[NSRCA-discussion] Fw: Altitude limits

[Ed White]

This is what I expected was the case, that AMA was well aware of the notice and possibly had a hand in it.  As I see it, the the purpose of the notice is to define the FAA's proposed approach to controlling UAV/UAS operations in the national airspace.  Something that badly needs to be done.  

The result was that approach proposes that model aircraft, flown for hobby purposes, would have authority to be in the national airspace under AC 91-57.  And there are no changes to AC 91-57, nothing in it was made mandatory.  The result is no change as far as we are concerned.  I think the AMA was neither letting sleeping dogs lie, nor did they charge in.  I think they were doing just what we pay them to do, work quietly and effectively behind the scenes to represent our interests.  The notice indicates to me that they (or least someone) successfully did exactly that.

Ed

Lance Van Nostrand <patterndude at tx.rr.com> wrote: The key points were forwarded to AMA and their conclusion is that this was a 
red herring.  The rule has been in effect since 1981.
--Lance

----- Original Message ----- 
From: "Dave Mathewson" 
To: 
; "'Greg Hahn'" 
Cc: "'Jim Cherry'" ; "'Bob Underwood'" 
; "'JIM RICE'" 
Sent: Thursday, January 24, 2008 10:21 PM
Subject: RE: Altitude limits


> Hi all,
> 1. Ed White is right. The "breaking news" Jim O. is referring to was part 
> of
> AC-91-57 dated 1981. AMA provided input into the drafting of that document
> in 1981.
> 2. Greg, has anyone run this discussion past Jay Mealy? I know Jay is not
> only aware of FRD No. FAA-2006-25714; Notice No. 07-01 dated 2/13/07, but 
> if
> I recall played a part in its development. Jim, see Jay's email of 2/15/07
> to the EC and Executive Staff.
>
> Dave
>
>
> -----Original Message-----
> From: patterndude at tx.rr.com [mailto:patterndude at tx.rr.com]
> Sent: Thursday, January 24, 2008 4:11 PM
> To: Greg Hahn
> Cc: Jim Cherry; Bob Underwood; Dave Mathewson; JIM RICE
> Subject: RE: Altitude limits
>
> Greg,
>
> It was pointed out by Chris Moon below that the regulation uses the words
> "should be flown below 400 ft" and not "must".  if true, then there is a
> subjective nature to the ruling.  This might affect the way we seek
> clarification.
>
> It appears the AMA is caught off guard in this.  I'm sure there's no way 
> to
> know what every ruling body is up to so I'm glad we were able to get this 
> on
> the radar.
>
> --Lace
>
> ---- Greg Hahn  wrote:
>
> =============
> All,
>
>
>
> So if I'm reading correctly Bryan Hudson's note, since last Feb, all
> altitude record attempts were, are or will be breaking Federal law. So to
> make such an attempt will now require some type of waiver from the FAA or
> the designated enforcement body.
>
>
>
> Also the Sailplane guys and gals are essentially breaking the law every 
> time
> they go for an afternoon of flying.
>
>
>
> I'm not sure just how the FAA handles enforcing such a law considering the
> difficulty and expense of proving the altitude of  a model size aircraft
> constructed mainly from wood or plastic. Radar doesn't work well below 500
> feet and wood/ plastic isn't a good reflector, even a 30 % model has a 
> very
> small foot print and would most likely never show up and also would 
> require
> altitude reporting capabilities.
>
>
>
> We do need to keep clear of the UAV distinction. They will no doubt cause 
> us
> (modelers) problems in the future. They want to be considered part of us 
> to
> limit regulation and keep their costs down.
>
>
>
> I'll look into this today
>
>
>
> Thanks for the head's up
>
> Gregory Hahn
>
> Technical Director
>
> AMA
>
>
>
> From: Jim Cherry
> Sent: Thursday, January 24, 2008 10:10 AM
> To: JIM RICE
> Cc: Lance Van Nostrand; Greg Hahn; Dave Mathewson; Robert Underwood Jr.
> Subject: RE: Altitude limits
>
>
>
> All:
>
>
>
> Those  familiar with the AMA position on the interpretation of FAA 
> Advisory
> Circular AC 91-57, with the 400 Ft. limit have always taken the next
> sentence as a part of the (key word here)  ADVISORY... within 3 miles of a
> airport.
>
>
>
> Thanks
> Jim
>
>
>
>
>
> ________________________________
>
> From: JIM RICE [mailto:District8VP at SATX.RR.COM]
> Sent: Wednesday, January 23, 2008 10:17 PM
> To: Jim Cherry
> Cc: Lance Van Nostrand
> Subject: Fw: Altitude limits
>
> Jim,
>
>
>
> Lance has forwarded this for consideration.  I guess it would fall into 
> Greg
> Hahn's area.  Seems doable but needs a professional look and I am not that
> guy.
>
>
>
> Thanks, see you tomorrow,
>
>
>
> JR
>
> ----- Original Message ----- 
>
> From: Lance Van Nostrand 
>
> To: JIM RICE 
>
> Sent: Wednesday, January 23, 2008 5:14 PM
>
> Subject: Fw: Altitude limits
>
>
>
> Jim,
>
>
>
> Thought you might already be aware of this, or might be able to help.
> AMA is our national SIG for flying models so if our political 
> representation
> in Washington was not aware of this they should be.  If they are and there
> is an implied waiver for us modelers then we might all benefit from this
> information.  If a waiver needs to be fought for, then let's initiate that
> process.
>
>
>
> Let me know if this needs escalating.
>
> Thanks,
>
> --Lance
>
>
>
> ----- Original Message ----- 
>
> From: Keith Hoard 
>
> To: NSRCA Mailing List 
>
> Sent: Wednesday, January 23, 2008 12:33 PM
>
> Subject: Re: [NSRCA-discussion] Fwd: Altitude limits
>
>
>
> Perhaps the AMA should contact the FAA about getting all of the 
> established
> model fields a fixed chunk of airspace up to, say, 1000 AGL and 1/2 mile
> radius.  The vast majority of model fields in the US would extend into
> uncontrolled airspace so it wouldn't be a problem and then people can quit
> worrying about the AC.  This would most likely end up being a simple 
> NOTAM,
> but it would finally put this issue to rest.
>
> There are many types of operations in uncontrolled airspace such as
> full-scale aerobatics, parachuting, model rockets. . . all of them get
> permission to use airspace above 400 AGL, model airplanes should get the
> same authority.
>
> On Jan 23, 2008 10:05 AM, chris moon  wrote:
>
> Here is the important excerpt from the clarification of policy letter:
>
> "Model aircraft should be flown below 400 feet above the surface to avoid
> other aircraft in flight."
>
> There is a BIG difference as far as the feds are concerned between the 
> words
> "should" "shall" and "must".  We are not regularly above 400 feet 
> throughout
> a flight and frankly have no means of determining our altitude accurately,
> so I don't see how this is any big change for us.
> The intent was of course to regulate the big UAV craft and they had to
> mention our models so that the big UAV guys could not claim their planes
> were just hobbyist models.
>
> Chris
>
> James Oddino wrote:
>
>
>
>
>
> Begin forwarded message:
>
>
>
>
>
> From: Bryan Hudson 
>
> Date: January 22, 2008 10:00:42 PM PST
>
> To: James Oddino 
>
> Subject: Re: Fwd: [NSRCA-discussion] Altitude limits
>
>
>
> Jim,
>
> That used to be correct up till Feburary last year. Long story short.
> FAA (Advisory Circular) AC 91-57 for model airplanes has been around since
> 1981. It "advises" fly models below 400 feet AGL (above ground level).
> Because of the growing unmanned aircraft industry, last February the NTSB 
> /
> FAA issued a "Policy Statement" in the Federal Register officially making 
> AC
> 91-57 the "Authority" under which models will be flown. So as of last Feb.
> fly below 400 AGL is federal law. This information has recently been added
> to the FAA's own web site, and now it looks like the new policy is being
> enforced.
>
> New regulation on FAA's web site www.faa.gov 
>
> To fly a UAS you must have an (Experimental Airworthiness Certificate) 
> EAC,
> unless you are a hobbyist and intend to fly your model aircraft in
> accordance with the guidance in AC 91-57 "Model Aircraft Operating
> Standards."
>
> In other words, if you want to fly higher than AC 91-57 allows (above 400
> AGL) then you must have an EAC. EACs are not being issued to modelers so
> don't even think about that.
>
> You can find the Federal Register Policy Statement that lays this out on
> this site also.
>
> Go to
>
> www.faa.gov 
>
> then click on:
>
> Aircraft Tab
>
> Aircraft Topics - Aircraft Certification
>
> Design Approvals
>
> Types of Aircraft - Unmanned Aircraft
>
> At this point click on Regulations and Policies for links to::
>
> * Advisory Circulars - AC 91-57 Model Aircraft Operating Standards
>
> * Policies - Federal Register Notice - Clarification of FAA Policy
> 
> otice_uas.pdf>
>
> Or after Unmanned Aircraft click on FAQ for statement on FAA's web site.
>
> Bryan
>
>
>
> James Oddino  wrote:
>
>
>
>
>
> Begin forwarded message:
>
>
>
>
>
> From: Ed White 
>
> Date: January 21, 2008 1:13:55 PM PST
>
> To: NSRCA Mailing List 
>
> Subject: Re: [NSRCA-discussion] Altitude limits
>
> Reply-To: NSRCA Mailing List 
>
>
>
> It is written in FAA Advisory Circular AC 91-57, dated June 9, 1981.
> You can download it from the the FAA website (www.faa.gov
>   and then type AC 91-57 into the search box).
>
> It says "Do not fly model aircraft higher than 400 feet above the
> surface." This applies to any location. But because the next sentence says
> "When flying aircraft within 3 miles of an airport, notify the airport
> operator ..." some people misinterpret the requirement as 400 feet only 
> when
> within 3 miles of an airport.
>
> The key point is that it is an ADVISORY Circular. It outlines the
> FAA's preferred model aircraft operating standards, but compliance with 
> the
> AC is voluntary. An AC is not the same as a FAR (Federal Aviation
> Regulation).
>
> Ed
>
> Mark Atwood  wrote:
>
> It was always my understanding that we were never supposed to exceed
> 400 ft
> and that full scale aircraft were to stay above 500ft. But I'm not
> sure
> where that's written...
>
> -M
>
>
> On 1/21/08 2:35 PM, "James Oddino" wrote:
>
> > I'm getting some breaking news that there is some type of advisory
> > that says we shouldn't be flying above 400 feet at our field in
> > Camarillo. Are there any general rules about altitude limits that
> we
> > should be aware of? We are pretty far from the Camarillo airport
> and
> > never get close to any full size stuff so I don't understand why
> there
> > would be a local restriction. More to follow I'm sure.
> >
> > Jim O
> > _______________________________________________

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