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jeide 12-10-2010 09:04 PM

FAA ceiling on R/C
 
What happens to pattern if the FAA new rules limit R/C to 400 feet maximum altitude? Also R/C gliders and IMAC.

Derek.Koopowitz 12-10-2010 10:43 PM

RE: FAA ceiling on R/C
 


ORIGINAL: jeide

What happens to pattern if the FAA new rules limit R/C to 400 feet maximum altitude? Also R/C gliders and IMAC.
I honestly do not see this happening. I've been on a workgroup that involves all R/C disciplines and the feeling was that the FAA will leave it up to the AMA to determine what the ceiling should be...

DMichael 12-11-2010 06:21 AM

RE: FAA ceiling on R/C
 
Derek I hope you are right. If you don't mind my asking- the workgroup you are involved in- is it made up of just modelers? Or is someone who would be in a position to have some "inside info" inovolved? Like a lot of flyers I've been paying attention to this issue lately(albiet, just what I can find on the internet) and this is the first I've seen this kind of information.

Jetdesign 12-11-2010 06:36 AM

RE: FAA ceiling on R/C
 
We will need to see how this whole thing pans out. Nothing is official or really published yet (according to the AMA newsletter I read).

What I heard was that the ceiling limit was for non-AMA regulated activity. Pattern events are AMA regulated, so if this were the case we would be fine.

I believe everything right now is more or less speculation, unless there was an official decision and announcement that I missed.

DMichael 12-11-2010 06:56 AM

RE: FAA ceiling on R/C
 
Assuming that is right- we'd be fine for events- but not practice.

Jetdesign 12-11-2010 07:03 AM

RE: FAA ceiling on R/C
 
Good point, although I thought AMA fields were also considered 'AMA regulated', but now I'm speculating...

onewasp 12-11-2010 08:44 AM

RE: FAA ceiling on R/C
 
Latest from the AMA.

"You're receiving this email because of your affiliation with the Academy of Model Aeronautics.

December 2010

Potential FAA regulations on model aircraft still up in the air

Your AMA leadership made yet another trip to the Washington DC offices of the FAA in late November. Negotiations, led by AMA Government Relations and Regulatory Affairs Representative Rich Hanson and AMA President Dave Mathewson, continue to focus on national airspace safety, model aircraft operations and potential regulations that may create serious restrictions on aeromodeling. Click the link below to read Dave's latest report on this important issue.
Got a question for the FAA concerning its attempt to regulate model aircraft operations? Take the Quick Poll survey at the right, which will ask you to submit a question for a discussion forum with FAA officials at January's AMA EXPO."

I received this as well as the link referenced from the AMA email service 12/9/10.
You probably did too.








Silent-AV8R 12-11-2010 09:43 AM

RE: FAA ceiling on R/C
 
1 Attachment(s)

ORIGINAL: Derek.Koopowitz



ORIGINAL: jeide

What happens to pattern if the FAA new rules limit R/C to 400 feet maximum altitude? Also R/C gliders and IMAC.
I honestly do not see this happening. I've been on a workgroup that involves all R/C disciplines and the feeling was that the FAA will leave it up to the AMA to determine what the ceiling should be...

That seems at odds with what I have gleaned from conversations with people like Rich Hanson and extensive reading of the available documentation. Initially it was the case but lately I have gotten the impression that things have changed.

The FAA folks that briefed the EC in January mentioned altitude caps within a certain radius of an airport and lateral operating limits. Dave Mathewson's column and Rich's comment seem to imply that they are tightening up from there.

Given that every time you see the FAA mention models they cite AC 91-57, which is where the 400 foot limit comes from, it seems reasonable that this is the direction they are headed. The attached pdf file is an FAA Fact Sheet on sUAS. From that memo, dated July 2010:


Recreational use of the NAS is covered by AC 91-57 which generally limits operations to below 400 feet above ground level and away from airports and air traffic.
We are clearly a recreational use.

The most recent comments from the AMA definitely indicate that the FAA is moving towards more restrictive definitions rather towards greater flexibility.

The AMA has a good web page with the latest info that they are able to share:

http://www.modelaircraft.org/news/ama-faa.aspx

Gulliver 12-11-2010 10:01 AM

RE: FAA ceiling on R/C
 
Check here to see what the FAA should really be worried about ifits not already:

http://fpvpilot.com/default.aspx

Run a Google on FPV RC to get an ida of the scope of this activity.

hook57 12-11-2010 10:31 AM

RE: FAA ceiling on R/C
 

ORIGINAL: Derek.Koopowitz


ORIGINAL: jeide

What happens to pattern if the FAA new rules limit R/C to 400 feet maximum altitude? Also R/C gliders and IMAC.
I honestly do not see this happening. I've been on a workgroup that involves all R/C disciplines and the feeling was that the FAA will leave it up to the AMA to determine what the ceiling should be...
I agree with Derek on this one. Silent has a point, but keep in mind Silent that the fact sheet says "generally limited" to 400'. There will likely be some lengthy discussions/issues with regard to operating less than 3 nautical miles from an airport. However,as in many instances, I'm betting that there may likely be a provision to waiver that restriction if it becomes one, depends on if it becomes an SFAR or justPart 107 under 14 CFR; then again there's the exemption process via 14 CFR Part 11 too. Something to consider.

hook

hook57 12-11-2010 10:39 AM

RE: FAA ceiling on R/C
 

ORIGINAL: Gulliver

Check here to see what the FAA should really be worried about ifits not already:

http://fpvpilot.com/default.aspx

Run a Google on FPV RC to get an ida of the scope of this activity.
Perhaps, instead of the constant blaming of this agency or that agency, we should look at the technology that has driven the changes that caused the FAAto look at it. If it's not LOS as in modeling, what is it; or what potentially is it? Doing what's been done with FPV (NYC, the 11K foot flight, etc) and OSD technologies puts it outside of the intent of recreational modeling (even the serious competition type). Obviously the stuff is selling or it wouldn't be out there. It might be cool, telemetry is one thing, but if it hurts this activity in any way I'm against its use, period.

hook

Interesting, the third tab on the left menu is "FPV Safety"yet one of the videos shows the helicopter flyingright at an individual, looks close too. Dumb and safety don't really mixin my book.

Silent-AV8R 12-11-2010 11:00 AM

RE: FAA ceiling on R/C
 
It is my understanding that they intend to publish this as SFAR Part 107.

It is also worth noting if you look at the ARC memo past the model sections to note the operating limits for those aircraft. Groups I and II are limited to 400 feet. Group III can go to 700 and Group IV can go to 1,200. However, all of the operations above 400 feet require a dedicated spotter AND altitude and position reporting equipment with a real time down link to the pilot.

All of the sUAS commercial/civil groups have lateral limits on them ranging from 1,500 feet to 1/2-mile. Their operations will be excluded from Class B airspace and will have set backs from all airports as well. An additional requirement will be to operate outside populated areas, which in FAA-speak is anything depicted in yellow on a sectional chart. Their operations will likely be restricted to VLOS, day VFR under 100 mph with the altitude caps noted above. In addition a 2nd class medical and other pilot and airframe certifications will be required.

To me the most logically consistent approach is for them to allow modelers to operate with the same physical limits on altitude and lateral areas while relieving us of the more onerous pilot certification requirements, medical certificates, airframe certification and so on. I have a difficult time understanding how the FAA could justify allowing models with much more lax operator certifications and training requirements to have greater operational flexibility as compared to the more stringently regulated pilot group.

If we are allowed to operate above 400 feet I predict that it will only be allowed well outside any populated area, away from airports and other busy airspace and will require some sort of waiver similar to what the rocket guys have to do now. If that is the case it is difficult to understand how we could practice!!

hook57 12-11-2010 12:42 PM

RE: FAA ceiling on R/C
 


ORIGINAL: Silent-AV8R

It is my understanding that they intend to publish this as SFAR Part 107.

It is also worth noting if you look at the ARC memo past the model sections to note the operating limits for those aircraft. Groups I and II are limited to 400 feet. Group III can go to 700 and Group IV can go to 1,000. However, all of the operations above 400 feet require a dedicated spotter AND altitude and position reporting equipment with a real time down link to the pilot. .......
If we are allowed to operate above 400 feet I predict that it will only be allowed well outside any populated area, away from airports and other busy airspace and will require some sort of waiver similar to what the rocket guys have to do now. If that is the case it is difficult to understand how we could practice!!
I know the ARC paper well, been following it and more for some time. There is more to it with those altitudes Silent, in fact Group IV is up to 1200' I'm sure, but only in sparsely populated areas. That's partly the key, it's smaller when closer and also lower when closer to public use airports etc. But it applies to commercial use operators, and that's key. I don't want to be considered commercial use in any way. Gotta run, but I'll check back.
hook

Silent-AV8R 12-11-2010 02:10 PM

RE: FAA ceiling on R/C
 
Yep, 1,200 feet. I misremembered that one!! It also requires a Letter of Authorization confirming that the intended operation area is considered uninhabited.

My points remains the same however, that is seems logical that we as modelers would not receive more liberal limits than the regulated sUAS does. My opinion is that the major difference between recreational and commercial/civil is going to be that they will have higher training standards and aircraft certification requirements than we do. It would not surprise me to see a stepped altitude cap as well for us such that if we want to fly in the middle of nowhere we would have fewer restrictions. As you say, the closer we get to things the greater the restrictions will be.

NJRCFLYER2 12-11-2010 02:34 PM

RE: FAA ceiling on R/C
 


ORIGINAL: DMichael

Assuming that is right- we'd be fine for events- but not practice.
Ithought you had heard - we're having a 365 day Pattern contest starting on 1/1/11 at my local field. Start charging your batteries now.

Rcpilot 12-11-2010 02:43 PM

RE: FAA ceiling on R/C
 
We've been following the 400' limit set forth by AMA for years and years. Since our club is only about 5 miles from a full scale airport, we try and regulate ourselves to 400' above ground level anyway.

See paragraph 2 - sub section (C)

http://www.modelaircraft.org/files/105.PDF

I don't know what all the fuss is about. 400 feet above ground level is pretty darn high for normal, every day flying. Why would you need to fly higher than 400' above the ground?

I can see an IMAC contest where large planes will exceed that during uplines, and I could see a pattern plane exceeding 400' on an upline. But those instances are rare when compared to the number of RC flights being flown on a daily basis.

We've put monitoring devices in a UAV that I work on part-time. It's a long ways up to 1200 feet above ground level. A 44lb UAV starts looking pretty darn small up there. I can't imagine flying a glow or gasoline powered RC model up to 1000 feet above ground level. I've flown thermal gliders up over 1500 feet above ground level. Gliders with 150" wingspans look like a DOT at that altitude.

So why all the fuss over a 400' limit?

mike31 12-11-2010 03:53 PM

RE: FAA ceiling on R/C
 
Fly at or under 400 feet!

shannah 12-11-2010 04:39 PM

RE: FAA ceiling on R/C
 
Since the FAA is trying to regulate the sUAS's then it seems that they should make a definitive statement about what is and isn't an sUAS. I have a simple definition that might help. If it has any capability of gathering information external to the aircraft (cameras, sensors etc) for live transmission or post flight downloading then it is an sUAS. Anything else is a model. Yes, models carry cameras today. I would say that if they do so then they must comply with sUAS rules. Leave the pure model aviators alone.

I guess this is too logical and simple.

shannah 12-11-2010 04:45 PM

RE: FAA ceiling on R/C
 
I should add in the definition for sUAS the capability of autonomous flight. Any of the capabilities (autonomous flight, sensors, cameras, external data communication would mean you are not operating a model.

DMichael 12-11-2010 05:27 PM

RE: FAA ceiling on R/C
 

ORIGINAL: Rcpilot

We've been following the 400' limit set forth by AMA for years and years. Since our club is only about 5 miles from a full scale airport, we try and regulate ourselves to 400' above ground level anyway.

See paragraph 2 - sub section (C)

http://www.modelaircraft.org/files/105.PDF

I don't know what all the fuss is about. 400 feet above ground level is pretty darn high for normal, every day flying. Why would you need to fly higher than 400' above the ground?

I can see an IMAC contest where large planes will exceed that during uplines, and I could see a pattern plane exceeding 400' on an upline. But those instances are rare when compared to the number of RC flights being flown on a daily basis.

We've put monitoring devices in a UAV that I work on part-time. It's a long ways up to 1200 feet above ground level. A 44lb UAV starts looking pretty darn small up there. I can't imagine flying a glow or gasoline powered RC model up to 1000 feet above ground level. I've flown thermal gliders up over 1500 feet above ground level. Gliders with 150'' wingspans look like a DOT at that altitude.

So why all the fuss over a 400' limit?
I'm not sure what kind of flying you are doing- but when I fly my pattern or IMAC planes I am flying multiple manuevers that are difficult to keep under 400 feet- humpty bumps, stall turns, vertical 8's, even looping manuevers would encroach or exceed 400ft.

Many sport flyers basically fly a racetrack pattern and I guess that's OK for them- but not for me.

You might also be flying a lot higher than you think you are. Keep me honest on my math but, by my calculations, at 60mph a plane is traveling 88ft every second. Assuming you are flying even 50 feet above the ground, if you were to pull vertical and maintain speed you'd be past 400 feet in about 4-5 seconds. If you count it out, that's not very long- and I bet many of us are flying faster than 60mph.

onewasp 12-11-2010 06:15 PM

RE: FAA ceiling on R/C
 
The last I read from Dave implied (very directly) that we WERE in for changes.
That all of the regulations had not been decided.
...and that the first publication of the proposed regulations would be made in June 2011.

I'm with those who have commented as to the negative aspect of FPV flights and their
published pictures (such as the one of the statue of liberty at night).
In the USA 9/11 rings quite loudly still .....regardless off what the rest of the world might think

My bet is that we will have some less than desirable regulations imposed upon us and that fields closer to functioning
airports will have more stringent requirements than those further away.
I've heard "within three miles" and also "within four miles" . All distances are as the crow flies.
I can think of two fields locally which are too close to full scale operations right now. And I'm not the FAA !!


Now, define "functioning airport".
Commercial ?
Or with operating tower ?
Or ?????

Hang loose as there is nothing yet .......BUT there will be !

The only certainty at this time is that changes are coming.
All of our speculation is just that.....SPECULATION .

One good aspect is that I haven't seen any rants lately putting down the AMA .

NJRCFLYER2 12-11-2010 06:21 PM

RE: FAA ceiling on R/C
 
Afew of us Pattern and IMACtypes did some informal testing one day with an onboard unit to record max altitude. Some testing was done by flying the sequence, and other testing was done to see if what we each thought was 400 feet was about right. We tried this with 2M Pattern airplanes and with a 40% Sukhoi. Suffice it to say that there is no way you can fly aerobatic sequences as we know them today without busting through 400 feet AGL. It was also very revealing that what we all thought was 400 feet, just flying straight and level, was wrong. Very wrong. Anyone who thinks that they have a good handle on on how high they are flying at all times, even with ordinary sport flying, is just fooling themselves. A 400 foot celiing is simply unrealistic, and is also unenforceable with RC flying as we know it today.

Silent-AV8R 12-11-2010 06:21 PM

RE: FAA ceiling on R/C
 

ORIGINAL: shannah

I should add in the definition for sUAS the capability of autonomous flight.

In reading the ARC memo the FAA classifies models as sUAS. The difference is they want to make us essentially an regulated sUAS. Autonomous flight does not look to be part of the sUAS concept. sUAS, us and the regulated ones, will be VLOS only. They will require a spotter pilot for FPV operations.

This is from the July 2010 Fact Sheet:


Introduction
Unmanned Aircraft Systems previously referred to as “unmanned aerial vehicles,” “UAVs,”“remotely operated aircraft/ vehicles,” or just “unmanned aircraft come in a variety of shapes and sizes, and serve diverse purposes. They may have a wingspan as large as a Boeing 737 or smaller than a radio-controlled model airplane. UAS operations always have a pilot in command who is flying the aircraft.

shannah 12-11-2010 07:35 PM

RE: FAA ceiling on R/C
 
Its easier for them that way, for sure. If the definition is broad and non-descript then everything falls under the guidelines and, therefore, under the regulations. I don't have a good feeling about this at all...

If we were somehow able to draw a distinction between truly recreational flying and the real intent of an sUAS then maybe we could get somewhere. After all, I doubt that the purpose of an sUAS is to take off, fly a prescribed set of aerobatic maneuvers in a 60degree box and then land. As I see it, there really isn't any gray area there. But, from the sUAS pilot/developer standpoint, they look at the hardware involved and say "hey, my heli/airplane is similar, why do I have to be regulated and not those guys????"

MTK 12-11-2010 08:07 PM

RE: FAA ceiling on R/C
 


ORIGINAL: NJRCFLYER2

A few of us Pattern and IMAC types did some informal testing one day with an onboard unit to record max altitude. Some testing was done by flying the sequence, and other testing was done to see if what we each thought was 400 feet was about right. We tried this with 2M Pattern airplanes and with a 40% Sukhoi. Suffice it to say that there is no way you can fly aerobatic sequences as we know them today without busting through 400 feet AGL. It was also very revealing that what we all thought was 400 feet, just flying straight and level, was wrong. Very wrong. Anyone who thinks that they have a good handle on on how high they are flying at all times, even with ordinary sport flying, is just fooling themselves. A 400 foot celiing is simply unrealistic, and is also unenforceable with RC flying as we know it today.
Control Line is about the only series of events that stay below 400' AGL. That and Indoor events ...maybe


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