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FAA says 400 class G is NOT waiverable

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FAA says 400 class G is NOT waiverable

Old 07-14-2021, 12:46 PM
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franklin_m
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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.
So Andy. As esteemed EC member. Care to acknowledge whether or not the financial trends I've shown in other threads are substantially correct? That they've been relatively unchanged (in trajectory) for over a decade?
Old 07-14-2021, 01:01 PM
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Originally Posted by franklin_m View Post
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.
I understand where you were coming from, but as you mentioned, both sides can be argued, and until that debate is hammered out with specifics, it is just that, a debate. I know my giant scale, gas-powered airplanes, there are more potential points of failure than on a simpler craft, but we also have built-in redundancy to account for failures, hence the statement I made in response to your original statement. Your original statement regarding complex craft was just as arbitrary as saying that because we've been safe for 80 years, we will continue with the same rates of instances.

Astro
Old 07-15-2021, 01:31 PM
  #53  
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In addition to the number of failure points is the consequence of a failure.

A failure in an LOS airplane at a typical r/c field will result in a crash on the field. There are typically specific "fly" and "no-fly" zones (keep within a certain perimeter, don't fly over the pits, etc.). A crash results in broken balsa, a bruised ego, perhaps some damage to vegetation, but typically no more.

A drone flying at 5,000 foot, or FPV well beyond the launch point, the collateral damage potential is greater.
Old 07-15-2021, 01:49 PM
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Originally Posted by PopeyeCharlotte View Post
In addition to the number of failure points is the consequence of a failure.

A failure in an LOS airplane at a typical r/c field will result in a crash on the field. There are typically specific "fly" and "no-fly" zones (keep within a certain perimeter, don't fly over the pits, etc.). A crash results in broken balsa, a bruised ego, perhaps some damage to vegetation, but typically no more.

A drone flying at 5,000 foot, or FPV well beyond the launch point, the collateral damage potential is greater.
In those cases where the sUAS crashes on land under exclusive control of the club, do not disagree. But that is not always the case. For example, right now the Kentucky Jets event is flying in a defined box that includes overflight of public roads and property not owned by the airport. Similarly, the club shut down in SE Pennsylvania was after years of club members crashing planes on their property and overlying people, equipment, and property. So I don't think we can universally assume that such failures will not result in crashes on private property, some of which put people and property at risk. I am of the belief that with establishment of FRIAs will bring unwanted attention to the club fields, specifically by those who own adjacent property, and especially any neighbors that do not enjoy the overflights.

Full scale airports routinely find themselves in court defending traffic patterns, and all too often despite the airfields pre-dating the homes by decades ... the patterns and ops are changed by court order. Now that the case in Pennsylvania is recorded, that means it can and will be searched by lawyers in and outside Pennsylvania looking for ways to shut down clubs. It's kind of a slow simmer issue, but I think it was awful that AMA let that reach the courts. Yes, the property owners were ultimately the ones defending the use, but it was the activities of the club that put them at risk.

But time will tell. I believe that FliteTest represents a serious challenge to AMA. Not for ALL members, as LMAs, FW turbine, sailplanes, and other small groups will always NEED the FRIA. However, they are a small minority compared to the FliteTest crowd who largely don't need above 400 feet and can pretty much fly anywhere. So the question will be can AMA survive in its current form on just those that truly NEED the FRIA fields?
Old 07-15-2021, 02:51 PM
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[QUOTE=franklin_m;12686121But time will tell. I believe that FliteTest represents a serious challenge to AMA. Not for ALL members, as LMAs, FW turbine, sailplanes, and other small groups will always NEED the FRIA. However, they are a small minority compared to the FliteTest crowd who largely don't need above 400 feet and can pretty much fly anywhere. So the question will be can AMA survive in its current form on just those that truly NEED the FRIA fields?[/QUOTE]

That has been exactly my contention for quite some time now. So I guess we can agree on at least one thing!
Old 07-16-2021, 10:43 AM
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Originally Posted by franklin_m View Post
I believe that FliteTest represents a serious challenge to AMA. Not for ALL members, as LMAs, FW turbine, sailplanes, and other small groups will always NEED the FRIA. However, they are a small minority compared to the FliteTest crowd who largely don't need above 400 feet and can pretty much fly anywhere. So the question will be can AMA survive in its current form on just those that truly NEED the FRIA fields?
Originally Posted by aymodeler View Post
That has been exactly my contention for quite some time now. So I guess we can agree on at least one thing!
My view is that AMA made a fundamental and irrecoverable error many years ago when they decided to take a hands off attidue toward compliance by members. Instead of being the ones seen as doing things right, and can prove it; they contend they're the ones doing it right - because they say they are.

For almost ten years I worked at a location in an industry heavily regulated by DOT, Interior, EPA, and OSHA at the Federal level, and by similar agencies at the state level. There were two major companies working in the same area, I supported one of them. Each took dramatically different approaches to compliance with the aforementioned regulatory agencies. One chose to follow the rules and check themselves to ensure they were following the rules (culture of compliance) and the other chose the approach of writing rules, but not really checking to see if indeed they were doing as they said. In the culture of compliance organization, when they found something out of compliance, they reported themselves to the appropriate agency along with their actions in response.

I'll give you one guess which company enjoyed much more favorable interactions with all of the regulatory agencies? Yep. The compliance culture. And why? Simple really. The government agencies did not expect anyone to be perfect, but concerns were greatly eased when they knew the company was checking themselves. And because they were checking themselves, the compliance culture company had decades of records to point to showing that they took substantial efforts to not just comply with the letter of the law, but the spirit and intent as well.

But AMA chose to be hands off. And other aviation stakeholders, as well as legislators, regulators, media, and the public are rightfully skeptical. One doesn't have to look to far to see examples of reckless behavior. But because AMA did not step in with a firm hand years ago, and enforce the culture these other groups want to see, now they cannot point to any pattern of conduct by them that shows they hold members accountable.
Old 07-16-2021, 12:14 PM
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Originally Posted by franklin_m View Post
My view is that AMA made a fundamental and irrecoverable error many years ago when they decided to take a hands off attidue toward compliance by members. Instead of being the ones seen as doing things right, and can prove it; they contend they're the ones doing it right - because they say they are.

For almost ten years I worked at a location in an industry heavily regulated by DOT, Interior, EPA, and OSHA at the Federal level, and by similar agencies at the state level. There were two major companies working in the same area, I supported one of them. Each took dramatically different approaches to compliance with the aforementioned regulatory agencies. One chose to follow the rules and check themselves to ensure they were following the rules (culture of compliance) and the other chose the approach of writing rules, but not really checking to see if indeed they were doing as they said. In the culture of compliance organization, when they found something out of compliance, they reported themselves to the appropriate agency along with their actions in response.

I'll give you one guess which company enjoyed much more favorable interactions with all of the regulatory agencies? Yep. The compliance culture. And why? Simple really. The government agencies did not expect anyone to be perfect, but concerns were greatly eased when they knew the company was checking themselves. And because they were checking themselves, the compliance culture company had decades of records to point to showing that they took substantial efforts to not just comply with the letter of the law, but the spirit and intent as well.

But AMA chose to be hands off. And other aviation stakeholders, as well as legislators, regulators, media, and the public are rightfully skeptical. One doesn't have to look to far to see examples of reckless behavior. But because AMA did not step in with a firm hand years ago, and enforce the culture these other groups want to see, now they cannot point to any pattern of conduct by them that shows they hold members accountable.
I'm not sure a "compliance culture" would help much with the AMA's demographic problem though, which in my opinion, is their bigger issue. And FliteTest could never be help up as a shining example of a compliance culture either. I would go so far as to say that FliteTest originally caught on with younger entrants to the hobby because they found the AMA (and AMA clubs) too rigid and stiff.
Old 07-16-2021, 01:28 PM
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Originally Posted by aymodeler View Post
I'm not sure a "compliance culture" would help much with the AMA's demographic problem though, which in my opinion, is their bigger issue. And FliteTest could never be help up as a shining example of a compliance culture either. I would go so far as to say that FliteTest originally caught on with younger entrants to the hobby because they found the AMA (and AMA clubs) too rigid and stiff.
And you would be right, it wouldn't help with the demographic problem. What it could have done is, if accurate records were maintained, showed the FAA and Congress that the AMA was proactively addressing each issue and holding members accountable to the rules and regulations put out by the clubs, AMA and, ultimately, the FAA. At the same time, had the AMA not tried to bring the "drone" community under it's "umbrella", it could have said that the members weren't the issue, it was those that weren't members and been telling the verifiable truth
Old 07-17-2021, 02:49 AM
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Originally Posted by aymodeler View Post
I'm not sure a "compliance culture" would help much with the AMA's demographic problem though, which in my opinion, is their bigger issue. And FliteTest could never be help up as a shining example of a compliance culture either. I would go so far as to say that FliteTest originally caught on with younger entrants to the hobby because they found the AMA (and AMA clubs) too rigid and stiff.
I was thinking along different lines. The FliteTest crowd may not be the picture of compliance, but nor are they big users of airspace over 400 feet. So in that sense, I figure the rest of the aviation stakeholders don't see that group as any threat to the airspace above 400 that others are looking to monetize. In short, "If you stay below 400', we kinda don't care."

That's where AMA, as a big user of airspace above 400 feet pi**ed away an opportunity to be seen as a non-risk. Non-risk because they followed the rules and held themselves accountable. But instead, they took hands off approach. And FAA (and others) can search any number of popular online forums and read examples of people all but admitting they don't follow the rules. "I never go higher than 399.99" or "The maximum speed of my jet is 199.99." Or, even open declarations that they don't intend to follow rules. Combine that with court cases, videos of AMA events where planes crash into crowds, videos of diving at high speed toward busy highways, or even flights to high altitude in the middle of a Victor Airway (with no spotter), and the sense is a culture that says one thing but does another. Which means self regulation has failed and creates reason for formal regulation.

Last edited by franklin_m; 07-17-2021 at 03:52 AM.
Old 07-17-2021, 06:34 AM
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Originally Posted by aymodeler View Post
I'm not sure a "compliance culture" would help much with the AMA's demographic problem though, which in my opinion, is their bigger issue. And FliteTest could never be help up as a shining example of a compliance culture either. I would go so far as to say that FliteTest originally caught on with younger entrants to the hobby because they found the AMA (and AMA clubs) too rigid and stiff.
My observation has been that the younger, potential modelers/members have been greeted with the FOG attitude and instead of promoting the fun side of the hobby, are told how they MUST join AMA, follow the rules, etc., etc, It is clear that Muncie has lead with the same FOG attitudes that have been at least somewhat responsible for turning the younger generation away from the AMA ranks.

Astro
Old 07-17-2021, 07:04 AM
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Originally Posted by franklin_m View Post
I was thinking along different lines. The FliteTest crowd may not be the picture of compliance, but nor are they big users of airspace over 400 feet. So in that sense, I figure the rest of the aviation stakeholders don't see that group as any threat to the airspace above 400 that others are looking to monetize. In short, "If you stay below 400', we kinda don't care."

That's where AMA, as a big user of airspace above 400 feet pi**ed away an opportunity to be seen as a non-risk. Non-risk because they followed the rules and held themselves accountable. But instead, they took hands off approach. And FAA (and others) can search any number of popular online forums and read examples of people all but admitting they don't follow the rules. "I never go higher than 399.99" or "The maximum speed of my jet is 199.99." Or, even open declarations that they don't intend to follow rules. Combine that with court cases, videos of AMA events where planes crash into crowds, videos of diving at high speed toward busy highways, or even flights to high altitude in the middle of a Victor Airway (with no spotter), and the sense is a culture that says one thing but does another. Which means self regulation has failed and creates reason for formal regulation.
Originally Posted by astrohog View Post
My observation has been that the younger, potential modelers/members have been greeted with the FOG attitude and instead of promoting the fun side of the hobby, are told how they MUST join AMA, follow the rules, etc., etc, It is clear that Muncie has lead with the same FOG attitudes that have been at least somewhat responsible for turning the younger generation away from the AMA ranks.
On one hand, there is criticism that the AMA was not doing enough to enforce compliance with rules. On the other hand, there is criticism that that the AMA telling new entrants that they MUST follow the rules was a turn off. Seems like a damned if you damned if you don't situation to me.

I am not saying I have all the answers, but I honestly believe that overall, the environment that the hobby finds itself in is both very nuanced and complex and cannot be reduced to simple soundbite solutions. There are so many actors, factors and agendas involved including demographics, prevailing social attitudes, commercial opportunities, bureaucratic posturing, politics, regulatory overreach, security paranoia, safety concerns, privacy concerns. History will tell us that whenever new a technology emerges (in this case, practical UAVs), it unleashes disruption and creates a VUCA environment. That's where we are right now, but history will also tell us that it will eventually settle into some new normal (one that we may not be totally happy with, but one that the majority of people can live with). The one certain thing is that you can never go back to the way it was before.
Old 07-17-2021, 07:30 AM
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Originally Posted by aymodeler View Post
On one hand, there is criticism that the AMA was not doing enough to enforce compliance with rules. On the other hand, there is criticism that that the AMA telling new entrants that they MUST follow the rules was a turn off. Seems like a damned if you damned if you don't situation to me.
My point was not that the rules shouldn't be followed. It was that (in my experience) those rules were presented in a manner that discouraged participation, rather than promoting them in a way that the potential new members understood their importance and garner respect for them. There are many AMA members who simply join the AMA for "the insurance" or because they, "have to join to fly" and I believe this breeds an apathetic, unengaged membership who passively let the few rule with the, "Good Ole Boy" approach.

Astro
Old 07-17-2021, 02:04 PM
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Originally Posted by astrohog View Post
There are many AMA members who simply join the AMA for "the insurance" or because they, "have to join to fly" and I believe this breeds an apathetic, unengaged membership who passively let the few rule with the, "Good Ole Boy" approach.
Fortunately, my club experience has not been like this at all. Yes, there are some who are more active and others who are more passive, but I have never personally experienced (now in 3 different clubs) the kind of good 'ole boy behavior others have described.
Old 07-17-2021, 07:28 PM
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Originally Posted by aymodeler View Post
Fortunately, my club experience has not been like this at all. Yes, there are some who are more active and others who are more passive, but I have never personally experienced (now in 3 different clubs) the kind of good 'ole boy behavior others have described.
The Good Ole Boy Club is alive and well in Muncie.

Astro
Old 07-18-2021, 06:07 PM
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Originally Posted by Hydro Junkie View Post
I didn't intend for my post to be an "AMA bashing". In fact, your last post's first paragraph's last few sentences kind of backed up what I was saying. I've also grown tired of the threads all turning into "AMA bash sessions" and all of the "anti-AMA" defensive posts that go along with them. Just wanted to throw out a friendly reminder that the AMA is financially weak and that they need to do something to shore up their financial deficiencies or they will be gone and all of the discussions, like this one, will have been a waste of time and that is something I would prefer to not see happen
Apropos of nothing, I'm pretty sure no other activity on earth has been taken over with more bureaucratic nonsense,
haggling, endless debate, etc., relative to the actual risk than flying model airplanes.

For myself, I've blown it all off. No FAA, no tests, no AMA, no nothing but flying where possible. I don't fly drones so sue me.

I just bought from an estate sale 5 wings from 36" to 72" and 6 other sailplanes from 48" span to 5 meter. I plan to fly them all
whenever and wherever I can.

Last edited by ECHO24; 07-18-2021 at 06:32 PM.
Old 07-18-2021, 08:31 PM
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Originally Posted by ECHO24 View Post
For myself, I've blown it all off. No FAA, no tests, no AMA, no nothing but flying where possible. I don't fly drones so sue me.
The FAA doesn't see it that way. You fly SUAS and they won't sue you, but they could fine you.

Hope you enjoy flying however you do, do not cause anyone else any issues, and never get cited by the FAA. That is the way it should be.

Astro
Old 07-19-2021, 02:02 AM
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yeah, the best way forward, is, just to remember, to not *uck up.
Old 07-19-2021, 11:15 AM
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Originally Posted by astrohog View Post
The FAA doesn't see it that way. You fly SUAS and they won't sue you, but they could fine you.

Hope you enjoy flying however you do, do not cause anyone else any issues, and never get cited by the FAA. That is the way it should be.

Astro
How many of those 100 or so reports each month to the FAA do you think are over model airplanes? My guess is zero. All the brouhaha in
the hobby is over drones, the bad rep, restrictions, testing, etc., all of it. No need to worry about me or anyone else flying model planes causing
"anyone else any issues".

I recently built an 8' Cub with a 50cc gas engine. I've never flown it. With a 24" prop and 5hp it would be like putting up a flying chainsaw with
hobby electronics controlling it and hoping nothing would go wrong. No thanks. Maybe someday way out in the desert. Electrics, on the other hand,
have made the hobby as risky as playing golf. Pointy nose gliders are more dangerous, which is why I don't own one.

As an aside, I'm a licensed pilot, which makes it ridiculous that I should have to pass a test to fly model airplanes. How about Franklin, a
career Navy jet pilot? Thirteen year-olds flying a RTF in a field, similarly a nonevent, are now banned. What's the average age at an AMA
club now, 60? The whole thing is a joke.
Old 07-19-2021, 04:17 PM
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^^^^ I don't disagree ^^^^^^
Old 07-22-2021, 08:20 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.
Ho Ho Ho He He Ha Ha Ha Ha! ... What do you think drones are designed to do?
Maybe AMA should have figured that out before getting on board the drone train.

As a result, the RC flying hobby is now pigeon-holed as a subset of drones, restricted to authorized fields.
Franklin will be sharing the declines in AMA membership as we all watch it swirl the drain.
Old Yesterday, 03:12 AM
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Not sure what you're laughing at.

FPV has been allowed with a visual LOS spotter. I'm talking about BLOS, that's not part of our programming.
Old Yesterday, 04:11 AM
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Originally Posted by BarracudaHockey View Post
Not sure what you're laughing at.

FPV has been allowed with a visual LOS spotter. I'm talking about BLOS, that's not part of our programming.
One of the themes that I have seen here is the perception that the AMA did not do enough to distance the hobby from "drone" flyers who routinely fly FPV BVLOS and are responsible for much of the bad press about renegade drones chasing police helicopters, flying over wildfires, and other reckless acts posted on YouTube. And worse, that the AMA made a failed power grab by trying to manipulate the situation to require all drone flyers to be AMA members, which then backfired and resulted in traditional model aircraft becoming caught up in the regulations that were the result of the reckless behavior of certain drone flyers.

I do tend to agree that the AMA could have done more to create a distinction between traditional model aircraft and "drones", but I also believe that no matter what the AMA did, we would not have gotten a free pass with regard to regulations. Further, I believe that the AMA has made positive contributions towards mitigating the worst aspects of the original proposed regulations. In that regard, I am in a vocal minority here.

On the other hand, I do also believe that the AMA is completely failing to keep current and attract younger entrants into the hobby (as compared to Flite Test, for example). I also am concerned about the AMA's financial trends (it is time to ditch the print magazine!).

Ultimately, the AMA is in a bit of a tightrope walk here and it is definitely starting to wobble.
Old Yesterday, 05:07 AM
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Originally Posted by franklin_m View Post
So Andy. As esteemed EC member. Care to acknowledge whether or not the financial trends I've shown in other threads are substantially correct? That they've been relatively unchanged (in trajectory) for over a decade?
Originally Posted by aymodeler View Post
I also am concerned about the AMA's financial trends (it is time to ditch the print magazine!).
I can't help but notice our esteemed EC member has yet to respond to questions about the financial trends...
Old Yesterday, 07:52 AM
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Originally Posted by franklin_m View Post
I can't help but notice our esteemed EC member has yet to respond to questions about the financial trends...
That is because there ain't no gettin' around them!

I don't think there is a way those abysmal numbers can be spun.

Astro
Old Yesterday, 08:47 PM
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the first step to solving your problems, is admitting that you have the problems...

then you can start to work on them.

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