[NSRCA-discussion] Update - UAS Registration Frequently Asked Questions | AMA Government Relations Blog

Fri Jan 15 19:10:47 AKST 2016

By the way folks, today is the last day to put in a public comment.  Here's
mine:

While I understand and support the FAA's intent behind the registration
requirement: to reach and educate people as they acquire model aircraft,
hopefully discouraging irresponsible use; the current regulation casts too
wide a net!   Model aircraft have been SAFELY operating in the NAS for 80
years!  Yes, the past decade of innovation that originated in the model
aircraft community has led to amazing capabilities in autonomous flight and
first-person view flight, both of which, to a greater or lesser extent
enable unmanned aircraft systems to be operated beyond visual line of sight
and that revolution introduces new risk to the NAS, but, there is a bright
line here that can clearly distinguish "traditional" model aviation which
has, and will continue to be, managed safely by the members and clubs of
the Academy of Model Aeronautics (AMA) from "potentially irresponsible"
model aviation and that line is the introduction of autonomous or
semi-autonomous flight control systems in the on-board electronics.

Quite simply, one cannot learn to fly a traditional model aircraft on their
own (youtube is full of videos of people trying to, and crashing within
seconds of launch) which leads people to seek out AMA clubs and
instructors.  As the lead instructor for a club of 480 members, I have
personally taught more than 100 people to fly, and our club has taught
hundreds more.  The very first thing we teach is "see and avoid".  There
isn't a person at our field or any other AMA field I have visited around
the country, that does not know what to do when they see, or when someone
at the field sees and yells "full scale" -- you bring your aircraft down --
preferably landing, but at the very least operating below 100' to maintain
a good margin of safety.  Many model aircraft activities DO involve flight
above the "400 foot AGL" limit suggested by AC91-57A and the FAA
registration site.  Precision aerobatics has aerobatic box corners that
reach 867 feet AGL, cross-country glider events involve altitudes above
1000 feet (all in visual line of sight, these gliders have 3-4 meter
wingspans).  Contests like these have been conducted safely for decades and
there is no reason they cannot continue for decades more unless the FAA
imposes arbitrary blanket limits like 400' AGL rather than the more
reasonable precautions of AC91-57 or 57A which impose the 400' limit within
3-5 miles of a PUBLIC airport (covered by the AMA safety code as well)
unless an agreement has been reached with the local airport (I am aware of
fields that are within 3 miles of a public airport which have arranged for
a standing NOTAM of model aircraft operations in a specific area with a
ceiling of 1200 feet AGL.  Further safety is possible by including model
airfields on full scale sectional maps so that pilots are aware of the
model aircraft operations just as model aircraft pilots see and avoid the
full scale aircraft.

Irresponsible use is a result of ignorant use, ignorant use is possible
only with autonomous or semi-autonomous flight systems.  Those same systems
rely on GPS and/or attitude & altitude sensors and therefore ignorant use
can be prevented through technology, geofencing 5 miles around public
airports, preventing ascent above 400 feet AGL, etc.  Simple
"acknowledgement" of "guidelines" on an FAA registration website is hardly
going to prevent or even discourage the irresponsible user.  In fact, even
with literature about registration in every box, the irresponsible user is
going to pull the "toy" out of the box and start using it.

The President has suggested using technology to help reduce irresponsible
and dangerous gun use, why not apply the same principles to model aircraft
use?

Finally, the model aviation community is your best defense against
malicious use of model aircraft.  The misguided plot to fly a radio control
jet laden with explosives into the white house was stopped because alert
modelers raised the flag with appropriate government agencies.  It is in
the best interests, not only of the NAS, but of national security, to
encourage and support responsible model aviation.

Thank you for your time,
Peter Vogel
AMA Life Member L732
AMA Intro Pilot
AMA District X Associate Vice President
Tresurer, National Society of Radio Control Aerobatics

On Fri, Jan 15, 2016 at 7:48 PM, Ed Alt <ed_alt at hotmail.com> wrote:

> I haven't seen any lawyers weigh in yet, so the rank amateur opinions
> continue on.  Mine included.  This is similar to what I was saying about
> "shall" and "will" a couple of weeks ago.  There's a distinction in what
> the words mean in a contract, but I don't think that it guarantees that you
> won't find yourself in hot water that is expensive to get out of if
> someone, somehow determines that you've violated an "intent".  Don't get me
> wrong, this seems to be progress.
> ------------------------------
> Date: Fri, 15 Jan 2016 19:27:37 -0800
> To: danamaenia at me.com; nsrca-discussion at lists.nsrca.org
> CC: jpavlick26 at att.net
>
> Subject: Re: [NSRCA-discussion] Update - UAS Registration Frequently Asked
> Questions | AMA Government Relations Blog
> From: nsrca-discussion at lists.nsrca.org
>
> 6.e uses the word "should", not "must" and that's a very important legal
> distinction, making that a guideline, not a requirement.  Further, as they
> said on Sunday, they are aware they got that wrong and are working with the
> AMA to fix it.
>
> Peter+
>
> On Fri, Jan 15, 2016 at 7:10 PM, Dana Beaton via NSRCA-discussion <
> nsrca-discussion at lists.nsrca.org> wrote:
>
> 6.e is a real eye-opener, and a lot less ambiguous than 91-57 was in its
> original form. Will be interesting to see what AMA gas to say about it.
> Thanks for the link!
>
> Sent from my iPad
>
> On Jan 15, 2016, at 7:59 PM, Mking via NSRCA-discussion <
> nsrca-discussion at lists.nsrca.org> wrote:
>
> Has anyone from the AMA commented on the new FAA Advisory Circular 91-57A
> Change 1?
>
>
> http://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_91-57A_Ch_1.pdf
>
> Marty King
> A&P/IA
> mking at kingaeroaviation.com
>
> King Aero Aviation, Inc.
> 574-304-5781
>
> Shop:
> 24751 US 6
> Nappanee, Indiana 46550
>
> Office:
> 56632 Boss Blvd
> Elkhart, Indiana 46516
>
> www.kingaeroaviation.com
>
>
>
> On Jan 15, 2016, at 8:32 PM, John Pavlick via NSRCA-discussion <
> nsrca-discussion at lists.nsrca.org> wrote:
>
> And to that end I PROMISE not to shoot anyone unless they actually break
> into my house. Now is it OK if I buy some 30 round mag’s for my AR-15? LOL
>
>
>
> John Pavlick
>
> Cell: 203-417-4971
>
>
>
> <image001.png>
>
> Integrated Development Services
>
>
>
> *From:* NSRCA-discussion [mailto:nsrca-discussion-bounces at lists.nsrca.org
> <nsrca-discussion-bounces at lists.nsrca.org>] *On Behalf Of *Ed Alt via
> NSRCA-discussion
> *Sent:* Friday, January 15, 2016 7:09 PM
> *To:* Dave Lockhart
> *Cc:* General pattern discussion
> *Subject:* Re: [NSRCA-discussion] Update - UAS Registration Frequently
> Asked Questions | AMA Government Relations Blog
>
>
>
> But Dave, did you like your doctor?  The promise was "if you like your
> doctor, you can keep your doctor".
>
>
> On Jan 15, 2016, at 7:06 PM, Dave Lockhart <davel322 at comcast.net> wrote:
>
> I have lots of video promising I can keep my doctor……
>
>
>
> *From:* NSRCA-discussion [mailto:nsrca-discussion-bounces at lists.nsrca.org
> <nsrca-discussion-bounces at lists.nsrca.org>] *On Behalf Of *Ed Alt via
> NSRCA-discussion
> *Sent:* Friday, January 15, 2016 6:42 PM
> *To:* Peter Vogel <vogel.peter at gmail.com>; John Gayer <jgghome at comcast.net>;
> NSRCA List <nsrca-discussion at lists.nsrca.org>
> *Subject:* Re: [NSRCA-discussion] Update - UAS Registration Frequently
> Asked Questions | AMA Government Relations Blog
>
>
>
> Anyone get that on video?  It's just hearsay until they put it into their
> regulations.  Meanwhile, we're signing up to a promise not to exceed 400'.
>  It would be nice to have that video for the trial.  lol
> ------------------------------
>
> Date: Fri, 15 Jan 2016 15:39:07 -0800
> To: jgghome at comcast.net; nsrca-discussion at lists.nsrca.org
> Subject: Re: [NSRCA-discussion] Update - UAS Registration Frequently Asked
> Questions | AMA Government Relations Blog
> From: nsrca-discussion at lists.nsrca.org
>
> Yep.  This was brought up directly with the FAA guy at the AMA Expo, he
> indicated that they got the 400' thing wrong and will be working to clarify
> their guidance.  The guidance on the web site right now is for people not
> flying under an approved set of rules from a community based organization
> like the AMA.
>
>
>
> Peter+
>
>
>
> On Fri, Jan 15, 2016 at 3:32 PM, John Gayer via NSRCA-discussion <
> nsrca-discussion at lists.nsrca.org> wrote:
>
> This is what the AMA says about the 400 foot barrier on the FAQs page:
>
>
>
>
> *Q: Am I permitted to fly above 400 feet? What if I had to check a box
> saying otherwise on the federal registration website?*
>
> A: Yes. AMA members who abide by the AMA Safety Code, which permits
> flights above 400 feet under appropriate circumstances, and are protected
> by the Special Rule for Model Aircraft under the 2012 FAA Modernization and
> Reform Act. Checking the box on the federal registration webpage signifies
> an understanding of the 400 foot guideline. This is an important safety
> principle that all UAS operators need to be aware of, and is the same
> guideline established in AC 91-57 published in 1981. However, the placement
> of this guideline on the FAA website is intended as an educational piece
> and more specifically intended for those operating outside of AMA’s safey
> program.  We have been in discussions with the FAA about this point and the
> agency has indicted that it will be updating its website in the next week
> to make clear that this altitude guideline is not intended to supplant the
> guidance and safety procedures established in AMA’s safety program.
>
>
> Sounds clear, right? No 400 foot barrier need apply.
> However, the following is what you have to "read, understand and follow",
> according to the FAA.
>
>
> Acknowledgement of Safety Guidance
>
>    - I will fly below 400 feet
>    - I will fly within visual line of sight
>    - I will be aware of FAA airspace requirements: www.faa.gov/go/uastfr
>    - I will not fly directly over people
>    - I will not fly over stadiums and sports events
>    - I will not fly near emergency response efforts such as fires
>    - I will not fly near aircraft, especially near airports
>    - I will not fly under the influence
>
> Learn More <http://www.faa.gov/uas/publications/model_aircraft_operators/>
>
> [ ] I have read, understand and intend to follow the safety guidance.
>
>
> Under the "learn more" link, we find the following:
>
>
>
> Model Aircraft Operations Limits
>
> According to the FAA Modernization and Reform Act of 2012 as (1) the
> aircraft is flown strictly for hobby or recreational use; (2) the aircraft
> is operated in accordance with a community-based set of safety guidelines
> and within the programming of a nationwide community-based organization;
> (3) the aircraft is limited to not more than 55 pounds unless otherwise
> certified through a design, construction, inspection, flight test, and
> operational safety program administered by a community-based organization;
> (4) the aircraft is operated in a manner that does not interfere with and
> gives way to any manned aircraft; (5) when flown within 5 miles of an
> airport, the operator of the aircraft provides the airport operator and the
> airport air traffic control tower…with prior notice of the operation; and
> (6) the aircraft is flown within visual line sight of the operator.
>
>    - More information about safety and training guidelines
>    <http://www.faa.gov/exit/?pageName=More%20information%20about%20safety%20and%20training%20guidelines&pgLnk=http://www.modelaircraft.org/>
>    - Visit knowbeforeyoufly.org
>    <http://www.faa.gov/exit/?pageName=Visit%20knowbeforeyoufly.org&pgLnk=http://www.knowbeforeyoufly.org/>
>
>
>
> This implies that the 400 foot barrier is not a limit for model aircraft
> and also refers you back to the AMA FAQs above.  Since the "learn more"
> link eventually refers you back to the AMA position on 400 feet under the
> "more info about safety"  link, it very fuzzily appears to be supporting
> the position that we can still fly pattern without lying to the FAA even
> though we appear to be agreeing to such a limit in the "Acknowledgement".
>
> Guess I'll register.
>
>
>
> On 1/15/2016 3:56 PM, Patternpilot One via NSRCA-discussion wrote:
>
> Here is what I got from Mark Radcliff just after  midnight Monday morning.
>
>
>
> He was at the Expo.  It has been posted all over Facebook.
>
>
>
>
>
>
> http://amablog.modelaircraft.org/amagov/2016/01/11/update-uas-registration-frequently-asked-questions/
>
>
>
> Sa.
>
>
>
>
>
> Sent from my Verizon Wireless 4G LTE smartphone
>
>
>
>
> _______________________________________________
>
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>
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>
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>
>
>
>
> --
>
> Director, Fixed Wing Flight Training
>
> Santa Clara County Model Aircraft Skypark
>
> Associate Vice President, Academy of Model Aeronautics District X
>
> Treasurer, National Society of Radio Control Aerobatics (NSRCA)
>
> <image001.jpg><image002.jpg>
>
>
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>
>
>
> --
> Director, Fixed Wing Flight Training
> Santa Clara County Model Aircraft Skypark
> Associate Vice President, Academy of Model Aeronautics District X
> Treasurer, National Society of Radio Control Aerobatics (NSRCA)
>
>
> _______________________________________________ NSRCA-discussion mailing
> list NSRCA-discussion at lists.nsrca.org
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>

-- 
Director, Fixed Wing Flight Training
Santa Clara County Model Aircraft Skypark
Associate Vice President, Academy of Model Aeronautics District X
Treasurer, National Society of Radio Control Aerobatics (NSRCA)
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