[NSRCA-discussion] FAA Rule Comments

[ronlock at comcast.net]

OK, my draft should be attached.   Feel free to utilize, rephrase, etc. 

Ron Lockhart 



----- Original Message -----


From: "Richard Lewis" <humptybump at sbcglobal.net> 
To: ronlock at comcast.net, "General pattern discussion" <nsrca-discussion at lists.nsrca.org> 
Sent: Thursday, July 10, 2014 4:46:36 PM 
Subject: Re: [NSRCA-discussion] FAA Rule Comments 


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 

----- Original Message -----




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: 

<blockquote>

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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