For your NPRM Response...s.
01-24-2020, 06:55 AM
#126
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The remote identification framework would provide UAS-specific data, which could be used in tandem with new technologies and infrastructure to facilitate future, more advanced operational capabilities (such as detect-and-avoid and aircraft-to-aircraft communications that support beyond visual line of sight operations) and to develop the necessary elements for comprehensive UAS traffic management (UTM).
Maybe the FAA would buy this if only applied up to a certain weight limit, say 2kg? And only if the models were flown at certain known locations. Not club fields, but suitable open spaces such as city parks? This could be used to establish a SECOND CATEGORY of PUBLIC FRIAs, where Remote ID will not be necessary because commercial unmanned traffic could avoid them? Call them "CAT B FRIA" or something.
01-24-2020, 07:43 AM
#127
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The remote identification framework would provide UAS-specific data, which could be used in tandem with new technologies and infrastructure to facilitate future, more advanced operational capabilities (such as detect-and-avoid and aircraft-to-aircraft communications that support beyond visual line of sight operations) and to develop the necessary elements for comprehensive UAS traffic management (UTM).
I suspect FAA is no fan of AMA. Any number of AMA EC's own comments indicate such, so anything that provides reasonable and defensible alternatives to AMA's proposed FRIA idea would likely fall on welcome ears. There's specific talking point phrases I think the FAA seeks in comments, and I intend to try and provide them.
But you clearly feel differently. Feel free to advocate why FAA should force 800,000 non-CBO members to join a PRIVATE organization ( "forced association" under the law ) in order to enjoy a privilege in the public airspace, feel free.
And while you're at it, perhaps you could propose something that would be analogous for manned aircraft, namely require membership in AOPA to operate from all but a minority of airports across the country. I suspect putting it in those terms will surely garner the FAA's support and convince them that forcing membership in AMA is a good move.
01-24-2020, 07:51 AM
#128
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FAA is pragmatic, if they can get 90% of what they want: collision avoidance (through lower altitudes, telemetry, and required response to alarms) to buy time for producers to develop add on equipment that achieve RemoteID strategy; or FRIAs that eventually go away all together in favor of RemoteID strategy; and avoid putting the FAA in the legally tenuous positon of a rule requiring membership in a PRIVATE dues collecting organization to access PUBLIC airspace; I think they'll go for it.
If you have different information...
01-24-2020, 12:04 PM
#129
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I believe that it is technically impossible to use the current form of altitude encoding telemetry for collision avoidance purposes. The signal is so weak that the collision would be over before an avoidance maneuver could be initiated.
If you have different information...
If you have different information...
01-24-2020, 02:07 PM
#130
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I said 90% of what FAA wants. The altitude info, combined with an operational limit, ensures the operator knows how high they're flying and then will be warned (and expected to take action in response to that warning) .... keeping them below the 400 / LAANC much more reliably.
So this isn't even 10% of "what the FAA wants".
01-24-2020, 03:20 PM
#131
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.
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.
So out of that 1.1 million you know exactly how many of those are competitive pilots? I'd love to see those numbers. And while we are at it let's take a look at some of the people that will be hit the hardest without FRIA sites. Keep in mind that this is just a very small fraction of the money that will be lost when you make these airplanes obsolete.
Average cost of each pattern airplane is $7,000
Other end of the flight line
Average cost of each sailplane $4,000
01-24-2020, 03:36 PM
#132
I am pretty sure the FAA could care less that a few folks have thou$ands tied up in their toy airplanes. If it is any consolation, they can still hang them on the ceiling and enjoy them that way (except for the pattern planes, they are fugly!).
Astro
01-24-2020, 06:22 PM
#133
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Actually the FAA was required to consider "loss of use" in their cost estimate for the proposed rule. I don't have the patience to look right now, but I believe they based their estimates on two cheap drones per user. Maybe if they'd bothered to gather more relevant information they'd have reached different conclusions?
It might interest you to know that career Federal employees at the GS-14 level and above are required to file annual financial disclosure statements, and divest themselves of any financial interest that might cause the appearance of conflict of interest. That means senior level FAA people working this issue would have had to sell their stock in drone or model airplane companies (diversified mutual funds excepted), and maybe had to sell any drones or planes they personally owned. That virtually guarantees that people approving the NPRM language (if not lower-level writers) were unfamiliar with the subject matter they were regulating.
It might interest you to know that career Federal employees at the GS-14 level and above are required to file annual financial disclosure statements, and divest themselves of any financial interest that might cause the appearance of conflict of interest. That means senior level FAA people working this issue would have had to sell their stock in drone or model airplane companies (diversified mutual funds excepted), and maybe had to sell any drones or planes they personally owned. That virtually guarantees that people approving the NPRM language (if not lower-level writers) were unfamiliar with the subject matter they were regulating.
01-24-2020, 07:07 PM
#135
Actually the FAA was required to consider "loss of use" in their cost estimate for the proposed rule. I don't have the patience to look right now, but I believe they based their estimates on two cheap drones per user. Maybe if they'd bothered to gather more relevant information they'd have reached different conclusions?
Astro
01-24-2020, 07:25 PM
#136
It's too bad we don't have numbers on that, I think you would be surprised. It's not unusual for some guys regardless of if they fly jets, giant scale, sailplanes or pattern to have $15,000 to $25,000 invested. Doing the math and splitting the difference it only takes about 100 guys to reach $1M. 1,000 guys which is perfectly plausible hits the $100M mark. Not exactly small potatoes.
01-24-2020, 07:42 PM
#137
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Good thing my wife doesn't read the forum...
01-24-2020, 09:10 PM
#138
And then you divide that by 1,000,000 (approx. total numbers of modelers, AMA members + FAA registered non-members) and you get.....drum roll........small potatoes! ($100.00/ea.)
The FAA wouldn't consider an average burden of $100 as extreme, and they certainly won't single out the 1,000 people that may have a somewhat significant amount invested and change the rule for them, just doesn't work that way.
Astro
The FAA wouldn't consider an average burden of $100 as extreme, and they certainly won't single out the 1,000 people that may have a somewhat significant amount invested and change the rule for them, just doesn't work that way.
Astro
01-25-2020, 07:04 AM
#139
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And then you divide that by 1,000,000 (approx. total numbers of modelers, AMA members + FAA registered non-members) and you get.....drum roll........small potatoes! ($100.00/ea.)
The FAA wouldn't consider an average burden of $100 as extreme, and they certainly won't single out the 1,000 people that may have a somewhat significant amount invested and change the rule for them, just doesn't work that way.
Astro
The FAA wouldn't consider an average burden of $100 as extreme, and they certainly won't single out the 1,000 people that may have a somewhat significant amount invested and change the rule for them, just doesn't work that way.
Astro
01-25-2020, 09:33 AM
#141
Tiny flaw with your math in that you assumed 999,900 guys with NOTHING invested. Even the FAA assumed $100 - $200 "loss of use" for those whose equipment could not be modified and would not have FRIA access. Take away FRIAs and both the affected numbers and the costs go up astronomically. Maybe there are only 100 guys over $10000, but the next 1000 might be $5000 - $10000, the next 10,000 might be $2000 - $5000, and so on.
But you are right. You always are, never mind the facts! LOL
Astro
01-25-2020, 11:06 AM
#144
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There are no "average" users. An average is simply a mathematical yardstick. Let's say you calculate the "average burden" as $500. Now go find me all the guys who have exactly that much, plus or minus $20, invested in their UAS. I'll bet the number will be very small.
And they absolutely should account for even a small number of users who will be hit especially hard.
Last edited by RCUer75345; 01-25-2020 at 11:24 AM.
01-25-2020, 11:42 AM
#145
I can think of one very small group (3.5% ) that has been getting all sorts of legal accomidations/protections in the last 20 years.
https://williamsinstitute.law.ucla.e...eople-are-gay/
https://williamsinstitute.law.ucla.e...eople-are-gay/
01-25-2020, 11:47 AM
#146
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If one believes that FAA is or should be concerned about a one time shelving of a couple million in equipment, then one must also believe they will be MORE concerned about $60 million or more (if add club fees) EVERY YEAR as a result of forced CBO membership by folks who are currently not members!
01-25-2020, 11:59 AM
#147
Originally Posted by grognard
There are no "average" users. An average is simply a mathematical yardstick. Let's say you calculate the "average burden" as $500. Now go find me all the guys who have exactly that much, plus or minus $20, invested in their UAS. I'll bet the number will be very small.
Originally Posted by grognard
And they absolutely should account for even a small number of users who will be hit especially hard.
Astro
01-25-2020, 12:05 PM
#148
I can think of one very small group (3.5% ) that has been getting all sorts of legal accomidations/protections in the last 20 years.
https://williamsinstitute.law.ucla.e...eople-are-gay/
https://williamsinstitute.law.ucla.e...eople-are-gay/
Astro
01-25-2020, 12:15 PM
#149
It was more in reference to out of the bloated 1M regestered users, there are more then 3.5% of the 1M that stand to lose >$10,000 in investments. However I fully understand that your default setting is " prove Speedy wrong ". Too bad, this whole mess IMO has been created by closed minds, sad to see you in that category.
01-25-2020, 12:24 PM
#150
It was more in reference to out of the bloated 1M regestered users, there are more then 3.5% of the 1M that stand to lose >$10,000 in investments. However I fully understand that your default setting is " prove Speedy wrong ". Too bad, this whole mess IMO has been created by closed minds, sad to see you in that category.
Astro