FAA Proposed Rules Comments

[Jacob]

The FAA has recently opened their document of proposed regulations up for commenting. It only has 473 comments as of this original post. We need the FAA to hear our voice, please use the link below to leave a comment. Many of you will remember when the FAA proposed a set of regulations a while back with far more strict propositions and it got thousands of comments from people rebutting the regulations and it was later removed.

I for one support this document and have let my voice be heard on their website. I request you do the same and share your opinions:http://www.regulations.gov/#!docketDetail;D=FAA-2015-0150

Jacob

 

[capodrone81]

PEOPLE WHO COMMENT PLEASE IF USING A TEMPLATE AND COPY AND PASTING WHERE IT SAYS INSERT PERSONAL INFORMATION HERE DELETE AND FOLLOW INSTRUCTIONS DONT POST WITHOUT FIRST MODIFYING TEMPLATE!!!

reading some of the comments on the link above people that are replying aren't even reading what they are posting.. how are we going to be taken seriously if they aren't even reading what they are posting.. so frustrating..

if you can't read you definitely shouldn't fly!!!! #frustrated!!

 

[SteveMann]

There's several hundred copies of the AMA template on the comment website. It's easy to spot them because the first line includes "[insert your profession...].

The AMA (yes, I am a member) has wasted a tremendous opportunity here. Of the four bullet points in their template, three are flat-out incorrect. The fourth, the plan to ban FPV is only partially correct. The NPRM would ban all FPV, hobby or pro, but not the way the AMA template implies.

I have read every reply, except for the few hundred with "[insert your profession..." in the first line. I can say that 90% of the comments come from people who haven't read the NPRM and are only commenting on what they heard on the news or forums.

If you fly FPV - read the NPRM and comment.
If you plan to fly for hire or as a business, read the NPRM and comment.

For the hobby flyer, this NPRM will make the AMA rules legally enforceable. Neat trick of the FAA to get around the Congress directive to not promulgate rules for hobby flight. Few have noticed it, yet.

The comment deadline is 4/24.

 

[SilentAV8R]

I guess I read the NPRM differently. While FPV is restricted to VLOS, it is not outright banned. The NPRM clearly states the EITHER the pilot OR observer must have VLOS on teh aircraft:

§ 107.31 Visual line of sight aircraft operation.

With vision that is unaided by any device other than corrective lenses, the operator or visual observer must be able to see the unmanned aircraft throughout the entire flight in order to: (a) Know the unmanned aircraft’s location; (b) Determine the unmanned aircraft’s attitude, altitude, and direction; (c) Observe the airspace for other air traffic or hazards; and (d) Determine that the unmanned aircraft does not endanger the life or property of another.

SO clearly the pilot can be flying FPV, but he must have a spotter with VLOS.

I will be shocked if FAA waivers from the VLOS requirement. But they are not banning the use of FPV devices.

 

[SilentAV8R]

As far as the NPRM making the AMA rules legally enforceable for hobby flying, it does no such thing. The enforcement standard was, and remains, as defined in Section 336 of P.L. 112-95. That being endangering the NAS or operating in a careless or reckless manner. Simply violating a part of the AMA Safety Code would not rise to the level of that enforcement standard alone.

Pages 46 - 48 provide a discussion of how model aircraft are to be handled. Part 101.41 makes this even more clear:

§ 101.43 Endangering the safety of the National Airspace System.

No person may operate model aircraft so as to endanger the safety of the national airspace system.

Again, nowhere is it stated or inferred that simply violating a part of the CBO safety guidelines will be defined as endangering the NAS.

 

[ianwood]

I guess I read the NPRM differently. While FPV is restricted to VLOS, it is not outright banned. The NPRM clearly states the EITHER the pilot OR observer must have VLOS on teh aircraft:

That's how I read it as well.

Not being able to use FPV equipment while VLOS is a concern. I find it hard to judge proximity to a distant object from the ground without checking the FPV for verification. Many times, I'll be closer and lower in relation to an object than it appears from the ground.

Having the additional perspective of the FPV is important for safe operation. This is very different to flying pure FPV.

 

[SilentAV8R]

It still comes down to the FAA's steadfast requirement that no matter what the operator is doing, a human (operator and/or observer) must have "eyes on" the aircraft. What they seem totally unwilling to consider under any circumstances is allowing operations beyond VLOS.

 

[TeamYankee]

There's nothing that says you can't use FPV ... just not use goggles right?

 

[SilentAV8R]

Without using goggles I think the FAA would say that FPV becomes a matter of degree. Their intention is that either the operator or observer have "eyes on" the aircraft except for brief moments when it may be out of sight behind a tree, etc.

So if you are using a monitor and spend most of the time looking at it rather than the aircraft, the FAA would likely say that is no longer VLOS.

Basically they want someone to be watching the aircraft as much as is possible.

 

[SteveMann]

Silent is correct - I missed the "or" in the NPRM.

But on "As far as the NPRM making the AMA rules legally enforceable for hobby flying, it does no such thing."

Here's my read of the NPRM:

§ 101.1 Applicability.
(a)(5) Any model aircraft that meets the conditions specified in § 101.41.

§ 101.41 Applicability.
This subpart prescribes the rules governing the operation of a model aircraft that meets all of the following conditions as set forth in section 336 of Public Law 112-95:
(a) The aircraft is flown strictly for hobby or recreational use;
(b) The aircraft is operated in accordance with a community-based set of safety guidelines and within the programming of a nationwide community-based organization;

(The underlines are my emphasis) It's that last line that makes the AMA rules enforceable. If you are an AMA member and fly in violation of one of their rules (which is quite easy since most of the AMA rules were written when model airplanes flew in circles at the end of a pair of fishing lines) then the FAA could bust you for violating § 101.41(b).

 

[GoodnNuff]

But on "As far as the NPRM making the AMA rules legally enforceable for hobby flying, it does no such thing."

Here's my read of the NPRM:

§ 101.1 Applicability.
(a)(5) Any model aircraft that meets the conditions specified in § 101.41.

§ 101.41 Applicability.
This subpart prescribes the rules governing the operation of a model aircraft that meets all of the following conditions as set forth in section 336 of Public Law 112-95:
(a) The aircraft is flown strictly for hobby or recreational use;
(b) The aircraft is operated in accordance with a community-based set of safety guidelines and within the programming of a nationwide community-based organization;

(The underlines are my emphasis) It's that last line that makes the AMA rules enforceable. If you are an AMA member and fly in violation of one of their rules (which is quite easy since most of the AMA rules were written when model airplanes flew in circles at the end of a pair of fishing lines) then the FAA could bust you for violating § 101.41(b).[/QUOTE]


No, FPV will not be banned....

Here are the community based safetly guidelines of the AMA:

• Do not interfere with manned aircraft operations.
• Yield the right of way to manned aircraft. See and avoid other aircraft at all times (AMA
Doc #540-D).

• Do not endanger persons or property. No intentional overflight of moving vehicles or

unprotected persons. Fly no closer than 25 feet.
• Fly no higher than necessary (less than 400 feet). Remain below surrounding
obstacles when possible.
• Avoid operations in close proximity to airports. When within 5 miles of an airport,

contact the airport/Air Traffic Control (ATC).
• Ensure pilot competency/proficiency and the safe operation of the aircraft.

• Remain within visual line of sight (VLOS). Use a spotter when necessary/appropriate.

Which ones specifically do you think will be a problem for you Steve?