We Lost our Flying Sites Due to DoD Regulations regarding COTS UaS
08-19-2019, 07:04 AM
#1
We Lost our Flying Sites Due to DoD Regulations regarding COTS UaS
Hello,
The Wiregrass Radio Control Club and Southern Radio Control Flyers had been flying from Army Stagefields related to Ft Rucker here in SE Alabama for 30 to 40 years. In April our flight privileges were revoked due to DoD guidelines restricting the use of Commercial Off The Shelf Unmanned Aerial Systems (COTS UaS). DoD's concerns regarding Cybersecurity are valid and should be taken seriously. Our relationship with Ft Rucker has been excellent over the years and they have supported our activities. The DoD does have a "Waiver" process but it is incredibly difficult. As a Club we would have to submit request to fly on a specific day. The request would have to list the Member, his radio equipment and manufacturer, aircraft to be flown that day including manufacturer, propulsion specs and manufacturer, payload specs. The request would go up the chain of command on Post then to DoD at the Pentagon, processed then the return approval or denial goes down the chain on Post to us. We would need to be monitored to see that the aircraft approved were the ones being flown. Ft Rucker contacts are sympathetic but are not willing to commit resources to do this unless the process becomes less onerous.
I wrote to the AMA and got some suggestions which were sent to our Rucker contact. Those did not help. I had herd that there are other clubs that have been flying from Military controlled property who have been restricted as well. The AMA did not set up to try and work with the DoD in our case. This action flies in the face of legislation that had carveouts for the hobby. We fly on remote Stagefields that are in the lowest risk category. We do no flying in the confines of Ft. Rucker proper.
Are there any AMA Clubs flying from Military controlled property that were able to get a waiver to continue flying and how did you achieve this?
Thanks,
Pete
The Wiregrass Radio Control Club and Southern Radio Control Flyers had been flying from Army Stagefields related to Ft Rucker here in SE Alabama for 30 to 40 years. In April our flight privileges were revoked due to DoD guidelines restricting the use of Commercial Off The Shelf Unmanned Aerial Systems (COTS UaS). DoD's concerns regarding Cybersecurity are valid and should be taken seriously. Our relationship with Ft Rucker has been excellent over the years and they have supported our activities. The DoD does have a "Waiver" process but it is incredibly difficult. As a Club we would have to submit request to fly on a specific day. The request would have to list the Member, his radio equipment and manufacturer, aircraft to be flown that day including manufacturer, propulsion specs and manufacturer, payload specs. The request would go up the chain of command on Post then to DoD at the Pentagon, processed then the return approval or denial goes down the chain on Post to us. We would need to be monitored to see that the aircraft approved were the ones being flown. Ft Rucker contacts are sympathetic but are not willing to commit resources to do this unless the process becomes less onerous.
I wrote to the AMA and got some suggestions which were sent to our Rucker contact. Those did not help. I had herd that there are other clubs that have been flying from Military controlled property who have been restricted as well. The AMA did not set up to try and work with the DoD in our case. This action flies in the face of legislation that had carveouts for the hobby. We fly on remote Stagefields that are in the lowest risk category. We do no flying in the confines of Ft. Rucker proper.
Are there any AMA Clubs flying from Military controlled property that were able to get a waiver to continue flying and how did you achieve this?
Thanks,
Pete
08-19-2019, 11:12 AM
#3
Do not give up on the AMA or the local Ft Rucker leadership. It will be a hard road, as this is coming from the Pentagon and people that live in the DC SFRA (Special Flight Rules Area).
Rafael
08-20-2019, 04:17 AM
#6
Banned
If you haven't already, you might ask them if they would provide you a list of acceptable equipment. With the understanding that the club would allow only what's on the list.
08-20-2019, 05:01 PM
#7
Appowner,
It's our understanding that the really offensive systems are those that allow flight beyond Line Of Sight, are controlled or process video through a cellphone or tablet. Ft. Rucker knows that our systems don't do this. The issue is with DoD. We need the AMA to lobby the DoD to allow the Post Commanders the discretion to allow RC flying under the rules of a community based organization like the AMA . Allow flying in low risk area (Low security risk) following the AMA Safety Code and Flying Field Guidelines.
If the AMA would step up and do this it would go a long way in earning the dues we pay them. Just Sayin
Pete
It's our understanding that the really offensive systems are those that allow flight beyond Line Of Sight, are controlled or process video through a cellphone or tablet. Ft. Rucker knows that our systems don't do this. The issue is with DoD. We need the AMA to lobby the DoD to allow the Post Commanders the discretion to allow RC flying under the rules of a community based organization like the AMA . Allow flying in low risk area (Low security risk) following the AMA Safety Code and Flying Field Guidelines.
If the AMA would step up and do this it would go a long way in earning the dues we pay them. Just Sayin
Pete
08-21-2019, 03:14 AM
#9
Banned
Appowner,
It's our understanding that the really offensive systems are those that allow flight beyond Line Of Sight, are controlled or process video through a cellphone or tablet. Ft. Rucker knows that our systems don't do this. The issue is with DoD. We need the AMA to lobby the DoD to allow the Post Commanders the discretion to allow RC flying under the rules of a community based organization like the AMA . Allow flying in low risk area (Low security risk) following the AMA Safety Code and Flying Field Guidelines.
If the AMA would step up and do this it would go a long way in earning the dues we pay them. Just Sayin
Pete
It's our understanding that the really offensive systems are those that allow flight beyond Line Of Sight, are controlled or process video through a cellphone or tablet. Ft. Rucker knows that our systems don't do this. The issue is with DoD. We need the AMA to lobby the DoD to allow the Post Commanders the discretion to allow RC flying under the rules of a community based organization like the AMA . Allow flying in low risk area (Low security risk) following the AMA Safety Code and Flying Field Guidelines.
If the AMA would step up and do this it would go a long way in earning the dues we pay them. Just Sayin
Pete
Interestingly enough, our main antagonist was an Army Major who swore up and down that we were taking pictures through his office window with our models. At one meeting I asked him to demonstrate how we were doing such a thing with fixed wing models? He walked away.
DoD is understandably concerned. We've found spyware in a variety of computer hardware manufactured overseas. Network (NIC) cards seem to be a favorite but also on memory sticks, hard drives, video cards, etc. I was dealing with it 20 plus years ago so it really isn't anything new. Just a new way of doing things with the drones.
09-03-2019, 07:09 AM
#10
Junior Member
With the insidious spying tech in computers I get it. Nearly all the hobby stuff I see comes from China. Add in all the flyers using POV cameras and posting the online. Low hanging fruit for foreign countries. That said, most of the new military tech is kept under wraps.
Would be easy enough to permit flying with a prohibition on cameras of any type.
Would be easy enough to permit flying with a prohibition on cameras of any type.
09-03-2019, 07:27 AM
#11
SteelonSteel,
You would think so. All our equipment is line of sight with no cameras. We thought a waiver would be easy but the DoD process in place is so burdensome the Command wants no part of it. Worst of all AMA is doing nothing to assist.
Pete
You would think so. All our equipment is line of sight with no cameras. We thought a waiver would be easy but the DoD process in place is so burdensome the Command wants no part of it. Worst of all AMA is doing nothing to assist.
Pete
09-03-2019, 07:52 AM
#12
Pete, I am genuinely sorry for the loss of your flying site however what is it that you are expecting the AMA to do in this particular case? I ask because there are a few guys in this forum that have been claiming that the AMA has no influence when it comes to the Federal Government yet are now criticizing them for not taking up your fight with the DOD. Leaves some people a bit confused.
09-03-2019, 09:58 AM
#13
Speedracerntrixie,
Frankly, we are resigned to the fact our fields are gone. We are at risk of loosing two clubs with a total of about 60 to 70 members. We are looking for land to lease. I started this thread to let members know the Hobby is under greater threat than most think. That the AMA takes our dues and says they are advocating for us but in fact are having little impact. I'm not confused
Frankly, we are resigned to the fact our fields are gone. We are at risk of loosing two clubs with a total of about 60 to 70 members. We are looking for land to lease. I started this thread to let members know the Hobby is under greater threat than most think. That the AMA takes our dues and says they are advocating for us but in fact are having little impact. I'm not confused
Last edited by Rocketman612; 09-03-2019 at 03:00 PM.
09-03-2019, 03:28 PM
#15
Our current situation is exactly why when all this started to come about I had advocated that guys maintain their membership and those who weren't members should become members. The reality is that a Special Interest Group of only 200,000 members only has so much pull with the Fed. The more members, the louder our voices and the more means to advocate for us. Now we are suffering the consequences of small membership. Would having 300,000 members have helped is anyone's guess but it certainly would not have hurt us any.
It's obvious that we are going to loose some flying fields, there is just no way around that. My earlier comments were in reference to what some others in this thread have said previously in other threads, that AMA has no pull, FAA does not consider them a major player, AMA isn't part of any negotiations etc. Yet these same guys are now critical over the fact that the AMA was unable to help with your particular loss.
Lastly I urge everyone to demonstrate some patience, we are at the beginning of a long road here. IMO to judge the overall effectiveness of the AMA to negotiate acceptable terms with the FAA at this point in time is premature to say the least. For the most part FAA has demonstrated their willingness to leave the traditional LOS guys alone. Examples of this are the numerous events and the NATs that were allowed to proceed without FAA interference.
It's obvious that we are going to loose some flying fields, there is just no way around that. My earlier comments were in reference to what some others in this thread have said previously in other threads, that AMA has no pull, FAA does not consider them a major player, AMA isn't part of any negotiations etc. Yet these same guys are now critical over the fact that the AMA was unable to help with your particular loss.
Lastly I urge everyone to demonstrate some patience, we are at the beginning of a long road here. IMO to judge the overall effectiveness of the AMA to negotiate acceptable terms with the FAA at this point in time is premature to say the least. For the most part FAA has demonstrated their willingness to leave the traditional LOS guys alone. Examples of this are the numerous events and the NATs that were allowed to proceed without FAA interference.
09-03-2019, 09:41 PM
#16
Okay, this is going to shock some BUT, in this case, I'm going to agree with much of Speed's post.
This thread, however, talks about a special case. This has nothing to with the FAA(the AMA's primary sparring partner) nor the AMA. This is strictly a DOD vs Club issue. What must be remembered is the base commander has given the clubs access to a DOD facility AS A COURTESY, not because he had to. The same thing has been done for several decades at NAS Whidbey Island WA with one of the local flying clubs. The only requirement, that I know of anyway, was that a certain amount of members of the club had to be DOD employees. FAST FORWARD TO LAST OCTOBER:
Per the Whidbey Island Radio Control Society newsletter, the Touch-N-Go, the club's field marshall had talked to the base about using the auxiliary landing field, the clubs home for the previously mentioned several decades. The results were that the DoD said no flying on any base area, but the old CO gave the club a waiver to fly. Also looking at MWR having a flying program with the club teaching the flying.
Since then, the base has closed the gates to the field and the club is now working on finding a new location.
What must be remembered is that most bases are commanded by either a Captain(navy and coast guard), a colonel or a low level general(air force, marines, army). They are not going to risk their careers by butting heads with the Pentagon over a small group of people with toy airplanes that has used their base as a flying field in the past. Security is now the watchword and, with quads and planes now being equipped with onboard cameras that transmit an unregulated signal that can be picked up by anyone with the tech to do so, it just makes sense to close the gates to protect what's classified from being seen by the wrong people.
This thread, however, talks about a special case. This has nothing to with the FAA(the AMA's primary sparring partner) nor the AMA. This is strictly a DOD vs Club issue. What must be remembered is the base commander has given the clubs access to a DOD facility AS A COURTESY, not because he had to. The same thing has been done for several decades at NAS Whidbey Island WA with one of the local flying clubs. The only requirement, that I know of anyway, was that a certain amount of members of the club had to be DOD employees. FAST FORWARD TO LAST OCTOBER:
Per the Whidbey Island Radio Control Society newsletter, the Touch-N-Go, the club's field marshall had talked to the base about using the auxiliary landing field, the clubs home for the previously mentioned several decades. The results were that the DoD said no flying on any base area, but the old CO gave the club a waiver to fly. Also looking at MWR having a flying program with the club teaching the flying.
Since then, the base has closed the gates to the field and the club is now working on finding a new location.
What must be remembered is that most bases are commanded by either a Captain(navy and coast guard), a colonel or a low level general(air force, marines, army). They are not going to risk their careers by butting heads with the Pentagon over a small group of people with toy airplanes that has used their base as a flying field in the past. Security is now the watchword and, with quads and planes now being equipped with onboard cameras that transmit an unregulated signal that can be picked up by anyone with the tech to do so, it just makes sense to close the gates to protect what's classified from being seen by the wrong people.
11-15-2019, 01:11 AM
#17
As a former base leader, the other problem is DoD rules on use of facilities by PRIVATE dues collecting organizations. Simply put, if the base (any base) allows one PRIVATE dues collecting organization to use base assets, then they must allow other PRIVATE dues collecting organizations to use the base too. And it gets even more complicated, from a DoD ethics perspective for the base commanders, when the private dues collecting organizations are holding money making events.
Are there bases that allow it? Sure, but shutting down the club is as easy as an Inspector General complaint by any other private dues collecting organization that was denied similar treatment.
Are there bases that allow it? Sure, but shutting down the club is as easy as an Inspector General complaint by any other private dues collecting organization that was denied similar treatment.
11-15-2019, 05:55 AM
#18
Franklin M,
That's true. We were very good at working with the Ft Rucker MWR (Morale, Welfare and Recreation). We submitted our minutes and financials monthly and recertified as a MWR Organization every two years. There are guidelines about how these organizations are run and we were in full compliance. There were no complaints. The issue is COTS Uas flying on military property.
Pete
That's true. We were very good at working with the Ft Rucker MWR (Morale, Welfare and Recreation). We submitted our minutes and financials monthly and recertified as a MWR Organization every two years. There are guidelines about how these organizations are run and we were in full compliance. There were no complaints. The issue is COTS Uas flying on military property.
Pete
03-29-2020, 09:50 AM
#19
Well I thought an update would be in order.
Our club disbanded in January and formed Wiregrass Radio Control Club Inc. a nonprofit corporation. We felt we needed a proper legal structure to move forward and rolled all our assets into the new organization. From about 43 members we shrunk to 14 who were willing to pony up the funds needed to lease property. Several of us tracked down leads on land and finally in February we followed a lead on a private full scale airstrip with decent proximal location for us. I met with the landowner and he was open to leasing his part of the strip to us with overflight permission from the other two owners. We negotiated grass cutting and the ability to move our shed and build a shade structure on the property. With a 5 year lease at $2,500 per year it was ready to fly on right out of the box. We already enlarged the area for the pits and for parking. We renewed our charter with this as the site so we will be registered with the FAA. The field is close to one of the flight corridors for Ft. Rucker and we were able to get a NOTAM issued for us. Yeah it was a lot of work and it isn't cheap but we are flying and for the intermediate future we saved our club. Attached are photo's of Day one
Pete
Our club disbanded in January and formed Wiregrass Radio Control Club Inc. a nonprofit corporation. We felt we needed a proper legal structure to move forward and rolled all our assets into the new organization. From about 43 members we shrunk to 14 who were willing to pony up the funds needed to lease property. Several of us tracked down leads on land and finally in February we followed a lead on a private full scale airstrip with decent proximal location for us. I met with the landowner and he was open to leasing his part of the strip to us with overflight permission from the other two owners. We negotiated grass cutting and the ability to move our shed and build a shade structure on the property. With a 5 year lease at $2,500 per year it was ready to fly on right out of the box. We already enlarged the area for the pits and for parking. We renewed our charter with this as the site so we will be registered with the FAA. The field is close to one of the flight corridors for Ft. Rucker and we were able to get a NOTAM issued for us. Yeah it was a lot of work and it isn't cheap but we are flying and for the intermediate future we saved our club. Attached are photo's of Day one
Pete
03-29-2020, 10:51 AM
#21
That is one nice looking field. You guys should be proud of what you accomplished. It's just sad that all the former club members couldn't stay involved though they had to have their reasons for dropping out.
03-29-2020, 11:07 AM
#22
As a former base leader, the other problem is DoD rules on use of facilities by PRIVATE dues collecting organizations. Simply put, if the base (any base) allows one PRIVATE dues collecting organization to use base assets, then they must allow other PRIVATE dues collecting organizations to use the base too. And it gets even more complicated, from a DoD ethics perspective for the base commanders, when the private dues collecting organizations are holding money making events.
Are there bases that allow it? Sure, but shutting down the club is as easy as an Inspector General complaint by any other private dues collecting organization that was denied similar treatment.
Are there bases that allow it? Sure, but shutting down the club is as easy as an Inspector General complaint by any other private dues collecting organization that was denied similar treatment.
First off, Rocketman thank you for the update and letting us know that with some effort we can continue our hobby. Your post brought something to my attention that I had missed before and that is why I have quoted Franklin here.
In his post that I quoted he seems to imply that having an AMA chartered club on a military installation is quite problematic. It is also my understanding that one of his foundation gripes with the AMA is that they refused to help fund a flying site on a military installation in Central California when he asked them. Seems to me that on one hand he tells us that it's not feasible yet on the other hand bashes the AMA for not funding a field on his base.
03-29-2020, 11:56 AM
#23
First off, Rocketman thank you for the update and letting us know that with some effort we can continue our hobby. Your post brought something to my attention that I had missed before and that is why I have quoted Franklin here.
In his post that I quoted he seems to imply that having an AMA chartered club on a military installation is quite problematic. It is also my understanding that one of his foundation gripes with the AMA is that they refused to help fund a flying site on a military installation in Central California when he asked them. Seems to me that on one hand he tells us that it's not feasible yet on the other hand bashes the AMA for not funding a field on his base.
In his post that I quoted he seems to imply that having an AMA chartered club on a military installation is quite problematic. It is also my understanding that one of his foundation gripes with the AMA is that they refused to help fund a flying site on a military installation in Central California when he asked them. Seems to me that on one hand he tells us that it's not feasible yet on the other hand bashes the AMA for not funding a field on his base.
Another MAJOR difference was the location and what was already happening on the land. In an area where we were already allowing private entities to farm as part of an agricultural outlease program AND we had an existing DoD only offroad motorcycle club operating in the same general area. So allowing a DoD ONLY rc club was pretty similar to another club already in operation. So in that sense, I was using the DoD policy to my advantage. Also it helped that the surrounding land use was compatible (farming). Those conditions will no be in place at all locations. So just because there are some places where this might happen, does not mean there can be a blanket policy.
I would note that the above example is NOT on the military installation, that's why he used the phrase "private full scale airstrip..." So it's NOT on government land. Proof that yes indeed, there are challenges with establishing RC clubs on military land ... hence this club's move to PRIVATE land. And even then, the NOTAM specifically limits them to 400 AGL, within a specific radius, and for a fixed duration - note ending date:
"M0209/20 (Issued for KOZR KHEY KFHK KSXS KLOR) - AO HAWK (VIC NOE ROUTE 170) - CAUTION - RADIO CONTROLLED MODEL AIRCRAFT/UAS CLUB AT 16R FV 6283379395 - MODEL AIRCRAFT/UAS OPERATING WITHIN 600 METERS OF COORDINATES, SURFACE TO 400' AGL, AREA IS AVAILABLE/SUBJECT TO FLIGHTS 24/7. 04 MAR 19:43 2020 UNTIL 29 MAY 23:59 2020 (emphasis added)."
And finally, even if off installation, it does appear close enough to Rucker Nape of the Ear (NOE) flight patterns that a change in leadership can just as quickly bring challenges. Just because the existing Rucker leadership is ok with it does not mean the next leader will not be. Installation commanders have a lot of pull when it comes to these issues.
Last edited by franklin_m; 03-29-2020 at 12:15 PM.
03-29-2020, 02:11 PM
#25
