Originally Posted by
Chris P. Bacon
Will you be doing the same with your letter to the Governor showing why he is right about the risk along with justifiable and verifiable analytics to support your position?
I don't think it's necessary to write the Governor, other than to support his decision, which I do.
I am however writing a letter to both Senators and my Congressmen asking them to support (via amendments) two issues:
(1) A national 400 foot limit on sUAS operations. The case I argue to them is that if they're going to restrict trained and certified operators (part 107 operators) to 400 feet and below out of concern for manned aircraft above 500 feet, then why allow a potentially larger group of untrained and uncertified operators (those 180,000 AMA members for example), to exceed that limit?
(2) In light of this most recent TFR incursion, I'm also asking them to support more more severe fines for violating any TFR that restricts operations of "all aircraft," whether or not "model aircraft" are specifically mentioned. Some believe that even though TFRs mention "all aircraft", they do not apply unless "model aircraft" are specifically mentioned. Despite the fact that the FAA has articulated that "model aircraft" are indeed a subcategory of "aircraft" (see note), it appears there's room for clarification.
Note: In the FAA interpretation of the special rule for model aircraft, on page 16 part IV "Examples of Regulations That Apply to Model Aircraft," the FAA uses as an example that a TFRs. In that paragraph on page 17, the FAA said that "the third category of rules relevant to model aircraft operations are rules relating to operations in areas covered by temporary flight restrictions and NOTAMs found in §§91.137 through 91.145. The FAA would expect that model aircraft operations comply with restrictions on airspace when established under these rules." So, it appears that if a TFR is issued under 91.137 through 91.145, whether or not "model aircraft" are specifically mentioned, the TFR still applies.