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Old 06-04-2021, 08:33 AM
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JSF-TC
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Default Turbine Waiver Rule Changes

I have not seen it mentioned here on RCU, but over on RCG there is a thread running where it was stated recently (24 May) by the Exec VP of the JPO that a GTP (Gas Turbine Program) rule change package was submitted to the AMA on 24 May 2021.

Whilst I don't see many (if any) substantive changes that would impact existing Waiver holders, there are some that affect us when signing off new applicants.

The 12lb rule change seems somewhat strange, but after asking some clarifying questions on RCG, I sort of follow their logic but I don't necessarily agree with the implementation of it.

To me though, the bigger issue seems to be the lack of transparency in setting these rules. Whilst I am not a member of JPO, I am an AMA member, but I don't recall seeing any formal AMA notification to members that a rule change is under consideration or requesting a solicitation for inputs. Are these an unsolicited proposal from the JPO that only JPO members got notification/ input into?

When submitted to the AMA Safety Committee will they (AMA) just vote on them or will they send out a notification for member inputs before voting & enacting them?

At least the FAA sent out a draft UAS rules package requesting inputs before finally enacting the final updated version. Even though we don't like the outcome it at least seemed a fair process.



Page 21, Post #309
https://www.rcgroups.com/forums/show...r-Rules/page21



The JPO this morning submitted a GTP change proposal package to the AMA for their consideration by the safety committee. The proposal is quite extensive (~100 pages of documents and support information) but I'll give you the "Cliff Notes" version:
  1. Change Proposal Package Overview - this is a presentation which provides a overview of what the proposal package includes, a summary of what proposed changes are being made and why. It serves as an introduction to the proposal package.
  2. Proposed revision to the GTP - this essentially is the GTP document (AMA #510a) that would be adopted if all the proposed changes are approved.
  3. Proposed changes to the the GTP - this is detailed list of changes, in order or appearance in the GTP, of what is proposed to change. It is given in a "Was/Proposed" format. This gives the reader a specific list of changes and saves having to compare the old version and the new version side-by-side which is particularly problematic if old and the proposed document don't follow the same order.
  4. Proposed revision to the waiver application (AMA #510d) including renaming the document from "Fixed Wing Turbine Waiver Application" to the proposed title of "Turbine Waiver Qualification Guide and Waiver Application" - similar to item 2 except this is the waiver document, not the GTP document.
  5. Proposed changes to the waiver application - similar to item 3 except this being for the waiver, not the GTP.
  6. A training presentation (separate from the GTP and the waiver. This would be a new document to provide ground operations and flight skills training to turbine waiver applicants

So that's the package but here is the nitty-gritty of what it contains. These are divided into substantive changes (which are "real" changes) and non-substantive changes (which are minor changes such as reordering existing rules, correcting typos, adding clarifications, etc).

Substantive Changes
  • Prior to the waiver flight(s), applicant must have completed a buddy box flight with one of the experienced turbine pilots supervising the waiver flight. This is intended to cover the case where an "unknown" pilot shows up at a field or event, claims that he's ready for a waiver flight, and is given one. Keep in mind that a waiver flight is solo (no buddy box). By first performing a buddy box flight, the supervising pilots can evaluate the applicant and be reasonably sure that they can safely control the model. Also keep in mind that this new rule has no effect on anyone who already has their waiver. For the overwhelming majority of potential turbine applicants, during their instruction they received buddy box training with their instructor, who is typically one of the two supervising pilots of the waiver flight. Essentially, the only people who are affected are folks to travel to events or alternate fields to get a waiver; all that is being asked is that they do a buddy box flight first.
  • Added a reminder that waiver flights, LTMA certification flights, maiden flights are not to be performed during official event hours. They can be performed before/after official event hours. There is nothing new about this rule, it is just being restated in the GTP since it is hard to find in other AMA documents. To this reminder was added a proposed requirement that test flights (following a major repair to the aircraft structure, propulsion system, or control system) cannot be performed during an event but can be performed before/after official event hours. Major repairs are defined as those which substantially modify or repair portions of the model such that the result differs from the original form. Replacement of parts with the same or equivalent parts is not considered a major repair. This rule is basically an extension of the "maiden" flight rule which is intended to prevent untested aircraft from flying at an event in front of spectators. It applies to cases where a previously flown model has received some major damage, is repaired, and should be test flown to make sure everything is OK before it is flown in front of spectators. Examples include structural damage, installing a larger turbine, or replacing the receiver/power distribution system with an entirely different system.
  • The required features and weight of models to be used in waiver flights were also examined. There were two changes to this section. Firstly, flaps/flaperons or a speed brake was added to the list of required features (controllable rudders, brake feature, etc). This was to ensure that the applicant could safely reconfigure the aircraft for landing while the model is in flight.
  • The weight requirement (currently 12 lbs dry) does not apply in cases where the waiver aircraft is an ARF that's been designed specifically for turbine power and has all of the features listed above. For these models, conversion to turbine power is allowed if the conversion kit is provided by the airframe manufacturer. In other words, you can buy a turbine ARF (that will weigh less than 12 lbs when completed) and use it for your training and waiver model. You cannot use your old EDF foamy, replace the engine and battery with a turbine and fuel tank, and use it for your waiver aircraft because you didn't use a conversion kit from the airframe manufacturer but rather you used some other conversion kit NOT approved by the manufacturer or you developed your own.

Unsubstantive Changes
  • Reformatted the document, reordered existing regulations (such as those applying to the fuel system) to be listed together, added clarifications (without changing the intent), corrected typos, etc.
  • Added the updated GTP rules to the waiver application to clarify what rules apply to waiver aircraft. This spares the applicant from having to do a line-by-line sweep of the GTP. This puts the info the applicant needs in one place (one-stop shopping).
  • Added a checklist to the reverse side of the waiver for use by the supervising pilots during the waiver qualification.
  • Added specific list of items to be checked in the ground operations (as opposed to "typical" items)

The JPO would like to thank the many folks from across the country for their input to this process.

Regards,

Jim McEwen
Exec VP - Jet Pilots Organization




Paul