Commercial sUAS petition is live at Whitehouse.gov

Bartman · Jul 10, 2014

The new website is up and running at www.understandingsUAS.com. it's a work in progress so check back from time to time for updated content.

JoeBob · Jul 10, 2014

Comment to the FAA. Right now there are so few comments that the MR community looks like only a dozen wackos.
Don't be afraid. They already know who you are and where you live. If you're too lazy to write your own letter, copy mine from below. Please.

http://www.regulations.gov/#!submitComment;D=FAA-2014-0396-0001

Be reasonable?

FPV with a spotter is safer than LOS in many situations.

Prohibiting 'for hire' flights adds no safety to the public.
If anything, forcing operators to work on the sly prevents the creation of reporting mechanisms for any unsafe flyers.

A simple flight test and equipment certification that accounts for current and allows for future UAV tech would be desirable.
Go back and read 'simple'.
Again. (Thanks)

AMA rules should apply.

JoeBob · Jul 10, 2014

Well spedudle!

At 3:45pm the petition website showed 304 signatures. I kept hitting refresh to get my signature to show up as 305.

At 9:20pm 18,755 signatures showed.

I like it! What did you do, Bart?

baileysookie · Jul 10, 2014

Adopting UK standards is not a good thing at all, there goes taking photo's of real estate then, as most real estate is in built up areas, maybe also signing this petition too? https://petitions.whitehouse.gov/pe...ntrol-aircraft-andor-paper-airplanes/kHsRbnPp

Bartman · Jul 10, 2014

JoeBob said:
Well spedudle!

At 3:45pm the petition website showed 304 signatures. I kept hitting refresh to get my signature to show up as 305.

At 9:20pm 18,755 signatures showed.

I like it! What did you do, Bart?

i'm still seeing 304

Bartman · Jul 10, 2014

baileysookie said:
Adopting UK standards is not a good thing at all, there goes taking photo's of real estate then, as most real estate is in built up areas, maybe also signing this petition too? https://petitions.whitehouse.gov/pe...ntrol-aircraft-andor-paper-airplanes/kHsRbnPp

taking photos of real estate would be a perfectly legitimate use, I'm not sure why you'd read it to mean you couldn't?

But honestly, a petiton to ban the FAA from regulating rc planes and paper airplanes gets more votes than a petition to have a working set of regulations adapted to the US airspace system thus freeing us to get licensed and back to work?

If there's no interest in promoting this idea then there's nothing I can do to force it along. I'm not one to bang my head against a wall for too long when people aren't willing to even click a box saying they want their own interests represented.

stitch1615 · Jul 11, 2014

Bartman said:
Hi everyone,
We've been discussing this in another thread and it's now live at whitehouse.gov. The link to sign the petition is
https://petitions.whitehouse.gov/pe...ommercial-suas-standards-immediately/2vbvcC0C
I've also penned a cover letter so that you can send a request to EVERYONE YOU'VE EVER MET asking them to sign the petition

Hi Bart and I applaud your initiative in creating this petition however, the government does not care about
100 petitions with 1000 signatures, it only cares about one petition with 100,000 signatures.
It's for every club, blog and forum in America to request this but it would be equally, and I believe, more beneficial for those 100,00 to support the AMA lobbyist who are the voice heard in DC.
Paul Brown, the president of the AMA, fly's FPV himself so he has a stake in the matter and has an entire staff of advocates.

Additionally, the people who do care are the ones that need our votes and when enough letters hit their desk's they sit up and take note.
Urge people to also send this letter to their elected representatives.
Frankly, with all they have on their plate, I assure you this is pretty close to the bottom but, none the less, if it is under their nose they will have to look at it.
I have signed many of these petitions and forwarded them to my congressional reps and am hopeful that they will guide the FAA in approval of some commercial application of MR's.

Actually, I believe that the FAA has already made up it's mind and will stick to the existing rules and will make very few changes in the end.
The rules cover everything they want but they may be further defined to address "drones" and their use.
I don't believe we will find it favorable where FPV and commercial use are concerned and will have to continue the fight.

JoeBob · Jul 11, 2014

I looked at the number closest to the FAA petition:
View attachment 19112

I didn't notice the thin grey lines.
BTW: I named the screenshot Idiot.jpg.

Av8Chuck · Jul 11, 2014

Bartman said:
taking photos of real estate would be a perfectly legitimate use, I'm not sure why you'd read it to mean you couldn't?

But honestly, a petiton to ban the FAA from regulating rc planes and paper airplanes gets more votes than a petition to have a working set of regulations adapted to the US airspace system thus freeing us to get licensed and back to work?

If there's no interest in promoting this idea then there's nothing I can do to force it along. I'm not one to bang my head against a wall for too long when people aren't willing to even click a box saying they want their own interests represented.

I've said this before, the value in your petition was not the petition itself but the effort to organize people around a common cause. Trouble is the common cause isn't the rules but the desire to operate an sUAS business profitably. The AMA does a good job of representing the hobby but there is no organization that represents the small aUAS business owners that I'm aware of. There's undoubtedly members of the AMA that would like to start an AP business, they would be good candidates for membership into an organization that would represent their interests but the petition didn't address those concerns, it addressed the rules and if your going to debate the rules, then stitch1616 is right, the AMA, the organization they already belong to is in a better position to represent them. However, the AMA does not represent the rights of small business and probably finds doing so would be antithetical to their mission so although they may not be overtly opposed to it they will damn it with faint praise.

So I hope that you are coming to the realization that the issue is not about the interest for flying paper airplanes versus a working set of regulations adapted to the US airspace system, its about defining the needs of your constituents and creating messaging that supports those needs and then developing the mechanisms to get those messages out there on the scale necessary.

The reason I keep hammering this point to you is not because I'm a troll but because you've already accomplished a lot of the heavy lifting, you own a website where approximately 15,000 people who do care about their ability to make a living in commercial sUAS congregate. The people here only care about the rules as it relates to their ability to work commercially. Replacing one set of confusing rules with another only served to confuse people more and confused people don't do anything. That's no reflection on you or me, that's just the way that it is.

So I think if you don't want to bang your head against the wall you need to decide was this effort about the petition or about protecting the rights of people who want to do what they love for a living. If its about the petition then you already have your answer in the 300 or so signatures, if its about the latter then I suggest taking two aspirin and the reaching out to those on this forum who really want to help solve this issue.

No one said this would be easy.

Bartman · Jul 12, 2014

stitch1615 said:
Hi Bart and I applaud your initiative in creating this petition however, the government does not care about
100 petitions with 1000 signatures, it only cares about one petition with 100,000 signatures.
It's for every club, blog and forum in America to request this but it would be equally, and I believe, more beneficial for those 100,00 to support the AMA lobbyist who are the voice heard in DC.
Paul Brown, the president of the AMA, fly's FPV himself so he has a stake in the matter and has an entire staff of advocates.

Additionally, the people who do care are the ones that need our votes and when enough letters hit their desk's they sit up and take note.
Urge people to also send this letter to their elected representatives.
Frankly, with all they have on their plate, I assure you this is pretty close to the bottom but, none the less, if it is under their nose they will have to look at it.
I have signed many of these petitions and forwarded them to my congressional reps and am hopeful that they will guide the FAA in approval of some commercial application of MR's.

Actually, I believe that the FAA has already made up it's mind and will stick to the existing rules and will make very few changes in the end.
The rules cover everything they want but they may be further defined to address "drones" and their use.
I don't believe we will find it favorable where FPV and commercial use are concerned and will have to continue the fight.

Stitch,

There are two things happening at the moment, both are a result of the FAA's interpretation.

The first is that the FAA is trying to prohibit RC flying via a video feed from the aircraft (aka FPV). This is an important issue for those that fly FPV and to a lesser degree those that use FPV techniques as a way to shoot better pictures and video. With it primarily being the concern of hobbyists, the AMA is the best organization to address the problem and it should be mostly hobbyists that are writing to the FAA to weigh in in on the issue.

The second thing being done is that the FAA appears to be using the "interpretation" to better define hobby use which will have the secondary effect of better defining commercial use. Commercial uses for sUAS class aircraft have thus far been represented by nobody. Not the AMA, not the AUVSI, not the RCAPA (even though they represented themselves as such from the beginning, they've done a lot more self promotion than any real advocacy)....nobody has taken up the cause of representing the commercial, small, unmanned aerial systems operators.

Chuck has suggested many times his position that a PAC would be a good idea but to date I don't know if he has done anything to get started with it.

So that brings us to the petition I've posted at whitehouse.gov. The petition wasn't intended to be the end-all, be-all of sUAS lobbying efforts and I'm as skeptical as anyone as to whether or not 100,00 signatures is even possible. Judging from the lack of signatures so far it's probably safe to say that the petition won't get 100,000. The value of the petition is that it brings to light the fact that where the FAA is bogged down by analysis-paralysis, other countries are moving on and benefitting from the very cost-effective services enabled by commercial sUAS operations. 100,000 signatures would certainly tell the politicians that a lot of people are paying attention and might be enough to force some frank discussions in Washington. Such might get the FAA to finish their draft regulations by the end of 2014 as they are currently forecasting. If 2014 is going to be another deadline to slip and fail then maybe big petition participation would give lawmakers an option that is very viable and proven by practical application to put in front of the FAA for their consideration.

Keep in mind, the FAA and Congress adopted the Age 65 retirement rule for commercial pilots more because ICAO had already implemented it than because of real scientific data.

We're playing catch up in trying to do anything regarding commercial sUAS operations. Unlike a lot of the players coming out of the woodwork to weigh in on the FAA's interpretation, multirotorforums.com HAS ALWAYS TRIED TO BUILD A BETTER COMMUNITY BY PREACHING SAFE HABITS AND RESPONSIBLE OPERATIONS. How many others have?

www.understandingSUAS.com is going to be around for a while although the sUAS space is certainly going to get very busy very quickly. MultiRotorForums.com is also going to be around for a while and will only get better in the coming months. We must all continue to preach safety and responsibility whether it's hobby or professional flight operations and wherever possible we must continue to bring attention to what is going on with the FAA's attempts to regulate model aircraft operations and commercial sUAS operations.

coreyperez · Jul 23, 2014

Bart and Crew...

I'm opening this up for review. Below is my proposed letter I'm posting to the whole FAA instance. You may be able to read my annoyance in the whole thing, but I tried to keep it together. This is my current draft.

FAA,

I’d like to submit my opinion regarding the recent Interpretation of the rule regarding Model Aircraft.

Model Aircraft is in many facets nothing that is subject to FAA rule thus would not be under government review/control. I understand that FAA does regulate airspace, classification and the safety of movement passenger aircraft. Model aircraft (Hobby) almost always operates within airspace that no manned aviation asset has a sensible right to be operating within. If there was a conflict of airspace, the manned aircraft in question would already be in a position/situation that impending doom was occurring, and this is regardless of the existence of any type of UAS in the same airspace. This would obviously be the situation within any controlled airspace to the surface, excluding the IMMEDIATE operating surface area of an airport. With this statement/intent, the FAA must also take into consideration Kites, Balloons and any other form of “non-natural” obstructions. Since this has not been included, it is therefore the highly (and irrational segregation of UAS, model/hobby and hobby level commercial) that is openly seen as an attack on a specific group of people within the United States. This, will NOT be tolerated.

While on the subject of non-natural obstructions, the FAA has no power regarding the building of physical assets such as towers, sky-scrapers or antenna. These can be hundreds of feet into controlled airspace as well. While these are obvious obstructions and typically “known” obstructions, aviators (to which I am included) for all sensible reasons, do not fly near the ground unless landing at an approved area. Once again, refocusing on the blatant attack on a specific group of US Citizens.

Since the FAA requires a 500 foot rule for manned aircraft (above the surface except in sparsely populated areas, to which aircraft should not come closer to 500 feet from people, vessel, vehicle or structure), there is absolutely no sensible reason that the FAA should be attempting to grossly expand their rights to rule into a realm they have no reason or justification controlling.

First Person View (FPV), while to the untrained and uneducated opinion may seem “hazardous”, common sense should be applied and reasonable thoughts should be applied. I’m a military Aviator, I fly weekly with aided vision devices, nearly always in densely populated areas, all while using an aided visual device. Once again, typically considered SAFER than unaided flight. The use of FPV devices not only enhances the experience, it promotes safer aviation, ensures safer operation as well as situational awareness.

The FAA has made the senseless argument against the use of goggles or other vision aided devices, presumably because of the possible lack of awareness. I have on numerous times flown “Hooded” flight with absolutely no other visual reference outsize the cockpit. I solely depend upon a “spotter” to ensure the safety of my multi-million dollar aircraft, crew and myself all while in densely populated areas. This is exactly the same type of operation as with two people performing FPV, one hobbyist under aided vision device and another as an active spotter. While this should never have become an issue for hobby level performance craft, we are possibly being subjected to unneeded regulations, thus at the FAAs wildly expanding (beyond Congress’s FAA approved) governances. Simply, the FAA seems to be lashing out at hobbyist when commercial use of Unmanned Aerial Systems in controlled airspace at distances (10+ miles) and significant altitudes (1000’ AGL) are what the FAA should be focused on.

We as a country are seriously lacking behind other countries with this technology. The continued expansion of this technology is growing faster than anybody could have imagined it would a few years ago. As hobbyist, the technology has far distanced what was available, the uses, development of this new technology and devised safety-of-flight has grown. This is especially true with the dying love for General Aviation. This impasse is due to the wasteful regulations and Trial Lawyers causing the costs to become only reachable by the elite. To continue to try and impede in those that enjoy flying model aircraft is unfounded, it is wasteful of taxpayer’s money and a trivial attempt at making a name for somebody in your Agency. This time and money that has been spent should have been spent making manned aviation safer. I have had (in controlled airspace) had 2 near misses, the most recent while on an instrument approach, under the control of a final controller (PAR). THESE are the issue that the FAA should be focused on, improving safety of flight, not trying to shutdown weekend father and son/daughter and group/solo (hobbyist) flights/gatherings.

In the United States, if the FAA continues to try and shut down model aircraft/aviation it is seriously undermining what the United States is all about. We are a country built on commerce, ideals and freedoms. Limiting the ability to develop income, constricting the hobby and even outlawing the idea of a citizen making money with RC aircraft is ridiculous. According to the IRS, a hobby is not taxable, how the FAA believes they can impose their misguided belief into something they have no regulative power over is unfathomable. If a pilot in an aircraft enjoys photography, they then take a photo while flying and sells it, the act is not considered “commercial”, but just a hobby. Now, If a RC aircraft is flow and a photo is sold that was captured from it the FAA is attempting to label the act as commercial. Absolutely ridiculous.

US Senator Sean Maloney has proven (first hand) that the implementation of UAS for personal and commercial use is not only practical, but it is safer, worthwhile, more efficient, and notably less harmful to the environment in all aspects. Quite simply, the fact that this issue of RC Aircraft being used in the airspace above the United States is a complete waste of time, tax payers money/assets. It is absolutely undeniable in proof that those with power are abusing what they perceive to be “their right” while imposing on the actual rights of citizens (as described by congress) for their (FAA’s) own personal gain.

In closing, the FAA needs to understand that manned aviation is rapidly approaching its expiration date. UAS far exceeds the limitations, capabilities, safeties, and usefulness of manned aviation. In nearly all points of aviation, the limiting factor of aviation IS manned use. This senseless attempt at unneeded regulation is a foolish attempt to stall or completely retard the United States in the realm of Aviation.

Manned aviation is today’s 35mm film vs. digital format. While yes, there are some foolish, narrow minded folks that believe light on film (manned aviation) is the only way to conduct business, but that is absolutely nothing but nonsense. UAS, both commercial and hobby is the best way to continue to develop as a country, economy, hobby, and front runner in aviation. This is the United States, we as citizens will stand our ground and continue to pursue our passions and develop technology. Attempting to limit and squander this development for your personal gain will not go unnoticed. The FAA needs to understand that UAS IS an emerging technology, the uses of far outweigh the perceived negative aspects. Think of how aviation has developed since the Wright Brothers in 1903. These types of advancements would not have been possible with the foolish squandering of technology that the FAA is attempting to implement. The FAA needs to rethink their short term goals and re-focus on what has made America great and what will keep us great.

Corey Perez
US Army UH60 Rotary Wing Aviator (Private, Commercial, IFR, Multi-Engine, Turbine engine) pilot and RC Hobbyist

Av8Chuck · Jul 23, 2014

Here's the comment that I submitted.

sUASSBC

The Honorable Michael P. Huerta Administrator Office of the Administrator
Federal Aviation Administration
800 Independence Avenue SW
Washington, DC 20591

July 20, 2014

Re: FAA-2014-0396 Interpretation of the Special Rule for Model Aircraft

Dear Administrator Huerta:

This sUAS Small Business Consortium comment represents a group of business people, including their respective organizations, who are deeply concerned about the proposed rule making governing the use of model aircraft in U.S. airspace.

It is our position that the rules submitted for comment are flawed in a fundamental way in that they do not address the needs, and opportunities, of the business community to avail of model aircraft for commercial purposes, other than to declare that activity illegal. The clear intent of Congress was for the FAA to regulate this established and previously growing sector in its entirety, not just the hobby segment. We embrace that intent. Guidelines do need to be set for the operation of model aircraft in a safe, effective and respectful manner. Hobby and commercial uses are indistinguishable in this respect. The same equipment is being employed by both for pleasure and business respectively.

There are serious negative consequences to not accepting the commercial use of model aircraft as a reality. The shutdown of US airspace to their use literally handcuffs the business community from moving forward, has killed off countless previously existing small enterprises and the jobs provided by them, and prevents the remaining and new ones from taking advantage of the opportunities presented by these technologies. As currently worded, only the largest corporations capable of fulfilling the certification requirements of Part 91 of the existing regulations, which were never intended to apply to model aircraft, would have commercial access to these technologies.

This is a nation which has advanced through grit and hard work motivated by the entrepreneurial spirit of countless generations. Even today, employment creation is largely focused in the small business arena. Underlying this growth is the freedom, within limits, to exploit opportunities created by technological advances and incorporate them in commercial operations, thereby advancing this nation at home and abroad. The freedom to act requires a known regulatory environment, one that sets reasonable limits but avoids to the extent possible, outright suppression of the spirit so well-embedded in our traditions by eliminating access to these technologies.

The rules therefore must fully encompass the commercial use of model aircraft, and set the guidelines for their use by the business community. There are others who have noticed this flaw and addressed it. I take particular note of the comment submitted by the American Modelers Association (AMA), excerpted in part hereinafter.

"FAA’s overreaching interpretation of the language in the Public Law is also evident in the rule’s interpretation of the requirement that model aircraft be “flown strictly for hobby or recreational use.” The application of this requirement is drastically narrowed by the examples provided in the Rule. Although the FAA acknowledges that manned aviation flights that are incidental to a business are not considered commercial under the regulations, the rule states that model aircraft flights flown incidental to a business are not hobby or recreational due to the nexus between the flight and the business. This again is inconsistent with FAA’s current regulatory premise and the assertions of other regulatory agencies such as the Internal Revenue Service. For instance, an individual who owns and operates his own full-scale aircraft for his personal pleasure and recreation is allowed to conduct aerial photography as a private civil operator whether or not he/she intends to sell the photographs. However, under the Interpretive Rule, a model aircraft enthusiast who uses his model aircraft for aerial photography and subsequently sells the photograph to an interested party is no longer considered a hobbyist."

Without also promulgating proposed rules for regulating that same conduct when carried out for commercial gain, there is no way to know whether such regulations would be rational, or arbitrary and capricious.

In conclusion, we respectfully request that the current rules be temporarily withdrawn and rewritten to include another section which sets out guidelines which both regulate and permit the use of model aircraft for commercial purposes.

Respectfully submitted,

Charles Spaulding

stitch1615 · Jul 23, 2014

My favorite argument is the Bow and Arrow and Fire.
Upon being invented the board of governors convened and declared;
"These shall not be allowed because the arrow could put somebody's eye out and the fire hurts my fingers".
There is no room for tecnlogical advances in a bureaucracy if the bureaucrats can't make money on it.
This is all about power and control and will lead to certification and licensing so get on with it and stop the nickle/dime crap.

Mike SF · Jul 23, 2014

coreyperez said:
Bart and Crew...

I'm opening this up for review. Below is my proposed letter I'm posting to the whole FAA instance. You may be able to read my annoyance in the whole thing, but I tried to keep it together. This is my current draft.

......

Very well written!

Old Man · Jul 23, 2014

Very well written but you should review FAA authority over structures. Within a certain distance and routing of federally funded airports they do have authority over structures and population density and have exercised such many times.

Roto5411 · Jul 31, 2014

[FONT=&quot]The following were my comments/thoughts to the FAA regarding their so-called "interpertation"!
**********
The FAA should separate UAS operations into three separate but distinct regulatory categories:

1) The first category, which requires the least amount of regulation, would include hobby or modeler, commercial and public safety UAS operations below 400 ft. AGL, under 55 pounds, outside of controlled airspace (Class E and G) and special use airspace (unless permission is granted from the controlling air traffic facility), and within positive sight of the operator at ALL times. [/FONT]

[FONT=&quot]
2) The second category would include hobby, commercial, and public safety UAS's that possess the capability to fly autonomously using autopilot systems that utilize pre-programmed GPS coordinates and are capable of flying out-of-sight of the operator. Flights would be limited to a height of 400 ft. AGL, outside of controlled or special use airspace (unless permission is granted from the controlling air traffic facility), and within a distance radius that would allow the unit to return to the take-off point without exhausting available fuel or battery power. When the unit is out-of-sight of the operator, a reliable First Pilot View system that displays flight path information and allows the pilot to maintain visual contact with the ground and airspace in its flight path would be required for safety.

3) Totally autonomous UAS's that will operate in the National Airspace System (i.e.: in navigable airspace above 400 ft. AGL, and in controlled or special use airspace). Autonomous operations in the NAS would no doubt require the operator to have stringent license requirements and extensive aviation knowledge, stringent equipment certification processes, redundant autonomous control and return to land systems, and proven collision avoidance technologies [/FONT]

[FONT=&quot] [/FONT]
[FONT=&quot]400 ft. AGL is an important distinction in this discussion, because this is truly where “navigable airspace” or the National Airspace System (NAS) begins. The Supreme Court has ruled time and again in trespass and 4th Amendment search and seizure cases that airspace below 400 ft. AGL is not "navigable airspace." The reason courts have ruled this airspace below 400 ft. AGL as non-navigable airspace is because manned flights at such a low altitude are generally considered rare and unsafe except in the vicinity of an airport. Also, the Supreme Court in Florida v. Riley used 400 ft. AGL as a guide in most part out of reasonableness and because of safety; this figure being the upper curve of most helicopter flight velocity engine out diagrams. [/FONT]
[FONT=&quot] [/FONT]
[FONT=&quot]Although courts formulated the 400 ft. AGL rule to define the limits of privacy, the FAA was not created to protect the privacy rights of citizens. So technically, the only argument the FAA can use to regulate this airspace is for the safety of citizens on the ground (14 C.F.R. @ 91.13 through 15), or for collision avoidance for aircraft landing or departing airports or operating in controlled and special use airspace (14 C.F.R. @ 91.126 through 135). I agree with and fully understand the need for the FAA to regulate or prevent UAS operations in these types of controlled airspace. [/FONT]
[FONT=&quot] [/FONT]
[FONT=&quot]The only guidance to modelers on this matter was outlined in 1981 in AC 91-57. This AC allows hobbyists to fly RC aircraft below 400 ft. (where nearly all manned flights should not occur except for takeoff or landing) over unpopulated areas and not within the immediate vicinity of an airport. The above referenced document was only an “Advisory Circular” and was not regulatory in nature. Apparently it worked fine for years, because Congress, in Public Law 112, again sets the bar for permissible hobby and modeler operations up to 400 ft. AGL.[/FONT]
[FONT=&quot] [/FONT]
[FONT=&quot]Manned aircraft and unmanned hobby RC operations generally don’t interfere with each other. I am a 12,000 helicopter pilot with 34-years of experience (24-years as a police helicopter pilot and 21-years as a military helicopter pilot) and have never had an incident with an RC flyer. And, as a RC hexacopter operator myself, I am always cognizant of manned aircraft operating in my chosen flight areas.[/FONT]
[FONT=&quot] [/FONT]
[FONT=&quot]If a 13-year old can fly a RC hexacopter in his backyard or a public park without any license or regulatory requirements, it is unreasonable to ask a real estate agent who wants to get a video of a client’s house to put on the internet to get a COA or SAC for his hexacopter. There is really no difference as long as he can do it safely. Let the local police or fire department fly a quadcopter with a FLIR for a perp search or over a fire to look for hot spots without a COA if it can be done safely. Let the commercial film crew get video of the latest model car driving across a bridge without obtaining a COA and equipment SAC if it can be done safely and within line-of-sight of the operator.[/FONT]
[FONT=&quot] [/FONT]
[FONT=&quot]The FAA does not have the manpower or financial resources to adequately regulate this explosive small UAS industry, nor should it be given additional funds or personnel to do so. The responsibility for the safe operations of these devices has, and will, continue to be dictated by the insurance industry and civil tort law. A strong body of civil case law has already been formulated in this area driven by 91-years of relatively safe “model aircraft” operations. And what one person may consider an unsafe operation might not be considered unsafe by another. Most UAS's in circulation today are relatively small, weigh less than five pounds, contain autopilot systems that include ring laser gyros and GPS for stability, and miniature microwave transmitters and receivers for First Pilot View (FPV). These systems have added an element of safety and stability to these devices that is unprecedented. And surprisingly, it makes them relatively safe to operate in proximity to people and objects.[/FONT]

[FONT=&quot] [/FONT]
[FONT=&quot]The FAA should adopt the three separate categories of UAS operations I have outlined above. It would simplify the rules for all small UAS operators (modeler, commercial, and public safety alike) and free up resources and money within the FAA to tackle the extensive and complicated job of integrating autonomous UAS's safely into the NAS.

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stitch1615 · Jul 31, 2014

Roto5411 said:
 [FONT=&amp]The following were my comments/thoughts to the FAA regarding their so-called "interpertation"!
**********The FAA should separate UAS operations into three separate but distinct regulatory categories: ,,,,,,,,,,,,,,,,,,,,,,,[/FONT][FONT=&amp]The FAA should adopt the three separate categories of UAS operations I have outlined above. It would simplify the rules for all small UAS operators (modeler, commercial, and public safety alike) and free up resources and money within the FAA to tackle the extensive and complicated job of integrating autonomous UAS's safely into the NAS.[/FONT]

At the risk of going political on you, I agree 100%. All very good points and an excellent argument however you may have forgotten who you are dealing with. The FAA is a Federal Bureaucracy in a dictatorial regime. They like, most other agencies, have been empowered by the administration to do as THEY seem fit and to what end THEY deem necessary. That includes anything which will keep them in control and in one way or another generate income for their agency. It will all be under the guise of "Public Safety" but in the end it is just control.

Congress directed them to separate model aircraft from the regulations but they don't like being ordered by anyone to do anything. Its their ball and the game will be played by their rules and if you don't like it, go get a lawyer.
They have snubbed the Congressional direction by missing deadline after deadline, something congress themselves are pretty good at, and are getting around to it in their good old time.
There will be no rapid resolution unless by edict during the congressional recess but I believe there are bigger fish to fry and this will get pigeon holed until they get around to it. I imagine the final ruling will be what THEY want no matter how many letters or petitions they get.

What they don't like is any congressional inquiry into their operation so I'd suggest that if you have a Democrat in your pocket, this 60 day extension period is the time to get him out. Especially just before an election.

Av8Chuck · Jul 31, 2014

stitch1615 said:
At the risk of going political on you, I agree 100%. All very good points and an excellent argument however you may have forgotten who you are dealing with. The FAA is a Federal Bureaucracy in a dictatorial regime. They like, most other agencies, have been empowered by the administration to do as THEY seem fit and to what end THEY deem necessary. That includes anything which will keep them in control and in one way or another generate income for their agency. It will all be under the guise of "Public Safety" but in the end it is just control.

Congress directed them to separate model aircraft from the regulations but they don't like being ordered by anyone to do anything. Its their ball and the game will be played by their rules and if you don't like it, go get a lawyer.
They have snubbed the Congressional direction by missing deadline after deadline, something congress themselves are pretty good at, and are getting around to it in their good old time.
There will be no rapid resolution unless by edict during the congressional recess but I believe there are bigger fish to fry and this will get pigeon holed until they get around to it. I imagine the final ruling will be what THEY want no matter how many letters or petitions they get.

What they don't like is any congressional inquiry into their operation so I'd suggest that if you have a Democrat in your pocket, this 60 day extension period is the time to get him out. Especially just before an election.

Its easy to go political on this because it seems to be such a political issue, however, that's not really true. This isn't as political as it is systemic. Yes the FAA is a large bureaucracy, but if you look at what they've been mandated to do, their approach to solving this issue is quite reasonable. They have created a number of test sites to help determine the impact regulations will have on industry, they have created a standards or rules committee to consult with and they've opened their interpretation up to public comment, which through the NPRM process they are required to do.

The trouble is that the companies on that committee are the whose who of the defense department contractors, the ones responsible for $10,000 toilet seats on the shuttle etc.,the test sites are either based in academia or potentially heavily influenced by their own trade organizations or standards committees, and most of the public debate is people telling them what rules they think are acceptable, basically telling the FAA how to do their job, good luck with that.

We have a constitution, and a part of that says, and I'm paraphrasing in laymen's terms, that when the government makes rules they cannot be arbitrary and capricious. As a citizen I have the right to start a small business, doing whatever I want and if any government agency has a problem with it the burden falls on them to prove why what I'm doing is harmful to the general public. I don't have to prove why its ok for me to do it.

When you look at what's happening every time the FAA has had to go to court they have lost, in large part because the differentiation between hobby and commercial application of RC's is arbitrary and capricious. Its no less safe to the public interest to fly a MR, for example, whether the operator is being paid or not. Its not OK for the FAA to define RC's as one thing, which is what the public comment is really about, and then if you don't meet that classification to say that you then fall into this category, in our case Part 91 and then be required to certify an RC and pilot in the same manner as a manned aircraft. MR's don't pose the same threat to the public at large in the same way that a 2500 pound plus aircraft full of fuel and people do, so having to certify an RC to the same specification as a manned aircraft is unreasonable and onerous. So they lose. The courts have gone so far as to tell the FAA that they don't even have the authority to tell us to stop what we're doing.

This pains me to say this but when you really stop and think about this, the system is working exactly the way it is meant to. The challenge for anyone who wants to leverage RC's commercially, either as their primary source of income or incidental to their income, is how to become influential in the FAA's rule making process. Even if the petition would have made it to 100,000 signatures that's less than .001% of the population. Does anyone think that's enough to influence the rules making process? We need a seat at the table and the only way to get that invitation is to either become a fortune 500 defense department contractor, become a congressman, or create an organization that represents the hundreds of thousands of individuals who want to profit from this industry behind the single purpose of operating a small sUAS business profitably.

Does anyone else see it differently? All I've heard is blah, blah, rules - blah blah blah FAA you suck. That dog just ain't gonna hunt.

stitch1615 · Jul 31, 2014

Av8Chuck said:
Its easy to go political on this because it seems to be such a political issue, however, that's not really true. This isn't as political as it is systemic. Blah blah blah blah blah,,,,,,,,,,,,, Does anyone else see it differently? All I've heard is blah, blah, rules - blah blah blah FAA you suck. That dog just ain't gonna hunt.

Well counselor, the only "dog I have in this hunt" is a hobbyist and he just wants to go to a field, or a state or national park, that I and hundreds of millions of other citizens pay to maintain, and fly his toy airplane 390 feet in the air and take a few photos of the scenery that he can't get from any other vantage point.
They very likely will not be good enough to sell and that is OK because he is only taking them for me.

I fully sympathize with and support the people who do want to sell their wares and believe, like I believe you do, that they should be able to do that without fear of retribution by an agency that has grown too big for its pants.

Our debate here matters little and in fact, I believe we may even be on the same side except for the fact that I do still believe the FAA sucks for even attempting to overstep its bounds.

The system is working? Well for the moment it may be but we have seen that for every judge who disagrees there is one who will agree and they will find that one sooner or later.

Do we need the FAA or someone like them? Of course we do. None of us would step on a plane without them but they have assignments and boundaries and they should just stay within them and stick to what they say they know.

Our single biggest voice may be the AMA and so far all I've heard from them publicly is a reiteration of what the FAA wrote. I/we can only imagine that there is more going on behind the scenes. Some day we may even find out.
Unfortunately until then, I'm staying out of National Parks and under 400 ft.
(You have no idea how hard it was for me to type that.)

I'm too old for the fight. You sound like an intelligent and well informed "Av8tor" so I hope that you are not.

Av8Chuck · Jul 31, 2014

I may have quoted some of what you said but my comments were not targeted at you, I just meant to address some of your concerns, sorry for coming off preachy.

The one thing that pissed me off and at the same time motivated me to get more involved was the ban on the national parks. Interestingly it wasn't the FAA that did that. We probably do agree on this issue, as do probably most of the people on this and other forums like it. Unfortunately this is not a popularity contest so its not about agreement but about action. Also this is where a lot of people, especially hobbyists might disagree with me but I think the fate of hobbyists and commercial operators are inextricable linked. The National Park Service didn't ban commercial sUAS they banned all RC flying for what I think are BS reasons and I don't recall the AMA saying much about it. Imagine if they would have banned Ansel Adams and his fancy new camera's, in fear that his flash might cause a forest fire, there probably wouldn't be a Park Service..

I agree the AMA should take a more predominant role in this issue but it appears that they are either unwilling or unable, or they don't feel that their membership is threatened by this action and they might be right. But what I am pointing out is that there is no representation for sUAS businesses and I do believe that any regulations that the FAA imposes on the commercial side will have an adverse effect on the hobby itself, just like the National Parks. Its funny if you read blogs that are more hobby centric the hobbyists want nothing to do with the professionals, conversely on commercial leaning blogs they blame the hobbyists for this mess and want nothing to do with them either.

I'm much closer to the end of my life than the beginning, old enough to know that a house divided cannot stand. We are all flying the same stuff and by and large want the same freedoms, whether or not someone gets paid for doing this is irrelevant. Isn't this the country where you tell your kids how lucky they are to be in a place where you can earn a living doing the thing you love. I guess people forget that.

Commercial sUAS petition is live at Whitehouse.gov

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