FAA intentionaly hyping up Drone News. AMA needs to go to WAR!
07-22-2014, 12:19 PM
#77
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I am writing to register my disagreement with the proposed rule interpretations as listed in Doc FAA-2014-0396-001. These interpretations clearly violate the “Spirit” of the FAA Modernization and Reform Act of 2012.
It is not in the spirit of the exemption by Congress, for the FAA to expand its rule making authority by re-defining the traditional use terms and activities commonly understood in the “model aircraft” community. We are sensitive to the proliferation of unmanned aerial vehicles and their potential impact upon our communities and airspace. However, “model aircraft” do not create similar issues and Congress clearly instructed the FAA to stop regulating the traditional use of “Model Aircraft.” The FAA’s proposed rules circumvent this instruction by redefining terms and activities to permit regulation of clearly exempted “model aircraft” equipment and use.
The FAA’s redefinition of the term, “flown within visual line of site of the person operating the aircraft”, violates the common usage in the industry and the spirit of Congess’ mandate. The common usage of “Line of Sight” by the Remote Control (or wireless) community is the straight path between the transmitting antenna and the receiving antenna when unobstructed by the horizon. A Model Aircraft can be flown within “Line of Sight” without a person maintaining visual contact.
The interpretation of the use of the words hobby and recreation, need to include some of the integral activities that are associated with hobbies and recreation. The first to consider are the businesses that manufacture the goods that are used in the hobby or recreation. The products must be tested (and therefore in this case flown) for design and safety purposes. Any rule that would restrict this would force the manufacture of untested and unproven design that would severely hinder the current safety level of the hobby. I believe that the testing of products that are intended for use for recreation and hobby purposes are also included in this exemption.
Hobbyists can also be paid under certain circumstances. Though the income is not their primary support, it can be used to further their enjoyment of the hobby or to supplement their normal commercial endeavors. This would include the payment of instructors for training in the hobby, payment for product testing, payment for building services and even payment for pictures or videos derived from the hobbyist’s equipment. Just because the activity may be a primary commercial interest to one party, it may only derive “hobby income” for the party being paid. A current example is the use of Model Aircraft Hobbyists to fly Dirigibles and other “Blimp-Like” aircraft at sporting event and receiving a small fee or getting equipment to enable that activity. It also includes amateur sponsorships that allow pilots to represent a company at events even though their main profession is not in the hobby. Many experts in a field come through the hobbyist side and are enthusiasts and not necessarily the professionals. These experts provide a passion and knowledge that enhances the hobby and should not be penalized. The IRS defines income in these circumstances as a hobby, if the income is not for profit. You must also not depend on this income and not make a profit over a particular number of years. (see www.irs.gov for details)
Congress intended that Model Aircraft be operated under the safety guidelines of a “membership based association that represents the aeromodeling community within the Unites States”. So, it would follow that if a Model Aircraft is operated under the rules of an organization such as this, for example the AMA (Academy of Model Aeronautics) then it would be deemed to have operated safely in the NAS. Therefore, would not fall under the purview of the FAA’s enforcement.
The broad interpretation, as presented by the FAA is over-reaching and infringes on the privileges expressly granted by Congress to the AeroModeling community. These proposed interpretations must be modified to comply with the letter and spirit of Congress’ directive to the FAA.
*******************
Rich (Krzy4RC)
*******
I am writing to register my disagreement with the proposed rule interpretations as listed in Doc FAA-2014-0396-001. These interpretations clearly violate the “Spirit” of the FAA Modernization and Reform Act of 2012.
It is not in the spirit of the exemption by Congress, for the FAA to expand its rule making authority by re-defining the traditional use terms and activities commonly understood in the “model aircraft” community. We are sensitive to the proliferation of unmanned aerial vehicles and their potential impact upon our communities and airspace. However, “model aircraft” do not create similar issues and Congress clearly instructed the FAA to stop regulating the traditional use of “Model Aircraft.” The FAA’s proposed rules circumvent this instruction by redefining terms and activities to permit regulation of clearly exempted “model aircraft” equipment and use.
The FAA’s redefinition of the term, “flown within visual line of site of the person operating the aircraft”, violates the common usage in the industry and the spirit of Congess’ mandate. The common usage of “Line of Sight” by the Remote Control (or wireless) community is the straight path between the transmitting antenna and the receiving antenna when unobstructed by the horizon. A Model Aircraft can be flown within “Line of Sight” without a person maintaining visual contact.
The interpretation of the use of the words hobby and recreation, need to include some of the integral activities that are associated with hobbies and recreation. The first to consider are the businesses that manufacture the goods that are used in the hobby or recreation. The products must be tested (and therefore in this case flown) for design and safety purposes. Any rule that would restrict this would force the manufacture of untested and unproven design that would severely hinder the current safety level of the hobby. I believe that the testing of products that are intended for use for recreation and hobby purposes are also included in this exemption.
Hobbyists can also be paid under certain circumstances. Though the income is not their primary support, it can be used to further their enjoyment of the hobby or to supplement their normal commercial endeavors. This would include the payment of instructors for training in the hobby, payment for product testing, payment for building services and even payment for pictures or videos derived from the hobbyist’s equipment. Just because the activity may be a primary commercial interest to one party, it may only derive “hobby income” for the party being paid. A current example is the use of Model Aircraft Hobbyists to fly Dirigibles and other “Blimp-Like” aircraft at sporting event and receiving a small fee or getting equipment to enable that activity. It also includes amateur sponsorships that allow pilots to represent a company at events even though their main profession is not in the hobby. Many experts in a field come through the hobbyist side and are enthusiasts and not necessarily the professionals. These experts provide a passion and knowledge that enhances the hobby and should not be penalized. The IRS defines income in these circumstances as a hobby, if the income is not for profit. You must also not depend on this income and not make a profit over a particular number of years. (see www.irs.gov for details)
Congress intended that Model Aircraft be operated under the safety guidelines of a “membership based association that represents the aeromodeling community within the Unites States”. So, it would follow that if a Model Aircraft is operated under the rules of an organization such as this, for example the AMA (Academy of Model Aeronautics) then it would be deemed to have operated safely in the NAS. Therefore, would not fall under the purview of the FAA’s enforcement.
The broad interpretation, as presented by the FAA is over-reaching and infringes on the privileges expressly granted by Congress to the AeroModeling community. These proposed interpretations must be modified to comply with the letter and spirit of Congress’ directive to the FAA.
*******************
Rich (Krzy4RC)
07-22-2014, 02:24 PM
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Been reading quite a lot of threads, posts and articles lately since it has been made into a big issue. I decided to see what the Australian CASA (which governs similarly to your FAA) has done. I have to say I tend to agreee with the way they have done things, although I think that our National organisation MAAA tends to work with CASA a lot better than what I have seen the AMA and your FAA.
I think that you have to balance the privacy issues that come up with the use of Drones, also balancing the use of airspace. The only way to do that is by regulation. A small percentage of people who fly any type of radio control plane, helicopter, or drone will misuse it, unfortunately it tends to impact everyone else because of that.
So far I see a lot of comments that seem to be not giving much thought to other peoples rights not involved in our hobby, or safety factors that commonsense dictates should be there, owning a model aircraft or drone doesnt automatically give us the right to impinge on others rights, and honestly a safety factor has to be built in when it comes to drones being in the same space as full size aircraft.
http://www.casa.gov.au/scripts/nc.dl...::pc=PC_100374 if your interested in what we have.
I think that you have to balance the privacy issues that come up with the use of Drones, also balancing the use of airspace. The only way to do that is by regulation. A small percentage of people who fly any type of radio control plane, helicopter, or drone will misuse it, unfortunately it tends to impact everyone else because of that.
So far I see a lot of comments that seem to be not giving much thought to other peoples rights not involved in our hobby, or safety factors that commonsense dictates should be there, owning a model aircraft or drone doesnt automatically give us the right to impinge on others rights, and honestly a safety factor has to be built in when it comes to drones being in the same space as full size aircraft.
http://www.casa.gov.au/scripts/nc.dl...::pc=PC_100374 if your interested in what we have.
07-22-2014, 03:54 PM
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to media and government, old saying here, If You control what They know, You know what They do ?? always was that way and repeats itself over and over again
i keep watching what happens now, The Jet attack B.S thing over the media went nirvana, hope this one goes there too.
i keep watching what happens now, The Jet attack B.S thing over the media went nirvana, hope this one goes there too.
07-23-2014, 04:22 AM
#81
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That's an interesting take, I've seen them vilified for many things, now they get the blame for this? What exactly is a negative pic, or video? The do promotional videos, just like Horizon. Why would you try to make this a vendor issue?
This isn't a vendor issue, it's a USER issue. Hop on Youtube or any FPV site to see the evidence of that. So far I've received e-mail alerts about the FAA comment period from Atlanta Hobby, Tower, and HK. Why nothing from HH, not even a mention on their site?
This isn't a vendor issue, it's a USER issue. Hop on Youtube or any FPV site to see the evidence of that. So far I've received e-mail alerts about the FAA comment period from Atlanta Hobby, Tower, and HK. Why nothing from HH, not even a mention on their site?
07-23-2014, 05:51 AM
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Its not a vendor issue, HK posted negative pic and vids at WOD, Are we not giving the fed ammo to do the hobby harm. 12 pages of nonsense, B-29 crash, it looks bad for us and good for the Fed.
07-23-2014, 05:54 AM
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Mike.
07-23-2014, 07:12 AM
#84
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if it's not a vendor issue, not sure why you felt the need to bring a vendor into the discussion then? Taking a shot at any vendor, while having another one in your signature line seems like a cheap shot. All the while, there isn't an RC site out there that doesn't have that video, and tons more like it. Sometimes videos such as that specific one can help future similar situations from happening again. If the B-29 was intentionally flying over people, or at 10,000 feet, or through city streets I would agree, that's bad. It was an accident that caused no injury, doubtful the feds would do anything about that.
07-23-2014, 07:22 AM
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Why is it so hard to understand that when the Government makes rules like this it is only going to hurt the law abiding ciizens? Gun laws: Criminals will still be criminals and get guns, Drug laws: people will still do drugs, Drone laws: pepole will still fly rogue. You cannot and will never be able to legislate morality or safety. The human condition simply does not allow for this. For the most part, people will do as they want regardless of the laws. The ONLY thing that would happen if the FAA flat out bans drones is that alot of law abiding people will not get to experience the fun of FPV, while the people we see doing stupid things with drones and FPV will continue because they dont give a crap about the laws to begin with. People are delusional when it comes to laws and restrictions.
07-23-2014, 09:00 AM
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I know, right! lol. Fortunately for me I only fly a few nitro planes, a couple electric planes and the occasional 450 heli. I am an AMA member and fly at a chartered field, so at this point it does not directly effect me. I do feel sorry for all the modelers it does effect.
07-23-2014, 09:25 AM
#92
Thread Starter
What the heck does a model B-29 crash have to do with this. Even with the strict tack the FAA is taking I doubt they really care if we endanger ourselves with model airplane crash's. Except mid airs with full scale of course.
07-23-2014, 12:11 PM
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I have commented on regulations.gov
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I am writing to register my disagreement with the proposed rule interpretations as listed in Doc FAA-2014-0396-001. These interpretations clearly violate the “Spirit” of the FAA Modernization and Reform Act of 2012.
It is not in the spirit of the exemption by Congress, for the FAA to expand its rule making authority by re-defining the traditional use terms and activities commonly understood in the “model aircraft” community. We are sensitive to the proliferation of unmanned aerial vehicles and their potential impact upon our communities and airspace. However, “model aircraft” do not create similar issues and Congress clearly instructed the FAA to stop regulating the traditional use of “Model Aircraft.” The FAA’s proposed rules circumvent this instruction by redefining terms and activities to permit regulation of clearly exempted “model aircraft” equipment and use.
The FAA’s redefinition of the term, “flown within visual line of site of the person operating the aircraft”, violates the common usage in the industry and the spirit of Congess’ mandate. The common usage of “Line of Sight” by the Remote Control (or wireless) community is the straight path between the transmitting antenna and the receiving antenna when unobstructed by the horizon. A Model Aircraft can be flown within “Line of Sight” without a person maintaining visual contact.
The interpretation of the use of the words hobby and recreation, need to include some of the integral activities that are associated with hobbies and recreation. The first to consider are the businesses that manufacture the goods that are used in the hobby or recreation. The products must be tested (and therefore in this case flown) for design and safety purposes. Any rule that would restrict this would force the manufacture of untested and unproven design that would severely hinder the current safety level of the hobby. I believe that the testing of products that are intended for use for recreation and hobby purposes are also included in this exemption.
Hobbyists can also be paid under certain circumstances. Though the income is not their primary support, it can be used to further their enjoyment of the hobby or to supplement their normal commercial endeavors. This would include the payment of instructors for training in the hobby, payment for product testing, payment for building services and even payment for pictures or videos derived from the hobbyist’s equipment. Just because the activity may be a primary commercial interest to one party, it may only derive “hobby income” for the party being paid. A current example is the use of Model Aircraft Hobbyists to fly Dirigibles and other “Blimp-Like” aircraft at sporting event and receiving a small fee or getting equipment to enable that activity. It also includes amateur sponsorships that allow pilots to represent a company at events even though their main profession is not in the hobby. Many experts in a field come through the hobbyist side and are enthusiasts and not necessarily the professionals. These experts provide a passion and knowledge that enhances the hobby and should not be penalized. The IRS defines income in these circumstances as a hobby, if the income is not for profit. You must also not depend on this income and not make a profit over a particular number of years. (see www.irs.gov for details)
Congress intended that Model Aircraft be operated under the safety guidelines of a “membership based association that represents the aeromodeling community within the Unites States”. So, it would follow that if a Model Aircraft is operated under the rules of an organization such as this, for example the AMA (Academy of Model Aeronautics) then it would be deemed to have operated safely in the NAS. Therefore, would not fall under the purview of the FAA’s enforcement.
The broad interpretation, as presented by the FAA is over-reaching and infringes on the privileges expressly granted by Congress to the AeroModeling community. These proposed interpretations must be modified to comply with the letter and spirit of Congress’ directive to the FAA.
*******************
Rich (Krzy4RC)
*******
I am writing to register my disagreement with the proposed rule interpretations as listed in Doc FAA-2014-0396-001. These interpretations clearly violate the “Spirit” of the FAA Modernization and Reform Act of 2012.
It is not in the spirit of the exemption by Congress, for the FAA to expand its rule making authority by re-defining the traditional use terms and activities commonly understood in the “model aircraft” community. We are sensitive to the proliferation of unmanned aerial vehicles and their potential impact upon our communities and airspace. However, “model aircraft” do not create similar issues and Congress clearly instructed the FAA to stop regulating the traditional use of “Model Aircraft.” The FAA’s proposed rules circumvent this instruction by redefining terms and activities to permit regulation of clearly exempted “model aircraft” equipment and use.
The FAA’s redefinition of the term, “flown within visual line of site of the person operating the aircraft”, violates the common usage in the industry and the spirit of Congess’ mandate. The common usage of “Line of Sight” by the Remote Control (or wireless) community is the straight path between the transmitting antenna and the receiving antenna when unobstructed by the horizon. A Model Aircraft can be flown within “Line of Sight” without a person maintaining visual contact.
The interpretation of the use of the words hobby and recreation, need to include some of the integral activities that are associated with hobbies and recreation. The first to consider are the businesses that manufacture the goods that are used in the hobby or recreation. The products must be tested (and therefore in this case flown) for design and safety purposes. Any rule that would restrict this would force the manufacture of untested and unproven design that would severely hinder the current safety level of the hobby. I believe that the testing of products that are intended for use for recreation and hobby purposes are also included in this exemption.
Hobbyists can also be paid under certain circumstances. Though the income is not their primary support, it can be used to further their enjoyment of the hobby or to supplement their normal commercial endeavors. This would include the payment of instructors for training in the hobby, payment for product testing, payment for building services and even payment for pictures or videos derived from the hobbyist’s equipment. Just because the activity may be a primary commercial interest to one party, it may only derive “hobby income” for the party being paid. A current example is the use of Model Aircraft Hobbyists to fly Dirigibles and other “Blimp-Like” aircraft at sporting event and receiving a small fee or getting equipment to enable that activity. It also includes amateur sponsorships that allow pilots to represent a company at events even though their main profession is not in the hobby. Many experts in a field come through the hobbyist side and are enthusiasts and not necessarily the professionals. These experts provide a passion and knowledge that enhances the hobby and should not be penalized. The IRS defines income in these circumstances as a hobby, if the income is not for profit. You must also not depend on this income and not make a profit over a particular number of years. (see www.irs.gov for details)
Congress intended that Model Aircraft be operated under the safety guidelines of a “membership based association that represents the aeromodeling community within the Unites States”. So, it would follow that if a Model Aircraft is operated under the rules of an organization such as this, for example the AMA (Academy of Model Aeronautics) then it would be deemed to have operated safely in the NAS. Therefore, would not fall under the purview of the FAA’s enforcement.
The broad interpretation, as presented by the FAA is over-reaching and infringes on the privileges expressly granted by Congress to the AeroModeling community. These proposed interpretations must be modified to comply with the letter and spirit of Congress’ directive to the FAA.
*******************
Rich (Krzy4RC)
07-23-2014, 04:27 PM
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The FAA’s redefinition of the term, “flown within visual line of site of the person operating the aircraft”, violates the common usage in the industry and the spirit of Congess’ mandate. The common usage of “Line of Sight” by the Remote Control (or wireless) community is the straight path between the transmitting antenna and the receiving antenna when unobstructed by the horizon. A Model Aircraft can be flown within “Line of Sight” without a person maintaining visual contact.
*******
The FAA’s redefinition of the term, “flown within visual line of site of the person operating the aircraft”, violates the common usage in the industry and the spirit of Congess’ mandate. The common usage of “Line of Sight” by the Remote Control (or wireless) community is the straight path between the transmitting antenna and the receiving antenna when unobstructed by the horizon. A Model Aircraft can be flown within “Line of Sight” without a person maintaining visual contact.
CR
07-24-2014, 03:30 AM
#97
I don't think it is hairsplitting at all, you are doing two things here.
1. Looking at one sentence in my response and not looking at the final message...if a model aircraft is flown following the AMA rules, then it is safe by Congress' definition, so the FAA is directed to treat these aircraft as exempt.
2. You are basing your line of sight and visual contact on the FAA interpretation and not the AMA interpretation, which allows for a spotter. This is what I argue is the industry standard. This is what Congress directed the FAA to use through their directive to the FAA.
Don't take one sentence out of context, but look at the whole message. I stand by by use of line of site. I think the AMA rules are sufficient for safe operation and therefore falls under the Congress directive.
1. Looking at one sentence in my response and not looking at the final message...if a model aircraft is flown following the AMA rules, then it is safe by Congress' definition, so the FAA is directed to treat these aircraft as exempt.
2. You are basing your line of sight and visual contact on the FAA interpretation and not the AMA interpretation, which allows for a spotter. This is what I argue is the industry standard. This is what Congress directed the FAA to use through their directive to the FAA.
Don't take one sentence out of context, but look at the whole message. I stand by by use of line of site. I think the AMA rules are sufficient for safe operation and therefore falls under the Congress directive.
07-24-2014, 03:59 AM
#98
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lol.....your "whole" message was one sentence, this:
"But you can stay within the boundary of line of sight without keeping visual contact...."
It's not as if you had a paragraph of information and I plucked out one sentence.
I guess we'll agree to disagree, I'm not sure how anyone can argue that something that cannot be seen by the naked eye is within the boundaries of line of sight. It doesn't really look like it matters at this point in time what our opinions are, the FAA is taking a very literal approach, and probably the most common sense one, in noting that the pilot must be able to see his aircraft at all times. Keep in mind I'm not saying I agree with it entirely, just seems like that's the way it's going to end up being decided.
"But you can stay within the boundary of line of sight without keeping visual contact...."
It's not as if you had a paragraph of information and I plucked out one sentence.
I guess we'll agree to disagree, I'm not sure how anyone can argue that something that cannot be seen by the naked eye is within the boundaries of line of sight. It doesn't really look like it matters at this point in time what our opinions are, the FAA is taking a very literal approach, and probably the most common sense one, in noting that the pilot must be able to see his aircraft at all times. Keep in mind I'm not saying I agree with it entirely, just seems like that's the way it's going to end up being decided.
07-24-2014, 04:35 AM
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The FAA’s redefinition of the term, “flown within visual line of site of the person operating the aircraft”, violates the common usage in the industry and the spirit of Congess’ mandate. The common usage of “Line of Sight” by the Remote Control (or wireless) community is the straight path between the transmitting antenna and the receiving antenna when unobstructed by the horizon. A Model Aircraft can be flown within “Line of Sight” without a person maintaining visual contact.
I don't think it is hairsplitting at all, you are doing two things here.
1. Looking at one sentence in my response and not looking at the final message...if a model aircraft is flown following the AMA rules, then it is safe by Congress' definition, so the FAA is directed to treat these aircraft as exempt.
2. You are basing your line of sight and visual contact on the FAA interpretation and not the AMA interpretation, which allows for a spotter. This is what I argue is the industry standard. This is what Congress directed the FAA to use through their directive to the FAA.
Don't take one sentence out of context, but look at the whole message. I stand by by use of line of site. I think the AMA rules are sufficient for safe operation and therefore falls under the Congress directive.
1. Looking at one sentence in my response and not looking at the final message...if a model aircraft is flown following the AMA rules, then it is safe by Congress' definition, so the FAA is directed to treat these aircraft as exempt.
2. You are basing your line of sight and visual contact on the FAA interpretation and not the AMA interpretation, which allows for a spotter. This is what I argue is the industry standard. This is what Congress directed the FAA to use through their directive to the FAA.
Don't take one sentence out of context, but look at the whole message. I stand by by use of line of site. I think the AMA rules are sufficient for safe operation and therefore falls under the Congress directive.
Your logic is flawed. What you refer to in your comments to the FAA as “Line of Sight by the Remote Control community” is actually referred to as LOS propagation and is true when referring to the electromagnetic spectrum, however Congress mandated;
H. R. 658 SEC. 336. SPECIAL RULE FOR MODEL AIRCRAFT. (c) Model Aircraft Defined. (2) flown within visual line of sight of the person operating the aircraft
This specifies “the person operating the aircraft” not the transmitter. In this instance the reference is to the sightline of the individual which is “a normally unobstructed line-of-sight between an observer and an object being observed.”
Regards
Frank
07-24-2014, 05:20 AM
#100
"(2) flown within visual line of sight of the person operating the aircraft" is the key.
I contend there are two terms relevant here. Line of Sight and Visual Contact.
Line of Sight is the unobstructed boundary. This does not infer visual contact. You can use the "person operating the aircraft" if you choose. It doesn't change the fact that it is a boundary, not necessarily maintaining visual contact. I chose the transmitter, because of an industry accepted definition, that is the Radio and Wireless Transmission industry which is what we rely on.
Visual Contact is to keep looking at the object (airplane in this case).
This become important because some can use a spotter to keep visual contact and the plane can be flown within the Line of Sight. The AMA has specific rules stating this.
The bottom line is that Congress Dictated to the FAA that Model Aircraft following the rules of an organization such as the AMA (not naming the AMA) is exempt from FAA rules because they are deemed as being operated in a safe manner in the NAS, by definition. The FAA violates Congress' directive with this interpretation.
I do agree with one point of yours..."It is not possible to write in such a way that cannot be misinterpreted by a reader determined to do so."
I contend there are two terms relevant here. Line of Sight and Visual Contact.
Line of Sight is the unobstructed boundary. This does not infer visual contact. You can use the "person operating the aircraft" if you choose. It doesn't change the fact that it is a boundary, not necessarily maintaining visual contact. I chose the transmitter, because of an industry accepted definition, that is the Radio and Wireless Transmission industry which is what we rely on.
Visual Contact is to keep looking at the object (airplane in this case).
This become important because some can use a spotter to keep visual contact and the plane can be flown within the Line of Sight. The AMA has specific rules stating this.
The bottom line is that Congress Dictated to the FAA that Model Aircraft following the rules of an organization such as the AMA (not naming the AMA) is exempt from FAA rules because they are deemed as being operated in a safe manner in the NAS, by definition. The FAA violates Congress' directive with this interpretation.
I do agree with one point of yours..."It is not possible to write in such a way that cannot be misinterpreted by a reader determined to do so."