Comment on tbe FAA NPRM
#28
And do an energy calculation on your 6.5 pound model impacting at 50 MPH. Works out to 735 joules, and it more than equivalent to what the construction industry considers a FATAL blow (i.e. from a dropped tool), and their calculations assume a construction grade hard hat. Which is PPE that anyone on the receiving end of your toy will not be wearing. The reason FARs say no overflight of non-participants. Keep in mind, all it takes is one disgruntled neighboring property owner...
And I couldn't help but notice you posted photo of slope soaring. How ironic that you imply these can't hurt anyone where in fact someone was just KILLED recently.
Last edited by franklin_m; 01-18-2020 at 08:54 AM.
#30
That was kind of you to identify all the places you fly. Again, FARs establish the rules. If you (or your fellow club member / participants) choose to break them, it's doing nothing but put your beloved FRIA at risk. It won't take long for those hostile to such places to create a "go by" for unhappy neighbors to inform themselves on what rules you're breaking and then how to articulate that to FAA in a way to have an impact.
#31

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LOL, more foolish assumptions. You have no idea the size of overfly areas, neighboring property lines, agreements with property owners etc. You responded exactly as I knew you would. So predictable, but now I'm going to go work on my new pattern airplane for 2020 that I will be flying in exactly the same fashion that I have previous years.
#32
LOL, more foolish assumptions. You have no idea the size of overfly areas, neighboring property lines, agreements with property owners etc. You responded exactly as I knew you would. So predictable, but now I'm going to go work on my new pattern airplane for 2020 that I will be flying in exactly the same fashion that I have previous years.
IG's are a good place to send letters too ... especially when there's a sweetheart deal that's not open to all taxpayers.
#34
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And do an energy calculation on your 6.5 pound model impacting at 50 MPH. Works out to 735 joules, and it more than equivalent to what the construction industry considers a FATAL blow (i.e. from a dropped tool), and their calculations assume a construction grade hard hat...
#35
In the interest of full disclosure, would you mind telling us what size/weight/speed threshold values you DO consider safe for model aircraft? And therefore won't be trying to ban? Some of those taken in by your "equal protection" agenda might like to know just what kind of "toys" they'll be left to play with if you get your way.
As for the rest, I think we should be looking at total energy. That way it automatically accounts for mass, velocity, and altitude. Beyond that, I think limits need to based on the airspace. I personally believe there should be be altitude separation between majority of manned aircraft and unmanned. I'm skeptical of spotters as a mitigation. Why? AMA's own video demonstrating spotters show both operator and spotter tracking the aircraft. An EFFECTIVE spotter should be looking 360 around the site, NOT be a second set of eyes looking at the same airspace as the operator. Without visual acuity verification and hearing checks, my confidence in spotters goes way down. So that means in class G, it's 400 AGL. However, with altitude reporting telemetry and alarm on transmitter, I could support recreational sUAS limited to no higher than 100 feet below floor of class E at the site. In controlled airspace, I support whatever ATO agrees. Additionally, I advocate a ban on recreational sUAS inside the lateral limits of Military Training Routes during published hours of operation.
I don't want to give a hard and fast size, but rather limit by TE, flying site dimensions, altitude limits per above, and flight path. Idea being that at any point in the path, based on the current velocity vector, a complete loss of control would result in sUAS impacting inside lateral limits of FRIA and no closer to 100 feet from any non-participant (FAA's definition of participant) inside the FRIA.
#36
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Idea being that at any point in the path, based on the current velocity vector, a complete loss of control would result in sUAS impacting inside lateral limits of FRIA and no closer to 100 feet from any non-participant (FAA's definition of participant) inside the FRIA.
If the aircraft remains within the FRIA, not even a fail-safe mode would help; since there are failure modes (loss of power at the receiver) which would inhibit the fail safe from acting. So you're basically wanting to ban anything physically capable of generating lethal force in a terminal dive -- with the power plant operating at 100%.
Since the post-failure path of the aircraft cannot be predicted, the requirement to miss non-participants by 100 feet is meaningless.
Of course you were cunning enough to put this in terms of "FRIA limits". But since your stated goal is to "stick a fork in FRIAs" that's bogus. Any regulatory body adopting this concept would have no alternative but to ban anything flying ANYWHERE which is capable of generating lethal force. Which, I have a funny feeling, will be construed as anything weighing more than 0.55lb.
Pay attention folks! This what this guy really wants, and if you don't oppose him, he'll work with the FAA to make it happen.
Last edited by RCUer75345; 01-18-2020 at 04:20 PM.
#37
I'm skeptical of spotters as a mitigation. Why? AMA's own video demonstrating spotters show both operator and spotter tracking the aircraft. An EFFECTIVE spotter should be looking 360 around the site, NOT be a second set of eyes looking at the same airspace as the operator. Without visual acuity verification and hearing checks, my confidence in spotters goes way down.
#38

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I can say with 100% certainty that having a spotter scanning the airspace happens more frequently then you may think. During a sailplane flight the timers job is not only to give the pilot time updates but to scan the sky for signs of lift usually in the form of wind change, cloud formations, birds, other sailplanes but most importantly since an altitude of 2,000' is not uncommon, manned aircraft. During a Pattern flight, the callers job is not only to remind the pilot of the sequence of maneuvers but to be scanning the path of the airplane to avoid other participants and help with aerobatic box positioning as well.
Since I know that some in this thread are " show me the numbers " kind of guys. Perhaps he can show statistics where see and avoid has failed in keeping traditional models and full scale aircraft from colliding.
Since I know that some in this thread are " show me the numbers " kind of guys. Perhaps he can show statistics where see and avoid has failed in keeping traditional models and full scale aircraft from colliding.
#39
Idea being that at any point in the path, based on the current velocity vector, a complete loss of control would result in sUAS impacting inside lateral limits of FRIA and no closer to 100 feet from any non-participant (FAA's definition of participant) inside the FRIA.
That is completely impossible to predict as you very well know. A complete loss of control could occur at any time, and the model could react in any conceivable way depending on the nature of the failure. Including cruising straight and level out of the lateral limits of the FRIA.
If the aircraft remains within the FRIA, not even a fail-safe mode would help; since there are failure modes (loss of power at the receiver) which would inhibit the fail safe from acting. So you're basically wanting to ban anything physically capable of generating lethal force in a terminal dive -- with the power plant operating at 100%.
Since the post-failure path of the aircraft cannot be predicted, the requirement to miss non-participants by 100 feet is meaningless.
If the aircraft remains within the FRIA, not even a fail-safe mode would help; since there are failure modes (loss of power at the receiver) which would inhibit the fail safe from acting. So you're basically wanting to ban anything physically capable of generating lethal force in a terminal dive -- with the power plant operating at 100%.
Since the post-failure path of the aircraft cannot be predicted, the requirement to miss non-participants by 100 feet is meaningless.
So your "loss of control at any time" [ironically almost word for word from FAR 107.19(C)], or loss of receiver power, etc. etc. etc. don't matter. FAR 107.19(C) is abundantly clear. NO MATTER WHAT, YOU are required to ensure that if YOU lose control of your sUAS for ANY reason, including all of the ones you mention above, it poses no undue hazard to to other people, other aircraft, or other property.
Of course you were cunning enough to put this in terms of "FRIA limits". But since your stated goal is to "stick a fork in FRIAs" that's bogus. Any regulatory body adopting this concept would have no alternative but to ban anything flying ANYWHERE which is capable of generating lethal force. Which, I have a funny feeling, will be construed as anything weighing more than 0.55lb.
Pay attention folks! This what this guy really wants, and if you don't oppose him, he'll work with the FAA to make it happen.
Pay attention folks! This what this guy really wants, and if you don't oppose him, he'll work with the FAA to make it happen.
I'm confident that regulators will see the flaw in the concept and rewrite the rule to ensure these flaws are fixed.
#40
I can say with 100% certainty that having a spotter scanning the airspace happens more frequently then you may think. During a sailplane flight the timers job is not only to give the pilot time updates but to scan the sky for signs of lift usually in the form of wind change, cloud formations, birds, other sailplanes but most importantly since an altitude of 2,000' is not uncommon, manned aircraft. During a Pattern flight, the callers job is not only to remind the pilot of the sequence of maneuvers but to be scanning the path of the airplane to avoid other participants and help with aerobatic box positioning as well.
Since I know that some in this thread are " show me the numbers " kind of guys. Perhaps he can show statistics where see and avoid has failed in keeping traditional models and full scale aircraft from colliding.
Since I know that some in this thread are " show me the numbers " kind of guys. Perhaps he can show statistics where see and avoid has failed in keeping traditional models and full scale aircraft from colliding.
Show me the numbers? No need. I suggest you consult the Aeronautica Information Manual, 4-4-10(d) where it discusses systematic visual scanning (note 1). You have an obligation under the FARs to always avoid manned aircraft. You DO NOT have an obligation under the FARs to avoid other toy planes. Therefore, it is rather obvious that your "spotter's" primary job is searching 360 for MANNED aircraft. I also suggest your refresh yourself on the FARs, particularly 107.37. If your spotter isn't looking for the other aircraft 100% of the time, you can't really avoid what you don't see.
Note 1: https://www.faa.gov/air_traffic/publ...d_10-12-17.pdf
Last edited by franklin_m; 01-19-2020 at 07:21 AM.
#41
Here's one kinda well publicized case of see and avoid becoming seen and crunched . While thankfully rare , it DOES happen , because there is no such thing as the 100% infallible human . Sure , we can work out butts off to make things as safe as possible and reduce the chances of accidents , but even if the "gross negligence" types could ever be completely eliminated there will always be the "small oops" kind of accidents waiting to rise up and bite your tail . I do , I do my best to follow all of the established safety rules in our hobby so that if there ever is an incident with my plane I'd like to think gross negligence on my part wasn't a factor . You wanna see some hair raising stats from the full scale manned flight world , try searching "Runway Incursions" sometime , , , It's enough to make even the most ardent aircraft aficionado wanna avoid airports altogether
#43

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Like you said, nothing is ever going to be 100%. If that were the goal for all of aviation then we simply wouldn't have any aircraft at all.
#44
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The intent of the regulation is clearly to prohibit obviously unsafe practices such as flying over crowds, flying in close proximity to full-scale aircraft, or "buzzing". It does not mean that flight should be limited so that collision with people, other aircraft, or other property is physically impossible.
FAR 107.19 (b) also notes that the remote PIC (not some reg writer) is directly responsible for and is the final authority as to the operation of the sUAS. FAR 107.21 (a) authorizes the remote PIC to deviate from any Part 107 rule to the extent necessary to meet an emergency.
#45
Idea being that at any point in the path, based on the current velocity vector, a complete loss of control would result in sUAS impacting inside lateral limits of FRIA and no closer to 100 feet from any non-participant (FAA's definition of participant) inside the FRIA.
Quite interesting that you're saying something is impossible that FARs essentially already requires you to do. To refresh, FAR 107.19(C) requires YOU to "ensure that the small unmanned aircraft will pose no undue hazard to other people, other aircraft, or other property in the event of a loss of control of the aircraft for any reason (emphasis added)." All I did was add some distances.
As my full-scale flight instructor taught me years ago: The FAA cannot tell you what is safe. The FAA cannot tell you what is smart. The FAA can only tell you what is LEGAL.
The word you should have emphasized is "UNDUE". Unlike you, the regulation writer clearly recognized the indisputable fact that aviation of any kind is an inherently risky activity.
The intent of the regulation is clearly to prohibit obviously unsafe practices such as flying over crowds, flying in close proximity to full-scale aircraft, or "buzzing". It does not mean that flight should be limited so that collision with people, other aircraft, or other property is physically impossible.
The word you should have emphasized is "UNDUE". Unlike you, the regulation writer clearly recognized the indisputable fact that aviation of any kind is an inherently risky activity.
The intent of the regulation is clearly to prohibit obviously unsafe practices such as flying over crowds, flying in close proximity to full-scale aircraft, or "buzzing". It does not mean that flight should be limited so that collision with people, other aircraft, or other property is physically impossible.
Oh, and your caveat that a remote PIC can deviate from the rule to meet an emergency, your understanding of that is flawed. You could deviate from speed. You can deviate from altitude. You can even deviate from flying over people. But that carve out does NOT include deviating from the rule of imposing "undue risk." Try and make that argument.
#47

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this will not be popular for most folk, but it is what i have done since real failsafes came available to us decades ago:
fixed wing: throttle to full idle/kill, all other controls to full positive snap inputsrotorwing: throttle to hold/kill, all others ail and rud to neutral, ele to full back.
this has worked, everytime it has been needed to keep an aircraft from flying away
fixed wing: throttle to full idle/kill, all other controls to full positive snap inputsrotorwing: throttle to hold/kill, all others ail and rud to neutral, ele to full back.
this has worked, everytime it has been needed to keep an aircraft from flying away
#48
this will not be popular for most folk, but it is what i have done since real failsafes came available to us decades ago:
fixed wing: throttle to full idle/kill, all other controls to full positive snap inputsrotorwing: throttle to hold/kill, all others ail and rud to neutral, ele to full back.
this has worked, everytime it has been needed to keep an aircraft from flying away
fixed wing: throttle to full idle/kill, all other controls to full positive snap inputsrotorwing: throttle to hold/kill, all others ail and rud to neutral, ele to full back.
this has worked, everytime it has been needed to keep an aircraft from flying away
#49

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That sounds fine provided the airplane is out a ways. What about when an airplane is slow and over the runway or the threshold? That type of setup could easily put the airplane into the pilots station. IMO a bit more likely as while on final approach some less experienced guys tend to point the TX antenna towards the airplane where the signal pattern emitted from the antenna is weakest. If said airplane has an ignition system in front of the receiver the problem gets worse. I will stick with my failsafes set to engine off, surfaces nuetral.
#50
That sounds fine provided the airplane is out a ways. What about when an airplane is slow and over the runway or the threshold? That type of setup could easily put the airplane into the pilots station. IMO a bit more likely as while on final approach some less experienced guys tend to point the TX antenna towards the airplane where the signal pattern emitted from the antenna is weakest. If said airplane has an ignition system in front of the receiver the problem gets worse. I will stick with my failsafes set to engine off, surfaces nuetral.
Last edited by franklin_m; 01-19-2020 at 12:25 PM.







