Are you ready to register your aircraft?
10-23-2015, 06:29 AM
#453
He already explained that he thinks the AMA should promote a registration program so that they can have a say in its implementation. Not a horrible idea, I don't think.
I personally would like to see a provision which allows AMA fields to be a haven for onerous registration and restrictions, since we have been MODEL (sorry) citizens of safe and responsible flying. Not necessarily regarding AMA Number registered models, which would simply expand on a rule already in place, but for the crazier crap coming down the pipe regarding software requirements, geo fence measures, etc.
I personally would like to see a provision which allows AMA fields to be a haven for onerous registration and restrictions, since we have been MODEL (sorry) citizens of safe and responsible flying. Not necessarily regarding AMA Number registered models, which would simply expand on a rule already in place, but for the crazier crap coming down the pipe regarding software requirements, geo fence measures, etc.
I do think it would be in the AMA's best interest to drop the FPV thing. See and avoid by the pilot in command is a fundamental premise of manned flight, and the most basic collision avoidance tool (even when flying under IFR), and I can't see them allowing two different standards given the data they're collecting. As I said above, it may not be AMA members, but the reality is the "who" is less important than the rapidly growing numbers of encounters.
As for what's onerous and what's not, I think that's likely in the eye of the beholder and there's room for intelligent people to disagree. Right now, if you take away the fact that AMA collects dues, they ask us for info, we give it to them, and they give us a number to put in/on our aircraft. Having the government do that is really no different, and I think it needs to be governmental as we need to face the fact that not everyone will be AMA members. Additionally, I'd argue it's much easier to hold someone accountable (as in filing charges) for not registering with a government agency vs. not registering with a private organization.
Lastly, I'm a big believer in data. Not only does it change behaviors, it also is a powerful tool to prove a point. FAA has tons of it, and they're gathering more by the day. AMA has been saying they are safe, but I don't think lack of claims is the best data to prove that. I'm of the belief, as articulated above, that we would be wise to start collecting minimal mishap data about every incident at a club. While some will see it as big brother, this is what professionally managed safety programs do, and it will allow us to not just say, but prove that we're as safe as we say we are. All we have to do is build the culture of honesty in reporting, which is certainly possible, but that's probably a discussion for another forum.
10-23-2015, 06:30 AM
#454
The easy thing would be to blame the messenger, the message etc. I can assure you that emails were cogent, polite, and professional. I suspect that since I was not 100% aligned with their desired approach, they chose not to respond at all.
As for the get out, press the flesh, etc., I'm doing that, in fact I had contact with media the other day. But I'm not supportive of AMA's position. I think their approach of trying to set some lower end threshold is problematic from a public policy perspective. A Blade 180QX ingested into a turbine is problematic not because of its capability or lack thereof, but where it is flown. The issue here is behavior.
While it's interesting that AMA is saying that it's not their members, at this point quibbling over the "who" is moot. The reality is there's evidence that the risk to manned aircraft, as measured by reported encounters, is increasing. FAA has data, and they're gathering more each day. With the possible huge increase in sales over the next few months, not only should DOT/FAA act, I feel they're compelled to.
I think that if AMA is to prevail, they have to fight data with data. I advocated adding a requirement for clubs to collect and report basic mishap data as part of their charter. Aircraft type, size, radio type, injury/non-injury, crash on club property / not, and general type of flight regime (aerobatics, landing/takeoff, etc.), and nearest human to crash site (in feet). In the aviation safety profession, this sort of data is called a leading indicator. In general safety circles, they call it "weak signals." (e.g. http://www.skybrary.aero/index.php/W...ty_Performance ).
Of course as soon as a reporting requirement is postulated, then all sorts of "so much work," "can't do it," etc. Ok, but that means the organization has no data. Imagine how powerful it would be if the AMA were able to say, "Our data shows that AMA members operating within the programming of our organization, crash off club grounds less than 1% of the time. And even then, in less than 0.001% of all crashes was there any human closer than 100 feet away."
I humbly submit that data like that is very powerful, but an organization can't use what they don't collect. As for honesty in reporting, that would be a culture that would have to be built. It won't be easy granted, but clubs have to be held accountable for accuracy. Random checks is probably a good tool in the beginning. Such reporting would also help identify trends that may be actionable before a serious event. People respond to data. When you put data in front of them that they can actually influence, they will most often do the right thing. I practice this as part of my vocation and can assure you it works.
As for the get out, press the flesh, etc., I'm doing that, in fact I had contact with media the other day. But I'm not supportive of AMA's position. I think their approach of trying to set some lower end threshold is problematic from a public policy perspective. A Blade 180QX ingested into a turbine is problematic not because of its capability or lack thereof, but where it is flown. The issue here is behavior.
While it's interesting that AMA is saying that it's not their members, at this point quibbling over the "who" is moot. The reality is there's evidence that the risk to manned aircraft, as measured by reported encounters, is increasing. FAA has data, and they're gathering more each day. With the possible huge increase in sales over the next few months, not only should DOT/FAA act, I feel they're compelled to.
I think that if AMA is to prevail, they have to fight data with data. I advocated adding a requirement for clubs to collect and report basic mishap data as part of their charter. Aircraft type, size, radio type, injury/non-injury, crash on club property / not, and general type of flight regime (aerobatics, landing/takeoff, etc.), and nearest human to crash site (in feet). In the aviation safety profession, this sort of data is called a leading indicator. In general safety circles, they call it "weak signals." (e.g. http://www.skybrary.aero/index.php/W...ty_Performance ).
Of course as soon as a reporting requirement is postulated, then all sorts of "so much work," "can't do it," etc. Ok, but that means the organization has no data. Imagine how powerful it would be if the AMA were able to say, "Our data shows that AMA members operating within the programming of our organization, crash off club grounds less than 1% of the time. And even then, in less than 0.001% of all crashes was there any human closer than 100 feet away."
I humbly submit that data like that is very powerful, but an organization can't use what they don't collect. As for honesty in reporting, that would be a culture that would have to be built. It won't be easy granted, but clubs have to be held accountable for accuracy. Random checks is probably a good tool in the beginning. Such reporting would also help identify trends that may be actionable before a serious event. People respond to data. When you put data in front of them that they can actually influence, they will most often do the right thing. I practice this as part of my vocation and can assure you it works.
I would think they would have plenty of data from their insurance claims?
10-23-2015, 06:45 AM
#455
(2) Put in place mishap data collection at all AMA chartered clubs as a condition of the charter. Data would be entered by club safety officer for events at the club, and create a way for individuals to enter data for events that are not at club fields (park fliers, private land, etc.). If the data is used in a non-punitive way, and if AMA puts in place ways to ensure / encourage reporting, then the data will become very useful. IF, and I say IF, we're as safe as we've been saying we are, then what's to fear? We could, I'd argue in the space of a year, be able to go back to the FAA with data that says though our sUAS crash, they seldom if ever crash off an AMA field (for those flights), seldom if ever crash close to humans on the ground, or seldom, if every cause property damage or injury. Mountains of data create a powerful argument for rebutting government / media / public policy makers.
(3) Embrace altitude deconfliction. Restrict AMA programming to be flights below 400' AGL. I think this will meet with some resistance, but that is the surest way to minimize chances that AMA programming sUAS will not come in conflict with full scale. If some activities have a compelling need to exceed this, then apply for a NOTAM.
(4) Present waiver revocations, large aircraft crash history info where CDs and such can make risk management decisions. As an operation officer scheduling flight crews, I knew which pilots and aircraft required more attention / care in scheduling than others. Contrast this with our system now where AMA only publishes who's waiver is currently expired. I can speculate that a CD who's looking at pilots might look differently at someone who's had his waiver pulled a couple times than someone who has a clean record. Now, I'm sure some will say "but we know in the community." I don't disagree, but people behave differently when they know their name might appear on a list. If the goal is safe operations in compliance with rules, isn't that the desired effect anyway? Again, I'd add that if we're as good as we say, it shouldn't be an issue.
(5) Self police. We need to be each other's keeper and stop tolerating behaviors that are not in compliance with AMA programming. I'm going to generalize, but I know we've all seen it, done it, etc. The point here is that nobody enjoys doing this, but the reality is that we're one major incident away from draconian oversight. Let's work together, actively police ourselves, and "not hand them a stick to beat us with."
10-23-2015, 06:49 AM
#456
I submit that it's no accident that FAA is capturing "drone" sightings...that would be a "leading" indicator.
10-23-2015, 06:58 AM
#457
You do understand that those sightings were from air controllers and per a review from the AMA many sightings were of legal drone operations. The AMA verified many of them and some even had permission to operate, some were sightings of model airplanes flying legally from a nearby model airfield.
When reviewing pilot reports and the near-miss reporting system there are not nearly so many entries. Also reports from flying fields would never happen and when they do would be suspect as well.
When reviewing pilot reports and the near-miss reporting system there are not nearly so many entries. Also reports from flying fields would never happen and when they do would be suspect as well.
10-23-2015, 07:07 AM
#458
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franklin_m, all good points, and I hadn't even considered Mixed Use airports. I certainly think that in terms of what is likely to happen, AMA members are going to be the starting point for any FAA registration program. I only hope that they at least protect their core chartered fields and the members who fly there from negative impacts of the hobby they enjoy. Regarding Leading Indicators captured by the AMA, I can tell you exactly how difficult it is implementing just such a reporting system at a club, been there have the T-shirt.
I found an indoor sUAS fit for registration!
https://www.youtube.com/watch?v=e_P_PToTKUk
I found an indoor sUAS fit for registration!
https://www.youtube.com/watch?v=e_P_PToTKUk
Last edited by Andy_S; 10-23-2015 at 07:12 AM. Reason: End of first P
10-23-2015, 07:10 AM
#459
(1) Embrace registration of all sUAS flown outdoors, and registrations will be done by the Feds. Concurrently, push that rather than registering each individual aircraft, a single registration number would be issued to the pilot (which is really the source of the problem isn't it?). Add the requirement that registration numbers shall be displayed on the exterior, and that sUAS owners shall remove their number upon sale or transfer. Demonstrate support for the DOT/FAA by requiring proper display of registration data for flight at AMA charted clubs, AMA sponsored events, etc. Show that AMA is willing to enforce on it's own to prove we want to be part of the solution. Premise is that if we're as good at putting AMA numbers in/on planes as we say we are, it's no big change. (For scale competitions, the number is an allowed exception).
Would you want to build a scale model of, say a Wildcat(sticking to Naval aircraft since you are familiar with them
), with all the insignia from one that "Jimmy" Thatch flew at Midway just to have the FAA/AMA require you to put your registration number on it? To me, that kind of kills the idea of building a scale model in the first place
10-23-2015, 07:17 AM
#460
(1) Embrace registration of all sUAS flown outdoors, and registrations will be done by the Feds. Concurrently, push that rather than registering each individual aircraft, a single registration number would be issued to the pilot (which is really the source of the problem isn't it?). Add the requirement that registration numbers shall be displayed on the exterior, and that sUAS owners shall remove their number upon sale or transfer. Demonstrate support for the DOT/FAA by requiring proper display of registration data for flight at AMA charted clubs, AMA sponsored events, etc. Show that AMA is willing to enforce on it's own to prove we want to be part of the solution. Premise is that if we're as good at putting AMA numbers in/on planes as we say we are, it's no big change. (For scale competitions, the number is an allowed exception).
(2) Put in place mishap data collection at all AMA chartered clubs as a condition of the charter. Data would be entered by club safety officer for events at the club, and create a way for individuals to enter data for events that are not at club fields (park fliers, private land, etc.). If the data is used in a non-punitive way, and if AMA puts in place ways to ensure / encourage reporting, then the data will become very useful. IF, and I say IF, we're as safe as we've been saying we are, then what's to fear? We could, I'd argue in the space of a year, be able to go back to the FAA with data that says though our sUAS crash, they seldom if ever crash off an AMA field (for those flights), seldom if ever crash close to humans on the ground, or seldom, if every cause property damage or injury. Mountains of data create a powerful argument for rebutting government / media / public policy makers.
(3) Embrace altitude deconfliction. Restrict AMA programming to be flights below 400' AGL. I think this will meet with some resistance, but that is the surest way to minimize chances that AMA programming sUAS will not come in conflict with full scale. If some activities have a compelling need to exceed this, then apply for a NOTAM.
(4) Present waiver revocations, large aircraft crash history info where CDs and such can make risk management decisions. As an operation officer scheduling flight crews, I knew which pilots and aircraft required more attention / care in scheduling than others. Contrast this with our system now where AMA only publishes who's waiver is currently expired. I can speculate that a CD who's looking at pilots might look differently at someone who's had his waiver pulled a couple times than someone who has a clean record. Now, I'm sure some will say "but we know in the community." I don't disagree, but people behave differently when they know their name might appear on a list. If the goal is safe operations in compliance with rules, isn't that the desired effect anyway? Again, I'd add that if we're as good as we say, it shouldn't be an issue.
(5) Self police. We need to be each other's keeper and stop tolerating behaviors that are not in compliance with AMA programming. I'm going to generalize, but I know we've all seen it, done it, etc. The point here is that nobody enjoys doing this, but the reality is that we're one major incident away from draconian oversight. Let's work together, actively police ourselves, and "not hand them a stick to beat us with."
(2) Put in place mishap data collection at all AMA chartered clubs as a condition of the charter. Data would be entered by club safety officer for events at the club, and create a way for individuals to enter data for events that are not at club fields (park fliers, private land, etc.). If the data is used in a non-punitive way, and if AMA puts in place ways to ensure / encourage reporting, then the data will become very useful. IF, and I say IF, we're as safe as we've been saying we are, then what's to fear? We could, I'd argue in the space of a year, be able to go back to the FAA with data that says though our sUAS crash, they seldom if ever crash off an AMA field (for those flights), seldom if ever crash close to humans on the ground, or seldom, if every cause property damage or injury. Mountains of data create a powerful argument for rebutting government / media / public policy makers.
(3) Embrace altitude deconfliction. Restrict AMA programming to be flights below 400' AGL. I think this will meet with some resistance, but that is the surest way to minimize chances that AMA programming sUAS will not come in conflict with full scale. If some activities have a compelling need to exceed this, then apply for a NOTAM.
(4) Present waiver revocations, large aircraft crash history info where CDs and such can make risk management decisions. As an operation officer scheduling flight crews, I knew which pilots and aircraft required more attention / care in scheduling than others. Contrast this with our system now where AMA only publishes who's waiver is currently expired. I can speculate that a CD who's looking at pilots might look differently at someone who's had his waiver pulled a couple times than someone who has a clean record. Now, I'm sure some will say "but we know in the community." I don't disagree, but people behave differently when they know their name might appear on a list. If the goal is safe operations in compliance with rules, isn't that the desired effect anyway? Again, I'd add that if we're as good as we say, it shouldn't be an issue.
(5) Self police. We need to be each other's keeper and stop tolerating behaviors that are not in compliance with AMA programming. I'm going to generalize, but I know we've all seen it, done it, etc. The point here is that nobody enjoys doing this, but the reality is that we're one major incident away from draconian oversight. Let's work together, actively police ourselves, and "not hand them a stick to beat us with."
When I came out to AZ that year I started one for the club I fly with out here. First 3 days I had 6 spots filled in. I hung it up on the bulletin board so others could fill it in when I wasn't there. Guess what the next day I found it torn up and in the garbage. It takes a year or better for the NTSB to come out with a crash report, How long and who for models.
The fact of the mater is all of us that are AMA members are registered just like U say and if U or all of are in compliance with the AMA rules we have that number in our planes or our Name Address and phone number.
The problem with this "OLD" age crap is that I have to go back and reread and reread the posts so as not to get off topic. If it been more than 15 seconds or mire that 25 years I can't remember it.
On another Note we've had planes (That we've found) as far a 4000' feet away from the field. Some never found.
10-23-2015, 07:18 AM
#461
While I like this, in general terms, it does have a flaw.
Would you want to build a scale model of, say a Wildcat(sticking to Naval aircraft since you are familiar with them), with all the insignia from one that "Jimmy" Thatch flew at Midway just to have the FAA/AMA require you to put your registration number on it? To me, that kind of kills the idea of building a scale model in the first place
Would you want to build a scale model of, say a Wildcat(sticking to Naval aircraft since you are familiar with them
), with all the insignia from one that "Jimmy" Thatch flew at Midway just to have the FAA/AMA require you to put your registration number on it? To me, that kind of kills the idea of building a scale model in the first place
10-23-2015, 07:21 AM
#462
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SP, you're right.
From the safety code
A. 2. (f) Ensure the aircraft is identified with the name and address or AMA number of the owner on the inside or affixed to the outside of the model aircraft. (This does not apply to model aircraft flown indoors.)
From the safety code
A. 2. (f) Ensure the aircraft is identified with the name and address or AMA number of the owner on the inside or affixed to the outside of the model aircraft. (This does not apply to model aircraft flown indoors.)
10-23-2015, 07:23 AM
#463
While I like this, in general terms, it does have a flaw.
Would you want to build a scale model of, say a Wildcat(sticking to Naval aircraft since you are familiar with them), with all the insignia from one that "Jimmy" Thatch flew at Midway just to have the FAA/AMA require you to put your registration number on it? To me, that kind of kills the idea of building a scale model in the first place
Would you want to build a scale model of, say a Wildcat(sticking to Naval aircraft since you are familiar with them
), with all the insignia from one that "Jimmy" Thatch flew at Midway just to have the FAA/AMA require you to put your registration number on it? To me, that kind of kills the idea of building a scale model in the first place
10-23-2015, 07:24 AM
#464
My Feedback: (21)
A little history, When I first got into RC in 1971 the first thing we had to do was get an FCC class c license for our radios. The world did not end and I have never heard of anyone having a problem with the FCC over it. That went away after a few years. Something like that is what most of you are talking about, a one time "registration of the pilot " . I would have to see how it was implemented. If it were like the FCC license was, no big deal.
Larry
Larry
10-23-2015, 07:24 AM
#465
Now this is second hand info but one of our members (Vice President) this year over heard a person from the local FSDO while at Falcon Field in Mesa tell a pilot "If he saw any thing like a Quad or model at any distance that he should report it (TO Him) as a near miss.
10-23-2015, 07:31 AM
#466
As for the crash data, it's easy to see why it got torn up. The data forced people to confront the fact they're not as good as they say they are, and that's scary. I'd also argue that crashes into the pits are absolutely a safety concern and should be pursued. I'm guessing that people were a bit more observant when the crash prone guy flew. And why shouldn't they be. All recording data does is force us all to be better and/or prove we're as good as we say we are.
As for preventing someone from tearing it down, if its kept in a reporting system, and the governing body (AMA) does periodic spot check to ensure compliance, it builds a system of accountability -- which was a stated goal of DOT/FAA as stated the other day.
10-23-2015, 07:31 AM
#467
We have several "mixed use airports in Western Washington. The biggest one is actually the auxiliary landing field operated by NAS Whidbey Island. This is a fully equipped instrument field with a tower that a local flying club has been flying at for years. Now comes the problems:
1) this field can only be used when naval aircraft are not using it for carrier landing training, it's primary use
2) this field is well under the 5 mile limit to Oak Harbor's AJ Eisenberg Airport, an uncontrolled regional airstrip. This airstrip's approach and departure patterns are roughly 90* to the NAS Whidbey ALF
The question is who do you contact to fly at the ALF? Of course, you must have approval from NAS Whidbey's operations office but does that cover AJE as well?
1) this field can only be used when naval aircraft are not using it for carrier landing training, it's primary use
2) this field is well under the 5 mile limit to Oak Harbor's AJ Eisenberg Airport, an uncontrolled regional airstrip. This airstrip's approach and departure patterns are roughly 90* to the NAS Whidbey ALF
The question is who do you contact to fly at the ALF? Of course, you must have approval from NAS Whidbey's operations office but does that cover AJE as well?
10-23-2015, 07:45 AM
#468
We have several "mixed use airports in Western Washington. The biggest one is actually the auxiliary landing field operated by NAS Whidbey Island. This is a fully equipped instrument field with a tower that a local flying club has been flying at for years. Now comes the problems:
1) this field can only be used when naval aircraft are not using it for carrier landing training, it's primary use
2) this field is well under the 5 mile limit to Oak Harbor's AJ Eisenberg Airport, an uncontrolled regional airstrip. This airstrip's approach and departure patterns are roughly 90* to the NAS Whidbey ALF
The question is who do you contact to fly at the ALF? Of course, you must have approval from NAS Whidbey's operations office but does that cover AJE as well?
1) this field can only be used when naval aircraft are not using it for carrier landing training, it's primary use
2) this field is well under the 5 mile limit to Oak Harbor's AJ Eisenberg Airport, an uncontrolled regional airstrip. This airstrip's approach and departure patterns are roughly 90* to the NAS Whidbey ALF
The question is who do you contact to fly at the ALF? Of course, you must have approval from NAS Whidbey's operations office but does that cover AJE as well?
10-23-2015, 07:55 AM
#469
I really don't see how requiring an FAA registration number completely defeats the purpose of building a scale model. After all, why couldn't it be used in lieu of the aircraft serial number? Besides, no aircraft is 100% true scale anyway. Additionally, easy enough to say that the FAA mandated registration number is exempt from scale judging criteria.
Last edited by Hydro Junkie; 10-23-2015 at 08:16 AM.
10-23-2015, 08:03 AM
#471
Originally Posted by franklin_m 
I really don't see how requiring an FAA registration number completely defeats the purpose of building a scale model. After all, why couldn't it be used in lieu of the aircraft serial number? Besides, no aircraft is 100% true scale anyway. Additionally, easy enough to say that the FAA mandated registration number is exempt from scale judging criteria.
FAR PART 45-29 Size of Markings
http://www.flightsimaviation.com/dat...art_45-29.html
Last edited by HoundDog; 10-23-2015 at 08:09 AM.
10-23-2015, 08:13 AM
#472
First it won't eliminate jets, IMAC, or gliders unless there's some law of physics or aerodynamics that makes it impossible for them to fly below 400 feet agl. Will it change how they're flown, sure, but if there's a compelling reason, put in for a NOTAM. Some fields used for skydiving etc. do them nearly every weekend. Just not that difficult. Different, but not difficult.
As for the crash data, it's easy to see why it got torn up. The data forced people to confront the fact they're not as good as they say they are, and that's scary. I'd also argue that crashes into the pits are absolutely a safety concern and should be pursued. I'm guessing that people were a bit more observant when the crash prone guy flew. And why shouldn't they be. All recording data does is force us all to be better and/or prove we're as good as we say we are.
As for preventing someone from tearing it down, if its kept in a reporting system, and the governing body (AMA) does periodic spot check to ensure compliance, it builds a system of accountability -- which was a stated goal of DOT/FAA as stated the other day.
As for the crash data, it's easy to see why it got torn up. The data forced people to confront the fact they're not as good as they say they are, and that's scary. I'd also argue that crashes into the pits are absolutely a safety concern and should be pursued. I'm guessing that people were a bit more observant when the crash prone guy flew. And why shouldn't they be. All recording data does is force us all to be better and/or prove we're as good as we say we are.
As for preventing someone from tearing it down, if its kept in a reporting system, and the governing body (AMA) does periodic spot check to ensure compliance, it builds a system of accountability -- which was a stated goal of DOT/FAA as stated the other day.
10-23-2015, 08:39 AM
#473
We have several "mixed use airports in Western Washington. The biggest one is actually the auxiliary landing field operated by NAS Whidbey Island. This is a fully equipped instrument field with a tower that a local flying club has been flying at for years. Now comes the problems:
1) this field can only be used when naval aircraft are not using it for carrier landing training, it's primary use
2) this field is well under the 5 mile limit to Oak Harbor's AJ Eisenberg Airport, an uncontrolled regional airstrip. This airstrip's approach and departure patterns are roughly 90* to the NAS Whidbey ALF
The question is who do you contact to fly at the ALF? Of course, you must have approval from NAS Whidbey's operations office but does that cover AJE as well?
1) this field can only be used when naval aircraft are not using it for carrier landing training, it's primary use
2) this field is well under the 5 mile limit to Oak Harbor's AJ Eisenberg Airport, an uncontrolled regional airstrip. This airstrip's approach and departure patterns are roughly 90* to the NAS Whidbey ALF
The question is who do you contact to fly at the ALF? Of course, you must have approval from NAS Whidbey's operations office but does that cover AJE as well?
10-23-2015, 08:53 AM
#475
Not just Jets and gliders but pattern and giant scale aerobatics. The box for botth pattern and giant scale is over 1,000 feet tall. Many maneuvers are over 400 feet tall. And sailplanes soar for thousands of feet. See and avoid has been working just fine, I don't see why we need to limit ourselves to 400 feet except near airports.
As for a sailplane at "thousands of feet," I am of the belief it is a hazard to full scale aircraft. I find it hard to fathom how a pilot on the ground could accurately judge constant bearing decreasing range from the ground with reliability worthy of protecting manned aircraft. The link to the study below shows considerable differences in perceived distance between two objects and actual distance without perspective cues, it warrants bringing sUAS closer to ground and further away from manned aircraft. The manned aircraft has perspective cues given they're field of view includes ground reference. On the other hand, the pilot looking up from the ground has no such perspective cues.
http://jov.arvojournals.org/article....icleid=2191614