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For your NPRM Response...s.

Old 01-21-2020, 08:10 AM
  #101  
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Old 01-21-2020, 08:40 AM
  #102  
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Wow, you were busy this morning! So let's just focus on one piece.

How do you reconcile this:

Originally Posted by franklin_m View Post
And you note, I'm not trying to put MORE restrictions on park flyers..
With this:

Originally Posted by franklin_m View Post
My proposal (400 AGL or LAANC whichever lower), spotter, altitude encoding, and PF limits...
You think those aren't new restrictions?

Seriously Franklin, you won't even let a kid fly a toy airplane in a park without a dedicated spotter and altitude encoding telemetry?

All Orwell got wrong was the date....
Old 01-21-2020, 09:55 AM
  #103  
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Originally Posted by grognard View Post
Wow, you were busy this morning! So let's just focus on one piece.

How do you reconcile this:
Originally Posted by franklin_m View Post
I'm not trying to put MORE restrictions on park flyers...
With this:
Originally Posted by franklin_m View Post
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.
You think those aren't new restrictions?
Easy. If you remember, I proposed these in lieu of FRIAs (long drive, tithing to one or more private dues collecting organizations, no federal due process protections from arbitrary and capricious restrictions like "No MRs here," or "No helicopters here," or "No 3D" and limited Remote ID (400 foot slant limit, other electronic requirements). Being able to fly anywhere in class G with altitude telemetry (very common and easily added) and a spotter seems a small price.

Originally Posted by grognard View Post
Seriously Franklin, you won't even let a kid fly a toy airplane in a park without a dedicated spotter and altitude encoding telemetry?
Well, if the rule gets published as is, they will require significant new equipment and capabilities, many of which are not yet developed. My proposal allows flight w/o that, and in fact the equipment already exists. Sounds like a win.

Originally Posted by grognard View Post
All Orwell got wrong was the date....
May I remind you that there's a NPRM out there?
Old 01-21-2020, 11:02 AM
  #104  
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Originally Posted by franklin_m View Post
Well, if the rule gets published as is, they will require significant new equipment and capabilities, many of which are not yet developed. My proposal allows flight w/o that, and in fact the equipment already exists. Sounds like a win.
You honestly don't get that putting altitude encoding telemetry on most park flyer models means replacing the transmitter and the receiver?

How is it a "win" for kids if they have to fork over more money just to keep doing what they're already doing? And bring along a nanny into the bargain?

Why don't you propose raising the weight limit for registration to something reasonable, like 2 lb (the park flyer limit), and just leaving kids alone? Even that wouldn't be "win" -- it's just the status quo.
Old 01-21-2020, 11:31 AM
  #105  
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Originally Posted by franklin_m View Post
Easy. If you remember, I proposed these in lieu of FRIAs (long drive, tithing to one or more private dues collecting organizations, no federal due process protections from arbitrary and capricious restrictions like "No MRs here," or "No helicopters here," or "No 3D" and limited Remote ID (400 foot slant limit, other electronic requirements). Being able to fly anywhere in class G with altitude telemetry (very common and easily added) and a spotter seems a small price.

Well, if the rule gets published as is, they will require significant new equipment and capabilities, many of which are not yet developed. My proposal allows flight w/o that, and in fact the equipment already exists. Sounds like a win.
Originally Posted by grognard View Post
You honestly don't get that putting altitude encoding telemetry on most park flyer models means replacing the transmitter and the receiver?

How is it a "win" for kids if they have to fork over more money just to keep doing what they're already doing? And bring along a nanny into the bargain?
Because I recognize that doing as they've always done is not an option. FAA wants some assurance that people are indeed operating where they should be, and the altitude reporting gives FAA some risk mitigation that may allow them to say yes to some rollback of the limited option.

Originally Posted by grognard View Post
Why don't you propose raising the weight limit for registration to something reasonable, like 2 lb (the park flyer limit), and just leaving kids alone? Even that wouldn't be "win" -- it's just the status quo.
See above. FAA is not going to accept the status quo. I invite you to advocate that. Let me know how it works out.
Old 01-21-2020, 11:41 AM
  #106  
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The problem is that the FAA has already set the weight limit that they think is "safe and sane"(I like it, a firework reference )
That said, I do have to agree, the .55lb limit is a bit ridiculous as there's only a handful of drones that actually are under that weight. Hell, most battery packs that I use weigh half of that by themselves. Then again, my boats and planes all are set up with Futaba/Sanyo 4.8 volt nicad packs
Old 01-21-2020, 01:00 PM
  #107  
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Originally Posted by franklin_m View Post
Because I recognize that doing as they've always done is not an option. FAA wants some assurance that people are indeed operating where they should be, and the altitude reporting gives FAA some risk mitigation that may allow them to say yes to some rollback of the limited option.
Well, I must say you're making the AMA look better and better. Practically speaking, you'd require every kid in America who wants to fly a model airplane to buy a new transmitter and receiver, and install the receiver in the plane. And that probably means a new plane in many cases - since many small receiver boards include servos and ESCs.

AMA clubs on the other hand will welcome kids to FRIAs, where they can fly their current equipment without altitude encoding capability or Remote ID capability. They can also meet experienced builders and fliers who will mentor them. As opposed to the kind of mentoring they'd receive from some of the, shall we say, colorful characters typically found in city parks.

And before you get all preachy about the cost remember that AMA youth membership is FREE.
Old 01-21-2020, 01:36 PM
  #108  
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Originally Posted by franklin_m View Post
Because I recognize that doing as they've always done is not an option. FAA wants some assurance that people are indeed operating where they should be, and the altitude reporting gives FAA some risk mitigation that may allow them to say yes to some rollback of the limited option.
Originally Posted by grognard View Post
Well, I must say you're making the AMA look better and better. Practically speaking, you'd require every kid in America who wants to fly a model airplane to buy a new transmitter and receiver, and install the receiver in the plane. And that probably means a new plane in many cases - since many small receiver boards include servos and ESCs.
Would require a new plan because "many small receiver boards include servos and ESCs?" Not so fast. You're obviously forgetting that the only ones seen regularly with "small receiver boards [that] include servos and ESCs" quite likely already exempt. So looking at the UMX series as an example of this type, most are around 4 ounces, HALF the maximum weight exempted from the rule.

As to the ones not exempted, they more often than not have stand alone receivers. And aren't we thankful that Taranis, FRSky, Orange, and other are on the scene and have low cost transmitters and receivers. Yes, it's some expense. But considerable savings because the kiddo can walk to a flying site instead of needing Mom or Dad to cart them to/from a FRIA - in between soccer, baseball, football, dance, or other after school activities.


Originally Posted by grognard View Post
AMA clubs on the other hand will welcome kids to FRIAs, where they can fly their current equipment without altitude encoding capability or Remote ID capability.
IF there's a club nearby
IF Mom or Dad have time to drive them to/from after work, or on weekends between soccer, baseball, football, field hockey, or other school or family events

Plus:
IF they can afford the club membership
IF they can afford additional AMA expense (see below)

Originally Posted by grognard View Post
And before you get all preachy about the cost remember that AMA youth membership is FREE.
Not for long. Read the latest EC notes. Some discussion of adding fees, even for "free" youth memberships.


So a new receiver and transmitter is cheap by comparison. Let's do a cost comparison shall we? Taranis QX7 is $125 on Amazon, an X8R receiver is 35 and a high resolution variometer (can be moved to other aircraft) is $33 (or you can buy a combined receiver / altimeter for $39).

Now say it's 20 minutes each way to the flying site. Sasy Mom or Dad doesn't sit and wait for several hours, so assume Mom or Dad drives home so they can do chores or take other kids to other events. So that's 80 miles per "event." Now say they do it three weekends a month, because during the week they have other things keeping them busy. That's 240 miles a month. Assume 24.7 miles per gallon (note 1) and regular unleaded is $2.54 per gallon. That's $24.68 a month just for gas, and it only gets more expensive in the summer as rates go up. So in less than 7 months (quicker if flies more often) the cost for new equipment has been offset by the cost of gas. And remember, it happens MUCH faster in high cost gas states (CA, NY, NJ) or during summer, or both.

And this does not even account for the parents' time driving back and forth and back and forth. So you see, flying locally in the local park, albeit with altitude reporting, means little Johnny can walk there himself, save time for Mom and Dad, and save money for them as well ... not to mention probably fly quite a bit more often!

Note 1: https://www.reuters.com/article/us-a...-idUSKBN1F02BX

Note 2: https://gasprices.aaa.com/
Old 01-21-2020, 02:43 PM
  #109  
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Obviously Franklin served at least one tour at the Pentagon...
Old 01-21-2020, 02:56 PM
  #110  
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Originally Posted by grognard View Post
Obviously Franklin served at least one tour at the Pentagon...
Why the snide comment? The very real time, distance, costs, and competing priorities is a principal reason why it's difficult to get younger kids involved. Unless Mom, Dad, or an older sibling is going there anyway, driving to the AMA field / FRIA is quite often a big investment. As they continue to be puzzled why younger folks don't get involved, this is one factor.
Old 01-21-2020, 03:26 PM
  #111  
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The problem Franklin is that you continually spin the worst case scenario as the norm. Not all kids are interested in sports, in fact with the dwindling education budget, some schools some are dropping sports programs all together. A good parent ( and I have seen my fair share at flying fields ) will support their kids interest in a hobby that helps keep them from developing other interests that could lead to trouble.
Old 01-21-2020, 04:16 PM
  #112  
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Originally Posted by speedracerntrixie View Post
The problem Franklin is that you continually spin the worst case scenario as the norm. Not all kids are interested in sports, in fact with the dwindling education budget, some schools some are dropping sports programs all together. A good parent ( and I have seen my fair share at flying fields ) will support their kids interest in a hobby that helps keep them from developing other interests that could lead to trouble.
And the problem with your perspective is that you just do not see that not everything is a best case either. Parents have to split time among several kids. Parents are not always supporting just one hobby. Parents have their own obligations. Parents have to work. Etc.

I'm not saying there aren't those who drop everything to drive 20 miles one way, each and every weekend. We did a lot more than that with baseball and softball. But I really don't think you're giving my point fair consideration either. The logistics of getting to / from an AMA field is not always trivial. And for many families, that impact choices.

While I don't disagree that you've seen some parents as you've described. But I submit that from a macro standpoint, they're not nearly as common as you seem to believe. For if your examples were the rule, one would not see such a low conversion rate of all those "free" memberships. Is it the logistics of getting to / from? Possibly. Is it that not enough people eat live and breathe toy planes like they did when you were young? Perhaps. Is it the cost of AMA, plus the cost of the club, plus the costs of the hobby itself? Perhaps. But regardless of how much of each is driving the declining membership and poor youth conversion rate, you cannot deny that it's exceedingly low. And that's a problem for the long term survival of the hobby.

Generally speaking if you want people to expend discretionary resources (time, effort, money), you have to make doing the right thing easy. Long drives to a field make it hard. Walking to a park is easy; driving there is even easier. And in doing so you save club fees, gas, time, etc. etc.
Old 01-21-2020, 04:24 PM
  #113  
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Originally Posted by speedracerntrixie View Post
The problem Franklin is that you continually spin the worst case scenario as the norm. Not all kids are interested in sports, in fact with the dwindling education budget, some schools some are dropping sports programs all together. A good parent ( and I have seen my fair share at flying fields ) will support their kids interest in a hobby that helps keep them from developing other interests that could lead to trouble.
I am surprised that with your wealth of experience that you haven't noticed that the VAST MAJORITY of kids are far more interested in drones with cameras, GPS, and FPV with autonomous capabilities, than they are with traditional aircraft. Using most of those technologies will require them to have some sort of position-reporting and a more, "advanced" registration with the FAA anyway..

Astro
Old 01-21-2020, 04:55 PM
  #114  
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Originally Posted by franklin_m View Post
Why the snide comment? (Pentagon tour)
Not "snide", merely descriptive. I've seen similar reasoning come out of that place before. In fact, I don't think I ever met a senior officer who had served there that wasn't profoundly changed by the experience.

"Two-Level Maintenance" was an instance. We've had a study done, said the Pentagon, and we can save money by eliminating all the intermediate maintenance shops. From now on, all malfunctioning subsystem components come straight off the airplane and go back to the Depot that's responsible for them. Replace them with spares. Look at all the money we can save and all the maintainers we can reassign!

"Just a minute, General", says the flight control engineer. You know about the software test issues with the flight control computers. Since the Depot has no airplanes, they sometimes ship them with a bad software load and we don't know it until we put them on an airplane. But we can re-flash memory at the unit level now, so we don't have to send every box all the way back to Ogden, Utah just because it failed preflight BIT. We keep a spare box in the back and swap it for the one in the plane. We re-flash the one out of the plane and it becomes the new spare. These boxes have very reliable HARDWARE - but the software is another story.

"What part of NO did you not understand?", replied the general. Turn in your spare boxes immediately. Get rid of your spare equipment. Your back shop maintainers will be reassigned within two weeks. The Pentagon has decided Two-Level Maintenance is a Good Thing. Get with the program!

Want to guess what happened to the mission capable rate?

And now, Johnny is about to learn his first lessons about Big Government. Franklin is going to make him throw away a perfectly functioning transmitter and receiver, and maybe the airplane too, and replace them with new ones that Johnny neither wanted nor needed. All because The Authority decided it was a Good Thing.
Old 01-21-2020, 05:56 PM
  #115  
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Originally Posted by franklin_m View Post
And the problem with your perspective is that you just do not see that not everything is a best case either. Parents have to split time among several kids. Parents are not always supporting just one hobby. Parents have their own obligations. Parents have to work. Etc.

I'm not saying there aren't those who drop everything to drive 20 miles one way, each and every weekend. We did a lot more than that with baseball and softball. But I really don't think you're giving my point fair consideration either. The logistics of getting to / from an AMA field is not always trivial. And for many families, that impact choices.

While I don't disagree that you've seen some parents as you've described. But I submit that from a macro standpoint, they're not nearly as common as you seem to believe. For if your examples were the rule, one would not see such a low conversion rate of all those "free" memberships. Is it the logistics of getting to / from? Possibly. Is it that not enough people eat live and breathe toy planes like they did when you were young? Perhaps. Is it the cost of AMA, plus the cost of the club, plus the costs of the hobby itself? Perhaps. But regardless of how much of each is driving the declining membership and poor youth conversion rate, you cannot deny that it's exceedingly low. And that's a problem for the long term survival of the hobby.

Generally speaking if you want people to expend discretionary resources (time, effort, money), you have to make doing the right thing easy. Long drives to a field make it hard. Walking to a park is easy; driving there is even easier. And in doing so you save club fees, gas, time, etc. etc.

Well your advise is so much appreciated, I don't know how on earth I managed to raise my 5 kids. Yes it was a busy time, between the wrestling tournaments, scouts meetings/outings, horseback riding lessons, trips to comic-con, trips to Disneyland etc. My wife and I supported the kid's interests and I still found time to enjoy my hobby and have a successful competition record. I get that some parents may not be quite as good at budgeting time as we were. None on my kids took to the hobby, I had hoped at least one would have, for the most part their interests were far more expensive.

You do make one good point, there are very few kids in our sport, far less then what I would like to see. The reality of that fact leads to a question. Why so much time and energy arguing for a practically non existent demographic? And before you go accusing me of not caring about youth in our hobby, watch the video.



Old 01-21-2020, 07:03 PM
  #116  
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Seems to me the FAA wants to put more restrictions on the building and flying of model airplanes than some full scale planes. it is obvious to me the FAA is going overboard with totally unnecessary rules.
Old 01-21-2020, 07:42 PM
  #117  
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Originally Posted by speedracerntrixie View Post
Well your advise is so much appreciated, I don't know how on earth I managed to raise my 5 kids. Yes it was a busy time, between the wrestling tournaments, scouts meetings/outings, horseback riding lessons, trips to comic-con, trips to Disneyland etc. My wife and I supported the kid's interests and I still found time to enjoy my hobby and have a successful competition record.
The discussion wasn't about YOU finding time to enjoy the hobby, it was about little Johnny making it easy for him to enjoy flying by walking to a park rather than relying on Mom and Dad to drive them somewhere. I note that wrestling is weather independent, as are scouts, comic-con, and Disney. Arguably horseback riding depends a bit on weather, but likely not as weather critical as flying toys. So now what happens when weather is good today, and bad tomorrow, but today is scouts day? Now add that you had an advantage that YOU liked flying toys. But say nither Mom nor Dad do, so they're not going to the field anyway. My point is it gets a lot harder when little Johnny can only fly at AMA field, requiring Mom and Dad to drive them. Why not make it easy and support park flyers w/ some relatively small (compared to limited RID) changes?

Originally Posted by speedracerntrixie View Post
None on my kids took to the hobby, I had hoped at least one would have, for the most part their interests were far more expensive.
My kids have lived on air bases, been on aircraft carriers, seen Dad do flybys for a change of command or other ceremony, been in cockpits, in simulators, been dressed in G-suits and torso harnesses, been to see the dunkers and survival training, and even gone flying with me in full scale. And not one of them ever developed an interest in aviation. It's just not the fascination that it was years ago.

Originally Posted by speedracerntrixie View Post
You do make one good point, there are very few kids in our sport, far less then what I would like to see. The reality of that fact leads to a question. Why so much time and energy arguing for a practically non existent demographic? And before you go accusing me of not caring about youth in our hobby, watch the video.
Why? Demographics. AMA is aging out.
Old 01-21-2020, 08:00 PM
  #118  
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Originally Posted by franklin_m View Post
...it was about little Johnny making it easy for him to enjoy flying by walking to a park rather than relying on Mom and Dad to drive them somewhere.
No, it was a contrived argument intended to provide bureaucratic cover for a foregone conclusion.

Little Johnny walking around carrying a model airplane is asking to get mugged in too many cities these days. The gangs will sell it for drug money, or use it as a delivery vehicle. Club fields, OTOH, tend to be in safe locations out of town.
Old 01-21-2020, 08:01 PM
  #119  
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Originally Posted by ira d View Post
Seems to me the FAA wants to put more restrictions on the building and flying of model airplanes than some full scale planes. it is obvious to me the FAA is going overboard with totally unnecessary rules.
This man gets it.

Don't forget the deadline for NPRM comments is March 2.
Old 01-21-2020, 08:15 PM
  #120  
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Let me start off with one thing that we do agree upon. As far as youth is concerned aviation is not magical as it was to you and I. Fond memories of growing up on both Travis and Dyess include a C-130 being rigged with spray equipment spraying for mosquitoes at 75' over base housing, watching the Thunderbirds at Dyess when they were flying F-4s, again at Travis watching the T-38s from our rooftop.


Now back to the usual, I used myself as an example because as just your everyday average Joe, my thoughts on just about anything is " If I can do it so can anyone else ". Getting back to youth in the hobby, sadly they just aren't interested, I don't see anything that will change that. It just does not make sense to create a bunch of regulations focused on such a small demographic, you yourself have made that same comment concerning competition pilots and there are many more competition pilots within the AMA then there are those under 18. The best we can do is when we do have the opportunity to support and mentor a youth in this hobby to not let that opportunity pass us by. Have you done any mentoring lately?


Lastly since it seems that all your proposed regulations seem to be focused on AMA members with a certain level of equipment/proficiency it begs the question of perhaps you are attempting to dumb down the hobby to your level?
Old 01-22-2020, 05:41 AM
  #121  
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Originally Posted by speedracerntrixie View Post
Let me start off with one thing that we do agree upon. As far as youth is concerned aviation is not magical as it was to you and I. Fond memories of growing up on both Travis and Dyess include a C-130 being rigged with spray equipment spraying for mosquitoes at 75' over base housing, watching the Thunderbirds at Dyess when they were flying F-4s, again at Travis watching the T-38s from our rooftop.
I grew up in rural Ohio. No planes nearby. Just born liking them I guess. My kids however grew up living on master jet bases, all carrier based TACAIR, been up in the Tower, in countless hangars, seen me do flybys, etc. etc. Heck, one of the kids' little league opening day parade even got a F/A-18 flyover!

Originally Posted by speedracerntrixie View Post
Now back to the usual, I used myself as an example because as just your everyday average Joe, my thoughts on just about anything is " If I can do it so can anyone else ". Getting back to youth in the hobby, sadly they just aren't interested, I don't see anything that will change that. It just does not make sense to create a bunch of regulations focused on such a small demographic, you yourself have made that same comment concerning competition pilots and there are many more competition pilots within the AMA then there are those under 18.
I'm confused. Per January 2020 Model Aviation Magazine, there are 110,000 paying members. Since AMA repeatedly boasts of 200,000 total members, that means there's 90,000 "youth" members. So are you saying there's more than 90,000 competitive pilots? I find that VERY hard to believe. So please provide the math that supports this statement: "there are many more competition pilots within the AMA then there are those under 18."

As to the regulation themselves. I'll go over it again. If the rule goes forward as written, there will effectively be ONE option for most recreational users who cannot upgrade their equipment to meet Remote ID criteria: join AMA, join a local club, and drive to FRIA to fly - if the club accepts new members and IF the club allows them to fly what they want to fly. My proposal would, in lieu of upgrading to meet limited Remote ID criteria, allow flight in class G, 400 AGL or below, with a spotter and altitude telemetry. By comparison, that's a pretty good trade I think. What it also does is allow Little Johnny (or other adults) to walk to a local park to fly. No need for expensive membership, no need for long drives, etc. Presuming they keep interest in the hobby, one might think local club members would see these individuals in parks as the "farm team" for new members.

Originally Posted by speedracerntrixie View Post
The best we can do is when we do have the opportunity to support and mentor a youth in this hobby to not let that opportunity pass us by. Have you done any mentoring lately?
It's hunting season here, so I'm out in the woods when I'm not working. But as the weather warms, there's an autisic boy that often goes with me to the park when I fly on the weekends.

Originally Posted by speedracerntrixie View Post
Lastly since it seems that all your proposed regulations seem to be focused on AMA members with a certain level of equipment/proficiency it begs the question of perhaps you are attempting to dumb down the hobby to your level?
How is a "dumb down?" My proposal makes it EASIER for people to be engaged in the hobby. Saves travel time. Saves the most expensive (and yet to be developed) equipment upgrades.
Old 01-22-2020, 07:17 AM
  #122  
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I have read the proposal more than a few times now, and something catches me as a bit odd. (well actually a lot of it does)

The part about upgrading existing equipment mentions doing so, and it also mentions not being able to as well. Literally.
Makes one wonder if any RC planes will be up-gradable at all. The single manufacturer thing basically makes mine not up-gradable, depending one how you interrupt it.

All of my RC planes have many manufacturers parts in them, and if one of those manufacturers doesn't get FAA approval they may not be up-gradable to be compliant depending on how you interrupt the proposal. Some of the companies, are no longer in business.

There is one AMA field near me, one. And it isn't a very big one either. There is a lot of public and private land here that no shipping drone will ever fly over. Same goes for State and Federal forest. There are zero low level VOR lanes over them either. So why does the FAA need to control that airspace at all? Simple answer, they don't. There is nothing to deliver there because there is nothing there but nature, and absolutely no reason for the FAA to control it.

On top of that, if you can't even fly most real helicopters there due to oddities like mountains in the way, (altitude issue), terrain, etc. Why does the FAA need to control it at all?

All of that is now being threatened so shipping companies can fly drone where I never could fly anything, rc or manned..
Where no one was allowed to fly, until last October.....

As it stands since October, any Airline Company can fly past your front porch, legally, literally. Even if it is against your state laws....
(UPS was granted an FAA airline company approval for low level heavy shipping/delivery drones)

So now that they gave approval to fly in that airspace, they are just going to take the airspace they didn't control before.
But the FAA already gave airlines permission to use it... Keep that in mind, it is a key point here...

This whole proposal stinks, as I am sure all of us will agree. But what we are not agreeing on is what to do about it.
I have already contacted Fox News about this, and my state representative. I suggest that everyone else do the same ASAP.
We are running out of time, and from what I can see many of the groups that are supposedly going to fight this have not done much, or gotten anywhere.
Old 01-22-2020, 08:25 AM
  #123  
RCUer75345
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Originally Posted by Shrrdavid View Post
Makes one wonder if any RC planes will be up-gradable at all. The single manufacturer thing basically makes mine not up-gradable, depending one how you interrupt it.
They're all upgradable IF someone decides to make components that will make the upgrade possible. But there's a catch. If you do the upgrade, YOU become a "UAS Producer" in the eyes of the FAA. That's UAS - Unmanned Aerial System - not just the airplane. You'll have to prove, to the FAA's satisfaction, that your complete system (including the transmitter), meets all of the Remote ID requirements. Including things like preventing the aircraft from "taking off" (apparently they don't know some of us hand launch) without an Internet connection. You'll have to prove that it does this RELIABLY. And you'll have to prove it's "tamper-proof" -- that you can't just take it out and fly without it when you want to.

It's not at all clear HOW you will prove this, and the FAA makes it clear that this is intended to be beyond the reach of most individuals. You'll need to set up some kind of test lab, perform "system-level tests" and document the results. You'll need to let the AMA come and inspect your facility upon request. You'll need to perform "audits" of all UAS you produce to verify that they continue to meet requirements. You'll need to keep all the resulting paperwork on file for inspection.

And you'll need to issue your UAS a serial number, using a written standard you can't even look at until you pay the organization that issues it something like $313.

And finally -- it's not at all clear whether you can use one transmitter for more than one Remote ID compliant UAS. The transmitter is part of the system. Can it be used for multiple systems? The NPRM doesn't say. Does the act of "binding" a different model require you to repeat all your system-level testing before you can go fly it? The NPRM doesn't say -- but it's best to assume the worst.

Of course, you can ignore all this stuff as long as you build at least 51% of the "system" and fly your UAS at a FRIA, without Remote ID. ARFs don't qualify -- if you merely put pre-finished components together you'll HAVE to put Remote ID in the thing and act as "Producer". Since the 51% thing applies at the SYSTEM level it's also not clear if the FAA expects you to build 51% of your TRANSMITTER.

What can we do about it? Well, at least if we do everything we can to defend FRIAs, we'll have more to play with than if we don't.
Old 01-23-2020, 04:53 PM
  #124  
speedracerntrixie
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Originally Posted by franklin_m View Post
I grew up in rural Ohio. No planes nearby. Just born liking them I guess. My kids however grew up living on master jet bases, all carrier based TACAIR, been up in the Tower, in countless hangars, seen me do flybys, etc. etc. Heck, one of the kids' little league opening day parade even got a F/A-18 flyover!


I'm confused. Per January 2020 Model Aviation Magazine, there are 110,000 paying members. Since AMA repeatedly boasts of 200,000 total members, that means there's 90,000 "youth" members. So are you saying there's more than 90,000 competitive pilots? I find that VERY hard to believe. So please provide the math that supports this statement: "there are many more competition pilots within the AMA then there are those under 18."

As to the regulation themselves. I'll go over it again. If the rule goes forward as written, there will effectively be ONE option for most recreational users who cannot upgrade their equipment to meet Remote ID criteria: join AMA, join a local club, and drive to FRIA to fly - if the club accepts new members and IF the club allows them to fly what they want to fly. My proposal would, in lieu of upgrading to meet limited Remote ID criteria, allow flight in class G, 400 AGL or below, with a spotter and altitude telemetry. By comparison, that's a pretty good trade I think. What it also does is allow Little Johnny (or other adults) to walk to a local park to fly. No need for expensive membership, no need for long drives, etc. Presuming they keep interest in the hobby, one might think local club members would see these individuals in parks as the "farm team" for new members.


It's hunting season here, so I'm out in the woods when I'm not working. But as the weather warms, there's an autisic boy that often goes with me to the park when I fly on the weekends.


How is a "dumb down?" My proposal makes it EASIER for people to be engaged in the hobby. Saves travel time. Saves the most expensive (and yet to be developed) equipment upgrades.



And obsoletes just about all forms of competition and giant scale airplanes. Again, you seem to want everyone to be brought down to your what you consider acceptable eqiopment. Your " look at how many people I have saved $75 " is chump change compared to the millions of dollars of equipment your proposal will obsolete.
Old 01-24-2020, 03:30 AM
  #125  
franklin_m
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Originally Posted by speedracerntrixie View Post
And obsoletes just about all forms of competition and giant scale airplanes. Again, you seem to want everyone to be brought down to your what you consider acceptable eqiopment. Your " look at how many people I have saved $75 " is chump change compared to the millions of dollars of equipment your proposal will obsolete.
Competition and giant scale are a microscopic position of the 1.1 MILLION registrations, in fact they’re small minority of even the AMA’s 200,000 member minority of recreational sUAS operators. To get a policy that opens up BILLIONS in commerce, jobs, and secondary industries, while preserving recreational sUAS for the overwhelming majority of registrants is a pragmatic approach.

I'm thinking of (for >0.55lb):
in class G no higher than 100 feet below class E w/ altitude telemetry and transmitter alarm only, in controlled airspace up to ATO approved limit w/ same telemetry required. FRIAs open to all citizens equally as condition of designation, if insurance “required” then charge amount no greater than amount proportional to that portion of CBO membership dues expensed to insurance (per AMA IRS 990s about 18% or $14), and ALL other money collected from users SHALL be used ONLY on direct expenses in support of a specific FRIA and no greater than the proportion of AMA member dues spent DIRECTLY on FRIAs (right now, about 0.67% of your dues, or about $0.46 out of your $75).

So AMA gets to control the FRIAs, get reimbursed for insurance no greater than what they're spending on insurance from members dues, get money to use FRIAs proportional to what AMA spends directly on FRIAs. This way non-CBO members are paying their "fair share" in exact same proportion to what CBO members are paying to use FRIAs. Non-CBO members are not forced to support competitions, conferences, record attempts, large staff in Muncie supporting all that, plus travel, lobbying, or magazines. If CBO members want that stuff, they can pay for it. All non-members want is ability to use FRIA. They shouldn't be forced to pay a penny more for that than what AMA is DIRECTLY spending on the same for their FRIAs. A small management and administration fee would be allowed, fortunately Federal Acquisition Regulations provide a framework for that, even for contracts with non-profits!

One last piece to figure out, that is fee structure for local clubs that are NOT on public land. Easier if they're 501c3s as they're accountable to non-members via tax filings that ALL money collected is spend directly on maintenance and operation of the FRIA. For groups that are not 501c3, I'll need to figure out how they are accountable for spending all money collected directly on maintenance and operation of the FRIA.

Last edited by franklin_m; 01-24-2020 at 04:34 AM.

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