[NSRCA-discussion] FAA Rule Comments

[steve hannah]

Here's a PDF of my submittal.  It was too long to directly post so I
submitted a summary and attached this doc.


On Thu, Jul 10, 2014 at 1:46 PM, Richard Lewis via NSRCA-discussion <
nsrca-discussion at lists.nsrca.org> wrote:

> Ron,
>
> Any chance of seeing your draft response here for our reference...?
>
> Richard
> Sent from my mobile device.
>
> On Jul 10, 2014, at 3:36 PM, ronlock--- via NSRCA-discussion <
> nsrca-discussion at lists.nsrca.org> wrote:
>
> As well as sending your own letter or email commentary, encourage others
> to comment.
>
> Last evening at my local club meeting I briefed members on the issue,
> provided some
>
> documents, my draft response, and encouraged all to get comments into into
> the system
>
> before July 25
>
>
>
> Ron Lockhart
>
> ------------------------------
>
> *From: *"SilentAV8R via NSRCA-discussion" <
> nsrca-discussion at lists.nsrca.org>
> *To: *"General pattern discussion" <nsrca-discussion at lists.nsrca.org>
> *Sent: *Thursday, July 10, 2014 4:16:42 PM
> *Subject: *Re: [NSRCA-discussion] FAA Rule Comments
>
> I'm with Steve on this one. Make your voice heard or live with the
> consequences of silence. As far as the 400 rule I think they mention it and
> AC 91-57 mostly as a means of establishing their history of actively
> "regulating" models. I see no mention of it moving forward or in the Public
> Law Section 336.
>
> Bill
>
> On 7/10/14, 1:09 PM, steve hannah via NSRCA-discussion wrote:
>
> As I am sure most of you are aware, the recent FAA interpretation is an
> active rule and is open for comment until July  25.
>
> Everyone needs to take a few minutes and read the rule and submit comments
> directly to the FAA.  No petitions or form letters.  Numbers matter.
>
> http://www.regulations.gov/#!docketDetail;D=FAA-2014-0396
>
> The rule has some really troubling things in it which will impact or shut
> down major portions of model aviation.  It is important that the ambiguous
> items, unacceptable items, or overly restrictive items be removed or
> clarified.
>
> One major aspect which affects us is their overly broad definition of
> commercial operations.  basically, anyone that helps a manufacturer in
> furthering their business (i.e. testing a product or aircraft, advertising,
> selling, etc.) is in violation of the published rule.  So, no sponsored
> pilots, no cash or prizes at contests, no manufacturer reps, and no US
> manufacturers or reps that test their products in US airspace.
>
> Another one is their repeated reference to the old AC 91-57 which has,
> amongst other things, a 400' altitude limit.
>
> If you don't want to live with these things (which are law already), then
> you have just 15 days to try and overturn them or get them clarified.
>
> Steve
>
>
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>
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