BV's letters to AMA and FAA
07-24-2014, 12:49 PM
#27
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Well, comment period extended by 60 days. Perhaps we should comment to the FAA to this affect, no?
Seems like people are really dividing up into 2 camps, but this camp doesn't sem to be formally represented outside of the letter that's the subject of this thread.
Seems like people are really dividing up into 2 camps, but this camp doesn't sem to be formally represented outside of the letter that's the subject of this thread.
07-24-2014, 01:06 PM
#29
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Keep in mind guys, the FAA is require to respond to every comment posted at the Federal Register. Typically, they bunch them together of like kind and respond to like questions out of efficiency, but they DO look at them all. A series of responses from us could have sway.
Don't get me wrong - I'm all for the AMA, but as was mentioned, I feel they are giving over to the greed of additional members/money/advertising rather than the overall safety of airspace on part of this. Distance from airport? - keep using the old rule as it has proved reliable for decades. Commercial flying by factory pilots? - Who safer to fly RC planes? I never understood that one...
Don't get me wrong - I'm all for the AMA, but as was mentioned, I feel they are giving over to the greed of additional members/money/advertising rather than the overall safety of airspace on part of this. Distance from airport? - keep using the old rule as it has proved reliable for decades. Commercial flying by factory pilots? - Who safer to fly RC planes? I never understood that one...
07-24-2014, 01:08 PM
#30
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So sorry guys but I couldn't disagree more with many of Mr Violett's thoughts. Too many to mention but here are just a few.
1.Drone, sUAS, model aircraft, flying missile (RC jet) etc etc. The name doesn't change the nature of the thing. Using names to villainize things or people is one of the oldest tactics in the book on argument, and one of the most easily disproved logical fallacies. This tactic is used all the time by unscrupulous marketing types in an effort to induce people to open their wallets. Also used by political activists as a cheap way of promoting their position. e.g. Abortion Rights vs Pro choice advocates.
2. IMO the AMA's position on FPV has been conservative, cautious and stepped so as to ensure that safety margins are maintained compared to those of VLOS flying.
3. Blaming the AMA for the actions of the outliers who do not fly within the constraints of the organizations guidance is simply wrong. The AMA has guidance for turbines yes? When someone with a turbine goes out and flies without regard for AMA's rules we do not blame the AMA. It makes no sense. We blame and pursue the offender. Now OTOH if the AMA is aware of violations and they do not act, we have a different problem and I agree we take steps to ensure compliance.
4. IMO we the citizens should do everything in our power to fight back against over bearing intrusions on our daily lives that do nothing to ensure the public safety. The FAA's recent "interpretation" Is one such intrusion that should be rejected in the strongest possible terms. I do not believe that the losing the battle on FPV will cause us to lose the hobby we all love. Congress has already mandated the FAA stay out and IMO the FAA is treading dangerously on so many toes including the recent attempt to harass a congressperson who had his wedding filmed for hire that a serious slap down from the public at large and congress in particular is close at hand. We also have the courts involved in this ongoing process.
5. Accepting the FAA's position on FPV while rejecting the commercial flying aspects is somewhat disingenuous especially given the nature of Mr Violett's business. I don't think there are any constitutional protections preventing the FAA from regulating commercial aviation. The federal government has been doing just this since 1926. The objections to their attempts to regulate and effectively eliminate the use of commercial sUAS since there are effectively no pathways to such legal activities if we accept the FAA's opinions on the matter should arise from the fact that they have steadfastly refused to even define what a sUAS is. Neither has the FAA made it's case that any sUAS that leaves the ground anywhere in the US and at any altitude can demonstrably show a threat to other users of the NAS. Commercial use of much of our nation's airspace at low altitudes should remain the domain of local authorities. This will require the FAA to very carefully consider with an eye towards defining limits how much of the atmosphere above the surface they really need to be involved in regulating. Claiming my backyard below 100 feet is not a reasonable answer that any of us should be willing to accept. This country already has too many unenforced laws protecting citizens privacy and we don't need the FAA involved in this area at all. FAR 91.11 and 121.580 already provide adequate protection against interference with manned aviation. These are the sections that IMO should be used to prosecute individuals that pose a threat. Not some silly attempt to suggest that a rubber band powered Guillows balsa plane must adhere to all elements of part 91 because it is after all an aircraft. Really?
6. The AMA has been a huge authority and large contributor to the safety of unmanned aviation for over 75 years. The fact is that until recently there has been an extremely limited commercial case for unmanned commercial flight. That has changed and I must ask you who is in a better position to advise and potentially partake in shaping this industry? The FAA with no interest in the costs of their rulemaking to the private sector? Mega corporations with an interest in creating virtual monopoly through excess regulation? Some boneheaded foreigner who has repeatedly and unrepentantly disrespected and endangered his host countries airspace? His attorney? Huge manned aviation advocates like the Airline Pilots Association who would just as soon ban all unmanned aircraft permanently from the skies? The military who till now have used unmanned aircraft largely for their war making utility over foreign soil and have no interest in the private sector? I for one applaud the AMA for their forward thinking on this matter including their decision to attend the AUVSI convention. As the times and technology change I'm encouraged that the AMA has taken a proactive stance. Still it is fundamentally a community based democracy and as such the membership should provide guidance to the parent body on whether or not they want their organization involved on a commercial level.
Mr Violett is a long time respected member of this community. Nevertheless his arguments on this matter fall short of the mark for me.
Steve Graham who has been a full scale pilot for 35 years and is a second generation commercial airline pilot for over 20 years with "skin in the game" concerned about the threat posed by unlimited use of FPV in the NAS but also an avid hobbyist who does not want the FAA involved beyond the very bare minimum necessary. Also, an individual who is greatly interested in the coming "age of unmanned aviation" and it's potential to contribute to our society and economy and does not want it regulated out of existence before it has a chance to get airborne simply because a federal safety agency has zero interest in the nations economy especially as evidenced by many of their recent rulemaking efforts directed at MY industry. This topic is of great complexity with associated potential benefits and costs. Drawing lines in the sand with ill considered rhetoric does no one any favors.
1.Drone, sUAS, model aircraft, flying missile (RC jet) etc etc. The name doesn't change the nature of the thing. Using names to villainize things or people is one of the oldest tactics in the book on argument, and one of the most easily disproved logical fallacies. This tactic is used all the time by unscrupulous marketing types in an effort to induce people to open their wallets. Also used by political activists as a cheap way of promoting their position. e.g. Abortion Rights vs Pro choice advocates.
2. IMO the AMA's position on FPV has been conservative, cautious and stepped so as to ensure that safety margins are maintained compared to those of VLOS flying.
3. Blaming the AMA for the actions of the outliers who do not fly within the constraints of the organizations guidance is simply wrong. The AMA has guidance for turbines yes? When someone with a turbine goes out and flies without regard for AMA's rules we do not blame the AMA. It makes no sense. We blame and pursue the offender. Now OTOH if the AMA is aware of violations and they do not act, we have a different problem and I agree we take steps to ensure compliance.
4. IMO we the citizens should do everything in our power to fight back against over bearing intrusions on our daily lives that do nothing to ensure the public safety. The FAA's recent "interpretation" Is one such intrusion that should be rejected in the strongest possible terms. I do not believe that the losing the battle on FPV will cause us to lose the hobby we all love. Congress has already mandated the FAA stay out and IMO the FAA is treading dangerously on so many toes including the recent attempt to harass a congressperson who had his wedding filmed for hire that a serious slap down from the public at large and congress in particular is close at hand. We also have the courts involved in this ongoing process.
5. Accepting the FAA's position on FPV while rejecting the commercial flying aspects is somewhat disingenuous especially given the nature of Mr Violett's business. I don't think there are any constitutional protections preventing the FAA from regulating commercial aviation. The federal government has been doing just this since 1926. The objections to their attempts to regulate and effectively eliminate the use of commercial sUAS since there are effectively no pathways to such legal activities if we accept the FAA's opinions on the matter should arise from the fact that they have steadfastly refused to even define what a sUAS is. Neither has the FAA made it's case that any sUAS that leaves the ground anywhere in the US and at any altitude can demonstrably show a threat to other users of the NAS. Commercial use of much of our nation's airspace at low altitudes should remain the domain of local authorities. This will require the FAA to very carefully consider with an eye towards defining limits how much of the atmosphere above the surface they really need to be involved in regulating. Claiming my backyard below 100 feet is not a reasonable answer that any of us should be willing to accept. This country already has too many unenforced laws protecting citizens privacy and we don't need the FAA involved in this area at all. FAR 91.11 and 121.580 already provide adequate protection against interference with manned aviation. These are the sections that IMO should be used to prosecute individuals that pose a threat. Not some silly attempt to suggest that a rubber band powered Guillows balsa plane must adhere to all elements of part 91 because it is after all an aircraft. Really?
6. The AMA has been a huge authority and large contributor to the safety of unmanned aviation for over 75 years. The fact is that until recently there has been an extremely limited commercial case for unmanned commercial flight. That has changed and I must ask you who is in a better position to advise and potentially partake in shaping this industry? The FAA with no interest in the costs of their rulemaking to the private sector? Mega corporations with an interest in creating virtual monopoly through excess regulation? Some boneheaded foreigner who has repeatedly and unrepentantly disrespected and endangered his host countries airspace? His attorney? Huge manned aviation advocates like the Airline Pilots Association who would just as soon ban all unmanned aircraft permanently from the skies? The military who till now have used unmanned aircraft largely for their war making utility over foreign soil and have no interest in the private sector? I for one applaud the AMA for their forward thinking on this matter including their decision to attend the AUVSI convention. As the times and technology change I'm encouraged that the AMA has taken a proactive stance. Still it is fundamentally a community based democracy and as such the membership should provide guidance to the parent body on whether or not they want their organization involved on a commercial level.
Mr Violett is a long time respected member of this community. Nevertheless his arguments on this matter fall short of the mark for me.
Steve Graham who has been a full scale pilot for 35 years and is a second generation commercial airline pilot for over 20 years with "skin in the game" concerned about the threat posed by unlimited use of FPV in the NAS but also an avid hobbyist who does not want the FAA involved beyond the very bare minimum necessary. Also, an individual who is greatly interested in the coming "age of unmanned aviation" and it's potential to contribute to our society and economy and does not want it regulated out of existence before it has a chance to get airborne simply because a federal safety agency has zero interest in the nations economy especially as evidenced by many of their recent rulemaking efforts directed at MY industry. This topic is of great complexity with associated potential benefits and costs. Drawing lines in the sand with ill considered rhetoric does no one any favors.
07-24-2014, 01:26 PM
#31
Steve,
While I agree with your opinion that, in an ideal world, we should push back on all of this and maintain a unified front, I am pessimistic that this approach will be successful and since the FPV community represents a VERY SMALL minority of current AMA members, I'd prefer that the AMA stay out of that fight and concentrate on the activities its members actually pursue...
Bob
While I agree with your opinion that, in an ideal world, we should push back on all of this and maintain a unified front, I am pessimistic that this approach will be successful and since the FPV community represents a VERY SMALL minority of current AMA members, I'd prefer that the AMA stay out of that fight and concentrate on the activities its members actually pursue...
Bob
07-24-2014, 01:43 PM
#32
I totally agree with the position on FPV. I do not, however, agree on the position of being paid to fly models in certain situations. I do not believe in paying for flight training nor in paying for product demonstrations. Reimbursing expenses for these kinds of activities is one thing and goes along with the notion of being reimbursed for expenses in a non-profit activity. But being paid to teach someone to fly is, in my optioning, not keeping with the idea of a "hobby". And while a full time marketing employee of a company should be able to fly in those marketing activates, a "professional" pilot who just does shows, etc, should only be paid if he files a flight plan with the FAA, just like real professional pilots. Again, that's my opinion and I know a lot of people disagree with it.
07-24-2014, 01:44 PM
#33
Just FYI. There are plenty of people calling rc jet guys "morons" flying missles through the sky, threatening our hobby etc.
We need to just band together and stop any and all goverment regulation. Even if it has a valid point, once they can stop one thing they can stop it all.
As it was said the public does not distinguish between a jet, foamie or tru drone. The same way the public does not distinguish between a handgun, assault rifle, or hunting rifle. You are asking way to much for them to see the difference. We can learn alot of from all the gun regulation that has been attempted recently, and mostly failed.
We need to just band together and stop any and all goverment regulation. Even if it has a valid point, once they can stop one thing they can stop it all.
As it was said the public does not distinguish between a jet, foamie or tru drone. The same way the public does not distinguish between a handgun, assault rifle, or hunting rifle. You are asking way to much for them to see the difference. We can learn alot of from all the gun regulation that has been attempted recently, and mostly failed.
cheers
Last edited by Bolshoi; 07-24-2014 at 01:47 PM.
07-24-2014, 02:09 PM
#35
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I fly both FPV and line of sight. I use the same aircraft to fly FPV that I previously used to fly line of sight(in this case a foamy glider). It did not cease to be an rc model just because I put a camera on it. It did not suddenly turn into a dangerous missile because I can fly it from the cockpit view. It is still just a model,guided by a competent pilot via radio control......an rc model. I am a responsible modeler and hobbyist,AMA member for 10yrs,and I take offense to anyone claiming what I do is not rc modeling. Thankfully, I've only encountered such attitudes online,not out in the real world! And it has mostly been right here on this forum. I will continue to do my part to support my fellow modeler whether they enjoy planes,helis,multi-rotors,sailplanes,jets,giant scale,line of sight or FPV.
07-24-2014, 03:11 PM
#36
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07-24-2014, 03:22 PM
#37
Steve,
While I agree with your opinion that, in an ideal world, we should push back on all of this and maintain a unified front, I am pessimistic that this approach will be successful and since the FPV community represents a VERY SMALL minority of current AMA members, I'd prefer that the AMA stay out of that fight and concentrate on the activities its members actually pursue...
Bob
While I agree with your opinion that, in an ideal world, we should push back on all of this and maintain a unified front, I am pessimistic that this approach will be successful and since the FPV community represents a VERY SMALL minority of current AMA members, I'd prefer that the AMA stay out of that fight and concentrate on the activities its members actually pursue...
Bob
07-24-2014, 03:25 PM
#38
I think the biggest issue is the new requirement that within 5 miles of an airport permission must be secured to fly RC. This is very different than the prior requirement of notification. Given our very litigious society, any airport owner/operator would be crazy to authorize this I think, as it would open them up to be sued should an accident happen. Lawyers would clearly try to go to where the money is and a case could be made that the accident would not have happened if the airport had not authorized the RC flying. I asked my company's general council that if hypothetically he were a general council for an airport and if he were asked to give council on whether the airport should agree to allow the RC flying, he said he would highly advise against it, as it would clearly open up the airport for litigation should accidents occur. Whether it's right or wrong is not the issue...you can sue anyone for anything in today's society. This IMHO will have the biggest impact to our hobby from these new rules....think about how many of your clubs are within 5 miles of ANY airport and that you are now required to get permission from them to fly.
Just my humble opinion.
Wes
Just my humble opinion.
Wes
07-24-2014, 03:47 PM
#39
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I think Steve Graham did a good job summing up my objections to BV's letter.
While I have the utmost respect for Bob, I think he is well off the mark on this subject.
Thd AMA approaches FPV safely and conservatively. While not used by most of the AMA members at present, it will be a significant part of the hobby in years to come. Our hobby has always had a tradition of using leading edge technology in our models and it will continue to be that way.
Bob barely mentioned the crackdown on "commercial" restrictions to RC wanted by the AMA and he competely ignored a number of other important issues put forth in the FAA in the infamous letter of interpretation.
While I have the utmost respect for Bob, I think he is well off the mark on this subject.
Thd AMA approaches FPV safely and conservatively. While not used by most of the AMA members at present, it will be a significant part of the hobby in years to come. Our hobby has always had a tradition of using leading edge technology in our models and it will continue to be that way.
Bob barely mentioned the crackdown on "commercial" restrictions to RC wanted by the AMA and he competely ignored a number of other important issues put forth in the FAA in the infamous letter of interpretation.
07-24-2014, 03:57 PM
#40
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The next years will see a huge explosion of fpv for use in commercial endeavors. Professional photographers, architects, advertising agencies, law enforcement, newspapers, tv stations, and myriad of other disciplines will jump on the wagon. The FAA, will need to regulate and enforce these people. We, as hobbyists, will get steamrollered by these regulations, in the future, if we are not separated from FPV. I agree entirely with BV....line of sight only. In this way FAA will actually be protecting us from what will be coming in the future, for FPV, and the AMA ruling body should be wise enough to see that.
07-24-2014, 03:57 PM
#41
AMA exist because of the membership. Mostly fixed wing and helicopter pilots. The best would be to allow the membership to vote on the separation subject and have a hand in decision making process and choosing the path.
07-24-2014, 05:00 PM
#43
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I've been involved in fed regulation development my entire 20+year career. It really unfolds the same with a little character difference between the agencies. While FAA has extended the comment period! the gist of the regs are done. Responses will slightly affect the final wording and may even get them to roll back on the traditional aspects of the hobby, but remember congress instructed the FAA to develop rules to include "drones" in the NAS safely. They're doing that and those regs have yet to be exposed and may be some time coming. Like it or not they are going to regulate autonomous flight and draw the barriers about what is hobby and what is regulated commercial. You can see where they stand currently and it truly is from a cautious point of view, erring on the side of human safety.
Yup, they do have a sort of draconian attitude, but most of the Feds do. The only thing stopping it at this point is some kind of significant congressional input- unlikely in this environment but not impossible. It'll only serve to delay promulgation of the rule. Right now, through the AMA we have the advantage of some negotiation. Delay the rule too much or wait until after a tragedy and we loose all leverage.
My guess is that the FAA will end up with a tiered process regarding commercial use and put autonomous, BLOS at the most restrictive end of things. There's way too much commercial demand to put in just the hands of the few multinationals. Plus, that would serve to encourage rouge use. May be optimistic on this last part, but it's about par for what I've experienced.
Our little nitch in this world is just that. The specter of a multi-billion dollar drone industry and thousands of drones filling the sky is what the FAA is worried about, not so much our fairly controlled portion, which I believe we have the most hope in influencing right now. We already have, literally thousands of quad copters filling the sky, just at different altitudes.
Pick your battles carefully.
Yup, they do have a sort of draconian attitude, but most of the Feds do. The only thing stopping it at this point is some kind of significant congressional input- unlikely in this environment but not impossible. It'll only serve to delay promulgation of the rule. Right now, through the AMA we have the advantage of some negotiation. Delay the rule too much or wait until after a tragedy and we loose all leverage.
My guess is that the FAA will end up with a tiered process regarding commercial use and put autonomous, BLOS at the most restrictive end of things. There's way too much commercial demand to put in just the hands of the few multinationals. Plus, that would serve to encourage rouge use. May be optimistic on this last part, but it's about par for what I've experienced.
Our little nitch in this world is just that. The specter of a multi-billion dollar drone industry and thousands of drones filling the sky is what the FAA is worried about, not so much our fairly controlled portion, which I believe we have the most hope in influencing right now. We already have, literally thousands of quad copters filling the sky, just at different altitudes.
Pick your battles carefully.
07-24-2014, 05:04 PM
#44
Very well said ! Though i hate to see any modelers faction of flying enjoyment be regulated , i have to jump on board with you guys. FPV and flying miles beyond point of take off really makes me nervous . We fly at a local airport and have a very good relationship with our town board and the airport board thanks to the airport manager . We have rules that prohibits free flight and FPV flying at our location . We feel it just isn't safe .If FPV are allowed to continue , i think it needs to be separated completely from line of sight flying , period . I agree that AMA would be millions of dollars ahead to get behind FAA on the FPV ruling .
07-24-2014, 05:56 PM
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Have you seen any of the others of those? I lost two whole nights of my life watching various mash-ups of that scene. I don't think there's a single topic that isn't covered and most of them are really funny. A lot of them are very specialized like this one so you'll either get it or you won't.
07-24-2014, 05:59 PM
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"The United States has deployed their Chuck Norris on us. He swims the Atlantic as we speak."
https://www.youtube.com/watch?v=ZrHmcpRAZNs
OK, no more hijacks. Sorry.
https://www.youtube.com/watch?v=ZrHmcpRAZNs
OK, no more hijacks. Sorry.
07-24-2014, 06:03 PM
#49
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+1 to Bob Violet's comments to the AMA!
Incidentally, I have written three such letters; almost verbatim to the AMA over the past 12 months. I've repeatedly asked the AMA to explain how they can support / promote FPV as this activity clearly violates one of the most important distinctions between a 'model aircraft' and a UAV; namely the 'line-of-sight' criteria.
Mark my words; if the AMA continues to embrace and defend FPV as an acceptable activity under AMA guidelines, there will be collateral damage for us all in terms of greater restrictions and or lost privileges!
This is a battle AMA will not win; so I sincerely hope the leadership of AMA will come to their senses and reverse their position on FPV immediately!
Joe Dirr
Incidentally, I have written three such letters; almost verbatim to the AMA over the past 12 months. I've repeatedly asked the AMA to explain how they can support / promote FPV as this activity clearly violates one of the most important distinctions between a 'model aircraft' and a UAV; namely the 'line-of-sight' criteria.
Mark my words; if the AMA continues to embrace and defend FPV as an acceptable activity under AMA guidelines, there will be collateral damage for us all in terms of greater restrictions and or lost privileges!
This is a battle AMA will not win; so I sincerely hope the leadership of AMA will come to their senses and reverse their position on FPV immediately!
Joe Dirr
07-24-2014, 06:05 PM
#50
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I didnt say anything about background checks not being needed. I do see that I said "stop all government regulation" but I mean it in the context of our hobby, not general geez.
The public doesnt distinguish between these types of planes. A parkzone mustang can be LOS or FPV. To them its just a "ban that".
If they ban FPV and then see you flying LOS to them you are breaking the law and more changes will be demanded to make you stop "that drone".
No how idea how you came up with the no background checks but you are twisting what I am saying for some reason. lets get back to reality, I agree.
The public doesnt distinguish between these types of planes. A parkzone mustang can be LOS or FPV. To them its just a "ban that".
If they ban FPV and then see you flying LOS to them you are breaking the law and more changes will be demanded to make you stop "that drone".
No how idea how you came up with the no background checks but you are twisting what I am saying for some reason. lets get back to reality, I agree.
Stop All Government Regulation? Check back when you discover the reality of our situation. Do you really believe that even a couple hundred thousand AMA members banning together is going to make a dent IN THIS CASE? the FAA will dictate the future of our hobby in any case. Clearly they're making the distinction whether we are flying "drones" or models based on line of site vs. fpv flying. The TYPE of airframe isn't the issue, it's the manner in which it is flown. The FAA has/is banning FPV, so be it, the most efficient way of ensuring the future of our hobby is to become a partner not an adversary of the FAA, in other words choose our battles intelligently. Commercial model aviation is a genuine concern and deserves to be fought for. The FPV battle is already lost. For the AMA leadership supporting this fpv for $ reasons, perhaps they should consider what the AMA will look like when the hobby ceases to exist; no members zero revenue. Personally, I wouldn't put my kids on a commercial flight if the FAA were to allow unregulated FPV (sUAS) aviation. Once the FAA decides how to regulate FPV flying then these enthusiasts can go through the process of getting licensed and carry on. And because you brought it up, background checks should be mandatory for gun ownership, which I am CCW and all.
cheers
cheers