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FAA COMMENT DEADLINE APPROACHING!

Discussion in 'News' started by phoby3, Jul 10, 2014.

  1. phoby3

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  2. Rizzo Media Factory

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  3. jadebox

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    I just left my comment.

    If you leave a comment, keep in mind that the FAA is concerned about safety. Don't say that you don't like the proposed rule simply because it would prevent you from having fun or whatever. Instead, make the point that it won't improve safety and would limit hobby and recreational use of the airspace. Try to include specific examples or reasons to back up your assertions.

    -- Roger
     
  4. Rizzo Media Factory

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    I gave my fair input on commercial usage because that is my primary goal. There can be a reasonable way to verify commercial use is done safely and insured.
     
  5. HML48

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    Filed my comment. Thanks for the reminder.
     
  6. SJBrit

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    Bump. My comments are in. Remember that this is lawmaking - impactful comments are those that point out flaws in the FAA's information or reasoning leading to incorrect conclusions that should be readdressed. For example, in defense of FPV, my comments were (in a nutshell):

    1) FPV systems consist of more than just goggles;
    2) FPV systems do not necessarily limit field of view (wide angle cameras, gimbals, head trackers);
    3) In any case, a limited field of view does not necessarily make an aircraft inherently unsafe or no manned aircraft would be allowed in the air;
    4) In any case, the assertion that limited field of view is dangerous might be true for manned aircraft (because you have to see the sky all around the aircraft to be safe) that this is not the case for flying models at a distance since the sky all around your model subtends only a small angle at the remote pilot;
    5) In fact, too wide a field of view admits distractions into the model pilot's field of view and so a limited field of view might actually be thought of as advantageous, therefore
    6) The FAA should reconsider its incorrect conclusions about vision enhancing devices, particularly FPV.

    Please put in your comments, but keep them to facts, not opinions. The goal is to educate the FAA into reason, and use their own thinking to make the point.

    Now go and comment!
     
  7. BMEWS

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    FoV is a subjective term. Remember the human vision has a finite FoV. Even with the head turning (also limited), thus providing a human pilot with a finite FoV. If that really is an argument for the FAA, then it's seriously flawed.

    Bmews
     
  8. SJBrit

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    Exactly. Their argument against "augmented vision" was FOV which is inherently flawed. I made the point that a well placed FOV camera on a gimbal has a better field of view than a human in a manned aircraft. In the Cessnas I've flown your FOV is very limited due obstructions from the fuselage and wings, but I can see 360 degrees with my GoPro on my Phantom.
     
  9. jadebox

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    I tried to make the point that the restrictions in the new rule are arbitrary.

    As one example, I pointed out that the FPV restrictions are based on the "visual line of sight" statement in the statute. That statement sets a limit on the range of the model aircraft - it may not be flown beyond the operator's line of sight.

    In the proposed rule, the FAA has broadened their interpretation of the statute to mean that the operator must maintain visual line of sight at all times. They then used the broadened interpretation as one reason to effectively ban FPV.

    In the rationale, the FAA stated that FPV allows the operator to fly beyond the operator's visual line of sight limit. I argued, that without FPV a pilot could also fly beyond that distance (and, if a pilot accidentally did fly beyond that range, FPV would be an asset - helping to return the aircraft safely).

    In summary, the law already limits the range that an operator may fly a model aircraft. Restricting FPV based on a broader interpretation of the law is arbitrary and does nothing to increase safety (and actually may reduce it).
     
  10. SJBrit

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  11. Phil H

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    I sent mine in.
     
  12. WinePrince

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    me too and posted to facebook