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franklin_m 04-02-2022 10:55 AM

FAA FOIA Request Results
 
Today's FEDEX brought the FAA's response to my Freedom Of Information Act (FOIA). I asked for copies of all agreements between the FAA and AMA clubs etc. I'm still going through the 600 plus pages of documents. So far:

(1) Have seen just one club approved for flight above LAANC, and that's Brunnerville RC club in PA that asked for 600, 200 more than their 400 LAANC value. Of note, the FAA included the entirety of the SRM panel document, all 72 pages. However the mitigations are interesting to read. Mandatory call to FAA or NOTAM when operating above 400, no more than one minute above 400 for every 10 minutes of flight; requirement for failsafes, and mandatory preflight, strict compliance with CBO & club rules, among others. Additionally, the FAA has performance monitoring provisions (i.e. compliance measures), one of which is more than a single near miss with manned aircraft in a year and in the agreement is invalidated, as is failure to adhere to CBO or club rules.

(2) Other than that, have yet to see a single agreement above 400 agl

(3) Many agreements 200 AGL and below

(4) A lot of expired agreements (most have 3 year time limits); every club operating w/o a valid agreement is doing so illegally

(5) Notably absent so far ... an agreement that allows AMA to operate above 400 AGL at "Taj-Muncie."

I'll keep digging through the rest. Also, there's a number of agreements that were between FAA facilities at DOD locations, and those were referred to DOD for response. I have two so far, awaiting the others.

franklin_m 04-03-2022 05:27 AM

I've completed my initial review of the FOIA documents sent by the FAA. As noted earlier, I am still awaiting additional set from DoD. My initial request was copies of all agreements with private dues collecting organizations that permit recreational flight above published LAANC maximums. FAA responded and said it would be easier to produce all agreements, whether they allow flight above 400 AGL or not, and I agreed. So unless the FAA ignored the law, they provided me a copy of EVERY agreement with AMA / AMA clubs (or other groups) meeting the criteria.

My initial review shows:

- I received no documentation from FAA that shows AMA has permission to above 400 AGL at Taj-Munice
- SRAs are VERY intensive. Agreements come with many strings, are NOT open ended (note 1)
- Surprising number of agreements limit flight to 200 AGL
- A number of approved flying areas are really small (for example, one was limited to just 800 feet from lat/long)

Obviously, this is just step 1 in a long term strategy to ensure that members of private dues collecting organizations are not permitted to do things that other taxpayers cannot do. Just as AAA members or BoatUS members do not enjoy extra privileges on public roads or waterways, neither should CBO members enjoy extra privileges in the public airspace. That whole Constitutional equal protection under the law thing. In addition to the DOD documents resulting from this FAA FOIA request, I have an additional FOIA out to DOD on a separate but related question. To answer that question, there will be some engagement of groups within DOD that heretofore may not have been aware that certain groups we being afforded use of DOD facilities in ways prohibited by regulation. And I have additional FOIAs set to launch in the weeks and months ahead. There's also the IG route too; that's proven successful in the past when I use it in one region.

Note 1: Requirements to get that precious 200 foot increase: Budreau, Radcliff, and Stillman attended. Club had to agree to no more than one minute above 400 for every 10 minutes of flight. Club must issue NOTAM or call tower before operating above 400. Club required to report flyaways to FAA. No more than one near miss per year (as determined by FAA, not the club). Club agrees to 2 year monitoring plan. Ironically, as Budreau, Radcliff, and Stillman are touting the AMA's safety code and it's requirement to follow laws and regulations (attached as appendix F to the agreement), those same three KNEW that AMA headquarters was not doing that at the Muncie site (they have no agreement to operate above 400 AGL, yet regularly and repeatedly allow it). Letters of agreement that result from SRA are not open ended, must be renewed.

astrohog 04-03-2022 06:56 AM

Interesting stuff.

Since our resident AMA rep can't, won't or doesn't answer succinctly, and other members who have submitted questions through their local channels have not produced any answers, I guess we can assume that the, "many" or, "plenty" of exemptions that we have been told have been granted, have been to clubs or fields that would have otherwise been completely grounded by the new regs, and they have been granted an exemption to 200' AGL, not an exemption to fly above 400' as we have (presumably) been discussing.

Only ONE granted for over 400' (LAANC)?

I wonder why Andy keeps assuring us there are, "Plenty"?

Speedy said that one Oregon soaring club he attends occasionally must have been granted an exemption because they are commencing with soaring events. Did you see anything for that club?


Astro

speedracerntrixie 04-03-2022 07:36 AM

Correction, I stated that the CVRC club in Visalia California had stopped holding events late last year while the agreement between them and the FAA was pending. I saw that they have 2022 events on the calendar so it stands to reason that an agreement is in place. Being that the agreement happened fairly recently I would not be surprised if it is not on Franklin’s list. Perhaps he could share with us the last date in which an agreement was processed.

franklin_m 04-03-2022 07:37 AM


Originally Posted by astrohog (Post 12722371)
Speedy said that one Oregon soaring club he attends occasionally must have been granted an exemption because they are commencing with soaring events. Did you see anything for that club?

I asked the FAA for copies of all agreements between the FAA and private dues collecting organizations (CBOs etc.). The FAA provided documents detailing FAA agreements with Oregon AMA clubs. Not one was approved by the FAA for recreational sUAS operations in excess of 400 AGL.

astrohog 04-03-2022 07:37 AM


Originally Posted by speedracerntrixie (Post 12722376)
Correction, I stated that the CVRC club in Visalia California had stopped holding events late last year while the agreement between them and the FAA was pending. I saw that they have 2022 events on the calendar so it stands to reason that an agreement is in place. Being that the agreement happened fairly recently I would not be surprised if it is not on Franklin’s list. Perhaps he could share with us the last date in which an agreement was processed.

My bad, I stand corrected on the club in question.

Astro

franklin_m 04-03-2022 07:42 AM


Originally Posted by speedracerntrixie (Post 12722376)
Correction, I stated that the CVRC club in Visalia California had stopped holding events late last year while the agreement between them and the FAA was pending. I saw that they have 2022 events on the calendar so it stands to reason that an agreement is in place. Being that the agreement happened fairly recently I would not be surprised if it is not on Franklin’s list. Perhaps he could share with us the last date in which an agreement was processed.

It arrived in yesterday's FEDEX. Their response is dated 30 March 2022.

And for the events last year, the FAA did not provide any agreement with the Visalia club that authorized flight above 400 AGL. Yes, there is an agreement, but it is limited to 400 AGL. I remember noting that agreement specifically, since it was near my base.

franklin_m 04-03-2022 07:49 AM

Also, my next FOIA to FAA is already written now that I know the specific title of the product of the SRM panels. I'll wait about six months or so and launch that one. It should scoop up the staggering number of "successes" the AMA is achieving. The nice thing is the documents show what LAANC previously allowed, what the club requested, and what the FAA approved.

Given that AMA has continued to obfuscate the language when they talk about successes, this next FOIA will yield a true measure of the AMA's "influence."

speedracerntrixie 04-03-2022 07:57 AM


Originally Posted by franklin_m (Post 12722379)
It arrived in yesterday's FEDEX. Their response is dated 30 March 2022.

And for the events last year, the FAA did not provide any agreement with the Visalia club that authorized flight above 400 AGL. Yes, there is an agreement, but it is limited to 400 AGL. I remember noting that agreement specifically, since it was near my base.


Franklin, that is not what I had asked. We know that the CVRC club had no agreement in 2021. No need to refer to that. What was asked was the last date in which an agreement was made with an AMA club. Surely each agreement will state an effective date right? You continually ask for transparency, how about you take the first step towards that instead of dodging my question?

franklin_m 04-03-2022 08:40 AM


Originally Posted by speedracerntrixie (Post 12722382)
Franklin, that is not what I had asked. We know that the CVRC club had no agreement in 2021. No need to refer to that. What was asked was the last date in which an agreement was made with an AMA club. Surely each agreement will state an effective date right? You continually ask for transparency, how about you take the first step towards that instead of dodging my question?

No, that’s not what you said. Your exact words:


Originally Posted by speedracerntrixie (Post 12722376)
Perhaps he could share with us the last date in which an agreement was processed.


And I answered based on the documents provided to me by the FAA. Their response is dated 30 March 2022. If a document was “processed” before that date, I can think of no reason why it would not be included … as excluding it would not comply with FOIA. Or, the more simple answer, there is no such document … for FAA would have included it if it existed

speedracerntrixie 04-03-2022 08:44 AM

LOL, have it your way. I’m not going to play your game. Have a pleasant Sunday.

franklin_m 04-03-2022 08:46 AM

As I know there's a lot of talk by some about various west coast soaring events etc. that are regularly operating above 400 AGL, I did another more detailed look. I did find one more club approved for flight above 400, the Las Vegas club. But no others. Here's a list of clubs that may be of interest to some. No particular order. I couldn't help but notice the Beckley WV club, which if memory serves is home field for a VP, is also limited to 400 AGL. The majority are those clubs in CA, OR, WA with a few other notables.

To me the big takeaway here is that in close to 1000 pages of documentation, with VERY few exceptions, all are limited to 400 AGL or less. In fact, I saw more limited to 200 AGL than I saw allowed higher than 400. I couldn't help but notice the plethora of "soaring" type clubs that are, like nearly every other club, limited to 400 AGL or less.

AMA Facility in Muncie?
NO AGREEMENT WITH FAA THAT PERMITS FLIGHT OVER 400 AGL

Lower Columbia RC Society - 400 AGL
Sierra Flyers Model Airplane Club - 400 AGL
Lake Sawyer Hawks - 400 AGL ( and 1000 foot radius)
Beckley Model Airplane Club - 400 AGL
Channel Island Condors - 400 AGL
Pomona Valley Model Airplane Club (Chino) - 400 AGL
Wenatchee Red Apple Flyers - 400 AGL
San Gabriel Valley Radio Control League - 400 AGL
Eugene RC Aeronauts - 400 AGL
Clovis Area Modelers - 400 AGL
Flagler County Radio Aero Modelers (FL) - 200 AGL
Whitman Flyers Club (NY) - 200 AGL
Soaring League of North Texas - 400 AGL
South Houston Radio Control Society - 200 AGL
Houston Sport Flyers - 400 AGL
El Dorado Silent Flyers - 400 AGL
Sacramento Area Modelers - 400 AGL
Red Barons RC Flying Club - 400 AGL
Sparks Inc (St. Pete) - 400 AGL
Prescott Valley Silent Flyers - 400 AGL
Kitsap Aircraft Radio Control Society - 400 AGL
Inland Empire Radio Control Club - 400 AGL
Field of Dreams RC Club - 400 AGL
Chollas RC Flyers - 400 AGL
Silent Flyers of San Diego County - 200 AGL
Harbor Soaring Society - 400 AGL
Soaring Union of Los Angeles - 400 AGL
San Fernando Valley RC Flyers - 250 AGL

franklin_m 04-03-2022 08:48 AM


Originally Posted by speedracerntrixie (Post 12722386)
LOL, have it your way. I’m not going to play your game. Have a pleasant Sunday.

It's really simple, I can't speak to the effective date of a club "document" the FAA did not include in the package of all agreements, the cover letter of which was dated AFTER this club "document" you mentioned was supposedly "processed."

Hydro Junkie 04-03-2022 04:22 PM

The 400 AGL limits for Lake Sawyer, Wenatchee and Kitsap don't surprise me. None of those sites has anything larger than a regional or GA airport within 10 miles so it makes sense. Not sure where most of the others are located but Kitsap is only:
  • 6.8 miles from Bremerton National Airport
  • 15.6 miles from Seattle-Tacoma International Airport
  • 15.1 miles from King County International Airport
  • 17.6 miles from Tacoma Narrows Airport
The Lake Sawyer Hawks are only:
  • 13.3 miles from Seattle-Tacoma International Airport
  • 18.5 miles from King County International Airport
  • 13.3 miles from Renton Municiple Airport
  • 6.8 miles from Crest Airpark in Kent
All of these distances are point to point using the Google Maps distance measuring functions and addresses from the flying site or club websites. I included Seattle, King County and Renton due to the fact that they all are either major airports(Seattle and King County) or associated with jetliners(Boeing has production facilities at King County and Renton)
The one that is interesting is the Wenatchee Red Apple Flyers. Their flying site is barely two miles from Pangborn Memorial Airport, a good sized regional facility. To make things even more interesting, the R/C field has a paved east/west runway that points right at the airport. Their only saving grace is that Pangborn's runway is set to a northeast/southwest direction so it isn't pointed in the direction of the R/C site

franklin_m 04-04-2022 04:10 AM


Originally Posted by Hydro Junkie (Post 12722449)
The 400 AGL limits for Lake Sawyer, Wenatchee and Kitsap don't surprise me ... (deleted for brevity) ... Their only saving grace is that Pangborn's runway is set to a northeast/southwest direction so it isn't pointed in the direction of the R/C site

I guess what struck me was the overwhelming number of sites with agreements capped at 400 AGL. And the absence of any agreement that allows flight over 400 AGL at AMA's home field. At some point, the non-compliance example set by the HQ will have an impact.

They're having all these SRM panels and attesting (to government) that they've got these rules members follow - all the while knowing they're not being followed in events at Muncie. Misrepresenting to the Federal government oftentimes has consequences. Maybe not immediate, but they usually catch up eventually. Shocked that AMA leadership is ignorant of potential impact of their own non-compliance!

Hydro Junkie 04-04-2022 07:52 AM

I was surprised at all the 200 AGLs and, come to think about it, the 400 AGL at Wenatchee. Being only two miles from a regional commercial airport, I would have thought they would be restricted to 200 AGL

paulsf86 04-04-2022 07:59 AM

Franklin:

Other than listening to yourself try to impress anyone that will listen, what is your end game hear other than trying to destroy the hobby we all love? It would be best for all of us if you would just go crawl in a hole and disappear.

franklin_m 04-04-2022 08:27 AM


Originally Posted by paulsf86 (Post 12722505)
Franklin:

Other than listening to yourself try to impress anyone that will listen, what is your end game hear other than trying to destroy the hobby we all love? It would be best for all of us if you would just go crawl in a hole and disappear.

My "end game hear (sic)?"

Originally Posted by franklin_m (Post 12722355)
Obviously, this is just step 1 in a long term strategy to ensure that members of private dues collecting organizations are not permitted to do things that other taxpayers cannot do. Just as AAA members or BoatUS members do not enjoy extra privileges on public roads or waterways, neither should CBO members enjoy extra privileges in the public airspace. That whole Constitutional equal protection under the law thing (emphasis added).


BarracudaHockey 04-04-2022 08:41 AM


Originally Posted by Hydro Junkie (Post 12722501)
I was surprised at all the 200 AGLs and, come to think about it, the 400 AGL at Wenatchee. Being only two miles from a regional commercial airport, I would have thought they would be restricted to 200 AGL

That's not surprising, you can be in the vicinity of an airport yet not be in their normal approach/departure paths, there's a club here that's well within the bubble of a major airport yet has 400 feet because they are nestled into a corner that doesn't get over flown.

paulsf86 04-04-2022 09:39 AM

Franklin:

I guess it worked as you did "hear" what I was saying but as usual you did not answer the question. Who appointed you as the lead constitutional expert and judge and jury on the matter. Remember this attack of yours is on a hobby that has existed for many years without your intervention. And now you seem to have a personal goal of destroying what has not already been injured. Seems to me you have way to much time on your hands to wager war against anything that comes into your mind. Maybe you should find a hobby like RC modeling and do something constructive rather than destructive. You might find it a refreshing change. Otherwise I would suggest as I did earlier that you just go away.

Hydro Junkie 04-04-2022 09:40 AM


Originally Posted by BarracudaHockey (Post 12722512)
That's not surprising, you can be in the vicinity of an airport yet not be in their normal approach/departure paths, there's a club here that's well within the bubble of a major airport yet has 400 feet because they are nestled into a corner that doesn't get over flown.

I was under the impression that direction from the airport didn't matter, just the distance. This is one case I'm almost relieved I may have had it wrong

BarracudaHockey 04-04-2022 09:44 AM


Originally Posted by Hydro Junkie (Post 12722524)
I was under the impression that direction from the airport didn't matter, just the distance. This is one case I'm almost relieved I may have had it wrong

I've seen exemptions granted based on location and not just distance, I regularly fly at one.

Propworn 04-04-2022 10:17 AM


Originally Posted by paulsf86 (Post 12722523)
Franklin:

I guess it worked as you did "hear" what I was saying but as usual you did not answer the question. Who appointed you as the lead constitutional expert and judge and jury on the matter. Remember this attack of yours is on a hobby that has existed for many years without your intervention. And now you seem to have a personal goal of destroying what has not already been injured. Seems to me you have way to much time on your hands to wager war against anything that comes into your mind. Maybe you should find a hobby like RC modeling and do something constructive rather than destructive. You might find it a refreshing change. Otherwise I would suggest as I did earlier that you just go away.

Do I hear a distant scrape of.............? Could it be..............the defenders of all things Franklin getting ready to rush to his aid? Beware Paul you just may have disturbed the nest.

Like you, I wondered the same thing, what is his motivation? It was explained to me that Franklin requested a discount for Vets/service persons re AMA membership plus funding for a private base club. The AMA agreed to the AMA discount but wanted credit as a supporter which was refused, so they did not follow through with it. They also turned down funding a private base site. From that point on Franklin has had a burr in his shorts and has made it his personal vendetta against anything AMA.

Hydro Junkie 04-04-2022 11:29 AM


Originally Posted by Propworn (Post 12722529)
Do I hear a distant scrape of.............? Could it be..............the defenders of all things Franklin getting ready to rush to his aid? Beware Paul you just may have disturbed the nest.

Like you, I wondered the same thing, what is his motivation? It was explained to me that Franklin requested a discount for Vets/service persons re AMA membership plus funding for a private base club. The AMA agreed to the AMA discount but wanted credit as a supporter which was refused, so they did not follow through with it. They also turned down funding a private base site. From that point on Franklin has had a burr in his shorts and has made it his personal vendetta against anything AMA.

His motivation is credibility. Either a claim is credible or it isn't. If it isn't, then the one making the claim can't be trusted.

franklin_m 04-04-2022 11:58 AM

In your most recent post, you said:


Originally Posted by paulsf86 (Post 12722523)
I guess it worked as you did "hear" what I was saying but as usual you did not answer the question.



I’ll remind you of the question you actually asked:

Originally Posted by paulsf86 (Post 12722505)
[W]hat is your end game hear other than trying to destroy the hobby we all love (emphasis added)?



I had already answered that question, in fact quoted it to you in the response to above, but perhaps you didn't read it. So for your convenience I'll repost here ... a direct answer to your question abou what is my end game?


Originally Posted by franklin_m (Post 12722355)
Obviously, this is just step 1 in a long term strategy to ensure that members of private dues collecting organizations are not permitted to do things that other taxpayers cannot do (emphasis added).



But as it turns out, it's not the question you actually asked, but rather another one you're now adding to it:


Originally Posted by paulsf86 (Post 12722523)
Who appointed you as the lead constitutional expert and judge and jury on the matter?”


And my response? It is a birthright of all citizens to pursue those issues that interest them consistent with law, which I’m doing. How I spend my time is my business. That's the beauty of this country. As is my right to see things differently than you. You say to get a hobby? Well, maybe this is one of my hobbies - advocating for those who either don’t WANT to be members of AMA or cannot afford it - yet want to enjoy the same privileges in the public airspace.


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