Tipover

My Feedback: (44)

Even if the NPRM were changed to include non AMA members access to FRIA sites , that still does not stop the private property owner from limiting ground operations to local club (dues paying members). I'm not so sure FAA can deny FRIA recognition to a location based on that specific detail, or if they will even care. In fact they may see that as being to their advantage by limiting availability of FRIA locations to the problematic drone activity. It's quite obvious after reading the NPRM that they are primarily concerned with cracking down on hobbyists that fly long distance drones.

franklin_m

That is an interesting dilemma for the rule writers. For the FAA is NOT in the business of serving AMA, but rather writing a rule that applies to ALL citizens. And the FRIA is a concept that allows ALL citizens to fly non-compliant equipment. But one major problem with the concept is that FAA did not account for the fact that access to the FRIAs is almost entirely controlled by a single private dues collecting organization. Local land owners add another reason why the rule is flawed.

Under the draft rule, the FRIAs function much like airports. In the full scale world, we do indeed have public and private airports. I don't know the numbers, but I'm sure FAA has them. However, there's ample numbers of both, and a quick glance at a few sectionals leads me to believe that the public airports far outnumber private ones. In the case of FRIAs, they are nearly all private. That is fundamentally different and the fatal flaw in the policy.

Tipover

My Feedback: (44)

Thank goodness the EAA has recently come on board to help educate the FAA on the requirements and intention of traditional fixed wing model aircraft hobbyists.

Tipover

My Feedback: (44)

Well the FAA certainly can't have it both ways. Considering that most public airports are generally near larger population urban areas, it would be counter productive for them to assume that the safest locations for model RC activities would also be public land spaces. I highly doubt they had any confusion over that distinction when they drafted the proposal.

franklin_m

Your position depends a lot on the definition of "larger population urban areas." Where I live now, State College PA, has a population of 42,000. Is that a "larger population urban area?" Because the local airport is public (UNV). As is nearby Midstate Airport (PSB), where nearest large population is Phillipsburg (pop. 2700). Similarly Bellefonte (N96) where population is about 6,000.

The rule as written gives three options to comply: full RemoteID, FRIAs, or limited. When one of those options is all but exclusively controlled by ONE private dues collecting organization, I argue that fails to protect all citizens equally (members and non-members) as well as fails to provide federal due process protections in the event a PRIVATE organization says someone cannot join.

astrohog

My Feedback: (1)

Yes, I know that. Again, take a step back from your myopic point of view in order to see the BIG picture!

Well, their best wasn't good enough, was it? It should have been, given their experience and track record in this "industry". None of the other "commercial" interests have nearly the track record or experience the AMA has. The AMA's number one goal should have been to advocate for the vast majority of its' membership, instead it went looking for a money grab. PERIOD. End of stary. FAIL!
The AMA took it AFTER they FAILED miserably in accomplishing a task that should have been a slam dunk for them! All of you staunch AMA advocates' whole platform (which I agree with) is that all of this regulation is completely unnecessary for traditional modeling activities. I agree. WHY, pray tell, couldn't the AMA get the FAA to see that? The facts support it, history supports it.....

Regards,

Astro

Tipover

My Feedback: (44)

Point being public spaces for full scale do not equal the same ideal for flying RC models. Not even rural public parks, because of the obvious safety concerns for the general public. Rural private properties have a huge safety advantage. Them being privately owned is coincidental to the safety concerns.

I'd say that depends on the FAA's perspective of exactly what they're trying to accomplish. Do they seriously want to solve the drone problem or keep everyone happy? I think once all stakeholders weigh in FAA will appreciate the need to keep already established fixed flying sites. If they chose to do that though CBO's or private clubs and property owners will be up to them.

astrohog

My Feedback: (1)

This is what the AMA should have pushed, and put to rest, YEARS ago when they were the only established game in town.

Astro

RCUer75345

Do you honestly think the AMA has more clout with the FAA than commercial drone vendors like DJI and delivery companies like Amazon? That's the "commercial stakeholders" I was referring to. Not other potential CBOs.

If you agree, aren't you sort of taking the wrong side? Or do you think what is about to happen to "our" hobby is inevitable, so it's just a matter of academic interest?

astrohog

My Feedback: (1)

UMMM...yeah, that is who I was talking about. The AMA ABSOLUTELY had more clout when this thing began years ago. Due to their strategic money grab, I believe they lost that status due to the transparency and arrogant nature of their tack at the time. That ship sailed long before any of the large, commercial interests had any kind of real presence in this. You were probably raising your AMA and pro drone flag back then, so you wouldn't have known what was happening....


I think that there was a chance years ago to carve out a nice exemption for traditional RC activities. That ship sailed when the AMA failed to create seperation from the drones and traditional operations. I believe they lost whatever favor and respect they had with the FAA through their arrogant, ignorant and transparent agenda. I believe it is largely a matter of acedemic interest now, with the exception of some of the messages and conversations coming out of some of the new and "fringe" organizations, i.e. the EAA and the PMA, FLITE TEST, etc. It is my belief that the Feds are fed up with the AMA, hence my disappointment in the AMA in recent years.
I believe we could have been the "spotted owl" of the unmanned world had the AMA spoken up they would have been able to carve out exemptions for our traditional activities, (first come, first serve) and made the $$ making, commercial entities figure out a way to operate around us. As soon as the AMA lumped us in with the drones, there was no way to accomplish that.

The ONLY chance we have is to CLEARLY distinguish and separate from the drones. PERIOD. It may or may not be too late for that. Time will tell....

Get it?

Astro

init4fun

I quickly came to believe that what the AMA EC needed to distance us from was the flying camera , in all of it's incarnations (BLOS , preprogrammed flight , etc) . When "AMA doc. #550" first came out I was against it because I knew it's "spotter" requirement was hogwash , how was someone going to spot a model beyond it's operator's line of sight ?!?! I know it's water over the dam now but our organization's primary focus should have been on protecting us line of sight flyers VS attempting the power grab and morphing into a "jack of all trades , master of none" by incorporating FPV ...

RCUer75345

Well, maybe you're worried about the historical record, but I'm worried about one thing: March 2. That's the date the NPRM comment period closes. After that we will have had our say and the issue will be in the FAA's hands.

So, maybe we should quit worrying about "who shot John" and concentrate on our NPRM comments? The FAA won't give us anymore than what's on the table if we don't ask for it. And some among us want to take away even that...

franklin_m

One thing is certain. AMA will continue to do more of the same and hope for a different result. Look no further than the total rookie they sent to CES. Absolutely ill equipped to take advantage of the opportunity. How many more missed opportunities will it take before any of folks like you start holding AMA accountable for their repeated missteps?

RCUer75345

What does that have to do with the NPRM?

franklin_m

Quiet a lot:
- In the comment period for registration, AMA thumped their chest, spoke of all their influence with FAA, and prompted thousands of form letters advocating why toy planes should be exempt and/or if it has to happen, that AMA number should be permitted in lieu of registration. They got neither.

- In the run up to the FAA reauthorization bill, AMA thumped their chest, spoke extensively about their influence with lawmakers, and again prompted thousands of form letters advocating the importance of preserving 336 among other things. They got nothing. And 349 was published with severe limits on operations instead.

- Now, we're in the comment period for Remote ID. AMA is again thumping their chest and speaking endlessly about their influence. And again they're prompting thousands of form letters....

So, like I said above. One thing is for sure. AMA will do the same thing and hope for a different result. Now they make it worse by sending amateurs to major events and squander opportunities.

RCUer75345

and
So basically, you're going to campaign openly for the most restrictive regulations possible, and then have the nerve to blame the AMA for failing to stop you?

When no one can fly an RC airplane anywhere, I suppose that's "equality", at least in a trivial sense. But it is hardly JUSTICE.

franklin_m

Hardly. I'm arguing the FRIA concept as a method of compliance is flawed because it give one PRIVATE dues collecting organization all but a total monopoly on a principal means of access to the PUBLIC airspace by recreational sUAS operators. I'm also advocating that if these sites are permitted under the rule, that operations are confined to the lateral limits. I'm also advocating that if these sites are permitted under the rule, that a condition of such approvals is mandatory reporting of crashes outside lateral limits, damage to property, and number of complaints so FAA can measure whether operations at such sites pose undue risk on neighboring property owners. The latter will also serve as a leading indicator and help the CBO and FAA concentrate resources on those sites where flight discipline may be lacking - thus prevent a major mishap.

That is unlikely. Just because there are significant issues with the FRIA concept does not mean the FAA cannot rewrite it. For example to allow flights in class G below 400 feet with only a spotter and altitude reporting telemetry. Just think of all the people that would be able to fly w/o a need to drive to a FRIA. Think of all the carbon emissions saved! Think of all the little Johnnys that would be positively influenced by seeing recreational sUAS flown at the park in walking distance of little Johnny's home (or school) vs. a FRIA that might very well be tens of miles away.

I see nothing but positive possibilities!

RCUer75345

Hardly.

First of all, you're on record as requiring the landowner's permission for flying model airplanes on or over property. So Johnny has to get the park owner (probably the city) to approve his model airplane flying. Unlikely in this day and age, as more and more "park fliers" are finding out.

Second, the same system redundancy and terminal energy requirements you've proposed within a FRIA (which is mostly uninhabited space) will obviously also have to apply within the park boundaries. Little Johnny's airplane will be so full of throttle return springs, extra batteries, extra servos, and redundant flight controllers that it won't be able to get off the ground. More than that, it will have to be flown in such a way that if control is lost at any time for any reason, it will impact no closer than 100 feet to any "uninvolved person". Since Johnny has no control over the dog walkers and ball players who also use the park, he'll have to get the local police department to put signs up at all the entrances and trails, granting him exclusive use for a specified period of time. The municipal authorities will be glad to grant this - on the sixth Tuesday of the thirteenth month of every Leap Year.

Taken as a whole, your proposals effectively kill model aviation. Which of them would you like to modify or withdraw? Or is that really your goal?

Giant Flyer

My Feedback: (6)

EXCELLENT reply

franklin_m

I said:To which you replied:Which was a misrepresentation. My initial statement above was clearly talking about flights NOT at a FRIA. And as to the land owner permission aspect, here's what I actually said:And here again, you will note the statement "Can a club, without explicit permission of the land owner, apply for FRIA status?" So here too it was abundantly clear that I was speaking only of FRIAs. Thus your comment was a clear misrepresentation. My comments related to land owners was clearly addressed ONLY for the case of FRIAs.



As to this statement:Your initial statement is not necessarily true. Again, my comment about total energy was in the context of what types of recreational sUAS to regulate inside a FRIA. Here's what I actually said:And low and behold, there it is again, a clear and unambiguous statement "... inside the FRIA..."

Also, the return spring is not an issue for the little Johnny example, as it's not a FRIA, not a club, and therefore is operating under park flyer safety code. And I'm sure you remember that's electric only, which makes the whole loss of battery with throttle full trivially easy. Lose the battery, no electricity to the motor. And it's easy to set a failsafe that also shuts down the motor if there's a BEC powering the receiver. So none of the parade of horribles you describe apply.

What I advocate will not kill the hobby. To the contrary. If FAA chooses to create more alternatives to the FRIA, because what was presented is fundamentally flawed, all those who don't go to club fields will surely benefit from having more places and options to fly legally w/o tithing to the AMA.

RCUer75345

So now you are on record as advocating one set of safety rules for those who operate in FRIAs, and a different set for those operating outside. NOT because their equipment is different -- many club members fly park flyers at club fields -- but simply because of the venue. That's not "equal protection of the laws".

Not if "the hobby" is electric powered, weighs less than 2lb, and is limited to 60 MPH.

And you failed utterly to address the main point: Those parks "within walking distance of little Johnny's home" which are airplane friendly may exist only in your imagination. Where is your survey data showing such venues are actually available? And that they can accomodate an increasing number of fliers driven out of now-closed club fields after you shut the FRIAs down?

speedracerntrixie

My Feedback: (29)

Just curious here, why different standards for park flying VS FRIA sites. From my perspective park flying has the higher potential for property damage and injury to general public then a FRIA site.

franklin_m

First, you're acting as the policy is fully developed. It's not. I have a general concept, a total energy based risk measure. I continue to develop the concept and the back and forth is actually good to further develop the concept. As to potential differences.

I see that that a FEDERALLY recognized site could rationally be held to a higher standard given the locus of activity there, and the presence of larger numbers of larger, faster, and higher flying sUAS. I could also see a rational reason that the standards are higher when there is a public event at such sites. Ultimately though, what I can see is classes of sUAS based on total energy, with "crash no closer than" distances according to those energy totals. Obviously electrics will enjoy a big advantage, as loss of power or signal means immediate loss of motive power. Also, the park flyers are smaller (less mass), limited to 60 MPH (less kinetic energy), and limited to 400 AGL or lower (less potential energy). Combination of all three of those means much smaller bubbles.

There are vastly more operators who's sUAS are closer to these parameters than those who fly large, fast, and high flying types. AMA has 110,000 paying members. Already outnumbered by the approx 2.2 lb group by 8:1. And that subset of AMA members that fly large, fast, and high flying stuff is even smaller. I just don't see public policy being centered on a small minority of a small minority.

Well, they apparently do exist lest AMA have no need for the Park Flyer program.

RCUer75345

Better hurry up then, you've only got until March 2 to submit comments. Unless, that is, you work for or are consulting for the FAA.

That's mitigated, or overshadowed, by other factors. People who live near club fields, or frequently visit them, soon become familiar not only with model airplanes in general, but the various types and their capabilities. They tend to keep an eye out for them. They know what's potentially dangerous and what isn't. The public in parks, on the other hand, tends to be generally clueless, distracted, otherwise engaged, or virtually unconscious.

Not every club hosts public events. There is no reason to set everyday public policy based on things that happen two or three times per year. Of course spectators need to be kept a certain distance from the flight line, that's easily handled with signs and caution tape.

Unless you're accounting for the energy of the splinters, "crash no closer than" is just ridiculous -- an inch is as good as mile. Recommended "stand no closer to the flight line than" distances might have some merit. I believe the 500' standard used at full-scale airshows is generally credited with preventing spectator deaths at US airshows since the 1950's. Obviously smaller distances would be appropriate for models.

Don't forget that the latest fatal casualty (at the slope soaring event in Taiwan) was killed by a sailplane, about 500 yards from the flying site. Loss of power doesn't equal immediate loss of energy. And the victim was in a public park. Maybe if a FRIA equivalent had been established she would have been expecting model airplanes flying around and kept a lookout?

So, you don't believe in protecting minorities?

You remind me of the story about Isaac Newton's cat. He got so attached to it that he invented the pet door. When the cat had kittens, he had a smaller door cut so they could come and go as well.

In case you missed it, the flaw in his reasoning is that both large and small cats can use a large hole. And both large and small planes can use a large field. There is no reason - none - to put more restrictions on park fliers just because they are flown in FRIA.

franklin_m

I appreciate the reminder. However there will be other opportunities to address things like safety standoff distances within FRIAs.

Courts are increasingly ruling in injury cases that one cannot assume that attendees "know what's potentially dangerous and what isn't." So I do not agree with your fundamental premise at public events with (comparatively) a large number of spectators. On the other hand, quite often parks are thinly used. And when combined with a dedicated spotter may well be safer in that there are many fewer people there. Of course this is not always the case. But a public event at a FRIA can be assumed to have much higher density of uninformed spectators.

Re-read "..WHEN there is a public event at such sites." Never said the public event standard was in place other than the two or three times per year. I don't see what use of caution tape and signs have to do with the LOCATION of the standoffs? I mean, you could put caution tape in the middle of the runway, that doesn't mean it's the right place for it. My comments were focused on discussing WHERE to put it, not WHAT to put.

An "inch is as good as a mile?" Wow. I'm in awe of the science behind that. Ironic that you quote the 500 foot limit at airshows (not entirely correctly). For if you checked (note 1), what you'd see is there's standoffs based on Vref vs. weight, activity type, etc. And those are just from the runway (takeoff and land), not from "airshow" box. So you see my concept of standoffs based on total energy is actually based in precedent. but the point is there is a defined stand off distance that's not waiverable by an "agent of the AMA" that has ZERO formal aviation safety training, ZERO formal risk management training, and ZERO formal understanding of physics. Oh, and that 100 foot buffer based on energy I mentioned? Looks more like existing FAA policy you noted rather than something arbitrary.

Interesting you pick at that scab. Unless you want to argue that the operator intended to operate the sUAS that far outside the flying area, lots of questions that have fairly ugly answers. For example, if getting caught by a waive is so common (it is apparently per the discussions on this event), why is acceptable to not develop a failsafe to account for it? Why is it acceptable to continue trying to regain orientation rather than put it in the dirt closer to where you have observers? The reason is obvious, it was more about saving the toy than protecting innocents. Also, why is it not standard operating procedure to require a failsafe of some sort? Why is flying in conditions such as this allowed at all? Or mandatory use of a drogue chute or other device to stop the sUAS and bring it down gently? There are any number of options.

At some point, the interests of a tiny minority of a minority are de minimis.

Interesting, though largely irrelevant. And you note, I'm not trying to put MORE restrictions on park flyers, you jumped to that assumption in an effort to discredit the argument. For as written, the rule would all but ban park flying in favor of FORCING those operators to FRIAs (where AMA "cha-ching" gets $75 each). My proposal (400 AGL or LAANC whichever lower), spotter, altitude encoding, and PF limits opens huge areas to fly w/o nearly the restrictions on sites as the FRIA. Saves carbon (don't need to drive long way to FRIA) too!

Note 1: https://www.faa.gov/airports/airport_safety/airshows/
and https://www.faa.gov/about/initiatives/airshow/waiver/ (among others)