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FAA says 400 class G is NOT waiverable

Old 07-10-2021, 03:25 PM
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Originally Posted by Hydro Junkie View Post
I didn't intend for my post to be an "AMA bashing" ...
Apologies if I misunderstood your intentions. I too find many of these discussion devolving into strong pro-con AMA rhetoric which is where I get frustrated. I certainly believe that there are things that the AMA needs to improve/fix or they will no longer be around, but I also truly believe that they have done some good things here with regard to the regulatory environment we have been facing. Could they have done better? Maybe, I was not in the room so I don't know. But what I do see are situations where the FAA is cooperating with the hobby in ways that they would not be otherwise compelled to, and the influence for that is coming from somewhere. That was the point I was trying to make.
Old 07-11-2021, 08:11 AM
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I'll comment / respond to some the things above, but won't burden the thread with a bunch of quotes.

In terms of rhetoric, I simply ask: "What IS it going to take for AMA to take ownership of their financial trends and the consequences of decisions they've made these past several years?" Talking politely and offering constructive advice doesn't seem to produce any changes. In fact, I don't think our resident EC members has ever acknowledged the financial trends I've noted in other threads. No acknowledgement that membership revenue trends are strongly down not one or two years, but year after year after year. Not once has he acknowledge that the third highest paid person is the publications director, yet the magazines have lost money for decades. Tens of millions of dollars. And the list goes on. Instead, the ED, President, and EC obfuscate. They talk "increased new member acquisition rate," but it's absent any context. By example, last year might have been ten, and this year was fifteen, so that's a 30% increase. But if they had a net loss of hundreds over that same period, it doesn't matter. That's what I mean by obfuscation. So maybe, let's just see if Andy will even acknowledge the trends have not been good for a decade or more, that revenue is decreasing faster than spending, and the magazines have lost money every year for years.

Again, what WILL it take for them to be open and fully transparent with members about their financial situation? When will they take ownership that nothing they've tried over the last five or ten years has changed these trends?

I note that "the only CBO" has come up again. We were asked not to criticize AMA, its decisions, and financials when they were fighting registration because they were the only CBO. We were asked to wait and the AMA would address these after they got through that. The "fix" never happened. Then we were asked again to refrain while they were fighting to keep 336, and again told the AMA would address these issues after that crisis. And again the "fix" never happened. This refrain repeated with the RemoteID, TRUST, and now the draft AC. Given that we've been told AMA would address these issues multiple times over the past few years, and each time that never happened, sorry if I no longer care that they are "the only CBO." It's long past time they address these issues, or as some have noted, they won't be a CBO much longer.

Lastly, it was asked what I would consider a win. That's a really good question. As you can tell, I do not subscribe to the "less bad than it could have been" school of win/loss. I come from a world where the guy who finishes second doesn't get a trophy, he (or she) gets a coffin. And third place? That's not even "the first loser." AMA has a fiduciary responsibility to its members to remain financially solvent. By any measure, given the trends I've identified, they're rocketing toward a second place finish. If they don't survive financially, it really doesn't matter what policy objectives they achieve. So their number one priority, by a long shot, is finances. And thus, I would define a win as follows (all constant year inflation adjusted dollars):
- Increase membership revenue, year over year, across five straight years; without a dues increase
- In any year where revenue does not increase, decrease spending by a greater amount (total dollars)
- Not liquidate any assets/investments for five straight years (unless reinvested the same year)
- Magazine advertising revenue exceed expenses, year over year, for five straight years

Did I address them all? If not, what did I miss and I'll comment further.

Old 07-11-2021, 09:02 AM
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Originally Posted by franklin_m View Post
Lastly, it was asked what I would consider a win. That's a really good question. As you can tell, I do not subscribe to the "less bad than it could have been" school of win/loss. I come from a world where the guy who finishes second doesn't get a trophy, he (or she) gets a coffin. And third place? That's not even "the first loser." AMA has a fiduciary responsibility to its members to remain financially solvent. By any measure, given the trends I've identified, they're rocketing toward a second place finish. If they don't survive financially, it really doesn't matter what policy objectives they achieve. So their number one priority, by a long shot, is finances. And thus, I would define a win as follows (all constant year inflation adjusted dollars):
- Increase membership revenue, year over year, across five straight years; without a dues increase
- In any year where revenue does not increase, decrease spending by a greater amount (total dollars)
- Not liquidate any assets/investments for five straight years (unless reinvested the same year)
- Magazine advertising revenue exceed expenses, year over year, for five straight years

Did I address them all? If not, what did I miss and I'll comment further.
Actually, my question about this was not at all about the AMA's status. The topic being discussed was about the regulatory environment and my contention that where we have landed (at least as of right now) does not represent "death" for the hobby. Your response to my posting was:

Originally Posted by franklin_m View Post
"If this is a "win," I'd sure hate to see a "loss." Just because it's "less bad" is not a reason for celebration. FAA got everything they wanted in this and more. As they have at every step of the way".


My question back was related to this comment and the regulatory environment, and what "win" would look like there. Unlike combat, politics is much more nuanced game in which wins and losses can be relative and where gains and losses are often incremental. So my question is really what would a win in the regulatory environment look like in your opinion? Again, a win that takes into consideration the realities of the forces and agendas of the legal, social, commercial, and security organizations and entities arrayed against the hobby.

In several posts, you have been clear that you do not think the AMA did enough and that the situation we now find ourselves in could have been better had they done more. What I am trying to understand is what better would look like and how we could possibly get there (or have gotten there)?

Last edited by aymodeler; 07-11-2021 at 11:49 AM.
Old 07-11-2021, 01:33 PM
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Originally Posted by aymodeler View Post
My question back was related to this comment and the regulatory environment, and what "win" would look like there. Unlike combat, politics is much more nuanced game in which wins and losses can be relative and where gains and losses are often incremental. So my question is really what would a win in the regulatory environment look like in your opinion? Again, a win that takes into consideration the realities of the forces and agendas of the legal, social, commercial, and security organizations and entities arrayed against the hobby.

In several posts, you have been clear that you do not think the AMA did enough and that the situation we now find ourselves in could have been better had they done more. What I am trying to understand is what better would look like and how we could possibly get there (or have gotten there)?
The question is not answerable when it includes the caveat: "...that takes into consideration the realities of the forces and agendas of the legal, social, commercial, and security organizations and entities arrayed against the hobby." Why? Because that statement is pretty much heat to light in its spectrum, and can mean different things to different people. What are the limits of the "realities" as you see them for each item in your list? As I'm not aware of any legal forces, save those that result from non-compliance. Nor am I aware of social factors that are specifically allayed against the hobby. The only ones I see that might be at play are commercial and security. I'll grant that commercial entities are looking to monetize the airspace, but if AMA assumed that they'd never face airspace competition, then that was probably the first step on the path that led them to where they are today. With respect to security, why should the hobby be immune from the security changes in a post 9-11 world? The hobby isn't even a Constitutionally enumerated right, and we've seen those impacted .. so why should toy planes be any different?

But moving forward. I think a "win" would have been FAA delegating authority to CBOs. I would have opposed that from the standpoint that regulation of airspace is inherently governmental, but I would have considered it a win. Other wins would have been allowing AMA number in lieu of registration, minor amendments to 336 instead of complete repeal, or no testing for CBO members.

But I maintain that any "win" must include remaining financially viable. For to get no testing for CBO members is worthless if the CBO cannot keep the lights on. Same for other things. I really think that the number one priority for AMA, far above all else, is reversing the financial trends. Policy wins are worthless if you're holding a going out of business sale at Muncie.

Last edited by franklin_m; 07-11-2021 at 01:35 PM.
Old 07-11-2021, 02:27 PM
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Originally Posted by franklin_m View Post
The question is not answerable when it includes the caveat: "...that takes into consideration the realities of the forces and agendas of the legal, social, commercial, and security organizations and entities arrayed against the hobby." Why? Because that statement is pretty much heat to light in its spectrum, and can mean different things to different people. What are the limits of the "realities" as you see them for each item in your list? As I'm not aware of any legal forces, save those that result from non-compliance. Nor am I aware of social factors that are specifically allayed against the hobby. The only ones I see that might be at play are commercial and security. I'll grant that commercial entities are looking to monetize the airspace, but if AMA assumed that they'd never face airspace competition, then that was probably the first step on the path that led them to where they are today. With respect to security, why should the hobby be immune from the security changes in a post 9-11 world? The hobby isn't even a Constitutionally enumerated right, and we've seen those impacted .. so why should toy planes be any different?

But moving forward. I think a "win" would have been FAA delegating authority to CBOs. I would have opposed that from the standpoint that regulation of airspace is inherently governmental, but I would have considered it a win. Other wins would have been allowing AMA number in lieu of registration, minor amendments to 336 instead of complete repeal, or no testing for CBO members.

But I maintain that any "win" must include remaining financially viable. For to get no testing for CBO members is worthless if the CBO cannot keep the lights on. Same for other things. I really think that the number one priority for AMA, far above all else, is reversing the financial trends. Policy wins are worthless if you're holding a going out of business sale at Muncie.
To be clear, what I meant by "legal" was laws that have been enacted related to the hobby (i.e.; USC 44809). What I meant by social, was the prevailing attitudes in social media and other public forms of discourse where there are often negative views related to "drones" invading privacy and/or engaging in reckless behavior, often sensationalized in the media. What I meant by commercial, as I suspect you understood, are those entities seeking to commercialize UAVs and who seem to feel that we are somehow in their way (to be honest, I still do not understand why they feel that way and why they would care, but apparently, they do). Of course, by security, which I also suspect you understood, are government security agencies who are seeking to control all that flies (and walks, runs, swims, or crawls for that matter) and were instrumental un forcing the RID agenda.

I do agree that had we been left with something like a modified version of 336, we would be in better shape, but there were so many aspects of that which were left up to interpretation that there was no way it would stand any longer, especially in light of the "realities" that I mentioned. What we ended up with is actually surprisingly similar to 336 in actual net impact. The rules are mostly the same (RID excepted) except now they are defined in black and white. What about 400' altitude limits which started this thread? Well that was always the FAA's intent, even back in the good old days of the original AC 91-57. It just now carries the weight of law UNLESS you get authorization. Ultimately, most people will be able to carry on with the hobby just like before.

RID is a bit of nuisance, but given that the security types were not going to let go of this one, I doubt that anything could have been done to prevent it (and that was the "limit" I had in mind there).

The knowledge "test" is another examp0le of a legal "limit" as it was written into law. I suspect it got into law because of a) the security types whispering bad things about "drones" to congress and b) constituents complaining to their representatives about renegade "drones", so another set of "limits".

Nowhere above do I reference the AMA and to be honest, I think that it is a good thing as I do not want to be dependent on the AMA explicitly in this area. Having clearly defined regulatory environment protects us from commercial actors, protects from renegade law enforcement types, protects from people who just don't like us doing our thing in their neighborhood (even when we have a right to be there). Even using our AMA number as a registration number with the FAA is potentially problematic as tends to codify the AMA's role in all this.

I think the AMA would have preferred a scenario in which they had ultimately more control too, but I believe that the FAA was never going to let that happen. Partly for the reasons I list above, but moreover because they would never cede authority to a civilian entity not under their control (another "limit" I suppose). But I do believe that the AMA had significant influence in ensuring that what we did end up with was for the most part livable.

Finally, I really don't care about the AMA remaining viable in the long run, because the basic framework that is in place is not dependent on the AMA or any other CBO. Do I want the AMA to use my money more effectively? Of course, but for me, that is totally separate issue. I think this is where you and find ourselves in frequent disagreement. I am compartmentalizing the AMA's financial behavior and do not mix it in with discussion of regulatory issues such as the 400 foot limit. I get that if the AMA implodes, then they are no longer there to advocate for us, but I am also happy that the framework that is in place is not totally dependent on them (or any CBO).

Sorry for the rambling response, I guess I am just a bit tired and didn't take the time to think this response through first
Old 07-12-2021, 06:01 AM
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Originally Posted by aymodeler View Post
To be clear, what I meant by "legal" was laws that have been enacted related to the hobby (i.e.; USC 44809). What I meant by social, was the prevailing attitudes in social media and other public forms of discourse where there are often negative views related to "drones" invading privacy and/or engaging in reckless behavior, often sensationalized in the media. What I meant by commercial, as I suspect you understood, are those entities seeking to commercialize UAVs and who seem to feel that we are somehow in their way (to be honest, I still do not understand why they feel that way and why they would care, but apparently, they do). Of course, by security, which I also suspect you understood, are government security agencies who are seeking to control all that flies (and walks, runs, swims, or crawls for that matter) and were instrumental un forcing the RID agenda.

I do agree that had we been left with something like a modified version of 336, we would be in better shape, but there were so many aspects of that which were left up to interpretation that there was no way it would stand any longer, especially in light of the "realities" that I mentioned. What we ended up with is actually surprisingly similar to 336 in actual net impact. The rules are mostly the same (RID excepted) except now they are defined in black and white. What about 400' altitude limits which started this thread? Well that was always the FAA's intent, even back in the good old days of the original AC 91-57. It just now carries the weight of law UNLESS you get authorization. Ultimately, most people will be able to carry on with the hobby just like before.

RID is a bit of nuisance, but given that the security types were not going to let go of this one, I doubt that anything could have been done to prevent it (and that was the "limit" I had in mind there).

The knowledge "test" is another examp0le of a legal "limit" as it was written into law. I suspect it got into law because of a) the security types whispering bad things about "drones" to congress and b) constituents complaining to their representatives about renegade "drones", so another set of "limits" ...
"What we ended up with is actually surprisingly similar to 336 in actual net impact." Really? I could not disagree more. PL 112-95 Section 336 contained the following explicit restriction on FAA: "...the Administrator of the Federal Aviation Administration may not promulgate any rule or regulation regarding a model aircraft, or an aircraft being developed as a model aircraft, if... (emphasis added)"

That is completely gone with the repeal of 336, and that is HUGE from an authority standpoint. Where 336 cont 115-249 contains no such provision AND allows recreational flight absent 107 certification only if one complies with six conditions. So the regulatory environment went from telling FAA what THEY could NOT do, do to telling all of US what we CAN do. And since repeal of 336, the additional regulations have come quickly: registration was retained, RemoteID added, testing added, explicit operational limits imposed. Yes, the 400 foot thing was always there as an ADVISORY, but now it's there explicitly. I see that as dramatically different.

As for RemoteID and testing being a nuisance, I would note that is the case NOW. Nothing prevents the Administrator from changing one or both to something that may not be a nuisance. Again, that's why the repeal of 336 was such a significant loss.

Another thing to consider is that even the FRIA thing is a Pyrrhic victory. If you read the fine print of the remote ID rule, page 49 of the PDF specifically, nothing requires FAA to designate EVERY CBO field as a FRIA. In fact, it says "Under § 89.215, the Administrator may take into consideration the following matters when reviewing a request for establishment of an FAA-recognized identification area: The effects on existing or contemplated airspace capacity; The effect on critical infrastructure, existing or proposed manmade objects, natural objects, or the existing use of the land, within or close to the FAA-recognized identification area; The safe and efficient use of airspace by other aircraft; The safety and security of persons or property on the ground."

Remember, before 336 was repealed, there was no limit on where one could place a CBO field, save zoning. NOW, the FAA has a list of reasons to consider whether to APPROVE a new field. Again, it went from telling THEM what they could NOT do, now it tells us where we CAN establish FRIAs.

So again, I do not see the current situation as "net effect" the same as when 336 was in place. It's remarkably different for the reason above, for no reason other than we've gone from limits on the FAA to limits on us. And that's without any meaningful limit on FAA regulating further.

Last edited by franklin_m; 07-12-2021 at 06:11 AM.
Old 07-12-2021, 08:52 AM
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Originally Posted by franklin_m View Post
"What we ended up with is actually surprisingly similar to 336 in actual net impact." Really? I could not disagree more ... [omitted for brevity] ...
As I said, I do agree that it would have been better had they not repealed 336, but in my opinion (and I wasn't in the room so I must qualify it as an "un-informed" opinion) that was never going to happen due to the "realities" I referenced earlier. There were just too many actors and too many agendas to allow this to stand. Where we ended up is with a legal/regulatory framework that does allow us to exist despite these other actors and agendas. Oh and despite the requirement not to promulgate new rules, if you recall, the FAA immediately produced an "interpretation" of the 336 based on their authority to regulate the NAS, which 336 did nothing to "revoke".

And you are right, that the FAA or Congress can change the rules to the game at any time. That was the case before, that is the case now, and that will be the case in the future. Obviously, the rules just changed and nothing will ever stop that from potentially happening again. But because we now have a legal framework, it will be harder to arbitrarily change rules without specific cause (note I said harder, not impossible).

Finally, I am extremely encouraged by actions the FAA has taken to find solutions in all of this that allows the hobby to continue within the context of these rules and the external "realities". And that is what I mean when I say the net effect is that not much will change from the perspective of the average RC model aircraft enthusiast. Most of will still be able to build and fly our planes with minimal interference from the outside parties.
Old 07-12-2021, 12:53 PM
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Originally Posted by aymodeler View Post
As I said, I do agree that it would have been better had they not repealed 336, but in my opinion (and I wasn't in the room so I must qualify it as an "un-informed" opinion) that was never going to happen due to the "realities" I referenced earlier. There were just too many actors and too many agendas to allow this to stand. Where we ended up is with a legal/regulatory framework that does allow us to exist despite these other actors and agendas. Oh and despite the requirement not to promulgate new rules, if you recall, the FAA immediately produced an "interpretation" of the 336 based on their authority to regulate the NAS, which 336 did nothing to "revoke".

And you are right, that the FAA or Congress can change the rules to the game at any time. That was the case before, that is the case now, and that will be the case in the future. Obviously, the rules just changed and nothing will ever stop that from potentially happening again. But because we now have a legal framework, it will be harder to arbitrarily change rules without specific cause (note I said harder, not impossible).

Finally, I am extremely encouraged by actions the FAA has taken to find solutions in all of this that allows the hobby to continue within the context of these rules and the external "realities". And that is what I mean when I say the net effect is that not much will change from the perspective of the average RC model aircraft enthusiast. Most of will still be able to build and fly our planes with minimal interference from the outside parties.
I do not view publishing interpretations as a rule. A rule, as used in the context of legislation or FARs has specific meaning. Also, AMA was in the process of challenging that interpretation in court. Now, one can challenge rules too, but challenging an interpretation is easier IMO.

Before: no test / After: testing required
Before: no statutory operational limits / After: statutory operational limits
Before: FAA prohibited from writing rules* on MA / After: No prohibition
Before: No RemoteID / After: RemoteID unless at FRIA
Before: Club field just about anywhere / After: FRIAs only where approved by FAA
Before: Prosecuting violator relied on "should have known" / After: FAA can prove you knew (the rules)

So I guess we have a much different definition of "minimal impact." I see required testing, statutory operational limits, no statutory prohibition on new rules, RemoteID, and FRIAs only where approved by FAA as something other than "minimal impact." I also disagree that this legal framework in place now does anything to preclude FAA from writing more rules or makes them more difficult to challenge. Nothing has changed in that regard. Actually, once a rule is in place I'd argue its actually easier to incrementally change it. If that's indeed true, it's actually easier now. If for no other reason than the FAA can point to the existing rule and say "That didn't work, so we need to tighten things up a bit more."

It remains to be seen whether AMA will demand a much greater level of compliance from members. If I were king for a day, I'd make insurance coverage for individuals and clubs conditioned on compliance. Some will argue we don't do that for motor vehicles. True, but then again there's standardized testing of drivers and a much more robust legal framework.
Old 07-12-2021, 02:57 PM
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Yes, there are bad things that can happen if they want to bring the hammer down on us, but that has always been the case. Lets discuss the material things that have actually changed:

1) We have to take a "test". You have taken this "test" and you know that it was more of an instructional slideshow than a true knowledge test. Was it a bit of an annoyance, sure it was 20 whole minutes of my life that I will never get back. In terms of an impact, I rate it as nll.

2) Statutory limits on altitude. I agree that this one is very painful for certain segments of the hobby. It was always the FAA's intent that model aircraft be limited to 400 feet. Had we remained a small niche group of enthusiasts, we probably could have remained under the radar. But given the realities we have discussed earlier, this was just no longer possible. So chalk one up to for the FAA here. BUT truthfully, most of never fly above 400 feet anyway (your plane starts to get pretty small at that distance) so what impact is it to most of us really?

3) FAA was prohibited from writing rules for model aircraft, but were not prohibited from writing rules that enforced airspace safety. That was clearly spelled out in 336. They were able to promulgate any rule they wanted in that guise and did so successfully with the notion of registration AFTER 336. So maybe they couldn't tell us that we need to paint our plains pink with yellow polka-dots, but with regard to operations in the NAS, they had the ability before and they still have the ability now. Nothing has changed. I would go so far as to say that 336 forced the FAA's hand to seek explicit clarity that they were in fact so authorized.

4) I called out Remote ID as something that is materially different and in that we agree. But what is the impact? In it's current form, it is minimal. I suspect that when license plates were first issued there was a lot of backlash too, but do you ever even think about the fact there is a license plat on your car? Of course, this could change, but it could have changed before and it will always be subject to change in the future. I rate this as an annoyance at best.

5) The FAA has the ability to not accept a location as a FRIA, well that does not prevent you from having a club at that location, you just need a broadcast module. And club fields could never be just about anywhere. There were always zoning and other issues related to neighborhood noise restrictions, proximity to populated areas and or airports, etc, etc. We do not yet know what the criteria for FRIAs are, but my suspicion is that location that are likely to be denied are already locations that were already problematic for clubs anyway. In the worst case, you need to use a broadcast module if your club cannot get FRIA status.

6) As you know, I do not think that passing the "test" subjects us to any more legal liability than before (as discussed in a previous thread). This is unprovable either way, so we will need to agree to disagree on this one.

Overall, most of us will be able to go about our business and enjoy the hobby more or less just like we did earlier. As in my original posting, the biggest impact to most of us is RID. Yes there are some who are severely impacted by the 400 foot rule, but based on the draft of AC 91-57C I remain hopeful that there will be at least some accommodation there as well.

A lot of what you seem to be concerned about is what the FAA might be able to do in the future. The truth is, that has been the case for as long as there has been an FAA.

Basically, what I am saying is that I refuse to buy into the sky is falling mindset. Maybe this wasn't a total "win", but is far, far, from a total loss for the hobby, and I choose to be optimistic that I will be able to enjoy the hobby for many years to come.

Last edited by aymodeler; 07-12-2021 at 03:00 PM.
Old 07-12-2021, 04:44 PM
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Originally Posted by aymodeler View Post
Basically, what I am saying is that I refuse to buy into the sky is falling mindset. Maybe this wasn't a total "win", but is far, far, from a total loss for the hobby, and I choose to be optimistic that I will be able to enjoy the hobby for many years to come.
Nobody is really saying the sky is falling. It is my take that NONE of the changes brought on to us were necessary and that our AMA let us down by not advocating for us and maintaining our status quo.

My stance is that, realistically, none of the new regulations we must abide by do a single thing to make the NAS a safer place. They were completely unnecessary for us, yet the AMA could not convince the FAA of that DESPITE our 80 year track record of almost zero incidents with full scale operations in the NAS. It really doesn't leave me feeling all that rosy toward the AMA, yet I feel compelled to join because of the affiliation they have with the vast majority of flying sites across the country.

Regards,

Astro
Old 07-12-2021, 04:57 PM
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We could go on like this indefinitely, with neither one of us convincing the other. My contention, since the beginning of this conversation, is that I will be able to enjoy the hobby more or less like I always have, with minimal interference. I understand that you would prefer total victory where we would be able to operate with no real regulation at all, but I never believed that would be possible given those pesky realities that I referenced earlier. I also understand that for some, this is a game changer, and that is truly unfortunate, but most of us will be able to carry on doing what we have always done. Given those realities again, I consider this a win, but that is just my opinion.

Oh and yes, there is noting that prevents this from getting worse in the future, but that has always been the case. And who knows, maybe it will get even better!
Old 07-12-2021, 09:18 PM
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Franklin:
So now you have reduced the discussion to the level that you always intended. It is never about model aviation, that is only your pathway to attacking AMA.

So lets take this back to where you started this thread, if you are such a model of the perfect person following the law to the letter, lets see how you really fit the law. I will make the same effort you have made and contact the Pennsylvania State Police and the local Police in State College. Instructions to follow you everywhere and make a citation every time you exceed the posted speed limit by 1mph or more.
Old 07-13-2021, 04:00 AM
  #38  
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Originally Posted by paulsf86 View Post
Franklin:
So now you have reduced the discussion to the level that you always intended. It is never about model aviation, that is only your pathway to attacking AMA.

So lets take this back to where you started this thread, if you are such a model of the perfect person following the law to the letter, lets see how you really fit the law. I will make the same effort you have made and contact the Pennsylvania State Police and the local Police in State College. Instructions to follow you everywhere and make a citation every time you exceed the posted speed limit by 1mph or more.
Getting a little personal, don't you think?

I don't think Franklin ever claimed to be a perfect human being, not to mention, he has kept his posts very professional and civil, just because his facts hurt your feelings, you want to try and call him out personally?

We are talking about toy airplanes, going after one personally for their opinions is a little creepy........just sayin'

Astro
Old 07-13-2021, 08:43 AM
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Great conversation, thank you.

Originally Posted by astrohog View Post
...the AMA could not convince the FAA of that DESPITE our 80 year track record of almost zero incidents with full scale operations in the NAS.
I'll put my two cents in on Astro's comments above: I think the situation has changed. The 80-year track record is no longer valid - thanks to drones and FPV.

Drones and FPV have significantly expanded the capabilities of r/c aircraft. LAX sees 400-1200 drone incursions every month. A FAA drone education person (I forget his exact title) recently gave a talk at our club. He mentioned a small airliner (Cessna 402-esque) came across a drone at 6,000 ft.

I am not saying the new regulations are good or bad - but I am not surprised by the increased regulation.

(The argument that drones should be classified different to non-FPV airplanes is a separate - and very relevant - discussion!)
Old 07-13-2021, 10:07 AM
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The FAA gets about 100 reports a month. Nationwide. Not sure where you got that number from.
Old 07-13-2021, 10:22 AM
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PopeyeCharlotte
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Originally Posted by BarracudaHockey View Post
The FAA gets about 100 reports a month. Nationwide. Not sure where you got that number from.
Wall Street Journal, 20 May 2021. https://www.wsj.com/articles/drones-...on-11621533604

My point being, the capability of FPV airplanes and drones today is not the same as it was over the past 80 years. Even 100 reports (of what?) a month is enough to prompt legislative action.
Old 07-14-2021, 02:40 AM
  #42  
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Originally Posted by paulsf86 View Post
Franklin:
So now you have reduced the discussion to the level that you always intended. It is never about model aviation, that is only your pathway to attacking AMA.

So lets take this back to where you started this thread, if you are such a model of the perfect person following the law to the letter, lets see how you really fit the law. I will make the same effort you have made and contact the Pennsylvania State Police and the local Police in State College. Instructions to follow you everywhere and make a citation every time you exceed the posted speed limit by 1mph or more.
California has some of the most progressive laws on doxing and swatting in the nation. I urge caution. But go ahead if you like. For unlike some communities in the toy plane flyers, I don't see following the rules as all that difficult (even if I don't like them).

What this illustrates though is how emotional this issue is to some. You fly toys, and look at how you're acting when someone has legitimate policy differences. Sorry your feelings got hurt. What's so onerous about following the rules?

Last edited by franklin_m; 07-14-2021 at 03:28 AM.
Old 07-14-2021, 02:48 AM
  #43  
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Originally Posted by PopeyeCharlotte View Post
I'll put my two cents in on Astro's comments above: I think the situation has changed. The 80-year track record is no longer valid - thanks to drones and FPV.
I would argue the vast majority of that 80 year record, easily 3/4 of it, is based on toy planes that were much simpler, non-turbine powered, no flight augmentation, etc. Not much more sophisticated than 6 channel glow powered single engine, maybe a few multis here or there. To say that because those comparatively simple toy planes WERE safe means that much more complex toys WILL be safe - is a logical fallacy.

Keep in mind, we have individuals talking about the need to build Faraday cages inside their turbine powered toy planes to prevent EMI from turbine control units from introducing false signals into the flight controls. Now add stabilization units and other equipment and you have a level of complexity that is considerably higher. With a lot more single points of failure.
Old 07-14-2021, 05:02 AM
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I was, of course, talking about flying LOS. It is extremely safe and easy to see and avoid full-scale aircraft while flying LOS with our models, regardless of model complexity and speed (assuming under 200 MPH).

Your mention of the logical fallacy above implied that more complex models are inherently more dangerous than simple models is, in itself, a logical fallacy as well.

Astro
Old 07-14-2021, 07:03 AM
  #45  
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Originally Posted by astrohog View Post
I was, of course, talking about flying LOS. It is extremely safe and easy to see and avoid full-scale aircraft while flying LOS with our models, regardless of model complexity and speed (assuming under 200 MPH).

Your mention of the logical fallacy above implied that more complex models are inherently more dangerous than simple models is, in itself, a logical fallacy as well.

Astro
Not sure I follow the second paragraph. I assume this is in response to my comment, reiterated by Franklin, that models today are more complex than they were for the past 80 years?

I agree with the comment that keeping LOS model aircraft safe and far from full scale aircraft is easy.

My point is that, only recently do we have the capability to fly a drone to thousands of feet altitude in a controllable manner. Only recently do we have high quality FPV systems that allow flight much further away from the pilot. These capabilities can be - and have been - used for malicious intent. Unfortunately, given the FAA and the AMA do not separate LOS airplanes, regulation is inevitable.
Old 07-14-2021, 11:33 AM
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Originally Posted by PopeyeCharlotte View Post
Not sure I follow the second paragraph. I assume this is in response to my comment, reiterated by Franklin, that models today are more complex than they were for the past 80 years?

I agree with the comment that keeping LOS model aircraft safe and far from full scale aircraft is easy.

My point is that, only recently do we have the capability to fly a drone to thousands of feet altitude in a controllable manner. Only recently do we have high quality FPV systems that allow flight much further away from the pilot. These capabilities can be - and have been - used for malicious intent. Unfortunately, given the FAA and the AMA do not separate LOS airplanes, regulation is inevitable.
If you’ve read my posts here over a period of time, you’d know that my main contention with the AMA is that they didn’t create the obvious distinction between LOS models and those capable of BLOVS ops. from the very beginning. You know, when it became obvious to any modeler that “drones” were being, and had the capability of, being operated in such a manner that they needed their own classification and rules.

Astro
Old 07-14-2021, 11:42 AM
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Originally Posted by astrohog View Post
If you’ve read my posts here over a period of time, …

Astro
Understood and agree. I’m still pretty new here, so I’m not familiar with many of your previous posts. Thanks for the clarification.
Old 07-14-2021, 11:45 AM
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The AMA has always represented VLOS, BLOS is not part of our coverage or mission.
Old 07-14-2021, 12:25 PM
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Originally Posted by BarracudaHockey View Post
The AMA has always represented VLOS, BLOS is not part of our coverage or mission.
Yet we are all lumped and regulated together…..
Old 07-14-2021, 12:45 PM
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Originally Posted by astrohog View Post
I was, of course, talking about flying LOS. It is extremely safe and easy to see and avoid full-scale aircraft while flying LOS with our models, regardless of model complexity and speed (assuming under 200 MPH).

Your mention of the logical fallacy above implied that more complex models are inherently more dangerous than simple models is, in itself, a logical fallacy as well.

Astro
Not questioning the see and avoid, depending of course on good lookout doctrine, good visual acuity, etc. Reality is, if someone is flying a high speed expensive sUAS, they're probably watching it and not the airspace all around them. That's where spotters come in. But most of the spotter video I've seen shows both of them watching the same model, which means neither is really scanning the sky in all directions.

With respect to complexity, my comment was a simple thought experiment.

Scenario 1. Say you have a four channel sUAS, and there's maybe 12 single points of failure in electronics: Battery, battery connector, switch, receiver, four servos, and four servo connectors. Say each of them has reliability less than one (i.e. imperfect, so some degree or another). You now can calculate a reliability figure of merit.

Scenario 2. Now say you look at more modern sUAS with multiple batteries, multiple battery connectors, one or more switches, a power distro box, 10-12 servos, 10-12 servo connectors, fuel control, and some stabilizer unit. Now you've got some number of single points of failure greater than the simple example. We can argue that some of the individual components are more reliable, but I don't think it's unreasonable to say the reliability of the entire system may well be lower. And worse yet, some of the failure modes are latent and may not be known until after a crash. NASA found that out the hard way - not once but twice. Not an exact quote, but one of the mishap investigation senior members famously said: "Complex systems fail in complex ways."

That was the basis for my comment.

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