FAA's Enforcable 400 Feet = Death to Jets?
#376
You should know I will never register and I will not break any FAA or AMA rules. I haven't flown any models in years and may be a year or so before I can. By then the FAA will be accepting the AMA number. If the FAA was serious about legal fences then they would not use a word like follow. I write specifications and contracts, if I were to say that they should follow a code I cannot then make them do any work that complies to the code. That is because the most advantageous definition to the contractor applies. One definition of follow simply means keep track of changes, that definition does not mean that you actually comply with the code.
#377
This is why an exemption to the 400 will not happen IMO. As you know, there is enormous pressure on the FAA with respect to reducing pilot workload and at the same time even more pressure to reduce ATC workload and ensuing errors. NextGen ATS will actually ADD to pilot workload, because we will now have direct information on other aircraft in their area. Having to add additional layers of information-processing as it relates to sUAS operations is unacceptable to the FAA.
RC needs are unfortunately not the FAA's concern, in view of the above. Maybe I'm off base. I'd be interested to hear from another pilot.
RC needs are unfortunately not the FAA's concern, in view of the above. Maybe I'm off base. I'd be interested to hear from another pilot.
I understand some are saying that because so and so said this in private conversation, or such and such organization says I can do it, but individual conversations and non-governmental agencies aren't the policy makers. As of now, if you have registered you've agreed to stay below 400' AGL. The language is clear and unambiguous in my opinion. Now, the FAA may change that in the future, but for now the only thing that matters is what the FAA has said and what we agree to when we register.
Unfortunately, I think that once the FAA starts to contemplate formally allowing folks to go above 400', then the equal protection issue will come into play and they'll have to consider that they're giving EVERYONE the ability to do that.
In my career I've entered and exited VR routes hundreds of times. In each case the altitude was around 500 and sometimes lower. Until you're actually in the route structure, you can't exceed 250KIAS, but once in it, then you're limited only by route restrictions. I can only think of once or twice where I was limited to less than 420KIAS (it was 360 for a couple legs). If I come off a VR route early, due to weather, a minor mechanical issue, or something else, the last thing pilots need to deal with is ambiguity in how high sUAS/UAS in the area may be operating.
Model aviation has arguably had a good record for a number of years. But keep in mind that NASA had a great record with shuttles...until the didn't. White Star had good record with Atlantic crossings...until that little issue with an iceberg. The British Airways Comet had a great record....until that little issue with metal fatigue. Asiana Airlines flew tens of thousands of flights safety...until that little issue landing in San Francisco. The whale watching boat in BC had a perfect 20 year safety record...until it hit rocks and sank. The Concord had a perfect safety record...until the crash in Paris.
My point is that when it comes to safety, past record is not terribly meaningful as an indicator of future performance, particularly with respect to the low probably / high consequence events ... like mid-airs.
#378
In my career I've entered and exited VR routes hundreds of times. In each case the altitude was around 500 and sometimes lower. Until you're actually in the route structure, you can't exceed 250KIAS, but once in it, then you're limited only by route restrictions. I can only think of once or twice where I was limited to less than 420KIAS (it was 360 for a couple legs). If I come off a VR route early, due to weather, a minor mechanical issue, or something else, the last thing pilots need to deal with is ambiguity in how high sUAS/UAS in the area may be operating.
#379
Please note I'm not blaming the Air Force pilot for the collision in South Carolina last year, but what is different about that scenario and the potential for UAS in the area? If you're coming off a VR route at 300-400+ knots, it's not going to make much difference if there's a 40% Extra or a 100% Piper Cub in the way. But you're basically arguing that the former be prohibited because of this possibility, while the latter is perfectly legal and frankly, much more likely to occur.
My issue is a single standard that all the rest of the users of the NAS, overwhelming majority of which are manned aircraft, that they can use to ensure they're at a safe altitude. I took a sparrow in an armored windscreen and it was a safety of flight issue. I assure you a 40% extra is going to result in major damage, as will a 2.2lb DJI MR - even at 250kias.
There's ample photos on the web of military helos, who travel well less than that speed even, who've had birds go compelete through the windscreen. The issue is knowing what may be operating at my altitude and how do I know, as a pilot that other stuff will be at or above 400 AGL?
#382
My Feedback: (7)
I understand some are saying that because so and so said this in private conversation, or such and such organization says I can do it, but individual conversations and non-governmental agencies aren't the policy makers. As of now, if you have registered you've agreed to stay below 400' AGL. The language is clear and unambiguous in my opinion. Now, the FAA may change that in the future, but for now the only thing that matters is what the FAA has said and what we agree to when we register.
Unfortunately, I think that once the FAA starts to contemplate formally allowing folks to go above 400', then the equal protection issue will come into play and they'll have to consider that they're giving EVERYONE the ability to do that.
In my career I've entered and exited VR routes hundreds of times. In each case the altitude was around 500 and sometimes lower. Until you're actually in the route structure, you can't exceed 250KIAS, but once in it, then you're limited only by route restrictions. I can only think of once or twice where I was limited to less than 420KIAS (it was 360 for a couple legs). If I come off a VR route early, due to weather, a minor mechanical issue, or something else, the last thing pilots need to deal with is ambiguity in how high sUAS/UAS in the area may be operating.
Model aviation has arguably had a good record for a number of years. But keep in mind that NASA had a great record with shuttles...until the didn't. White Star had good record with Atlantic crossings...until that little issue with an iceberg. The British Airways Comet had a great record....until that little issue with metal fatigue. Asiana Airlines flew tens of thousands of flights safety...until that little issue landing in San Francisco. The whale watching boat in BC had a perfect 20 year safety record...until it hit rocks and sank. The Concord had a perfect safety record...until the crash in Paris.
My point is that when it comes to safety, past record is not terribly meaningful as an indicator of future performance, particularly with respect to the low probably / high consequence events ... like mid-airs.
Unfortunately, I think that once the FAA starts to contemplate formally allowing folks to go above 400', then the equal protection issue will come into play and they'll have to consider that they're giving EVERYONE the ability to do that.
In my career I've entered and exited VR routes hundreds of times. In each case the altitude was around 500 and sometimes lower. Until you're actually in the route structure, you can't exceed 250KIAS, but once in it, then you're limited only by route restrictions. I can only think of once or twice where I was limited to less than 420KIAS (it was 360 for a couple legs). If I come off a VR route early, due to weather, a minor mechanical issue, or something else, the last thing pilots need to deal with is ambiguity in how high sUAS/UAS in the area may be operating.
Model aviation has arguably had a good record for a number of years. But keep in mind that NASA had a great record with shuttles...until the didn't. White Star had good record with Atlantic crossings...until that little issue with an iceberg. The British Airways Comet had a great record....until that little issue with metal fatigue. Asiana Airlines flew tens of thousands of flights safety...until that little issue landing in San Francisco. The whale watching boat in BC had a perfect 20 year safety record...until it hit rocks and sank. The Concord had a perfect safety record...until the crash in Paris.
My point is that when it comes to safety, past record is not terribly meaningful as an indicator of future performance, particularly with respect to the low probably / high consequence events ... like mid-airs.
My initial reaction was to take the "fly below 400'" statement literally but the above link is the FAA's guidance to LEO and it basically says if it's a model airplane, it's registered and it's following the safety guidelines of their community based organization (AMA Safety Code), then they are fine as far as the FAA is concerned.
#383
Well I think that's my point. Even if there is a mandate that UAS stay below 400ft, you will still never know as a pilot that other stuff won't be above 400 because you still have to be alert for other full scale aircraft, birds, etc. I'm a full scale pilot as well - though not with your military experience - but just because I know there are no UAS where I'm operating doesn't mean I'm free and clear with no threats in the sky to look out for. Obviously the smaller the UAS the more difficult they become to see, which is where it becomes a mutual job to see and avoid (and why I won't ever defend flying beyond line of sight). But if I'm flying over an RC field at 500' and see/hear a full scale approaching, I'm going to reduce altitude. We've been doing it this way for years, just like you've been seeing and avoiding other airplanes at 500' and above for years.
#384
What you're saying doesn't seem to agree with this https://www.faa.gov/uas/law_enforcem...dance_card.pdf
My initial reaction was to take the "fly below 400'" statement literally but the above link is the FAA's guidance to LEO and it basically says if it's a model airplane, it's registered and it's following the safety guidelines of their community based organization (AMA Safety Code), then they are fine as far as the FAA is concerned.
My initial reaction was to take the "fly below 400'" statement literally but the above link is the FAA's guidance to LEO and it basically says if it's a model airplane, it's registered and it's following the safety guidelines of their community based organization (AMA Safety Code), then they are fine as far as the FAA is concerned.
#385
My Feedback: (49)
I understand some are saying that because so and so said this in private conversation, or such and such organization says I can do it, but individual conversations and non-governmental agencies aren't the policy makers. As of now, if you have registered you've agreed to stay below 400' AGL. The language is clear and unambiguous in my opinion. Now, the FAA may change that in the future, but for now the only thing that matters is what the FAA has said and what we agree to when we register.
Unfortunately, I think that once the FAA starts to contemplate formally allowing folks to go above 400', then the equal protection issue will come into play and they'll have to consider that they're giving EVERYONE the ability to do that.
In my career I've entered and exited VR routes hundreds of times. In each case the altitude was around 500 and sometimes lower. Until you're actually in the route structure, you can't exceed 250KIAS, but once in it, then you're limited only by route restrictions. I can only think of once or twice where I was limited to less than 420KIAS (it was 360 for a couple legs). If I come off a VR route early, due to weather, a minor mechanical issue, or something else, the last thing pilots need to deal with is ambiguity in how high sUAS/UAS in the area may be operating.
Model aviation has arguably had a good record for a number of years. But keep in mind that NASA had a great record with shuttles...until the didn't. White Star had good record with Atlantic crossings...until that little issue with an iceberg. The British Airways Comet had a great record....until that little issue with metal fatigue. Asiana Airlines flew tens of thousands of flights safety...until that little issue landing in San Francisco. The whale watching boat in BC had a perfect 20 year safety record...until it hit rocks and sank. The Concord had a perfect safety record...until the crash in Paris.
My point is that when it comes to safety, past record is not terribly meaningful as an indicator of future performance, particularly with respect to the low probably / high consequence events ... like mid-airs.
Unfortunately, I think that once the FAA starts to contemplate formally allowing folks to go above 400', then the equal protection issue will come into play and they'll have to consider that they're giving EVERYONE the ability to do that.
In my career I've entered and exited VR routes hundreds of times. In each case the altitude was around 500 and sometimes lower. Until you're actually in the route structure, you can't exceed 250KIAS, but once in it, then you're limited only by route restrictions. I can only think of once or twice where I was limited to less than 420KIAS (it was 360 for a couple legs). If I come off a VR route early, due to weather, a minor mechanical issue, or something else, the last thing pilots need to deal with is ambiguity in how high sUAS/UAS in the area may be operating.
Model aviation has arguably had a good record for a number of years. But keep in mind that NASA had a great record with shuttles...until the didn't. White Star had good record with Atlantic crossings...until that little issue with an iceberg. The British Airways Comet had a great record....until that little issue with metal fatigue. Asiana Airlines flew tens of thousands of flights safety...until that little issue landing in San Francisco. The whale watching boat in BC had a perfect 20 year safety record...until it hit rocks and sank. The Concord had a perfect safety record...until the crash in Paris.
My point is that when it comes to safety, past record is not terribly meaningful as an indicator of future performance, particularly with respect to the low probably / high consequence events ... like mid-airs.
All VR routs MOA are listed on Sectionals and it's very simple to know if a flying site
is even any ear a route or MOA. Now if a club knows if they are located under near
(1 Mile) of a VR it's a no brainer. other wise It's inconsequential. As for MOA's It's
just a phone call away (CELL PHONES) to find out when & if the MOA's is active or
not. Same for Restricted areas. So What's the problem?
#386
What you're saying doesn't seem to agree with this https://www.faa.gov/uas/law_enforcem...dance_card.pdf
My initial reaction was to take the "fly below 400'" statement literally but the above link is the FAA's guidance to LEO and it basically says if it's a model airplane, it's registered and it's following the safety guidelines of their community based organization (AMA Safety Code), then they are fine as far as the FAA is concerned.
My initial reaction was to take the "fly below 400'" statement literally but the above link is the FAA's guidance to LEO and it basically says if it's a model airplane, it's registered and it's following the safety guidelines of their community based organization (AMA Safety Code), then they are fine as far as the FAA is concerned.
#387
My Feedback: (49)
Well I think that's my point. Even if there is a mandate that UAS stay below 400ft, you will still never know as a pilot that other stuff won't be above 400 because you still have to be alert for other full scale aircraft, birds, etc. I'm a full scale pilot as well - though not with your military experience - but just because I know there are no UAS where I'm operating doesn't mean I'm free and clear with no threats in the sky to look out for. Obviously the smaller the UAS the more difficult they become to see, which is where it beci. omes a mutual job to see and avoid (and why I won't ever defend flying beyond line of sight). But if I'm flying over an RC field at 500' and see/hear a full scale approaching, I'm going to reduce altitude. We've been doing it this way for years, just like you've been seeing and avoiding other airplanes at 500' and above for years.
it becomes a mutual job to see and avoid (and why I won't ever defend flying beyond line of sight).
BLOS is not a problem to any aircraft if kept below 400'AGL If U are dumb enough
to play (JET JOCKEY) Down Low 500' then U deserve what ever U HIT. Period.
What about FPV racing through the woods or flying BLOS over the desert among the
cactus. U don't fly FUll Scale DOWN LOW do ya?
#388
Most of what U say is completely Correct in my opinion. Except for the BLOS.
it becomes a mutual job to see and avoid (and why I won't ever defend flying beyond line of sight).
BLOS is not a problem to any aircraft if kept below 400'AGL If U are dumb enough
to play (JET JOCKEY) Down Low 500' then U deserve what ever U HIT. Period.
What about FPV racing through the woods or flying BLOS over the desert among the
cactus. U don't fly FUll Scale DOWN LOW do ya?
it becomes a mutual job to see and avoid (and why I won't ever defend flying beyond line of sight).
BLOS is not a problem to any aircraft if kept below 400'AGL If U are dumb enough
to play (JET JOCKEY) Down Low 500' then U deserve what ever U HIT. Period.
What about FPV racing through the woods or flying BLOS over the desert among the
cactus. U don't fly FUll Scale DOWN LOW do ya?
#389
So what if you are flying BLOS and a helicopter is landing just outside of your cameras field of vision? And your FPV goes though the open helicopter door and kills the pilot, and the passengers die when it crash's?
Where is the FAR that you could fly FPV BLOS, cause I don't see any FAR not NPRM that allows this.
Where is the FAR that you could fly FPV BLOS, cause I don't see any FAR not NPRM that allows this.
#390
My Feedback: (24)
Well I think that's my point. Even if there is a mandate that UAS stay below 400ft, you will still never know as a pilot that other stuff won't be above 400 because you still have to be alert for other full scale aircraft, birds, etc. I'm a full scale pilot as well - though not with your military experience - but just because I know there are no UAS where I'm operating doesn't mean I'm free and clear with no threats in the sky to look out for. Obviously the smaller the UAS the more difficult they become to see, which is where it becomes a mutual job to see and avoid (and why I won't ever defend flying beyond line of sight). But if I'm flying over an RC field at 500' and see/hear a full scale approaching, I'm going to reduce altitude. We've been doing it this way for years, just like you've been seeing and avoiding other airplanes at 500' and above for years.
+1000!
Safe operation in the NAS = see and avoid manned aircraft at all costs! That is how we have done it safety before and how we will continue to do it safely going forward!
Bob
#391
My Feedback: (24)
So what if you are flying BLOS and a helicopter is landing just outside of your cameras field of vision? And your FPV goes though the open helicopter door and kills the pilot, and the passengers die when it crash's?
Where is the FAR that you could fly FPV BLOS, cause I don't see any FAR not NPRM that allows this.
Where is the FAR that you could fly FPV BLOS, cause I don't see any FAR not NPRM that allows this.
FPV can be done safely, see AMA Document #550. Guys are doing FPV racing at my club field (its a hoot actually) safely, according to this document. Note section 3 b) "All FPV flights require an AMA FPV pilot to have an AMA FPV spotter next to him/her maintaining VLOS with the FPV aircraft throughout its flight." FPV racing around obstacles or through trees can be done as long as VLOS can be maintained (which it can, if you do it right).
I don't believe that you will ever see operations BLOS approved in the AMA safety code and I have heard from some working with the FAA through the ASTM committee process that BLOS operations will NOT be part of the sUAS rules in Part 107.
BLOS for UAS in the NAS will come to pass at some point (its actually already being done experimentally now), for economic reasons if nothing else, but it will require ALOT of things like commerical, instrument pilot's ratings, redundant communications links, aircraft and systems certification (not just registration), ADS-B, filing instrument flight plans, continuous communications with ATC, etc., etc.
Bob
#393
Thread Starter
My Feedback: (54)
Gentlemen:
Evidently, Marke Gibson has been listening and this came out on 1/11/16:
http://www.faa.gov/regulations_polic...mentID/1028086
[h=2]91-57A - Model Aircraft Operating Standards - Including Change 1[/h]Date IssuedJanuary 11, 2016Responsible OfficeAJV-115, Emerging Technologies Team Description
Evidently, Marke Gibson has been listening and this came out on 1/11/16:
http://www.faa.gov/regulations_polic...mentID/1028086
[h=2]91-57A - Model Aircraft Operating Standards - Including Change 1[/h]Date IssuedJanuary 11, 2016Responsible OfficeAJV-115, Emerging Technologies Team Description
This advisory circular (AC) provides guidance to persons operating UnmannedAircraft (UA) for hobby or recreation purposes meeting the statutory definition of "model aircraft" contained in Section 336 of Public Law 112-95, the FAA Modernization and Reform Act of 2012. This AC describes means by which model aircraft may be operated safely in the National Airspace System (NAS). Nothing in this AC changes the requirement to comply with the statute or any applicable regulations.
- AC 91-57A Change 1 (PDF, 176 KB)
- AC 91-57A (PDF, 220 KB)
#394
My Feedback: (24)
Gentlemen:
Evidently, Marke Gibson has been listening and this came out on 1/11/16:
http://www.faa.gov/regulations_polic...mentID/1028086
91-57A - Model Aircraft Operating Standards - Including Change 1
Date IssuedJanuary 11, 2016Responsible OfficeAJV-115, Emerging Technologies Team Description
Evidently, Marke Gibson has been listening and this came out on 1/11/16:
http://www.faa.gov/regulations_polic...mentID/1028086
91-57A - Model Aircraft Operating Standards - Including Change 1
Date IssuedJanuary 11, 2016Responsible OfficeAJV-115, Emerging Technologies Team Description
This advisory circular (AC) provides guidance to persons operating UnmannedAircraft (UA) for hobby or recreation purposes meeting the statutory definition of "model aircraft" contained in Section 336 of Public Law 112-95, the FAA Modernization and Reform Act of 2012. This AC describes means by which model aircraft may be operated safely in the National Airspace System (NAS). Nothing in this AC changes the requirement to comply with the statute or any applicable regulations.
- AC 91-57A Change 1 (PDF, 176 KB)
- AC 91-57A (PDF, 220 KB)
Another thing to notice is that in the original "interpretive rule" that the FAA put out said that modelers must receive approval from an airport within 5 miles before operating and the AMA objected to that. Reading section 6.c.5, we're back to the original, very reasonable state of notifying the airport and working out mutually agreeable operating procedures.
Finally note that Section 336 of PL112-95 is acknowledged yet again in an FAA document. Personally, that makes me believe we're going to be OK, and don't forget, Section 336 exists SOLELY because of efforts by the AMA.
People are guick to jump on the anti-AMA band wagon (boy you should read the comments on AMA's own blog - talk about ranting!), but in this whole process, the AMA leadership has worked with the FAA to be part of the solution, not part of the problem. My own personal opinion is that this approach will ultimately bear fruit - that, along with making sure that we will stand up for our rights as they have been in the past, which is what Section 336 and the lawsuit about the "interpretive rule" is all about.
Bob
Last edited by rhklenke; 01-14-2016 at 11:06 AM.
#395
My Feedback: (49)
I'll give you some of that, especially the racing through the woods/near the ground. The #1 method of any full scale pilot of not running into another airplane is not radar, it's not relying on ATC, it's using your eyes. See and avoid. The rule should be the same for UAS operators. But if you can't see your UAS, you can't see and avoid the other aircraft near it unless they happen to cross your camera's field of vision. "Period."
So What Racing is Racing ... in Pylon they have Mid Airs
all the time and it's all done LOS in a confined area....
Accidents and crashes are all part of racing. That's what
the SPECTATORS (blood Thirsty as they are) love to see.
#396
My Feedback: (49)
So what if you are flying BLOS and a helicopter is landing just outside of your cameras field of vision? And your FPV goes though the open helicopter door and kills the pilot, and the passengers die when it crash's?
Where is the FAR that you could fly FPV BLOS, cause I don't see any FAR not NPRM that allows this.
Where is the FAR that you could fly FPV BLOS, cause I don't see any FAR not NPRM that allows this.
Now that makes as much sense as some one landing a helicopter in the woods or in the desert . May be they came to see the Quads that are racing BLOS FPV ... I'd think the course marshals would shoo them off. Gimme a break there all what ifs. What if your Stupid spectrum radio fales LOS but your 3D peice of crap flys into a group of spectators and kills a dozen or so... Just as Likely.
The FAA is making all kinds of rules and FAR's that will not solve the original problem ... Stupid People Flying Stupid Junk WHERE, WHEN,& HOW they are not supposed to even be. Simple problem difficult solution. Registration is not the answer but it's something in the CYA world of the FAA.
#397
My Feedback: (49)
Yep, it sounds reasonable in its approach - we should limit our operations to 400', and most of the time we do, but there should not be a prohibition from exceeding 400' when "necessary" as long as its done safely. I think that this is what will ultimately come about, and I can live with that - its what we do as AMA modelers now.
Another thing to notice is that in the original "interpretive rule" that the FAA put out said that modelers must receive approval from an airport within 5 miles before operating and the AMA objected to that. Reading section 6.c.5, we're back to the original, very reasonable state of notifying the airport and working out mutually agreeable operating procedures.
Finally note that Section 336 of PL112-95 is acknowledged yet again in an FAA document. Personally, that makes me believe we're going to be OK, and don't forget, Section 336 exists SOLELY because of efforts by the AMA.
People are guick to jump on the anti-AMA band wagon (boy you should read the comments on AMA's own blog - talk about ranting!), but in this whole process, the AMA leadership has worked with the FAA to be part of the solution, not part of the problem. My own personal opinion is that this approach will ultimately bear fruit - that, along with making sure that we will stand up for our rights as they have been in the past, which is what Section 336 and the lawsuit about the "interpretive rule" is all about.
Bob
Another thing to notice is that in the original "interpretive rule" that the FAA put out said that modelers must receive approval from an airport within 5 miles before operating and the AMA objected to that. Reading section 6.c.5, we're back to the original, very reasonable state of notifying the airport and working out mutually agreeable operating procedures.
Finally note that Section 336 of PL112-95 is acknowledged yet again in an FAA document. Personally, that makes me believe we're going to be OK, and don't forget, Section 336 exists SOLELY because of efforts by the AMA.
People are guick to jump on the anti-AMA band wagon (boy you should read the comments on AMA's own blog - talk about ranting!), but in this whole process, the AMA leadership has worked with the FAA to be part of the solution, not part of the problem. My own personal opinion is that this approach will ultimately bear fruit - that, along with making sure that we will stand up for our rights as they have been in the past, which is what Section 336 and the lawsuit about the "interpretive rule" is all about.
Bob
flying a Quad near Airports and others flying FPV in and
around clouds well above any sensible altitude . Flying
1500' AGL at a Registered Flying site is perfectly safe
been doing it for 50 years.
#398
Well I think that's my point. Even if there is a mandate that UAS stay below 400ft, you will still never know as a pilot that other stuff won't be above 400 because you still have to be alert for other full scale aircraft, birds, etc. I'm a full scale pilot as well - though not with your military experience - but just because I know there are no UAS where I'm operating doesn't mean I'm free and clear with no threats in the sky to look out for. Obviously the smaller the UAS the more difficult they become to see, which is where it becomes a mutual job to see and avoid (and why I won't ever defend flying beyond line of sight). But if I'm flying over an RC field at 500' and see/hear a full scale approaching, I'm going to reduce altitude. We've been doing it this way for years, just like you've been seeing and avoiding other airplanes at 500' and above for years.
Now, sUAS/UAS have none of those, and certainly the operator of an sUAS/UAS does not lose his life in a midair. That alone results in a much greater risk tolerance. As for folks know that they're flying under, in, or around an MTR, we have trouble with GA traffic not knowing about them, so my confidence that AMA members know is much lower. Some do I'm sure, but just what I've seen here in terms of just plain bad information about flying does not give me an abundance of confidence.
I want to see a nationwide 400' AGL and below limit for all sUAS/UAS (regardless of whether anyone is a member of a CBO or not) because it eliminates the ambiguity. In conjunction with that, I would like to see it made more streamlined for fixed RC fields to get a NOTAM, that ensures it's in the system and then shifts burden for knowledge to the manned pilots. But more importantly, it protects the manned aircraft like military jets and helicopters as well as any other aircraft that operate in these remote areas.
#399
My Feedback: (2)
The only change that was introduced with AC 91-57A Change 1 was the correction of the following in section 6.c.5 regarding flying within 5miles of an airport;
Was (AC 91-57A);
When flown within 5 miles of an airport, the operator of the model aircraft provides the airport operator or the airport air traffic control tower.......
Is (AC 91-57A Ch1);
When flown within 5 miles of an airport, the operator of the model aircraft provides the airport operator and the airport air traffic control tower.........
No other changes to wording was made. Everything else is as published back in September 2015.
Was (AC 91-57A);
When flown within 5 miles of an airport, the operator of the model aircraft provides the airport operator or the airport air traffic control tower.......
Is (AC 91-57A Ch1);
When flown within 5 miles of an airport, the operator of the model aircraft provides the airport operator and the airport air traffic control tower.........
No other changes to wording was made. Everything else is as published back in September 2015.
#400
In my career I've entered and exited VR routes hundreds of times. In each case the altitude was around 500 and sometimes lower.
All VR routs MOA are listed on Sectionals and it's very simple to know if a flying site
is even any ear a route or MOA. Now if a club knows if they are located under near
(1 Mile) of a VR it's a no brainer. other wise It's inconsequential. As for MOA's It's
just a phone call away (CELL PHONES) to find out when & if the MOA's is active or
not. Same for Restricted areas. So What's the problem?
All VR routs MOA are listed on Sectionals and it's very simple to know if a flying site
is even any ear a route or MOA. Now if a club knows if they are located under near
(1 Mile) of a VR it's a no brainer. other wise It's inconsequential. As for MOA's It's
just a phone call away (CELL PHONES) to find out when & if the MOA's is active or
not. Same for Restricted areas. So What's the problem?