JohnShe

Nope, I got it right the first time.

cj_rumley

Exactly. Modelers cannot intelligently and responsibly exercise their right to comment on the sUAS NPRM without knowing what it means.

As a member of the Mile High Club, I know exactly what 'programming' means in that CBO. I am considering citing my association with that CBO if ever challenged by FAA over meeting the Sect 336 criteria for exemption from regulation of my model flying.

cj_rumley

Just trying to understand what 'programming' means in Sect 336, Frank. Re-distributing TFRs is the only thing that came mind as providing safety information that changes frequently enough to remotely justify requiring modelers to remain in contact with the CBO such that they remain current on safety rules.
The turbine and over 55 lb waivers requirements are stated in the proposed rules. No need for CBO contact to stay informed by a CBO on that, as these would become FAA rules and the CBO cannot change them.

added: more on the relevance of TFR to the discussion in reply to your question

ira d

I agree this is all speculation until it is clarified but I think it's the FAA that needs to go on record and let us know if they intend to cite flyers that operate certain types of
RC models just because they are not AMA members.

init4fun

Since we're just speculating , I'd like to speculate that so long as one doesn't give them reason to notice , I doubt the FAA is going to have the drone inspectors hiding in the trees waiting to hand out improper use citations . Guys at club fields and folks where parkflyers are allowed will have no problem . Start causing any kinds of notice from manned aircraft or cause a menace to those on the ground and you can expect a visit now already , this just gives them a catagory into which to place knuckleheads ; Either abuser of hobby technology or abuser of commercial technology . Can ya guess which catagory of abuse will get the higher fines ?

JohnShe

Well, I didn't say that it went to the ground everywhere. It applies only where full scale aircraft are flying and now includes commercial sUAS operations.

JohnShe

Ira, the FAA has gone on record to state that they will apply appropriate FARs to any violation of the NAS by a model aircraft. Isn't that enough?

cj_rumley

Init4fun, while I generally agree with what you wrote, it stops short of addressing a real concern with laws that are not enforced or unevenly enforced. There is plenty of history to illustrate the basic truth that laws/rules that go unenforced become laws/rules that are enforced selectively.

JohnShe

Why do modelers care? the sUAS NPRM only effects commercial operators.


Do you still believe that jack-booted FAA storm-troopers will descend on you in black helicopters?

cj_rumley

Not speaking for Ira, but for me it is plenty. That is what the proposed Part 101 says, and modelers that comply the CBO exception criteria are subject to it. Isn't that enough for non CBO camp followers too? Answer your own question, Johny Boy.

JohnShe

Like I said, it is perfectly clear to me. If you are speaking of the frequent references to 14CFR Part 101, I agree with the FAA. I don't see it as any threat to responsible model aircraft operators CBO members or not.

cj_rumley

No, that is not in agreement with FAA. FAA proposes language that says non-CBO modelers that are not in conformance with all of the conditions delineated in Sect 336 are subject to Part 107, which is supposed to be intended for non-recreational sUAS. That is most certain to be perceived as a threat to non-CBO members.

cj_rumley

This may explain why what you have posted in this thread and others appears so utterly oblivious to what the subject is.....................

ira d

To answer your question NO it's not enough. We need to know if the FAA intends to force modelers into the AMA to operate certain types of models for example models
that weigh over 55 lb's.

ira d

I agree I don't think the FAA will try to be everywhere, Also I think commercial operators will likely receive the higher fines and for the most point if we don't give the FAA a reason to
notice we should be fine. However I still feel we need to know what the FAA intends for modelers as they pertain to the AMA.

HoundDog

My Feedback: (49)

What good is the Safety Code of the AMA/CBO.

They don't even enforce or can they Enforce anything in the Safety Code or any of their other documents. There are no Penalties or fines for not abiding by or not following any thing the AMA/CBO says or does.
If they did enforce the safety code and the other policys they have Published, there would be a lot of AMA members fined, suspended and ought right ejected from the AMA. Most of these would be the officers of many clubs because many have the opinion that the Rules are made for others no them. Then U have the out right Dangerous flyers for witch there never has been any sanctions by the AMA/CBO for such violations.

HoundDog

My Feedback: (49)

The Only thing the FAA might do is if U are STUPID enough to cause some sort of incident or Accident.

What part of #336 don't U all understand ... The FAA is not allowed to make any rules pertaining to Model airplanes Not used for commercial purposes i.e compensation or Hire. The only thing that has anything that remotely has the FAA having any thing to do with Model Aviation is if That in no way may the FAA Administrator be restricted from enforcing the FAR's concerning Model. It only pertains to commercially used sUAS. PERIOD.

SEC. 336. SPECIAL RULE FOR MODEL AIRCRAFT.(a) In General.--Notwithstanding any other provision of law relating to the incorporation ofunmanned aircraft systems into Federal Aviation Administration plans and policies, includingthis subtitle, the Administrator of the Federal Aviation Administration may not promulgate anyrule or regulation regarding a model aircraft, or an aircraft being developed as a model aircraft,if--
(1) the aircraft is flown strictly for hobby or recreational use;
(2) the aircraft is operated in accordance with a community-based set of safety guidelines andwithin the programming of a nationwide community-based organization;
(3) the aircraft is limited to not more than 55 pounds unless otherwise certified through a design,construction, inspection, flight test, and operational safety program administered by acommunity-based organization;

cj_rumley

I think you are right on point, HoundDog. FAA will have the enforcement power they need when Part 101 changes proposed are put into the FAR. AMA safety code may be good advice for the most part, and that is how/why FAA has referred to it, but it has almost never been enforced (two exceptions In the history of AMA that I am aware of, including the AMA member that flew his model into the Goodyear blimp) and at that the only enforcement option available to AMA is to void the offender's insurance coverage. As a related matter the only deterrent they have is to threaten voiding a member's insurance which they do as a matter of course.
BTW, it has been my observation over many years that most of us have the opinion that the rules are made for others, not ourselves. The self perception is "I can operate responsibly without mommy's rules, but they are needed to control the less gifted amongst us."

JohnShe

You better believe that it is a threat. Endanger the NAS and you ass is grass. Doesn't matter if you are commercial, CBO or non-CBO, you are doomed if they catch you.

ira d

The part we don't understand is what the FAA intends to do about non AMA members that for example wish to operate a model over 55lb's. They have the option to not
do anything or they can say you will be cited if you do so while not being a AMA member. We can speculate all we want to but we wont know for sure until the FAA says
what they intend.

cj_rumley

Oh, I do believe it. It's one of many reasons why I believe Sect 336 provisions relating to AMA (why do we still apply the deceptive CBO identity to what everyone knows is AMA exclusively?) has no redeeming value and should go down the toilet, lest Congress bear any more embarrassment for having been duped by "a nameless CBO."

JohnShe

Ira, you just don't seem to get it. It doesen't matter if you belong to a CBO or not. If you do anything that recognizably endangers the NAS with any size aircraft and get caught, you will be punished. That is all the they legal mumbo-jumbo in section 336 and the FAA interpretation of 336 really says.

JohnShe

CJ you just don't seem to get it. It doesen't matter if you belong to a CBO or not. If you do anything that recognizably endangers the NAS with any size aircraft and get caught, you will be punished. That is all the they legal mumbo-jumbo in section 336 and the FAA interpretation of 336 really says.

HoundDog

My Feedback: (49)

When's the last time U have or seen someone else "ENDANGER the NAS" ...
Either at an AMA Chartered field or any place else. If U fly Like U have been U don't have to worry about, nothing is going to change. We have all followed the AMA Safety Code to the letter and never violated any of the Reles of the AMA/CBO have WE/U. Ya Right!

cj_rumley

Okay, right. I don't get why FAA would put into the FARs language requiring one to buy into the superfluous AMA aka CBO crap to avoid being subject to proposed Part 107 rules in order to legally fly a toy airplane. The language is clear despite your attempt to pass it off as legal mumbo-jumbo of no possible consequence. Whether or not FAA will ever take action against anyone for being non-compliant with the CBO terms in the proposed rules seems unlikely to me, yet uncertain. Will some people be mislead into thinking they have to buy AMA membership to either avoid prosecution for non-compliance with Part 107 or alternatively accept its terms? I think the answer is clearly yes, and that is the illicit "why" of Sect 336. I want to see it killed, or at least castrated. A simple change from "Part 107" to "Part 101" is all it takes for FAA to accomplish the latter. Why would you argue with that, given that you have repeatedly droned on about how it doesn't matter?