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Old 05-11-2009, 07:52 PM
  #1  
rack
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Default feds considering banning turbines?

(11) Model fixed-wing and rotorcraft aircraft shall not use metal-blade propellers.
(12) Model Aircraft shall not use gaseous boosts.
(13) Model Aircraft shall not use fuels containing tetranitronmethane or hydrazine.
(14) Model Aircraft shall not use turbine-powered engines (e.g., turbo-fan, turbo-jet) as
a propulsion source. !
April 1, 2009
Page 7
http://www.rcuniverse.com/forum/m_87...tm.htm#8760909


Old 05-11-2009, 08:04 PM
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smaze17
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Default RE: feds considering banning turbines?

Jesus - here we go again!

Can you say Rabbit Dry Lake???????

SM
Old 05-11-2009, 08:05 PM
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invertmast
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Default RE: feds considering banning turbines?

People really need to start reading all of things like that, instead of skimming thru it.. but my 2 cents on it are as follows:

I think a few are missing some KEY statements in this entire document:


Section 2.2
"RATIONALE: Reflects FAAÂ’s concept of regulating model aviation by
exempting Model Aircraft from regulation. Under this approach, modelers
participating within an aeromodeling structure/organization such as the
Academy of Model Aeronautics (AMA) may operate their Model Aircraft
in accordance with an accepted set of standards and operating
procedures. Based on a more rigorous attention to safety, risk assessment,
and risk mitigation, the accepted standards may provide greater latitude
in the Model Aircraft operations. Modelers not participating in the
additional safety programming established in an accepted set of standards
shall comply with the requirements of Section 3. "

"3. Model Aircraft Not Operated in Accordance with
Accepted Set of Standards !
3.1 Applicability !
The following general requirements and limitations apply to Model Aircraft which are not
operated in accordance with an FAA accepted set of standards, but are operated by hobbyists
for the sole purpose of sport, recreation, and/or competition.
April 1, 2009
Page 6
ALTERNATIVE VIEW: Eliminate Section 3.0 in its entirety.
ALTERNATIVE RATIONALE: AMA believes this approach is flawed in
that it fails to recognize the substantial diversity of the hobby, establishes
unrealistic and unenforceable restrictions, and leaves absent a safety
surveillance program to oversee the activities of those modelers who
choose not to participate in a formal aeromodeling structure/organization
More importantly, as a baseline set of standards, these limitations have
the inherent potential of imposing a devastating impact on the
aeromodeling activity and the hobby industry. "

Section 3.1 mentions an " an unaccepted set of FAA standards" but section 2.2 mentions that the FAA recognizes the AMA and accepts the AMA operation standards. Sooo

From my interpretation of all of this.. their are 2 "operation criteria".

A. In Accordance with AMA (in which all of the above are not applicable, and you revert to the AMA safety and operation standards/guidelines).

B. In accordance with the above FAA document (if it is accepted).

So basically, if you operate w/n the AMA standards, you are far less restricted, but if you aren't a part of the AMA, you are highly restricted in your operations and activities... But thats just my interpretation.
Old 05-11-2009, 08:06 PM
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Eddie P
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Default RE: feds considering banning turbines?

(woops, looks like I posted 30 seconds after the previous post...)
To the initial assumption in this thread. No. At least not in the way I read it.

That information you have cut and pasted resides in "Section 3" as below:

***************
3. Model Aircraft Not Operated in Accordance with
Accepted Set of Standards !
3.1 Applicability !
The following general requirements and limitations apply to Model Aircraft which are not
operated in accordance with an FAA accepted set of standards, but are operated by hobbyists
for the sole purpose of sport, recreation, and/or competition.......
***************

Above that section is the portion that referrs to the AMA, such as:
***********
2. Model Aircraft Operated in Accordance with
FAA Accepted Standards
2.1 Applicability
Model Aircraft operations that are conducted in accordance with an FAA accepted set of
standards established and administered by a community based association as discussed in
Section 2.2, shall otherwise be exempt from the requirements of any Special Federal
Airworthiness Regulation (SFAR) that results from this recommendation as long as they are
operated by:
• Hobbyist for the sole purpose of sport, recreation and/or competition under the
conditions of such an FAA accepted program
• Manufacturers which are flight testing aircraft intended to be operated for the sole
purpose of sport, recreation, and/or competition and they are tested at an approved
field as defined by and in accordance with an FAA accepted program with the
approval of the community-based association responsible for the location
• Educational institutions and/or students for the sole purpose of education or research
and they are operated at an approved field as defined by and in accordance with an
FAA accepted program with the approval of the community-based association
responsible for the location
• Manufacturers which are flight testing aircraft intended to be operated for other than
sport, recreation, and/or competition and they are tested at an approved field as
defined by and in accordance with an FAA accepted program with the approval of the
community-based association responsible for the location
RATIONALE: Reflects FAAÂ’s concept of regulating model aviation by
exempting Model Aircraft from regulation. Under this approach, modelers
participating within an aeromodeling structure/organization such as the
Academy of Model Aeronautics (AMA) may operate their Model Aircraft
in accordance with an accepted set of standards and operating
procedures. Based on a more rigorous attention to safety, risk assessment,
and risk mitigation, the accepted standards may provide greater latitude
in the Model Aircraft operations. Modelers not participating in the
additional safety programming established in an accepted set of standards
shall comply with the requirements of Section 3.
**********

Of course, this is my first look at this NPRM, if it is a notice at all. From knowledge of how the FAA writes things, it always says you canNOT do anything unles, "A,B,C.. etc". So in my very quick initial look at this, it may appear that they are saying unless you operate under the guise and rules of the AMA, you may not fly turbines. There are some other little bits of language there that reek of massive regulation and red tape and unsustainable compliance that may threaten all civil model airplane activity. Don't be scared for turbines. No. Be scared for model aviation! We do not want any of this. We've seen before that rules generated, from people with ZERO experience in the area they try to regulate, lead to nothing but disfunctionality.

I'd love to think the AMA is all over this. It seems they are in some ways, with their name plastered all over this. But I'm certainly listening right about now.
Old 05-11-2009, 08:09 PM
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Default RE: feds considering banning turbines?


Of course, this is my first look at this NPRM, if it is a notice at all. From knowledge of how the FAA writes things, it always says you canNOT do anything unles, "A,B,C.. etc". So in my very quick initial look at this, it may appear that they are saying unless you operate under the guise and rules of the AMA, you may not fly turbines. There are some other little bits of language there that reek of massive regulation and red tape and unsustainable compliance that may threaten all civil model airplane activity. Don;t be scared for turbines, be scared for model aviation! We do not want any of this.

Yea thats basically what i was saying, I just forgot to mention the ama as accepted and was in the process of editing my post as you typed this
Old 05-11-2009, 08:15 PM
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Eddie P
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Default RE: feds considering banning turbines?

Agreed Thomas!

But if this is all true and not just a hoax or scare... as if the AMA has been backed into the corner and this is the best they could do given the circumstances... I'm all for them trying to preserve our ability to engage in model aviation. I just have not heared of any of this coming down the (sewer) pipe.
Old 05-11-2009, 09:16 PM
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tp777fo
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Default RE: feds considering banning turbines?

Looks like a good reason to be part of the JPO, the turbine community's voice with the AMA. Lots of things have changed (for the better) with JPO and the AMA over the last couple of years and the more people represented by the JPO, the better informed the AMA can be to HELP US. There is strength in numbers and if we want to continue to fly jets we need more voices speaking as one.
Old 05-11-2009, 09:35 PM
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Default RE: feds considering banning turbines?


ORIGINAL: tp777fo

Looks like a good reason to be part of the JPO, the turbine community's voice with the AMA. Lots of things have changed (for the better) with JPO and the AMA over the last couple of years and the more people represented by the JPO, the better informed the AMA can be to HELP US. There is strength in numbers and if we want to continue to fly jets we need more voices speaking as one.
I agree with that.. and i guess now is as good a time as ever to join up for the first time..
Old 05-11-2009, 09:58 PM
  #9  
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Default RE: feds considering banning turbines?


ORIGINAL: invertmast


ORIGINAL: tp777fo

Looks like a good reason to be part of the JPO, the turbine community's voice with the AMA. Lots of things have changed (for the better) with JPO and the AMA over the last couple of years and the more people represented by the JPO, the better informed the AMA can be to HELP US. There is strength in numbers and if we want to continue to fly jets we need more voices speaking as one.
I agree with that.. and i guess now is as good a time as ever to join up for the first time..
Easy to do:
Go to www.jetpilots.org and an application can be done and payment through PayPal compleated in minutes.

Greg
Old 05-11-2009, 10:24 PM
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Default RE: feds considering banning turbines?


ORIGINAL: invertmast


Of course, this is my first look at this NPRM, if it is a notice at all. From knowledge of how the FAA writes things, it always says you canNOT do anything unles, "A,B,C.. etc". So in my very quick initial look at this, it may appear that they are saying unless you operate under the guise and rules of the AMA, you may not fly turbines. There are some other little bits of language there that reek of massive regulation and red tape and unsustainable compliance that may threaten all civil model airplane activity. Don;t be scared for turbines, be scared for model aviation! We do not want any of this.

Yea thats basically what i was saying, I just forgot to mention the ama as accepted and was in the process of editing my post as you typed this
The key phrase is NPRM... someone in the swamp is getting happy with the keyboard again! Relax!
Old 05-12-2009, 12:10 AM
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Default RE: feds considering banning turbines?

Why do I see April 1 all over that document?
Old 05-12-2009, 06:46 AM
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rack
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Default RE: feds considering banning turbines?

looks like the AMA is going to be part of the FAA putting us all under the Obama umbrella of control
Old 05-12-2009, 09:31 AM
  #13  
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Default RE: feds considering banning turbines?


ORIGINAL: rack

looks like the AMA is going to be part of the FAA putting us all under the Obama umbrella of control
You could always leave the country...
Old 05-12-2009, 11:31 AM
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Default RE: feds considering banning turbines?

I have some connections with the FAA in D.C. I'll ring him up and see what he says.

Beave
Old 05-12-2009, 12:18 PM
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Default RE: feds considering banning turbines?

Ahhhhh....Change that we can believe in.....be careful what you ask for, cause you may not like it when you get it....
Old 05-12-2009, 12:24 PM
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Default RE: feds considering banning turbines?

Does anyone know the source of these ARC comments? I found the SUAS committee section on the FAA website but I don't see a specific committee discussion model airplanes. Anyone know where it is?

Thanks,
Old 05-12-2009, 01:18 PM
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Default RE: feds considering banning turbines?

As has been said before, it is dated April 1st. Does this not ring any alarm bells as to its authenticity???
Old 05-12-2009, 01:28 PM
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rack
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Default RE: feds considering banning turbines?

that is what was proposed on that date its still in negotiations.

seems they have a huge problem with the ever increasing no fly zones .
constant violation by civil aircraft and model aircraft keep showing up on radar when there shouldn't be any thing except military
Old 05-12-2009, 03:04 PM
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Default RE: feds considering banning turbines?

The current administration has been in the office for only a few months, so that doesn't make it solely responsible for everything. Things have been set in motion waaayy back. It's not like the first order of business that Obama had was to stop us from flying model jets... come on, get real. The previous administration had done tons of things to limit our freedoms and barely anyone squealed about it, so let's not go there. I know we shouldn't get into politics, but sometimes i just can't help when people are suddenly on their high horse of righteousness. So let my post be the last on THAT particular issue.

Wasn't there a law passed that we can't pilot a model aircraft if we're doing it using a "first person" camera view directly in front of our eyes, which makes it a UAV? I remember reading that somewhere on this forum, so correct me if i'm wrong. I hope AMA does fight for this, because once they start limiting us with something, there's no stopping them - it's just a foot in the door.
Old 05-12-2009, 03:44 PM
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Eddie P
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Default RE: feds considering banning turbines?

ORIGINAL: Silver182

The key phrase is NPRM... someone in the swamp is getting happy with the keyboard again! Relax!
That's funny! My question, too, is where the source document "is". www.faa.gov has them all and so far I'm not seeing it. I admittedly have to look a little harder, possibly. And it may not be a NPRM at all, maybe just a technical fact sheet or something else entirely.

I did find one good article the FAA put in it's newpaper a few years ago:
http://www.faa.gov/news/aviation_new...janfeb2003.pdf

However, as you may already know, once the feds publish a "true" Notice of Proposed Rule Making, it's well on it's way to becoming regulatory. The feds are not floating a baloon in a NPRM, they are giving advance notice of something they've researched and are ready to implement. On occasions, when a large user group within the aviation industry heavily opposes certain proposals and back up the position with conclusive arguments, then the proposals can be largely altered or stopped. Smaller groups and organizations can sometimes effect gentle movement for side to side changes to the oncomming freight train - but it's much harder to stop when the group doesn't have the juice.
Old 05-12-2009, 04:20 PM
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Default RE: feds considering banning turbines?

An old Advisor Circular from the 1980's:
http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular.nsf/0/1acfc3f689769a56862569e70077c9cc/$FILE/ATTBJMAC/ac91-57.pdf

A recent FAA "Fact Sheet" educating FAA staff on UAV's:
http://www.faa.gov/news/fact_sheets/...fm?newsId=6287

Small Unmanned Aircraft System, FAA Rule Committe Order of 2007
http://www.faa.gov/documentLibrary/m...r/1110.150.pdf

I'm starting to wonder where "the" source document is!!
Old 05-12-2009, 11:00 PM
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Default RE: feds considering banning turbines?


Sorry this is so large, I'm not smart enough to provide a link, but this is a real proposal and will likely be implemented in some form (maybe not exactly like this) within a year or so.

Moderators if this is to big cut/delete as you see fit. Only the first part is about models and the bulk is about small Uavs, but interesting read.

Steve




April 1, 2009
Small Unmanned Aircraft System
Aviation Rulemaking Committee
Comprehensive Set of Recommendations
for sUAS Regulatory Development

April 1, 2009
Co-Chairs:
Bruce Tarbert, Federal Aviation Administration
Ted Wierzbanowski, AeroVironment, Inc
Aviation Rulemaking Committee Members
Ellis Chernoff, Air Line Pilots Association
Patrick Egan, Remote Control Aerial Photography Association
Mike Fagan, Association of Unmanned Vehicle Systems International
Carrie Haase, Auora Flight Sciences
Rob Hackman, Aircraft Owners and Pilots Association
Richard Hanson, Academy of Model Aeronautics
Andrew Lacher, The MITRE Corporation
Fred Marks, FMA
Douglas Marshall, University of North Dakota
Paul McDuffe, Boeing - Insitu
Tad McGeer, Aerovel Corporation
Mike OÂ’Shea, Department of Justice
Andrew Roberts, National Aeronautics and Space Administration
Don Shinnamon, International Association of Chiefs of Police
Dan Schultz, ASTM International
LTC Wade Wheeler, Department of Defense—Policy Board for Federal
Aviation
Ardyth Williams, Federal Aviation Administration
David York, Helicopter Association International
April 1, 2009
Page ii
Unless flagged with a solid dot (!), the material contained in this document represents
general consensus of the members of the Small Unmanned Aircraft System (sUAS) Aviation
Rule-making Committee. When there is less than general consensus, alternative views are
included along with their accompanying rationale.
April 1, 2009
Page iii
Forward
The Small Unmanned Aircraft System (sUAS) Aviation Rulemaking Committee (ARC) was
focused on making recommendations for Federal regulations for the operation of civil
(commercial) sUAS. However it was understood by the members of the ARC that a public
entity could fly under the provisions of any rule that might result from these
recommendations in lieu of flying under the provisions of a Certificate of Authorization
(COA) or in restricted, prohibited, or warning areas. In formulating the recommendations
contained in this document, sUAS ARC used the following guiding principles:
1. Enable the operation of sUAS by mitigating, to an acceptable level of risk, the
hazards posed to manned aircraft and other airborne objects operating in the National
Airspace System (NAS) as well as the public on the surface.
2. The development of regulations authorizing specific operations of certain sUAS
could provide a means for operators to request a waiver(s) from such a rule. Such an
option is not available to operators today.
3. Visual “see and avoidance” will be used by the sUAS flight crew to mitigate the risk
of collision with other aircraft and airborne objects.
4. The primary burden of maneuvering for potential collision risk avoidance should be
on the sUAS flight crew.
5. All other aircraft have the right-of-way over sUAS.
6. The above two principles do not relieve burden upon any pilot to see and avoid other
aircraft.
7. Operating limitations will be defined to reduce or minimize potential encounters
between manned and unmanned aircraft and reduce vulnerability of those on the
surface.
8. A formal Federal Aviation Administration (FAA) safety risk assessment will be used
to determine whether proposed regulations are acceptable to the FAA from a safety
perspective. If a specific recommendation is not acceptable from a safety perspective
then the FAA may require additional mitigations and/or controls.
9. Mitigations and controls should be tied to the level of risk to avoid being overly
burdensome on the application of sUAS technology. If a specific recommendation is
overly excessive or burdensome then the FAA may elect to modify the
recommendation in developing proposed regulations.
10. The recommended regulations should not be overly complex to facilitate analysis by
the FAA and other stakeholders.
11. Recommendations will leverage existing standards and regulations which govern the
operation of small unmanned and Model Aircraft.
12. Where feasible, the ARC will use existing definitions and regulations to develop
recommendations.
April 1, 2009
Page iv
13. sUAS ARC recommendations for an Special Federal Airworthiness Regulation
(sFAR):
• Are intended to enable some initial sUAS operations
• Are not intended to cover all potential applications or aircraft
- Existing processes such as COAs for public-use aircraft and Special
Airworthiness Certificate will remain options.
- Recommendations are directed at sUAS not necessarily all unmanned aircraft
systems.
Overall the committee was focused on a layered approach to ensuring that the potential risks
associated with mid-air collisions and/or injury to persons and property is within acceptable
levels. Many of the committeeÂ’s recommendations were made based upon experience with
existing aviation operations and regulations and perceptions of risk. Overall, the committee
was equally focused on protecting existing air traffic and persons/property on the surface. In
general, the philosophy was to minimize encounters, keep sUAS separated from other
aircraft and surface risks, avoid collisions, and minimize the impact of collisions that may
happen. See Figure 1.
The committee perceives that the recommendations in this document combine together to
enable sUAS operations at an acceptable level of risk. As more experience with sUAS is
gained and more data generated, these recommendations should be revisited.
For the most part, the committeeÂ’s recommendations are written in a language like proposed
regulations. Rationale and commentary which explain the recommended regulations are
imbedded throughout the document and appear inside boxes in italic text. Unless flagged
with a solid dot (!), the material contained in this document represents general consensus of
the members of the sUAS ARC. When there was less than general consensus, alternative
views are included inside boxes in italic text along with their accompanying rationale.
April 1, 2009
Page v
Acceptable Level of Risk
People & Property
on the Surface
Aircraft & Other
Airborne Objects
Reduce Encounters
Keep Separated
Avoid Collisions
Minimize Impact
• Altitude limits
• Airspace class limits
• Fly-away protection / C2 link
robustness
• Away from airports
• Crew training
• VMC/Day/VLOS
• ATC Notifications
• Visual Observer
• Comm monitoring
• Visual Observer
• Performance requirements
• Visibility (Paint, strobe,
transponder)
• Crew training
• Physical size
• Frangibility
• Airspeed limits
• VMC/Day/VLOS
• Telemetry
• Proximity to people/property
• Crew training
• Visual Observer
• Crew training
• System Design/testing
• Take-off/Landing areas
• Population density considerations
• Access controls
• Buffer zones
• Crew training
• Physical size
• Frangibility
• Airspeed limits
• System
design/testing
• Crew training
• Telemetry
Figure 1. Layered Approach for Ensuring Safety
This page intentionally left blank
April 1, 2009
Page vii
Table of Contents
1. Definitions 1
Subpart A. Model Aircraft 3
2. Model Aircraft Operated in Accordance with FAA Accepted Standards 3
2.1 Applicability 3
2.2 Accepted Model Aircraft Standards and Procedures 4
3. Model Aircraft Not Operated in Accordance with Accepted Set of Standards ! 5
3.1 Applicability ! 5
3.2 General Requirements ! 6
3.3 General Limitations ! 7
Subpart B. Operating Rules 11
4. General Operating Limitations 11
4.1 Daylight Operations 11
4.2 Visual Meteorological Conditions (VMC) 11
4.3 Visual Line-of-Sight 11
4.4 Safety of Those on the Surface ! 11
4.5 Notifications—Air Traffic Coordination 12
4.6 Operational Area 12
5. Operational Considerations Regarding Other Aircraft 13
5.1 Proximity to Other Aircraft 13
5.2 Requirement for a Qualified Visual Observer ! 13
5.3 Visual Observer Duties 13
5.4 Right-of-Way Rules 14
5.5 Communications Monitoring 15
6. General Operational Considerations 15
6.1 Take-off and Landing Area 15
6.2 Control Station Operations ! 16
6.3 Pilot-in-Command 16
6.4 Pre-flight Procedures 16
6.5 Crew Fitness for Duty 17
6.6 Alcohol or Drugs 17
6.7 Dropping Objects 18
6.8 Careless and Reckless 18
6.9 Reserves 18
6.10 Cloud Clearance ! 18
6.11 Operation from a Moving Vehicle ! 19
April 1, 2009
Page viii
6.12 Airspeed 20
7. General Operational Capabilities 20
7.1 Command and Control Link 20
7.2 Fly-away Protection 20
7.3 High Visibility 21
7.4 Maneuverability ! 21
7.5 Position Reporting 21
8. Multiple Kinds of sUAS Operations 22
9. Additional Provisions—Group I sUAS 22
9.1 Group I Physical Characteristics 22
9.2 Group I Additional Operational Limits ! 23
9.3 Group I Additional Operational Capabilities ! 24
9.4 System Certification 25
10. Additional Provisions—Group II sUAS 25
10.1 Group II Physical Characteristics 25
10.2 Group II Additional Operational Limits ! 25
10.3 Group II Additional Operational Capabilities 26
10.4 System Certification 27
11. Additional Provisions—Group III sUAS 27
11.1 Group III Physical Characteristics 27
11.2 Group III Additional Operational Limits 27
11.3 Group III Additional Operational Capabilities 28
11.4 System Certification 28
12. Additional Provisions—Group IV sUAS 28
12.1 Group IV Physical Characteristics 28
12.2 Group IV Additional Operational Limits ! 29
12.3 Group IV Additional Operational Capabilities 30
12.4 System Certification 30
13. RESERVED: Additional Provisions—Group V Lighter-than-Air sUAS ! 30
14. Provisions Concerning sUAS Operations in Designated Testing Areas 31
14.1 Groups of sUAS Allowed 31
14.2 Additional Operational Limits for Operations in Designated sUAS
Testing Areas 31
14.3 Operational Capabilities 32
14.4 System Certification 33
Subpart C. Personnel 35
15. Pilots 35
April 1, 2009
Page ix
15.1 Applicability 35
15.2 Certificate 35
15.3 Eligibility 35
15.4 Operations Not Requiring a Pilot Certificate 36
15.5 Aeronautical Knowledge Requirements 36
15.6 Flight Proficiency 37
15.7 Flight Review: Pilot-in-Command ! 38
15.8 Medical Certificate: Requirements and Duration 39
15.8.1 Operations Requiring a Medical Certificate ! 39
15.8.2 Operations Not Requiring a Medical Certificate 39
15.8.3 Duration of Medical Certificate ! 40
15.9 Issuance of sUAS Certificate and Authorizations 40
16. Qualified Visual Observer 41
16.1 Eligibility 41
16.2 Aeronautical Knowledge Requirements 41
16.3 Medical Requirements ! 42
16.4 Duration of Medical Certificate ! 43
17. UAS Instructor 44
17.1 Eligibility Requirements 44
17.2 Aeronautical Knowledge 44
17.3 Flight proficiency 45
17.3.1 Areas of Operation 45
17.3.2 Endorsement 45
17.4 sUAS Instructor Limitations and Qualifications 46
17.4.1 Hours of Training 46
17.4.2 Aircraft Type Training 46
17.4.3 Limitations on Endorsements 46
17.4.4 Qualifications of the Instructor for Training First Time sUAS
Instructor Applicants 46
18. sUAS Training Programs 47
18.1 Requirements for Training Courses 47
18.2 Operating Rules and Limitations 47
Subpart D. Aircraft and Systems 49
19. Registration, Identification, and Marking 49
19.1 Registration Required 49
19.2 Identification and Marking 49
20. Initial Airworthiness Certification 49
April 1, 2009
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20.1 Eligibility 50
20.2 Initial Test and Evaluation 50
20.3 Production Approval 51
21. Continued Airworthiness 51
21.1 Inspection and Maintenance 51
21.2 Record Keeping 51
21.3 Repairs and Modifications 51
22. Reporting 52
22.1 Operational Safety Monitoring 52
22.2 Annual Flight Hour Reporting 52
22.3 UAS Incident Reporting 52
Subpart E. Alternative Means of Compliance 53
23. Demonstration of Acceptable Level of Risk 53
Appendix A: Summary Matrix 55
Appendix B: Summary of Recommendations for System Standards 63
April 1, 2009
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1. Definitions
The following definitions apply to all small unmanned aircraft systems (sUAS) referred to in
this regulation.
Auto Flight Management: Pilot-in-Command (PIC) is able to maintain stable flight without
constant direct intervention. To at least some degree, control surface movements result from
sensors and software automation on-board the aircraft.
Collision Avoidance: Considered a last resort maneuver of an aircraft to avoid an imminent
collision. Without the maneuver a collision might occur.
Conflict Avoidance: Activity which seeks to ensure that aircraft remain safely separated and
well clear of each other as to not present a collision hazard.
Control Station: Equipment, not on the aircraft, used to maintain control, communicate,
guide, or otherwise operate an unmanned aircraft.
Data Communications Links: All links between the unmanned aircraft and the Control
Station which includes the command, status, communications, and payload links.
Launch/Recovery Equipment: Equipment, not on-board the aircraft, used to launch and
recover an unmanned aircraft which could also include unique navigation and differential
positioning equipment used for autonomous landing.
Model Aircraft: A sUAS used by hobbyists and flown within visual line-of-sight under
direct control from the pilot, which can navigate the airspace, and which is manufactured or
assembled, and operated for the purposes of sport, recreation and/or competition.
“Mode C Veil”: The airspace within 30 nautical miles (NM) of an airport listed in
Appendix D, Section 1 of 14 Code of Federal Regulations (CFR) Part 91 (generally primary
airports within Class B airspace areas), from the surface upward to 10,000 feet mean sea
level (MSL). Unless otherwise authorized by Air Traffic Control (ATC), aircraft operating
within this airspace must be equipped with automatic pressure altitude reporting equipment
having Mode C capability. However, an aircraft that was not originally certificated with an
engine-driven electrical system or which has not subsequently been certified with a system
installed may conduct operations within a Mode C veil provided the aircraft remains outside
Class A, B, or C airspace; and below the altitude of the ceiling of a Class B or Class C
airspace area designated for an airport or 10,000 feet MSL, whichever is lower. [Directly
quoted from the Federal Aviation AdministrationÂ’s (FAAÂ’s) Aeronautical Information
Manual: Official Guide to Basic Flight Information and ATC Procedures, February 14,
2008].
Pilot-in-Command: Same as 14 CFR 1.1
Manual Flight Control: PIC is able to directly control the aircraft such that control inputs
made at the Control Station are translated directly into corresponding control surface
positions. Augmentations which help maintain flight stability are permitted.
sUAS Flight Crewmember: A pilot, visual observer, payload operator or other person
assigned duties for a sUAS for the purpose of flight.
sUAS Pilot: A person exercising control over an unmanned aircraft during flight.
April 1, 2009
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Unmanned Aircraft: An aircraft (as defined by 14 CFR 1.1) that is intended to navigate in
the air without an onboard pilot.
Unmanned Aircraft System (UAS): An unmanned aircraft and its associated elements
related to flight operation which may include Control Stations, data communications links,
support equipment, payloads, flight termination systems, and launch/recovery equipment.
Visual Line-of-Sight: Unaided (corrective lenses and/or sunglasses exempted) visual contact
with aircraft sufficient to be able to maintain operational control of the aircraft, know its
location, and be able to scan the airspace in which it is operating to decisively see and avoid
other air traffic or objects.
Visual Observer: A sUAS flight crew member who assists the sUAS PIC in the duties
associated with collision avoidance. This includes, but is not limited to, avoidance of other
traffic, airborne objects, clouds, obstructions, and terrain.
April 1, 2009
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Subpart A. Model Aircraft
2. Model Aircraft Operated in Accordance with
FAA Accepted Standards
2.1 Applicability
Model Aircraft operations that are conducted in accordance with an FAA accepted set of
standards established and administered by a community based association as discussed in
Section 2.2, shall otherwise be exempt from the requirements of any Special Federal
Airworthiness Regulation (SFAR) that results from this recommendation as long as they are
operated by:
• Hobbyist for the sole purpose of sport, recreation and/or competition under the
conditions of such an FAA accepted program
• Manufacturers which are flight testing aircraft intended to be operated for the sole
purpose of sport, recreation, and/or competition and they are tested at an approved
field as defined by and in accordance with an FAA accepted program with the
approval of the community-based association responsible for the location
• Educational institutions and/or students for the sole purpose of education or research
and they are operated at an approved field as defined by and in accordance with an
FAA accepted program with the approval of the community-based association
responsible for the location
• Manufacturers which are flight testing aircraft intended to be operated for other than
sport, recreation, and/or competition and they are tested at an approved field as
defined by and in accordance with an FAA accepted program with the approval of the
community-based association responsible for the location
RATIONALE: Reflects FAAÂ’s concept of regulating model aviation by
exempting Model Aircraft from regulation. Under this approach, modelers
participating within an aeromodeling structure/organization such as the
Academy of Model Aeronautics (AMA) may operate their Model Aircraft
in accordance with an accepted set of standards and operating
procedures. Based on a more rigorous attention to safety, risk assessment,
and risk mitigation, the accepted standards may provide greater latitude
in the Model Aircraft operations. Modelers not participating in the
additional safety programming established in an accepted set of standards
shall comply with the requirements of Section 3.
April 1, 2009
Page 4
COMMENTARY: It is important that manufacturers of Model Aircraft
are able to test fly their aircraft as they do today without having to adhere
to sUAS regulations. In order to give educational institutions (e.g.,
universities) the flexibility to provide "hands on" instruction and training
to students preparing for careers in the UAS and aviation industries they
are allowed to fly these systems under the requirements for Model
Aircraft. For consistency, manufacturers who develop sUAS that are
functionally similar to Model Aircraft, are allowed to test at a location
following a community-based and FAA-accepted program.
2.2 Accepted Model Aircraft Standards and Procedures
Accepted Model Aircraft Standards and Procedures may be established and administered by
a community-based association. An accepted set of standards shall be based upon accepted
and recognized safety principles and will include but not be limited to the following:
RATIONALE: Community based organizations, such as the AMA, that
have credibility within the Model Aircraft community and that have an
established safety record and have demonstrated the ability to influence
participant compliance shall be afforded the opportunity to establish a set
of safety standards that are more comprehensive than the requirements
and limitations given for non participating modelers, and use these
standards as an alternative means of compliance with any regulations
which may results from these recommendations. Since such standards are
more comprehensive, operations under such standards shall allow for a
broad spectrum of operations and greater latitude in the AMA operations.
(1) Prescribed safety program entailing oversight, assessment, risk mitigation, and
accident/incident reporting.
(2) General safety guidelines and operating principles.
(3) Operating guidelines specific to the location and to the type, size, performance, and
propulsion of the various Model Aircraft.
(4) Comprehensive programming addressing Model Aircraft having non standard
weight, or identified as having unusual propulsion types or extraordinary flight
characteristics.
(5) Programming to facilitate Model Aircraft events, competition, national and
international record attempts, gatherings, and Model Aircraft demonstrations and
exhibitions.
(6) Educational programming that assures participants are provided relevant safety
information and validates the learning process.
(7) Educational programming that addresses essential piloting issues including:
• Recognition and avoidance of manned aircraft
• Safe operation near spectators and other non participants
April 1, 2009
Page 5
• Safe and cooperative operation with other modelers
• Transitioning to higher performance and more complex models
(8) Methodology for establishing and designating dedicated Model Aircraft flying sites
providing:
• Guidelines for flying site location, configuration and design layout applicable to
its intended use and the type(s) of Model Aircraft flown, and which ensures
Model Aircraft operations do not interfere with manned flight operations
• Safety guidelines that ensure the safety of the public and provide adequate
separation of persons and property from the Model Aircraft operations
• Guidelines for coordinating and reviewing operating policies and procedures
with the airspace controlling authority for those flying sites located within
controlled airspace
• Guidelines for coordinating and reviewing operating policies and procedures
with the airport and applicable airspace control authority for those flying sites
located within 3 NM of a military or public-use airport, heliport, or seaplane
base.
• Guidelines for establishing and disseminating flying site operating procedures,
limitations and safety guidelines including the following:
– Hours of Operation
– Flying site operating procedures
– Frequency control procedures (if applicable)
– Traffic pattern and flight operations
– Cooperation with other modelers
– Applicable altitude restrictions
– Applicable No-Fly zones and operating area limits
– Flight line and pit area safety procedures
– Spectator and public access policies
– Emergency Procedures (e.g., Fire, First Aid)
3. Model Aircraft Not Operated in Accordance with
Accepted Set of Standards !
3.1 Applicability !
The following general requirements and limitations apply to Model Aircraft which are not
operated in accordance with an FAA accepted set of standards, but are operated by hobbyists
for the sole purpose of sport, recreation, and/or competition.
April 1, 2009
Page 6
ALTERNATIVE VIEW: Eliminate Section 3.0 in its entirety.
ALTERNATIVE RATIONALE: AMA believes this approach is flawed in
that it fails to recognize the substantial diversity of the hobby, establishes
unrealistic and unenforceable restrictions, and leaves absent a safety
surveillance program to oversee the activities of those modelers who
choose not to participate in a formal aeromodeling structure/organization
More importantly, as a baseline set of standards, these limitations have
the inherent potential of imposing a devastating impact on the
aeromodeling activity and the hobby industry.
3.2 General Requirements !
(1) Model Aircraft shall be flown in open spaces and in a manner that does not
endanger the life and property of others.
(2) Model Aircraft shall yield the right of way to all manned aircraft.
(3) Model Aircraft shall not interfere with operations and traffic patterns at airports,
heliports, and seaplane bases.
(4) Model Aircraft shall not be operated at locations where Model Aircraft activities
are prohibited.
(5) Model Aircraft are limited to unaided visual line-of-sight operations. The Model
Aircraft pilot must be able to see the aircraft throughout the entire flight well
enough to maintain control, know its location, and watch the airspace it is operating
in for other air traffic. Unaided visual line-of-sight does not preclude the use of
prescribed corrective lenses.
(6) Model Aircraft shall be designed, equipped, maintained and/or operated in a
manner in which the aircraft remains within the intended area of flight during all
operations.
(7) Model Aircraft pilots may not intentionally drop any object from a Model Aircraft
that creates a hazard to persons or property.
(8) Model Aircraft shall be operated in a manner that respects property rights and
avoids the direct overflight of individuals, vessels, vehicles, or structures.
(9) Model Aircraft shall not be operated in a careless or reckless manner.
(10) Model Aircraft pilots shall not operate their aircraft while under the influence of
alcohol or while using any drug that affects the person’s faculties in any way
contrary to safety.
(11) Model fixed-wing and rotorcraft aircraft shall not use metal-blade propellers.
(12) Model Aircraft shall not use gaseous boosts.
(13) Model Aircraft shall not use fuels containing tetranitronmethane or hydrazine.
(14) Model Aircraft shall not use turbine-powered engines (e.g., turbo-fan, turbo-jet) as
a propulsion source. !
April 1, 2009
Page 7
RATIONALE: Turbine powered aircraft are perceived by many members
of the sUAS Aviation Rulemaking Committee (ARC) as being a higher
risk.
ALTERNATIVE VIEW: Eliminate the limitation.
ALTERNATIVE RATIONALE: The blanket prohibition of turbine
engines does not take into consideration the various and diverse turbine
engines currently produced and impose an unjustified economic impact on
the hobby industry.
3.3 General Limitations !
(1) Model Aircraft shall not exceed 55 pounds (lbs).
(2) Model Aircraft shall remain clear of clouds.
(3) Model Aircraft will not operate in Class B airspace without the permission of the
ATC authority.
(4) Model Aircraft shall not be operated within 3 NM miles of an airport, heliport, or
seaplane base without the permission of the ATC authority or airport manager.
(5) Model Aircraft shall operate in close proximity to the ground, at or below
400 feet (Â’) above ground level (AGL), and shall at all times remain below and well
clear of all manned aircraft. !
RATIONALE: By keeping Model Aircraft at or below 400Â’ encounters
with manned aircraft are reduced. This recommended general limitation
is consistent with the current Model Aircraft guidance contained in
AC91-57.
ALTERNATIVE VIEW: Replace (5) with the following:
Model Aircraft shall operate in close proximity to the ground, shall stay at
or below 400Â’ AGL when within 3 NM of an airport, and shall at all times
remain below and well clear of all manned aircraft.
ALTERNATIVE RATIONALE: Though it is agreed that there needs to
be some altitude limit on the modelers that are not participating in a
structured safety program such as AMAÂ’s, AMA also knows from their
experience that creating a hard and fast across the board altitude limit,
such as 400Â’ is unnecessarily restrictive, unrealistic, and arguably poses a
greater risk to personnel on the ground. AMAÂ’s experience has shown that
the greatest risk to other participants in the NAS and perhaps the only
significant risk posed by model aviation is when Model Aircraft are
operated within three miles of an airport. The language in the
ATERNATIVE VIEW mirrors the current guidelines in the AMA Safety
Code.
(6) Notwithstanding the above limitations, Model Aircraft weighing less than or equal
to two lbs incapable of reaching speeds greater than 60 miles per hour (mph)
(52 knots), and powered by electric motor or mechanical stored energy (e.g.,
April 1, 2009
Page 8
rubber-band powered) may operate within 3 NM of a military or public-use airport
or heliport; if they remain a safe distance from the airport or heliport, remain well
clear of all manned aircraft, and remain below 400Â’ AGL.
RATIONALE for the above limitations:
(1) Currently accepted domestic weight limit and has international
precedent as well.
(2) Is consistent with the concept of visual line-of-sight (VLOS).
(3) Class B is positive control. All aircraft are required to operate on a
clearance. Gaining permission from ATC is equivalent to receiving a
clearance.
(4) Model Aircraft permitted to operate within 3 NM of the airport will be
provided applicable operating limitations.
(5) 400Â’ is appropriate for Model Aircraft operations in Class C airspace
without coordinating with ATC and is consistent with the intention of
current domestic policy and with the UK, CASA, and Canada.
(6) This is consistent with the guidelines currently established by
AC91-57.
(7) Makes a blanket exception for models weighing two lbs or less. This
is an appropriate allowance for “Park Flier” and “toy” type models
and allows them to use parks and small fields closer to airports.
(7) Model Aircraft will not be flown at an airspeed that would cause the aircraft to
inadvertently leave the prescribed maneuvering area. !
RATIONALE: The pilot will be responsible for limiting their speed so
that they can remain within the prescribed maneuvering area.
ALTERNATIVE VIEW: Replace (7) with the following:
Model Aircraft cannot be operated at airspeeds which exceed 100 mph
(87 knots).
ALTERNATIVE RATIONALE: Restricting the speed of Model Aircraft
not participating in an FAA-accepted safety program will mean that highperformance
aircraft will not be operated by individuals that are not
being scrutinized by their peers. Eliminating high-performance aircraft
will also help to ensure that the operator will be able to keep their aircraft
within the defined operational area (line-of-sight and below 400Â’ AGL).
Limiting the speed also will reduce the likelihood of turbine powered
aircraft being operated without the guidance of an FAA-accepted safety
program. Turbine powered aircraft are perceived by many members of
the ARC as being a higher risk.
(8) Model Aircraft cannot launch pyrotechnic devices which explode or burn.
April 1, 2009
Page 9
(9) Excluding take-off and landing, no powered Model Aircraft may be flown closer
than 25 feet to any individual, except for the pilot and the pilots helper located at
the flight line.
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April 1, 2009
Page 11
Subpart B. Operating Rules
4. General Operating Limitations
The following general operating limitations determine the times, locations, and notification
requirements for all sUAS operated under this regulation.
4.1 Daylight Operations
No person may operate a sUAS except between the hours of sunrise and sunset.
RATIONALE: Visual “see and avoid” is the primary mitigation for midair
collisions.
4.2 Visual Meteorological Conditions (VMC)
No person may operate a sUAS except in VMC with a minimal visibility of three miles.
RATIONALE: Visual “see and avoid” is the primary mitigation for midair
collisions.
4.3 Visual Line-of-Sight
No person may operate a sUAS unless they or another sUAS flight crew has sufficient
unaided (corrective lenses exempted) visual contact with aircraft to be able to maintain
operational control of the aircraft, know its location, and be able to scan the airspace in
which it is operating for other air traffic.
RATIONALE: Visual “see and avoid” is the primary mitigation for midair
collisions.
4.4 Safety of Those on the Surface !
(1) No person may operate an sUAS in a manner that endangers the safety of persons
and property on the surface.
(2) No person may operate a sUAS directly over an open air assembly of people. !
ALTERNATIVE VIEW: Add text – “unless the sUAS is certified to have
reliability and lack of lethality equal to any aircraft certified by the FAA
for operation over an open air assembly of people.”
ALTERNATIVE RATIONALE: The applicant must have an opportunity
to offer evidence that his sUAS can operate over open air assemblies
without creating a hazard for people in that crowd. Public safety could be
enhanced by the presence of sUAS in situations in which manned aircraft
cannot operate without risk to people on the ground.
(3) During an emergency, the safety of people on the surface must be given priority
over the sUAS.
April 1, 2009
Page 12
RATIONALE: Makes it clear that the sUAS PIC is responsible for the
safety of persons on surface (whether on the ground or on the surface in a
vessel or vehicle).
(4) In an in-flight emergency requiring immediate action, the PIC may deviate from
any rule of this part to the extent required to meet that emergency.
RATIONALE: Consistency with 14 CFR 91.3b.
4.5 Notifications—Air Traffic Coordination
(1) UAS PIC must establish communications with the ATC and notify the airport
manager if planning to operate within 10 NM of an airport with an operating
control tower. sUAS PICs must comply with ATC instruction regarding operations.
(2) When operating within 3 NM of a military or public-use airport, heliport, or
seaplane base without an operating control tower, sUAS PIC must notify the airport
manager, if available.
(3) For all flights which are intended to operate greater than 400Â’ AGL and are either:
a) expected to exceed 30 minutes in duration or b) there is an expectation of one or
more additional flights within a four hour period, the PIC will request the issuance
of a Notice to Airmen (NOTAM) for the length of the operation as far in advance as
feasible (recommend more than 24 hours, but less than 48 hours) by notifying the
nearest ATC facility or Flight Service Station (FSS).
RATIONALE: Makes the responsibility clear when the ATC or airport
manager needs to be aware of sUAS operations. The ATC would be
aware of all sUAS operations in Class C and D airspace or near toweredairports.
ATC or FSS awareness would enable the ability to issue a
NOTAM. All operations over 400Â’ AGL would be eligible for a NOTAM
as well.
The group did not intend that the PIC would be required to have access to
two-way ATC communications in Class C airspace unless ATC requires
such access.
4.6 Operational Area
No person may operate a sUAS in the following areas:
(1) In a prohibited, restricted, or warning area without permission from the using or
controlling agency, as appropriate.
(2) In a Flight Restricted Zone (FRZ) or Washington, DC Metropolitan Area Special
Flight Rules Area (SFRA).
(3) On a published low altitude Military Training Routes (MTRs) without prior
authorization from the controlling authority.
(4) In Class B Airspace.
April 1, 2009
Page 13
RATIONALE: Keeps sUAS from operating in areas where there are
restrictions on civil operations. Also, keeps sUAS from operating in Class
B airspace due to the complexity of these operations. Avoiding low
altitude MTRs helps to reduce risk of collision between a low-flying fastmoving
military aircraft and a sUAS.
5. Operational Considerations Regarding Other
Aircraft
5.1 Proximity to Other Aircraft
No person may operate a sUAS so close to manned aircraft as to create a collision hazard.
5.2 Requirement for a Qualified Visual Observer !
The PIC must determine if a visual observer is necessary. A visual observer is necessary:
(1) If the sUAS is operated by a PIC either in a shelter or “headsdown”, the operation
requires the use of a qualified visual observer.
(2) For operations >400Â’ AGL one dedicated qualified visual observer is required. !
(3) If the PIC determines that a visual observer is necessary to maintain the safety of
the operation.
RATIONALE: Visual see and avoid is the primary mechanism of
ensuring safe separation and avoiding collisions. These considerations
make it clear when additional qualified visual observers are required.
Given that there is more likely to be other aircraft above 500Â’AGL
increasing the probability of a collision, an additional visual observer is
added for sUAS operations over 400Â’ AGL to aid in the ability to see and
thus avoid other aircraft.
ALTERNATIVE VIEW: Require two dedicated qualified visual
observers when operating above 400Â’ AGL.
ALTERNATIVE RATIONALE: Given that there is more likely to be
other aircraft above 500Â’AGL increasing the probability of a collision a
minimum of two visual observers should be used.
5.3 Visual Observer Duties
A qualified visual observer must scan the airspace around the sUAS for other aircraft which
may be potential collision hazards.
(1) PIC or qualified visual observer (close proximity of PIC) must maintain position of
the sUAS through direct visual observation in order to avoid creating a collision
hazard with other aircraft, airborne hazards, persons on the ground, terrain, or
obstructions.
April 1, 2009
Page 14
(2) The qualified visual observer, if used, must maintain effective two-way
communications with the PIC.
RATIONALE: Clearly defines visual observer duties as being focused on
the “seeing” component of “see and avoid”. Emphasizes that the visual
observer is not necessarily focused on the sUAS but focused on scanning
the airspace with awareness of the sUASÂ’s location.
(3) When using other aids to vision, such as binoculars, field glasses, or telephoto
television, qualified visual observers must use caution to ensure that the unmanned
aircraft remains within the approved visual limitation distance. Due to field of view
and distortion issues, the use of such aids can be used to augment the qualified
visual observerÂ’s visual capability, but cannot be used as the primary means of
visual contact.
5.4 Right-of-Way Rules
sUAS must yield the right-of-way to all other aircraft. UAS flight crews must assume that
other pilots cannot see their aircraft and therefore the burden of maneuvering for potential
collision risk shall be on the sUAS PIC.
(1) The PIC must yield the right-of-way and when a manned aircraft is detected,
always maneuver early to prevent a potential conflict. The preferred means of
conflict avoidance is to descend and maneuver closer to the landing area and the
PIC and/or qualified visual observer.
(2) Although sUAS should descend as its primary means of collision avoidance; the
PIC should use the most appropriate maneuver for the situation.
(3) During an emergency, the safety of manned aircraft must be given priority over the
sUAS.
(4) For sUAS encounters with other sUAS, the right-of-way rules defined in 14 CFR
91.113 apply, except that all sUAS must yield the right-of-way to manned aircraft.
RATIONALE: Most sUAS approximate the size of birds. Manned pilots
expect birds to dive when encountering an aircraft, thus sUAS should
behave similarly. Given that the PIC and/or observer on the surface may
not always be able to accurately determine relative altitude or relative
lateral bearing, it was felt by the consensus of the group that by
descending as close to the surface as possible, the risk of collision could
be reduced to the maximum extent. The working group also wanted to
make it clear that the prime responsibility for maneuvering was on the
sUAS PIC and that the safety of manned aviation had priority.
COMMENTARY: It is not the intent of the ARC to limit the options
available to the PIC, but to offer guidance as what is likely to be the most
appropriate maneuver.
COMMENTARY: These recommendations will need to be updated
pending the development of recommendations focused on Lighter-Than-
Air (LTA) sUAS.
April 1, 2009
Page 15
5.5 Communications Monitoring
When operating in Class C and D airspace, a sUAS PIC or qualified visual observer shall
monitor ATC voice communications as instructed by ATC.
COMMENTARY: If the Control Station is equipped with ATC
communications radio, the PIC and/or qualified visual observer should
monitor ATC voice communications when operating in Class E or G
airspace in the “Mode C veil” to identify aircraft that could potentially
enter the airspace in which the sUAS is operating.
If the Control Station is equipped with a UNICOM radio (Frequencies
Used For Aeronautical Advisory Services To Private Aircraft) or Common
Traffic Advisory Frequency (CTAF), the PIC and/or qualified visual
observer should monitor to identify aircraft that could potentially enter
the airspace in which the sUAS is operating.
RATIONALE: For added situational awareness, it was felt that
monitoring appropriate frequencies would aid the PIC and/or visual
observers in being aware of other aircraft potentially in the airspace.
While there may be some costs associated with the capabilities required,
the consensus of the group was that the added safety value warranted the
investment.
Using the term “monitor” was deliberate. It was not the group’s intent
that the PIC or visual observer would be transmitting via 2-way ATC
communications. This was for the following reasons:
• It is unclear that a transmitter located on the surface several miles
from the ATC radio antenna would be effective
• We did not want to increase the workload of ATC controllers and
increase ATC frequency congestion with chatter from sUAS operators.
If controllers need to instruct all sUAS operators to cease operations
due to an emergency in their sector, they can simply broadcast on the
ATC channel which would be monitored by the sUAS operators
6. General Operational Considerations
6.1 Take-off and Landing Area
(1) The PIC must ensure that sufficient space is available at the flying location to
conduct safe take-off and landings.
(2) The PIC must ensure that the take-off and landing area(s) is clear of persons and
property not associated with the operation to which the aircraft could pose a hazard.
COMMENTARY: It may be appropriate to establish a consensus
standard on how a manufacturer should go about determining the
minimum space required for take-off and landing.
April 1, 2009
Page 16
6.2 Control Station Operations !
No person may operate a sUAS unless there is a one-to-one correspondence between Control
Station and the unmanned aircraft. Control may be transferred from one Control Station to
another provided procedures exist to affect the transfer including clear and immediate
designation of the PIC at all times. The following is prohibited under this regulation:
(1) Using a Control Station to control more than one unmanned aircraft at a time.
(2) Simultaneously controlling an unmanned aircraft from more than one Control
Station. NOTE: This does not apply to control of a payload or sensor package
provided that operation of the sensor package or payload is electrically isolated
from the sUAS flight control systems and operation has no significant effect on the
flight parameters of the sUAS.
(3) A second Control Station cannot be used to increase operational range. !
ALTERNATIVE VIEW: Replace (3) with the following:
A second Control Station may be used to increase operational range if all
other provisions of this regulation are met.
ALTERNATIVE RATIONALE: If each Control Station is equipped
manned and operated like the initiating station with the required observer,
communication capability and conforms with all required airspace
restrictions minimal additional risks are introduced by transferring
control and extending the operational range. It would be analogous to the
aircraft landing at close to its maximum range and then taking off again
under control of a second Control Station with overlapping coverage.
6.3 Pilot-in-Command
With the exception of those aircraft operated in accordance with the provisions described in
Section 9, no person may operate a civil sUAS under this regulation without a PIC who is
certified to operate a sUAS consistent with the requirements in 15.
RATIONALE: Operators of Group I sUAS will not require certification.
6.4 Pre-flight Procedures
The PIC is responsible for the following pre-flight procedures:
(1) Familiarization: The PIC must become familiar with the following information
concerning the intended flight:
• Available weather reports and forecasts
• Fuel requirements
• Take-off and landing minimum space requirements
• Landing alternatives and emergency ditching locations
• Potential ground hazards
• Location of personnel directly involved with the operation
April 1, 2009
Page 17
• Restrictions or limitations associated with the airspace in which operations will
occur
• Local air traffic activity
• Location of persons and property on the surface
• Weight and Balance
(2) Crew Verification: The PIC must verify that all persons involved in the operation
are trained and sufficiently knowledgeable and skilled in their operational
responsibilities and that they meet the appropriate certifications, currency
requirements, and medical qualifications for the intended flight.
(3) Environment Assessment: The PIC must assess the operating environment
considering risks to people and property in the immediate vicinity both on the
surface and in the air. This assessment must include weather conditions, local air
traffic activity, the location of persons and property on the surface, and other
ground hazards.
(4) Pre-Flight Briefing: The PIC must ensure that all sUAS flight crew members
receive a pre-flight briefing on the operating conditions, emergency procedures,
contingency procedures, roles and responsibilities, and potential hazards.
(5) Aircraft and Equipment Inspections: The PIC must ensure that the aircraft,
Control Station, and other flight critical equipment are inspected for damage and
are ready for flight per manufacturer guidelines.
(6) Communications Check: The PIC must ensure that the command, control, and
communications link is working properly.
(7) Weight and Balance: The PIC must ensure that the weight is appropriately
distributed in order to maintain the aircraft center of gravity to ensure stable flight
in accordance with manufacturer recommendations.
6.5 Crew Fitness for Duty
The PIC must ensure that all crew members are rested and fit for intended duty. For flight
operations, 10 hours of consecutive rest in the 24 hour period preceding the planned
completion of his duty time. Non-local travel and other work duties associated with the
employer are not considered part of the rest period.
RATIONALE: As with any commercial operation, crew duty day limits
will help ensure that the flight crew is alert to maintain appropriate safety
vigilance.
6.6 Alcohol or Drugs
No person may act as a crewmember of a sUAS under the following conditions:
(1) Within eight hours after the consumption of any alcoholic beverage.
(2) While under the influence of alcohol.
April 1, 2009
Page 18
(3) While using any drug that affects the person’s faculties in any way contrary to
safety.
(4) While having an alcohol concentration of 0.04 or greater in a blood or breath
specimen. Alcohol concentration means grams of alcohol per deciliter of blood or
grams of alcohol per 210 liters of breath.
RATIONALE: Consistent with operational regulations contained in
14 CFR 91.17.
6.7 Dropping Objects
No PIC of a sUAS may allow any object to be dropped from that aircraft in flight unless
reasonable precautions are taken to avoid injury or damage to persons or property.
RATIONALE: Consistent with operational regulations contained in
14 CFR 91.15.
6.8 Careless and Reckless
No person may operate a sUAS in a careless or reckless manner so as to endanger the life or
property of another.
RATIONALE: Consistent with operational regulations contained in
14 CFR 91.13.
6.9 Reserves
The PIC must ensure that there is enough fuel and/or battery charge to fly for the intended
time period and for no less than five minutes of reserved power.
RATIONALE: This requirement is loosely based upon 14 CFR 91.151,
fuel requirements for flight in Visual Flight Rules (VFR) conditions. By
having a reserve requirement, helps to ensure that the PIC does not run
out of fuel/power during flight resulting in an uncontrolled aircraft.
91.151 requires 20 minutes VFR fuel reserves for rotorcraft. Given that
sUAS will not be flying far from their landing areas, will remain relatively
close to the surface, and have flight duration that may be extremely short,
the requirement was modified five minutes. The main purpose of the
reserve is to ensure that there is sufficient power for the aircraft to return
from its farthest point and to ensure that it can remain aloft for a
sufficient time period to ensure that the landing area is clear of hazards.
6.10 Cloud Clearance !
The sUAS PIC must ensure that the aircraft remains at least 500 feet below and 2000 feet
horizontal from clouds in Class C, D, and E airspace and clear of clouds in Class G airspace.
RATIONALE: Enables the sUAS PIC and/or visual observer an
opportunity to visually identify potential collision threats which may
emerge from the clouds.
April 1, 2009
Page 19
ALTERNATIVE VIEW: The sUAS PIC must ensure that the aircraft
remains at least 500 feet below and 2000 feet horizontal from clouds in all
classes of airspace.
ALTERNATIVE RATIONALE: The 500 feet below and 2000 feet
horizontal distances are consistent with the ultra-light requirements in
14 CFR 103.23 and parachute cloud clearance requirements in 14 CFR
105.17.
6.11 Operation from a Moving Vehicle !
No person may control a sUAS from a moving vehicle or aircraft.
RATIONALE: Ensures that the area of sUAS operation is contained and
controlled. Operation from a vessel on the water is allowed provided that
this vessel is not moving. It is envisioned that those who desire to operate
from a moving marine vessel in open water (e.g., Ocean or Great Lakes)
could petition the FAA for a waiver from this provision.
COMMENTARY: The sense of the sUAS ARC was that operations in
open ocean from a moving ship should not necessarily be a significant risk
and should be enabled. Considerations should be made for existing air
traffic density (e.g., Gulf of Mexico where there is significant rotorcraft
operations associated with oil platforms).
ALTERNATIVE VIEW: Eliminate restriction of operating from a
moving vehicle.
ALTERNATIVE RATIONALE: Military operators have found that
operating a sUAS from a ground vehicle or vessel on the water is not
significantly different than operating from a fixed location provided the
PIC and/or visual observer is placed in a position in the vehicle or vessel
where they have the same unobstructed view as they would if they were on
the ground and "waypoint position relative" feature as discussed below is
provided.
"Waypoint position relative" feature rationale. Mobile operations are
very different from stationary operations because navigation waypoints
maintain a position relative to Earth, not the PIC at the ground station. A
PIC at a control station will lose relative knowledge of position if the PIC
and the control station move. Global Positioning System (GPS) reports
absolute position but an interface can also be provided to calculate and
report position relative to another position. Key waypoints for relative
situational awareness do not move with the PIC and control station unless
the particular system has some sort of "waypoint position relative" feature
to manage this. The ground station also must have its own GPS or similar
to keep track of its position in order to make relative aircraft position
reports to the PIC and provide relative situation awareness such as range
and bearing to the aircraft relative to PIC/ control station (situational
April 1, 2009
Page 20
awareness during mobile operations are really difficult without this
capability).
6.12 Airspeed
No person may operate a sUAS faster than an airspeed of 87 knots.
RATIONALE: The AMA has determined that aircraft flying faster than
100 mph are considered a high performance aircraft. Faster aircraft are
perceived as having greater risks.
7. General Operational Capabilities
RATIONALE: These operational capability and/or equipment provisions
are analogous to the provisions contained in 14 CFR 91, subpart C,
Equipment, Instrument, and Certificate Requirements.
All sUAS operated under this regulation must have the following operational capabilities:
7.1 Command and Control Link
(1) The PIC must only operate a sUAS that employs appropriate technology to ensure
reliability of communications control links and minimizes system vulnerability to
radio frequency interference.
(2) When operating using 72-76 Megahertz (MHz) commonly used by the Model
Aircraft community, the PIC must employ technology which ensures that there is
no interference with Model Aircraft operations.
COMMENTARY: Consensus standards will clearly define how to
appropriately achieve the intended capabilities above. Thus, the defintion
and specification of the appropriate technology will be left to consensus
standards. The technology defined for 72-76 Mhz must ensure that the new
transmission technology does not intefere with the legacy technology used
by Model Aircraft today.
7.2 Fly-away Protection
No person may operate a sUAS that does not employ a technical mechanism which
automatically executes a strategy to retain the aircraft in the intended operational area in the
event of the loss of control. The fly-away protection mechanism must return the sUAS
safely to the surface, as soon as practical.
COMMENTARY: Consensus standards will clearly define how to
appropriately achieve the capabilities intended. Thus, the definition and
specification of the appropriate technical mechanisms will be left to
consensus standards.
April 1, 2009
Page 21
7.3 High Visibility
All sUAS operated under this regulation must be colored with a high-contrast scheme.
RATIONALE: Facilitates unmanned aircraft tracking by the PIC and
visual observers as well as to increase the probability that it would be
detected by pilots of manned aircraft.
COMMENTARY: Consensus standards will clearly define how to
appropriately achieve the capability intended. A single consensus
standard could not only address coloring schemes for sUAS visibility, but
also address the issue of identification markings (See Section 19.2). Thus,
the sUAS ARC envisions a standard like “Standard Guide to the Visibility
and Identification Markings of Small Unmanned Aircraft Systems for
Commercial Use.”
7.4 Maneuverability !
All sUAS must have the capability to descend 50 feet within five seconds of the PIC
recognizing the need for an avoidance maneuver. Maneuver should be repeatable or the
aircraft should return to the ground. !
RATIONALE: Helps to ensure that the PIC can maneuver the sUAS to
avoid potential conflicts and maneuver in the event of an imminent
collisions threat. Capability could accommodate larger descents through
repeat instruction or continued control surface deflection.
ALTERNATIVE VIEW: To allow either a climb or descent of 50 feet
within five seconds.
ALTERNATIVE RATIONALE: Limiting an avoidance maneuver to only
a descent may be impractical and could introduce risks. Circumstances
may dictate that other options may be more appropriate. Having options
may reduce risks.
7.5 Position Reporting
If operating greater than 400Â’ AGL all sUAS weighing over 4.4 lbs (2 kilograms (kgs)) must
have the capability to display position and altitude information to the PIC.
RATIONALE: Helps the PIC maintain situational awareness and ensure
that the aircraft remain within appropriate operating limits. If available,
down-linked aircraft telemetry can be used by the PIC and/or qualified
visual observers to aid in flight operation and visual acquisition.
COMMENTARY: In the future, the FAA may want to consider having
Automatic Dependent Surveillance-Broadcast (ADS-B) OUT either
transmitting from on-board the aircraft or as a relay from the Control
Station. This may assist manned aviation in the vicinity with situational
awareness of the location of sUAS operations, especially as ADS-B IN
utilization grows in the aviation community whom typically fly at low
altitudes.
April 1, 2009
Page 22
8. Multiple Kinds of sUAS Operations
There are multiple kinds of operations for sUAS each with different operational limits and
required operational capabilities determined by gross take-off weight, system robustness, and
relative risk. The PIC is responsible for ensuring that operations are conducted consistent
with these constraints. The five operating groups are summarized in the table below.
Group
Gross
Take-Off Weight
Additional
Operational Limits
Additional Required
Operational Capabilities
I < 4.4 lbs (2 kgs) Section 9.2 Section 9.3
II < 4.4 lbs (2 kgs) Section 10.2 Section 10.3
III < 19.8 lbs (9 kgs) Section 11.2 Section 11.3
IV < 55 lbs (25 kgs) Section 12.2 Section 12.3
V LTA only Section 13 (Reserved) Section 13 (Reserved)
9. Additional Provisions—Group I sUAS
Group I sUAS are very maneuverable, frangible, and slow moving aircraft which pose
minimal risk to those on the surface and other aircraft.
9.1 Group I Physical Characteristics
The following physical characteristics apply to all Group I sUAS:
(1) Gross take-off weight equal to or less than 4.4 lbs (2 kgs) including fuel, batteries,
and payload.
(2) Must not be capable of exceeding more than 30 knots calibrated airspeed at full
power in level flight.
(3) Constructed in a frangible manner that would minimize injury to those on the
surface and reduce damage to other aircraft in the event of a mid-air collision. A
sUAS can be considered frangible if it is made of paper, wood, or breakable plastic
and contains no substantial metal parts.
RATIONALE: A key differentiator between Group I and Group II sUAS
is frangibility.
Some alternatives discussed include the following:
• Given that the word frangible means “breaks into pieces” the
definition could focus on the nature of pieces such as the size of the
largest hard piece or the frontal area of the largest piece
• Ratio of plan view area to weight
• Energy absorbing of the material
With the “keep-it-simple” guidance in mind, the above definition is being
proposed. The notion of frangibility is important in that the consequence
April 1, 2009
Page 23
of a collision between a sUAS and another aircraft or person/property on
the surface is reduced if the sUAS itself is frangible.
COMMENTARY: Consensus standards could be developed for how to
construct a sUAS that would be considered frangible.
9.2 Group I Additional Operational Limits !
In addition to the limitations outlined in Sections 4, 5, and 6 of this regulation, a Group I
sUAS must be operated:
(1) At or below 400Â’ AGL in Class C, D, E, and G airspace.
RATIONALE: Limiting Group I aircraft to at or below 400Â’ mean that
sUAS which are certified to a lower degree of robustness and operated by
unlicensed PICs are less likely to encounter manned aircraft (since in the
majority of airspace, manned aircraft must be at a minimum altitude of
500Â’ or higher for fixed winged aircraft).
(2) Within visual line-of-sight of the PIC and/or qualified visual observer or less than
1500Â’ lateral distance from the location of the PIC and/or visual observer whichever
is less.
(3) Greater than 3 NM of a military or public-use airport, heliport, or seaplane base.
RATIONALE: Within 3 NM of an airport is the airspace where manned
aircraft are likely to be operating close to the ground. To reduce
encounters with unmanned aircraft which are certified to a lower degree
of robustness and operated by unlicensed PICs, Group I aircraft are
restricted from operating within 3 NM of an airport. The Group I sUAS is
limited to specific operating areas.
April 1, 2009
Page 24
ALTERNATIVE VIEW: (Replace 9.2) with the following:
In addition to the limitations outlined in Sections 4, 5, and 6 of this
regulation, a Group I small UAS must be operated:
(1) At or below 400Â’ AGL in Class C, D, E, and G airspace.
(2) Within visual line-of-sight of the PIC and/or qualified visual observer
or less than 1500Â’ lateral distance from the location of the PIC and/or
visual observer whichever is less.
(3) Greater than 3 NM of a charted public-use airport, heliport, or
seaplane base unless the following requirements are met:
(a) The PIC, no less than one hour prior to beginning a flight,
informs the controlling authority of all public use airports,
heliports or seaplane bases within three miles of the area in which
the flight will take place, the time and place of the flight
operations, and inquires regarding any specific areas where sUAS
flight shall be avoided.
(b) The PIC will initiate a call by cell phone to the nearest controlling
authority to assure cell coverage and provide a call back number
to facilitate contact of the PIC by the Controlling Authority if for
any reason sUAS flight operations must suddenly be restricted or
suspended.
(c) The sUAS shall operate no more than 200Â’ higher than the
maximum height of obstructions such as trees, power lines,
structures, steep cliffs or bluffs within the flight area, or 400Â’ AGL
whichever is the lower altitude.
ALTERNATIVE RATIONALE: A distance of 3 miles from airport
identified in this recommendation limits the commercial viability of sUAS
employment for small business. It prohibits operation in the environment
where nearly all the commercial opportunity exists. The mitigating factors
in the alternate view establish definable and analyzable risk
characteristics.
9.3 Group I Additional Operational Capabilities !
In addition to the operational capabilities outlined in Section 7 of this regulation the
following capabilities are required:
(1) Manual Flight Control: Group I SUAS must be capable of only manual flight
control, ensuring that PIC control inputs made in the Control Station are translated
directly into corresponding control surface positions. !
RATIONALE: The idea for Group I aircraft were that they are operated
like a Model Aircraft for compensation and hire. Model Aircraft are not
generally operated in any other manner than manual flight control. Such
April 1, 2009
Page 25
a system is likely to be less complex and thus easier for a non-license PIC
to operate.
For operations requiring other than manual flight control (i.e., auto flight
management) would thus have to be operated as Group II.
ALTERNATIVE VIEW: Group I sUAS should be allowed to utilize
simple auto flight management systems as long as manual flight cont
Old 05-12-2009, 11:37 PM
  #23  
causeitflies
 
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Default RE: feds considering banning turbines?

Yeah, that's pretty long. Where does it say anything about models in there? It's about commercial sUAS.
Old 05-13-2009, 12:41 AM
  #24  
quist
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Default RE: feds considering banning turbines?

I received the copy from a FAA official in San Diego. It is a 74 page pdf. It definately discuses the hobbiest, AMA and Turbine bans. It also talks about 100mph max speed for all aircraft.
Old 05-13-2009, 06:55 AM
  #25  
rojos
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Default RE: feds considering banning turbines?

Models are discussed at the beginning of the document around page 3 break. It's very close to the top of the document.


Steve


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