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Comment on tbe FAA NPRM

Old 01-19-2020, 12:35 PM
  #51  
astrohog
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Originally Posted by franklin_m View Post
Operators are not the public. They are participants under the FARs. Your system protects participants during a small fraction of the entire flight, but might well minimize damage to the toy. His method protects the public during the majority of the flight and does not consider preservation of the toy.
EXACTLY! I agree that as participants in this hobby, we have an obligation to minimize risk to the non-participating public, even if it means that there is a higher risk that we suffer injury or harm. It is one of the prices to pay to play. Very simple, really. Kind of like the free flight contest video that was posted a while back. There should be no individual liablility posed on the participants in that event by the spectators who CHOSE to attend an event where they know there is an increased chance for harm as opposed to, say, staying in bed!

Regards,

Astro
Old 01-19-2020, 12:47 PM
  #52  
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Originally Posted by astrohog View Post
EXACTLY! I agree that as participants in this hobby, we have an obligation to minimize risk to the non-participating public, even if it means that there is a higher risk that we suffer injury or harm. It is one of the prices to pay to play. Very simple, really.
Agree.

Originally Posted by astrohog View Post
Kind of like the free flight contest video that was posted a while back. There should be no individual liablility posed on the participants in that event by the spectators who CHOSE to attend an event where they know there is an increased chance for harm as opposed to, say, staying in bed!
I'm less convinced the hobby will be successful here. MLB is adding more extensive netting as a result of injuries to spectators. I think the concept of knowing of a risk is evaporating in favor of the injured party.

Old 01-19-2020, 01:04 PM
  #53  
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Originally Posted by franklin_m View Post
I'm less convinced the hobby will be successful here. MLB is adding more extensive netting as a result of injuries to spectators. I think the concept of knowing of a risk is evaporating in favor of the injured party.
There are differences. MLB spectators PAY to spectate. MLB is a for-profit venture. I believe they have more of an expectation of safety, where large profits are at stake.

I believe in survival of the fittest (WITHOUT stepping on anyone else's toes, or infringing on their rights). I have my thresholds for what I consider safe, others have theirs. I prefer we not legislate safety, for fear of living a completely vanilla, mundane existance in a world overpopulated with non-thinkers.

Astro

Last edited by astrohog; 01-19-2020 at 01:07 PM.
Old 01-19-2020, 01:12 PM
  #54  
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Sorry guys I'm not buying it. There are too many variables to accurately say which one has the more favorable odds of protecting the general public. That is unless either of you have accurate data. Perhaps this falls under what would be best for the flying site. Since the flying fields that I frequent are well away from the General public, there is virtually no risk to them should a loss of signal happen. The risk is to the participants at the field.

Now that being said, an actual failsafe event is quite rare. Most out of control situations are battery related with linkage failure being a close second. A Brown out is not a failsafe event. Since failsafe was introduced I have only had 1 failsafe event which I had all surfaces to neutral and engine off. The airplane glided into a hillside and was destroyed. However if flying a small model in a residential zone with minimal overflight to reach houses then the " all in " method my be best.
Old 01-19-2020, 02:26 PM
  #55  
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Originally Posted by franklin_m View Post
Exactly. And I'd argue such a setup would be the minimum folks should do in order to ensure they stay on the right side of the "undue risk" as noted in the rule.
Actually you've suggested more if the model is IC powered:

Originally Posted by franklin_m View Post
Simple, just add a return spring on the throttle... FAA expects you to already be taking steps to ensure this does not impose undue risk if something as simple as a battery becomes disconnected. Not only is that a very concerning single point of failure on a large and obviously higher risk toy, to not add redundancy and something as simple as a throttle return spring would seem rather cavalier were I the investigator.
Hands up all those who fly IC powered models who think this is reasonable. For my money, putting a spring of any kind in opposition to a servo is generally bad practice. In this specific case, the spring will have to be strong enough to overcome the resistance of the servo with power off in order to close the throttle. No I don't have numbers but those of us who set up our own control systems know that it takes a few ounces to get the servo moving. So the servo will be fighting the spring all through each and every flight, drawing more current, running the battery down faster, and shortening the life of the servo.

Knee jerk solutions imposed by bureaucrats on the spur of the moment are rarely well thought out.

Old 01-19-2020, 02:34 PM
  #56  
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Originally Posted by mongo View Post
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
I'm glad that meets your needs. I would not impose it on others without statistics showing how often loss of signal occurs and for how long. One size does not fit all.

My fail safe settings for power planes are generally set to the factory default: Hold the last position at signal loss. That gives me the best chance to regain control of the model, in which case I can direct it to a safe area or simply resume flying. I could support a fail safe which would "dump" it after signal loss persisted for an extended time -- say 10 or 15 seconds.

For sailplanes, I set my fail safe to motor off, full crow (flaps down/ailerons up) and full up elevator. This should put the model into a slow speed descent. With neutral spiral stability it will fall off on a wing anyway, no reason to force it. This doubles as a "thermal escape" mode.
Old 01-19-2020, 02:39 PM
  #57  
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I'm fairly sure that he ment adding ( modifying) the throttle gimbal. Do the new proposed regulation mention anything about equipment modifications?
Old 01-19-2020, 02:45 PM
  #58  
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Originally Posted by grognard View Post
Hands up all those who fly IC powered models who think this is reasonable. For my money, putting a spring of any kind in opposition to a servo is generally bad practice. In this specific case, the spring will have to be strong enough to overcome the resistance of the servo with power off in order to close the throttle. No I don't have numbers but those of us who set up our own control systems know that it takes a few ounces to get the servo moving. So the servo will be fighting the spring all through each and every flight, drawing more current, running the battery down faster, and shortening the life of the servo.......
Grog is correct here , a spring heavy enough to force the throttle servo to the carb's idle position would quickly fry the servo , so the spring idea is not a solution .

Of course , gas powered models (with a spark ignition VS glow) can easily be equipped with an optical ignition cutoff that will kill the spark instantly should the TX and RX loose radio contact . I know of no such handy system for glow engine powered models , but I'm sure if it's that important some enterprising engineer should be able to come up with something . Perhaps a small "emergency battery" with a servo driver circuit that would electronically close the throttle in the event of radio system failure ?
Old 01-19-2020, 02:49 PM
  #59  
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Originally Posted by speedracerntrixie View Post
I'm fairly sure that he ment adding ( modifying) the throttle gimbal. Do the new proposed regulation mention anything about equipment modifications?
What happens with the throttle gimbal (in the transmitter) means nothing to the model who has lost radio contact with that TX , no , I'm pretty sure he meant a spring at the throttle servo itself , an unworkable idea as per my above post .

See ? I DON'T always agree with Franklin, or anyone else out here for that matter .

...... Hell , there are days when I don't even agree with MYSELF !
Old 01-19-2020, 03:28 PM
  #60  
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Originally Posted by grognard View Post
Hands up all those who fly IC powered models who think this is reasonable. For my money, putting a spring of any kind in opposition to a servo is generally bad practice. In this specific case, the spring will have to be strong enough to overcome the resistance of the servo with power off in order to close the throttle. No I don't have numbers but those of us who set up our own control systems know that it takes a few ounces to get the servo moving. So the servo will be fighting the spring all through each and every flight, drawing more current, running the battery down faster, and shortening the life of the servo.

Knee jerk solutions imposed by bureaucrats on the spur of the moment are rarely well thought out.
The wonderful thing is that I don't have to design YOUR system. You do, as you're the one who's obligated 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)."

So add redundant wiring, or batteries, or receivers, or all of them. You decide. And if something happens, you'll get your chance to tell investigators or litigators or a jury that what you decided was more than adequate - that 'accidents happen.'
Old 01-19-2020, 03:39 PM
  #61  
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I've been asked by the OP to take this out of the EAA vs AMA thread, and since we're talking about failures and incidents, it seems an appropriate place to bring it up:

Originally Posted by speedracerntrixie View Post
...there is not a single reported incident that I am aware of a traditional model airplane bringing down a manned aircraft.
Not to hand the naysayers more ammunition, but there was a fatal midair collision in Germany in 1997:
https://aviation-safety.net/wikibase/wiki.php?id=58711

A brief summary:
(A Grob motorglider) collided in mid-air with a remote controlled aircraft ("Dingo", wing span 2,40 m and a weight of 10 kg) and crashed into a wooded area. Both occupants of the motorglider were killed.
The collision occurred at an altitude between 702 m and 768 m amsl, which corresponds to 219 m and 285m agl.
The Grob should have been at an altitude of at least 600 m agl.
You can read the full report (auf Deutsch!) at this link:
https://www.bfu-web.de/DE/Publikatio...ublicationFile

I applied Google Translate to some of the relevant paragraphs here:

The organizer put up a poster about the friendship flying of the model flying group Schopfheim taking place on 02./03.97 on the door of the canteen of the Hütten gliding area. It could not be determined whether the motor glider pilot took note of this and was thus informed about the special event.
The weather conditions (according to witnesses: wind from 360 ° with 1-2 kt, visibility> 10 km, cloudless) were suitable for carrying out the flight operations. The position of the sun at the time of the accident causes the motor glider driver to be blinded by the sun.
For the model flying site, a permit issued by the competent authority for ascent lay, among other things. the above Aircraft models before. There was no exact flight height limit for models. There were the requirements that flight operations should only take place within a specified flight sector, the airspace should be monitored by the flight manager and that the model aircraft pilot should be warned when man-carrying aircraft fly into the flight sector and instructed to land or evade them.
A drop below the minimum altitude for cross-country flights by the powered glider and leaving the flight sector by the powered aircraft model could not be ruled out. However, even in these cases, a collision could have been avoided with timely detection and evasion.
Conclusions
The accident is due to the fact that the pilot of the powered model noticed the powered glider too late and therefore avoided it too late, and that the powered glider pilot was blinded by the sun, which was already relatively low at that time, and did not notice the powered aircraft model or did not notice it too late and did not avoid it or avoided it too late.
Relevant to our current discussions, I see this case as a good argument in favor of the FRIA concept, and having FRIA locations marked on aeronautical charts. The Grob pilot violated the lower altitude limit of 600 m AGL for cross country flight in the area where the collision occurred. If he had known about an established flying site he might have paid more attention to his altitude - or been careful not to approach it from a direction where he was blinded by the sun.
Old 01-19-2020, 03:45 PM
  #62  
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Originally Posted by franklin_m View Post
So add redundant wiring, or batteries, or receivers, or all of them. You decide. And if something happens, you'll get your chance to tell investigators or litigators or a jury that what you decided was more than adequate - that 'accidents happen.'
Or not. I use typical, practical, and prudent steps to reduce my operational risk. Such as making sure my solder joints are good and by battery connectors are snug. Such as making sure the wires aren't kinked. Such as checking my battery voltage before each flight. Such as verifying flight controls are "free and correct" before each takeoff.

That has served me well for over 40 years, and I don't propose to change anything until forced to. Experience shows it's entirely sufficient for my fleet and my usage.
Old 01-19-2020, 04:01 PM
  #63  
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Originally Posted by grognard View Post
...I see this case as a good argument in favor of the FRIA concept, and having FRIA locations marked on aeronautical charts. The Grob pilot violated the lower altitude limit of 600 m AGL for cross country flight in the area where the collision occurred. If he had known about an established flying site he might have paid more attention to his altitude - or been careful not to approach it from a direction where he was blinded by the sun.
Regarding your statement "if he (the Grob pilot) had known ... and he (the Grob pilot) might have paid more attention ... and (he) been more careful to approach..." - In the US, no matter what the manned aircraft does, FAR 107.37 clearly puts the responsibility on the unmanned aircraft operator. No exceptions. For your convenience, I've appended the applicable section below.


§107.37 Operation near aircraft; right-of-way rules.

(a) Each small unmanned aircraft must yield the right of way to all aircraft, airborne vehicles, and launch and reentry vehicles. Yielding the right of way means that the small unmanned aircraft must give way to the aircraft or vehicle and may not pass over, under, or ahead of it unless well clear.

(b) No person may operate a small unmanned aircraft so close to another aircraft as to create a collision hazard.
Old 01-19-2020, 04:02 PM
  #64  
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Originally Posted by grognard View Post
Or not. I use typical, practical, and prudent steps to reduce my operational risk. Such as making sure my solder joints are good and by battery connectors are snug. Such as making sure the wires aren't kinked. Such as checking my battery voltage before each flight. Such as verifying flight controls are "free and correct" before each takeoff.

That has served me well for over 40 years, and I don't propose to change anything until forced to. Experience shows it's entirely sufficient for my fleet and my usage.
Again, if something bad happens, it isn't you that gets to decide whether something was "typical, practical, and prudent," the FAA or the jury does.
Old 01-19-2020, 04:17 PM
  #65  
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Originally Posted by grognard View Post
Relevant to our current discussions, I see this case as a good argument in favor of the FRIA concept,
I say that it is the RC pilots' responsiblility to yield the right-of-way to a manned aircraft EVERY time. And is a better argument for a spotter than for a FRIA!

Astro
Old 01-19-2020, 05:05 PM
  #66  
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Originally Posted by franklin_m View Post
In the US, no matter what the manned aircraft does, FAR 107.37 clearly puts the responsibility on the unmanned aircraft operator. No exceptions.
Of course, and the model pilot stated that he took evasive action as soon as he saw the Grob:

According to his own information, he had only noticed the motor glider a few meters away from his model after he had released the glider model and is said to have attempted an evasive maneuver.
And actually there is an exception, in that the regulation language contains the qualifier "unless well clear". If the Grob had been flying above the minimum enroute altitude, it would have been "well clear" and no evasive action would have been required.

Originally Posted by astrohog View Post
I say that it is the RC pilots' responsiblility to yield the right-of-way to a manned aircraft EVERY time. And is a better argument for a spotter than for a FRIA!Astro
Evidently a spotter was required to be on duty:

There were the requirements that flight operations should only take place within a specified flight sector, the airspace should be monitored by the flight manager and that the model aircraft pilot should be warned when man-carrying aircraft fly into the flight sector and instructed to land or evade them.
All I'm saying is a FRIA would have resulted in better situational awareness. If model aircraft operations are concentrated in known areas (FRIAs) full-scale pilots, as well as unmanned aircraft, can more easily avoid them.

Last edited by RCUer75345; 01-19-2020 at 05:08 PM.
Old 01-19-2020, 05:10 PM
  #67  
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Originally Posted by franklin_m View Post
Again, if something bad happens, it isn't you that gets to decide whether something was "typical, practical, and prudent," the FAA or the jury does.
IF.

And if nothing bad happens, the issue will never be put to the test.
Old 01-19-2020, 06:13 PM
  #68  
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Originally Posted by grognard View Post
IF.And if nothing bad happens, the issue will never be put to the test.
Some have said the current hullabaloo is unwarranted. Perhaps. But you cannot deny the fact that the public, media, regulators, and legislators are taking action none the less. Can you imagine what it will be like the first time something bad does happen?

My point to the AMA is that all it will take is one. One "Fast Freddy" at Mayhem Park that instead of pulling out of his high speed dive loses control and crashes his turbine in the middle of a busy interstate resulting in big pile up with injuries or worse. Or a slight change in circumstances that put the MR in New York through the windscreen of that helo and a resulting crash. All it will take is one. And yet they continue to take a hands off view of safety ... that it's the club's responsibility.
Old 01-19-2020, 07:14 PM
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Originally Posted by franklin_m View Post
My point to the AMA is that all it will take is one....And yet they continue to take a hands off view of safety ... that it's the club's responsibility.
Well why don't you go tell AMA that instead of posting it on a social media forum?

And what does it have to do with the NPRM?
Old 01-20-2020, 04:55 AM
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Originally Posted by grognard View Post
Well why don't you go tell AMA that instead of posting it on a social media forum?
I have. Despite losing on registration, losing on preservation of 336, and now Remote ID staring them in the face, the don't realize how precarious their situation really is.

Originally Posted by grognard View Post
And what does it have to do with the NPRM?
Examples of irresponsible behavior by AMA members, especially when there's video supporting them, can be powerful influencers that this particular CBO should not be trusted to ensure the operations at FRIAs is as the FAA expects.
Old 01-20-2020, 02:45 PM
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Originally Posted by franklin_m View Post
My point to the AMA is that all it will take is one. One "Fast Freddy" at Mayhem Park that instead of pulling out of his high speed dive loses control and crashes his turbine in the middle of a busy interstate resulting in big pile up with injuries or worse.
And all it will take is one...commercial delivery drone that goes stupid and crashes in the middle of a busy interstate resulting in big pile up with injuries or worse. Or one that loses power and crashes through the roof of an occupied house, causing injuries or worse.

I haven't finished writing up my comments, so I'm thinking about adding a couple of items related to commercial delivery drone safety. I mean, these things are obviously going to be bigger, heavier, and probably faster than typical model airplanes; so their damage potential is greater. In addition, projected numbers are much greater than the number of model airplanes, further increasing the risk. So it's entirely appropriate to recommend risk mitigation, such as:

Requiring all UAS used for commercial delivery purposes to undergo a formal risk analysis, and prohibiting commercial operations unless the manufacturer can show all flight-critical components have a MTBF of not less than 1,000,000 flight hours.

For each flight critical component having an MTBF of 1,000,000 to 1,000,000,000 flight hours, a backup component shall be provided. The system shall auto-detect failures and shall be capable of continued operation with one component failed. For a non-simultaneous second like failures, the system (if fixed wing type) shall be controllable to a safe landing. If rotary wing type it shall immediately enter a vertical descent to impact. (In the flight control business we call this "fail-op/fail-safe")

Furthermore, given the low altitudes at which such systems will operate, they shall at all times be operated such that, considering the current velocity vector, a total loss of control will result in impact no closer than 100' to any person, vehicle, or building, other than the intended points of departure and landing.

Ya wanna fly pizza to my neighbor's house? Fine with me -- just keep the thing 100' away from mine. Houses in the neighborhood not separated by 200'? Too bad. Safety is paramount, ya know.

Now would you like to help me word it more properly?
Old 01-20-2020, 02:48 PM
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Originally Posted by grognard View Post
And all it will take is one...commercial delivery drone that goes stupid and crashes in the middle of a busy interstate resulting in big pile up with injuries or worse. Or one that loses power and crashes through the roof of an occupied house, causing injuries or worse.

I haven't finished writing up my comments, so I'm thinking about adding a couple of items related to commercial delivery drone safety.

( ... deleted for brevity ... )

Now would you like to help me word it more properly?
I think you're off to a great start. I really think you should write that up and submit it.
Old 01-21-2020, 01:23 PM
  #73  
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Originally Posted by speedracerntrixie View Post
See any buildings to be overflown in any of these pictures? Would these sites be the " problem FRIA sites " that Franklin warns people about? I don't think so.
nice planes and flying site...
Old 01-21-2020, 01:43 PM
  #74  
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Originally Posted by mach5nchimchim View Post
nice planes and flying site...
Again, what a coincidence that you hail from the same spot as SpeedRacerTrixie. I also noticed that of your three total posts, two are quoting him. The coincidences are just stunning.
Old 01-21-2020, 01:59 PM
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Originally Posted by franklin_m View Post
Again, what a coincidence that you hail from the same spot as SpeedRacerTrixie. I also noticed that of your three total posts, two are quoting him. The coincidences are just stunning.
Who's this guy?

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