Commercial sUAS petition is live at Whitehouse.gov
- Thread starter Bartman
- Start date
Roto5411
Member
Bart,
Just quickly scanned through CAP658 and I just can't bring myself to sign. In typical European fashion, its just too much regulation in my opinion. I really think this whole issue could be greatly simplified by dividing UAS operations into three separate, distinctive categories: small line-of-sight only operations below 400' AGL outside controlled airspace, small FPV operations with waypoint control below 400' AGL, and autonomous UAS operations in the NAS.
This particular requirement in CAP658 is nuts:
"Failsafes: Any powered model aircraft fitted with a receiver capable of operating in failsafe mode should have the failsafe set, as a minimum, to reduce the engine(s) speed to idle on loss or corruption of signal."
Obviously this regulation was written before the age of multi-rotored UASs, and if this were followed to the letter, we would have quads and hexes falling out of the sky!
Perhaps something in between what we have now (nothing enforceable), and the Brit's rules is what we need. Nonetheless, send your comments folks to the FAA regarding their "Interpretation of Special Rules for Model Aircraft" comment period at:
http://www.regulations.gov/#!documentDetail;D=FAA-2014-0396-0001
ROTO
Just quickly scanned through CAP658 and I just can't bring myself to sign. In typical European fashion, its just too much regulation in my opinion. I really think this whole issue could be greatly simplified by dividing UAS operations into three separate, distinctive categories: small line-of-sight only operations below 400' AGL outside controlled airspace, small FPV operations with waypoint control below 400' AGL, and autonomous UAS operations in the NAS.
This particular requirement in CAP658 is nuts:
"Failsafes: Any powered model aircraft fitted with a receiver capable of operating in failsafe mode should have the failsafe set, as a minimum, to reduce the engine(s) speed to idle on loss or corruption of signal."
Obviously this regulation was written before the age of multi-rotored UASs, and if this were followed to the letter, we would have quads and hexes falling out of the sky!
Perhaps something in between what we have now (nothing enforceable), and the Brit's rules is what we need. Nonetheless, send your comments folks to the FAA regarding their "Interpretation of Special Rules for Model Aircraft" comment period at:
http://www.regulations.gov/#!documentDetail;D=FAA-2014-0396-0001
ROTO
Bartman
Welcome to MultiRotorForums.com!!
CAP658 ain't it in the UK.
http://www.multirotorforums.com/sho...UK-regulations&p=172197&viewfull=1#post172197
from Dave's post it is CAP722 and CAP393 unless CAP658 also contributes to it.
you can get hung up on whatever details you want but suffice it to say there are loads of sUAS operators in the UK, doing what we do, legally, with helicopters that are virtually identical to ours, within the limits that any reasonable person in the US would be happy to respect if they could do so without the threat of FAA actions against them.
details are there, fine, but they aren't stopping very many people from proceeding successfully with their operations.
Bartman
http://www.multirotorforums.com/sho...UK-regulations&p=172197&viewfull=1#post172197
from Dave's post it is CAP722 and CAP393 unless CAP658 also contributes to it.
you can get hung up on whatever details you want but suffice it to say there are loads of sUAS operators in the UK, doing what we do, legally, with helicopters that are virtually identical to ours, within the limits that any reasonable person in the US would be happy to respect if they could do so without the threat of FAA actions against them.
details are there, fine, but they aren't stopping very many people from proceeding successfully with their operations.
Bartman
Av8Chuck
Member
I think you kind of miss the point of the petition. Few people disagree with your suggestion for simple rules to live by, but that's not what's on the table. As I understand it, there have been several requests for comments regarding the "interpretation" of congresses mandate to regulate UAV's and through the FAA's proposed "interpretation" commercial sUAS operations is not an option, you can only fly RC's for the "passion of flight." So this petition is an attempt to get some form of regulation in the interim so that it is legal for commercial sUAS operation until the FAA goes through the official NPRM process.
I also think that everyone should keep in mind that this process has been on going for almost ten years, its been kind of a don't ask, don't tell policy. The FAA has stated that since losing the recent lawsuit that the rules default back to previous "guidelines," firstly, that's not true, the ruling by the federal judge was very clear on FAA's jurisdiction regarding commercial RC operation, however this is all somewhat unprecedented, but I think its fair to say that if the FAA can successfully redefine the "interpretation" that they will proceed with regulating UAV and there will be no pressure to regulate sUAV's and it will take them another decade to get around to that. The difference is that in the meantime it won't be "don't ask don't tell" commercial operation of sUAV's will be illegal.
Bartman
Welcome to MultiRotorForums.com!!
The petition has exceeded 150 signatures so it is now listed on the front page of the Petitions section of the website. It's taken a few days to do that though so I'm not sure how much of a push we can expect in the coming week or two. We'll keep at it and see where it goes.
Motopreserve
Drone Enthusiast
its a start. Any idea what's happening with the email blast/server? I'm still not getting notifications from subscribed threads - and I haven't received any email yet.
ChrisViperM
Active Member
It's a shame that we apparently have app. 15.000 members, but only 150 signatures......just get that lazy a$$ up and sign :livid: :livid: :livid: :livid:
Chris
Chris
Bartman
Welcome to MultiRotorForums.com!!
i'm trying to get an answer from the hosting company as to what is going on with the email server. i'm not getting any notifications either.
Old Man
Active Member
It's worse than that Chris. The link to the petition is posted at just about every major U.S. RC hobby forum, all the MR forums, Facebook, and other locations and all that have signed so far is 150? That makes me wonder if we'll get the traction and exposure we need. Public apathy is a terrible thing, and thinking it will be handled by someone else always leads to disaster. Seems most would rather play than put in a minute for formalities. Sort of like Nero with his fiddle while Rome burned.
Some are thinking the FAA has performed an illegal act with their advisory, which they have. The problem is the FAA can get away with doing something illegal while forcing others to abide by an illegal act in the time it takes for their illegal advisory to become law. It will require very little effort for the FAA to have a legislator piggyback their document with some law or bill being handled by some other non DOT committee and get it passed into law without anyone knowing the advisory was being voted on.
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Av8Chuck
Member
Maybe we will miraculously get 99,831 signatures in the next 19 days, lets hope we do. But if we plan on winning this war everyone should realize that the petition was simply the first of many battles yet to come and if we want to be heard then we need a strategy to go from spectator to participant. Just because some of us do AP commercially and we signed a petition does not make us participants in the process.
The thing that encouraged me to join this fight was that there was some great dialog starting to take place on the blast mail thread between others frustrated enough to take some sort of action. The kindling of an organization, great. But for some reason once the petition was launched that initial thread splintered into four or five other threads and it seems to me that the momentum that started in the initial thread was lost. Discussion about what to do to get more signatures, what to do next, what's our possible end game, is all but none existent. The petitions was just the first shot, the shot across the bow so to speak, don't you think we should be figuring out what to do when they shoot back?
We can blame the fact that we have so few signatures on others or we can take a critical look at what we did that might not have produced the results we were hoping for. Here's a quote from something I wrote in another thread: "I also think that many here have an unrealistic expectation, even if the petition gets the required signatures of what that will accomplish. The White House has stated on several occasions the goal for these petitions is not to change policy, but to provide people the opportunity to organize around a common interest. Which is the real value in what your doing.
The goal should not be to change the minds of the rule committee with a petition, that was never going to happen. Don't you think that everyone on that committee know's how other countries regulate sUAS's? If they were inclined to go that direction their rhetoric would be very different. The FAA's recent rhetoric regarding sUAS's has been all about the "passion" for flying."
This is not about the rules, that's a red herring, the FAA is trying to use regulatory procedure to circumnavigate a court case that they lost and their using the Mandate from Congress to accomplish it. None of the companies on the FAA's rules committee knows any more about the rules than we do, there on that committee to protect their market share. You can throw the herring a fish but the appeal to the public to get them to sign the petition should have included more about o[FONT=Verdana, Arial, Tahoma, Calibri, Geneva, sans-serif]ur intent is[/FONT] in protecting the rights of small AP businesses in the US to operate and remain competitive in this industry. The only people who have a vested interest in signing a petition about MR rules is the people who fly them and potentially the people who hire them directly, which is a very small percentage of the overall population. But the percentage of people having a vested interest in protecting the rights of small businesses is significantly bigger. We would get the the MR enthusiasts for free, so to speak, but we would have potentially received many more signatures from people who have never even seen a MR.
If you want to be successful in this effort I'd suggest creating a new thread, a central point of focus to discuss what's working, what's not working and what's next. I kind of feel that I've out stayed my welcome on this subject so I'm going to refrain from commenting for a while.
The thing that encouraged me to join this fight was that there was some great dialog starting to take place on the blast mail thread between others frustrated enough to take some sort of action. The kindling of an organization, great. But for some reason once the petition was launched that initial thread splintered into four or five other threads and it seems to me that the momentum that started in the initial thread was lost. Discussion about what to do to get more signatures, what to do next, what's our possible end game, is all but none existent. The petitions was just the first shot, the shot across the bow so to speak, don't you think we should be figuring out what to do when they shoot back?
We can blame the fact that we have so few signatures on others or we can take a critical look at what we did that might not have produced the results we were hoping for. Here's a quote from something I wrote in another thread: "I also think that many here have an unrealistic expectation, even if the petition gets the required signatures of what that will accomplish. The White House has stated on several occasions the goal for these petitions is not to change policy, but to provide people the opportunity to organize around a common interest. Which is the real value in what your doing.
The goal should not be to change the minds of the rule committee with a petition, that was never going to happen. Don't you think that everyone on that committee know's how other countries regulate sUAS's? If they were inclined to go that direction their rhetoric would be very different. The FAA's recent rhetoric regarding sUAS's has been all about the "passion" for flying."
This is not about the rules, that's a red herring, the FAA is trying to use regulatory procedure to circumnavigate a court case that they lost and their using the Mandate from Congress to accomplish it. None of the companies on the FAA's rules committee knows any more about the rules than we do, there on that committee to protect their market share. You can throw the herring a fish but the appeal to the public to get them to sign the petition should have included more about o[FONT=Verdana, Arial, Tahoma, Calibri, Geneva, sans-serif]ur intent is[/FONT] in protecting the rights of small AP businesses in the US to operate and remain competitive in this industry. The only people who have a vested interest in signing a petition about MR rules is the people who fly them and potentially the people who hire them directly, which is a very small percentage of the overall population. But the percentage of people having a vested interest in protecting the rights of small businesses is significantly bigger. We would get the the MR enthusiasts for free, so to speak, but we would have potentially received many more signatures from people who have never even seen a MR.
If you want to be successful in this effort I'd suggest creating a new thread, a central point of focus to discuss what's working, what's not working and what's next. I kind of feel that I've out stayed my welcome on this subject so I'm going to refrain from commenting for a while.
Nope nothing.
But i have signed it + passed it to family, friends, colleagues and clients. Most if not all are big on the whole 'freedom' concept, so FAA crap like this isn't taken lightly or positively.
Roto5411
Member
Bartman wrote: "CAP658 ain't it in the UK.
http://www.multirotorforums.com/show...l=1#post172197
from Dave's post it is CAP722 and CAP393 unless CAP658 also contributes to it."
When I did a search for UK rules Bart, 658 was the first that came up. Now you direct me to two more regulations to include 722 that is 109 pages. Geeze, no thanks. Way too much regulation. It's unnecessary, and sorry, but I will not be signing the petition. This issue is very similar to regular flight regulations in that you can have thousands upon thousands of dos and don't on the books but it will never prevent stupid pilot acts. What we really need is one simple rule to cover all manned and unmanned aviation flight; don't do anything stupid. But of course that is totally unrealistic and unenforceable. Which is why we are at this point with the FAA Interpretation and their request of comments. They were body slammed by an NTSB administrative law judge and their omnipotence was directly challenged. Now, Washington realizes that they have no power to enforce the rules that they assumed would also apply to unmanned flights, specifically commercial operators. Law Enforcement manned flight operations are "Public Use" which the FAA has always had a "hands off approach" to. The FAA imposed a COA requirement on LE and because most LE agencies want to have a great relationship with the FAA and keep them out of the maintenance shacks and pilots rooms no agency has ever challenged the COA requirement. A requirement that has no basis in law by going through a proper NPRM process.
The model aircraft industry has pretty much self-regulated itself for 91-years and in those instances where operators have crossed the line of stupidity and negligence civil courts and insurance companies have stepped in and resolved the issues. I just don't think more regulation is the answer. And I'm certainly not willing to subscribe to European forms of unnecessary excessive regulation.
ROTO
http://www.multirotorforums.com/show...l=1#post172197
from Dave's post it is CAP722 and CAP393 unless CAP658 also contributes to it."
When I did a search for UK rules Bart, 658 was the first that came up. Now you direct me to two more regulations to include 722 that is 109 pages. Geeze, no thanks. Way too much regulation. It's unnecessary, and sorry, but I will not be signing the petition. This issue is very similar to regular flight regulations in that you can have thousands upon thousands of dos and don't on the books but it will never prevent stupid pilot acts. What we really need is one simple rule to cover all manned and unmanned aviation flight; don't do anything stupid. But of course that is totally unrealistic and unenforceable. Which is why we are at this point with the FAA Interpretation and their request of comments. They were body slammed by an NTSB administrative law judge and their omnipotence was directly challenged. Now, Washington realizes that they have no power to enforce the rules that they assumed would also apply to unmanned flights, specifically commercial operators. Law Enforcement manned flight operations are "Public Use" which the FAA has always had a "hands off approach" to. The FAA imposed a COA requirement on LE and because most LE agencies want to have a great relationship with the FAA and keep them out of the maintenance shacks and pilots rooms no agency has ever challenged the COA requirement. A requirement that has no basis in law by going through a proper NPRM process.
The model aircraft industry has pretty much self-regulated itself for 91-years and in those instances where operators have crossed the line of stupidity and negligence civil courts and insurance companies have stepped in and resolved the issues. I just don't think more regulation is the answer. And I'm certainly not willing to subscribe to European forms of unnecessary excessive regulation.
ROTO
Bartman
Welcome to MultiRotorForums.com!!
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Old Man
Active Member
I think Roto holds the position that we should not be regulated, and therefore will not end up that way. I only wish that were so. Unfortunately it's not possible to write one paragraph of regulation without an additional 10 pages of explanatory and defining information.
What may not be understood is that "Free World" nations got together a few years ago and established a rough timeline for the integration of UAV's in their air spaces. Australia, Canada, U.K., and Europe have had their concepts pretty much in place for some time. Our airspace is among the last to see that incorporation occur, but that process is now gaining speed. We WILL be regulated, only the extent has yet to be finalized. That this is so was ordained during the period the ARC committee was in session. That wasn't a group meeting to determine if they should or should not, but one formulating the ground rules upon which regulation will happen. People that fly RC aircraft were denied a voice in that committee group. They were only permitted to listen to the proposals being presented.
What may not be understood is that "Free World" nations got together a few years ago and established a rough timeline for the integration of UAV's in their air spaces. Australia, Canada, U.K., and Europe have had their concepts pretty much in place for some time. Our airspace is among the last to see that incorporation occur, but that process is now gaining speed. We WILL be regulated, only the extent has yet to be finalized. That this is so was ordained during the period the ARC committee was in session. That wasn't a group meeting to determine if they should or should not, but one formulating the ground rules upon which regulation will happen. People that fly RC aircraft were denied a voice in that committee group. They were only permitted to listen to the proposals being presented.
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coreyperez
Member
I didn't receive it. But, I'm a forum follower, so I've got it covered 
Roto5411
Member
I'm under no illusion "Old Man" that we can continue to live under zero regulation, I've been involved in aviation for 34-years. But we in this hobby are our own worst enemies. Look at all the crap that happened over the weekend all over this country. Guys flying into fireworks, stupid rich kids with no concept of airspace or safety flying over the George Washington Bridge in New York City at 2000' AGL, and a host of other violations of common air sense and safety protocols were posted on You Tube. The FAA is going to have to do something to stem the tide of this rampant stupidity or they will look like inept fools (I know, that statement is a oxymoron!), but it's also a great opportunity to do more empire building and increase their budget from Congress. Roll your eyes about my comments about the petition, but in my opinion petitions are a waste of time. Posting your comments to the FAA would do more good. As of just a few minutes ago, 2624 comments were posted to the Regulations.gov web site. That number should be at least 10X that number. But I realize that most people are apathetic and figure their comments won't mean anything. There apathy is probably founded, but its like winning the lottery; your chances of winning are slim to none. But you can't win if you don't play.
Droider
Drone Enthusiast
On the contrary.. if you think operating in the uk is over complicated fine.. at least we can operate. if the us wants commercial none military uav operations you'll need a level playing field that any one serious about setting up understands an follows the rules. If you make it simple the simpletons will be allover the place like a rash and $10 photo shoots and phantoms down every high street will be the norm.
That cannot and will not happen. get serious or go fly a kite
D
Old Man
Active Member
Had an hour long conference call regarding waivers, formats, regulations, and presentation today with a group of sUAS professionals of our type. Included in that discussion was an individual that has been working with and making presentations to the FAA of late. The general consensus was the FAA doesn't want to be bad guys, their lawyers are actually pretty good fells, but they don't have a clue as to what we fly, how it works, and how it should work. Worse yet is the Tier system used to describe UAS doesn't really cover what we do very well, if at all. So there is need of a 5th tier that expands on opes and products relative to what I'll call VLL-SD-SR for Very Low Level-Short Duration-Short Range air vehicles such as what most of us work with. This would largely exclude fixed wing sUAS that have the ability to fly out many kilometers and back. Those would unfortunately probably get lumped into the next higher tier.
There was also discussion about the use of FPV, and how it could be used to assist in "See and Avoid" for commercial operators utilizing a two or more person flight crew. Especially if the FPV camera could be directed to cover more than a narrow, straight ahead field of vision. There wasn't much concern with how the hobby side of things might be affected because it will be in our best interests to block them from the ability to strap on a camera and go make salable video. What all this boils down to is presenting waiver requests that accurately describe aircraft, operators, ops methodology, and flight training to educate as well as possible those reviewing the requests, which will help establish "interim" regulations for us to proceed with. Ultimately for this to work we're going to have to become aviation professionals in addition to our payload skills. That may not be a bad thing.
The 7 waiver requests presented thus far have all been a pretty much canned approach limiting product descriptions to each firms particular aircraft or system. There's not much following depth to enlighten the FAA with operational methods.
There was also discussion about the use of FPV, and how it could be used to assist in "See and Avoid" for commercial operators utilizing a two or more person flight crew. Especially if the FPV camera could be directed to cover more than a narrow, straight ahead field of vision. There wasn't much concern with how the hobby side of things might be affected because it will be in our best interests to block them from the ability to strap on a camera and go make salable video. What all this boils down to is presenting waiver requests that accurately describe aircraft, operators, ops methodology, and flight training to educate as well as possible those reviewing the requests, which will help establish "interim" regulations for us to proceed with. Ultimately for this to work we're going to have to become aviation professionals in addition to our payload skills. That may not be a bad thing.
The 7 waiver requests presented thus far have all been a pretty much canned approach limiting product descriptions to each firms particular aircraft or system. There's not much following depth to enlighten the FAA with operational methods.