognised body for free flyers in the UK.
Typically Hang Gliders and Paragliders, particularly on cross country flights, are unable to predict landing locations or may have to land immediately due to unforeseen circumstances. At 50 feet the pilot will be particularly busy checking the chosen location for obstacles, local wind environment etc. It would be extremely difficult for pilots to keep a lookout for UAVs at this stage of flight. In addition, landing sites are usually selected near roads for obvious reasons
Hang gliders and paragliders carry reserve parachutes. In the event of a collision with a UAV it is a possibility that the UAV would become entangled with canopy lines or rigging. At reasonable altitudes there is a possibility that the pilot could survive a collision and deploy an emergency reserve parachute. If the UAV remained entangled then the extra weight would render this parachute all but useless.
At altitudes envisaged for AAE drone operation a collision with a UAV would prove problematic as there would be insufficient height for parachute deployment with a high risk of injury or death.
Hang glider and paraglider pilots are exposed and not protected by a cockpit. Should an UAV collide with the pilot this would almost certainly result in an injury and loss of control of the aircraft.
Many paragliders carry EC devices typically FLARM any UAVs operating in AAE should be required to have DAA capability for FLARM equipped aircraft or an alternative effective system yet to be deployed. This should be compatible with systems currently being evaluated by EASA.
The system for notification of drone activity in AAEs would needs to be improved so that areas of operation can easily be ascertained using properly authenticated interactive online maps.
The free flying community in Scotland is having to spend an inordinate amount of resource tracking and commenting on UAV TDA applications. It is felt that another layer of complexity should not be added to the system until both EC and notification procedures have been properly modernised.
Having recently encountered topographic survey UAVs being operated line of sight where the drone operators themselves stated that it was difficult to locate the drone against a hillside due to its black colour, the SHPF would strongly suggest that drones are required to be painted in high visibility colour schemes with strobes and audio beacons to enable early visual detection.
If you wish to raise any additional points it can be done very simply via the CAA website.
https://www.caa.co.uk/our-work/publications/documents/content/cap2968/