Considering MRF blastmail system to address FAA regulatory process but need your help
- Thread starter Bartman
- Start date
Mike SF
Banned
I like the idea of a petition pushing to adopt the UK sUAS rules. At a minimum it would show that there is a sensible way to deal with it. For example they have a much clearer definition of what VLOS operations really means:
Visual Line of Sight Operations
Visual Line of Sight is termed as being the maximum distance that the flight crew is able to maintain separation and collision avoidance, under the prevailing atmospheric conditions, with the unaided eye (other than corrective lenses). For flights within Visual Line of Sight, the pilot of an unmanned aircraft is required to employ the 'see and avoid' principle through continued observation of the aircraft and the airspace around it, with respect to other aircraft and/or objects. Within the United Kingdom, Visual Line of Sight operations are normally accepted out to a maximum distance of 500m horizontally, and 400ft vertically, from the pilot.
Visual Line of Sight Operations
Visual Line of Sight is termed as being the maximum distance that the flight crew is able to maintain separation and collision avoidance, under the prevailing atmospheric conditions, with the unaided eye (other than corrective lenses). For flights within Visual Line of Sight, the pilot of an unmanned aircraft is required to employ the 'see and avoid' principle through continued observation of the aircraft and the airspace around it, with respect to other aircraft and/or objects. Within the United Kingdom, Visual Line of Sight operations are normally accepted out to a maximum distance of 500m horizontally, and 400ft vertically, from the pilot.
Av8Chuck
Member
I'm confused or maybe you misunderstood what I was saying. I'm not saying to join the AMA, they don't have a dog in this hunt either, what I'm saying is that they have a reasonably large constituency that can probably be persuaded to join a PAC, I don't think the differentiation for membership should be whether flying MR's is based on compensation. Its either our right to do it safely or is in't whether I get paid should be irrelevant, though I realize according the FAA that's not the case.
I don't understand the point of the first paragraph?
I don't agree with some of the second point, I'm an AOPA member and I have spoken to other members and AOPA employees and I don't get the sense that they pretty much hate MR's. There's certainly a lot of uncertainty but most don't think that if RC's remained below 400 feet that there's that much of a safety risk. If your flying that low on a full size acft your scanning a lot more for potential conflict anyway. And as far as RC's taking work away from full size acft I doubt that would happen on that large of a scale. there are things that encompass large area's or altitudes that larger acft are uniquely suited to do and there are jobs that require an aerial platform for close air support that is impractical or unsafe for large aircraft. Again having a PAC similar to AOPA would help facilitate dialog to mitigate many of those types of conflicts.
I suspect that if a sizable PAC was created that there could be a dialog between that PAC and AOPA to partner.
Sorry for the confusion. Everything I'm talking about is in the context of commercial sUAS work, specifically aerial filming with sUAS. You mentioned earlier:
What I'm saying is that a ban won't change anything- just increase activity under the table. A ban will equate to less safety.
As as far as full size ops there is no question at all that sUAS has cut into their business. That chatter is ongoing and getting louder. Believe me, I think the two compliment each other and are suited to different things. But car spots, our bread and butter, use far less full size ops than they did just a few years ago. Between conventional aerials and the low level, intimate shots they can get with MR's it's usually no contest. Directors and DP's prefer the shots we provide. Ditto the russian arm guys- they don't like us either. As for the AOPA, it'd be great if they support and advocate on our behalf. I don't see that happening, however.
Old Man
Active Member
I think Bart is correct with this assessment. The hobbyists are the ones that have generated the dark cloud surrounding M/R's and currently there is no distinction between a hobby and commercial M/R, or their operators. making this more difficult is the fact that a "hobby" level M/R can also easily be a "professional" level M/R. The actual distinction is found in how they are operated and the people at the controls. Unless such a distinction is made at government level all will lose. How such a distinction is made is completely up to those involved in the professional side of the market. Who will present that distinction is another story altogether. It's too late to build a new organization to promote our interests so what's needed is a massive outpouring of response to the FAA ruling at their level, concurrent with as much discussion with the AMA as possible to assist in development of a new classification within the Code of Federal Regulations and FAR's that would establish a rule set for us to survive within. Barring that we will be lumped in with the hobbyists, those same people that have repeatedly demonstrated they have zero regard for anyone but themselves and their public relations disaster de jour.
Old Man
Active Member
The contents of the link provide some insight of what needs to be addressed to split us off from the hobbyists. Maintaining lin of sight with our aircraft and a 100% assured aircraft action in the event of lost comm is what will get us there.
http://www.oig.dot.gov/sites/dot/files/FAA Oversight of Unmanned Aircraft Systems^6-26-14_0.pdf
http://www.oig.dot.gov/sites/dot/files/FAA Oversight of Unmanned Aircraft Systems^6-26-14_0.pdf
Av8Chuck
Member
Its unfortunate that we take such a dim view of the hobbyists, not that it isn't deserved but as an STC owner I can tell you pretty much what's about to happen:
All MR's manufactured for commercial use will have to comply with ISO9000:2000, they will have to comply with Title 14 Code of Federal Regulations (14 CFR) Certification Procedures for Products, Articles, and Parts, and part 45, Identification and Registration Marking. This is a certification procedure and identification requirement for aeronautical products and articles. Specifically, it encompasses updated and standardized Quality System requirements for production approval holders, revised export airworthiness approval requirements, and amended identification requirements for products and articles.
The Flight Controllers will have to comply with "MIL-SPEC." There are two FC's that I'm aware of that meet this requirement, AeroVironment which has the only sUAV to pass this certification that it sells for something like $400,000 per copy and Lockheed Martin that offers a controller for RC Helicopters and the starting price is about $50,000. What do both of these companies have in common? Oh yeah, their both on the FAA's rule making committee.
So what does this mean? Well for starter's it means that a MR capable of carrying a Red and Gimbal that costs approximately $8000 today will costs at least $80,000 after its certified and that's only if the manufacturers can afford the certification process which could costs hundreds of thousands of dollars. How many of the people manufacturing MR's today could meet that requirement? Oh yeah, the ones on the FAA's rule making committee.
Do you think that DJI can get any of its controllers certified? Do any of you know anyone willing to invest that kind of time and money to get any Chines FC certified? No?
OK lets get real with this. All of you have proposed what might be considered reasonable solutions to pilot certification, great but the FAA knows that no matter what that process is it doesn't matter if the certified pilot can't afford a certified MR.
Old Man you say that "The actual distinction is found in how they are operated and the people at the controls. Unless such a distinction is made at government level all will lose." Sorry but the government has made the distinction and its in post #39 of this thread. Maybe if your an alumni of New Mexico State and you've donated millions of dollars, you might have some influence with them, or a senior executive of one of the other companies, but short of that we had better be able to pull together 20,000+ people willing to pay dues that can be used to hire the attorneys its going to take to fight this in court and provide a voice to this new industry.
I would love to be wrong about this, I hope that I am and have to eat these words, but we can't even agree in this forum, what possible hope do you think there is because we all make a comment. The mother of the Marine being held in a Mexican jail got over 100,000 signatures in less than three days and last I heard the government has not responded and he's still in jail. That whole "if you get the necessary number of signature on a petition" is a political PR ploy that has no accountability.
All MR's manufactured for commercial use will have to comply with ISO9000:2000, they will have to comply with Title 14 Code of Federal Regulations (14 CFR) Certification Procedures for Products, Articles, and Parts, and part 45, Identification and Registration Marking. This is a certification procedure and identification requirement for aeronautical products and articles. Specifically, it encompasses updated and standardized Quality System requirements for production approval holders, revised export airworthiness approval requirements, and amended identification requirements for products and articles.
The Flight Controllers will have to comply with "MIL-SPEC." There are two FC's that I'm aware of that meet this requirement, AeroVironment which has the only sUAV to pass this certification that it sells for something like $400,000 per copy and Lockheed Martin that offers a controller for RC Helicopters and the starting price is about $50,000. What do both of these companies have in common? Oh yeah, their both on the FAA's rule making committee.
So what does this mean? Well for starter's it means that a MR capable of carrying a Red and Gimbal that costs approximately $8000 today will costs at least $80,000 after its certified and that's only if the manufacturers can afford the certification process which could costs hundreds of thousands of dollars. How many of the people manufacturing MR's today could meet that requirement? Oh yeah, the ones on the FAA's rule making committee.
Do you think that DJI can get any of its controllers certified? Do any of you know anyone willing to invest that kind of time and money to get any Chines FC certified? No?
OK lets get real with this. All of you have proposed what might be considered reasonable solutions to pilot certification, great but the FAA knows that no matter what that process is it doesn't matter if the certified pilot can't afford a certified MR.
Old Man you say that "The actual distinction is found in how they are operated and the people at the controls. Unless such a distinction is made at government level all will lose." Sorry but the government has made the distinction and its in post #39 of this thread. Maybe if your an alumni of New Mexico State and you've donated millions of dollars, you might have some influence with them, or a senior executive of one of the other companies, but short of that we had better be able to pull together 20,000+ people willing to pay dues that can be used to hire the attorneys its going to take to fight this in court and provide a voice to this new industry.
I would love to be wrong about this, I hope that I am and have to eat these words, but we can't even agree in this forum, what possible hope do you think there is because we all make a comment. The mother of the Marine being held in a Mexican jail got over 100,000 signatures in less than three days and last I heard the government has not responded and he's still in jail. That whole "if you get the necessary number of signature on a petition" is a political PR ploy that has no accountability.
Old Man
Active Member
In essence you've reaffirmed what I said sometime ago. It's about locking out the little guy by enacting regulatory processes only the big players can afford to comply with. As previously mentioned, mega corporations love regulations because they already have the funding and staff necessary to participate. The little guy has to hire a full time team that produces nothing other than paperwork and a new stack of policies and procedures that end up requiring additional staff to enforce and track. I see this everyday in my line of work and little is accomplished in any kind of time frame that could be considered reasonably efficient. It's the reason NASA spent $10,000.00 of an every day off the hardware shelf hammer. It's the reason I have to spend $ hundreds of dollars to make a departmental purchase for $3.00 worth of common hardware.
Av8Chuck
Member
I don't think we disagree about much, except for maybe what do about it.
I almost feel like some sort of political hack suggesting forming a PAC, but when you look at how far we've all come in the past four years and think how great AP could be four years from now it really pisses me off to think that it might not happen. Not because its unsafe but more likely because of BS politics that we're not even a part of.
I'm tired of feeling like a criminal for wanting to shoot AP commercially, there is absolutely no reason for it but how can we defend our right to operate small AP businesses?
I almost feel like some sort of political hack suggesting forming a PAC, but when you look at how far we've all come in the past four years and think how great AP could be four years from now it really pisses me off to think that it might not happen. Not because its unsafe but more likely because of BS politics that we're not even a part of.
I'm tired of feeling like a criminal for wanting to shoot AP commercially, there is absolutely no reason for it but how can we defend our right to operate small AP businesses?
Motopreserve
Drone Enthusiast
Chuck,
you keep mentioning that we can't agree here, and although I realize that time is an issue, it seems to me that the dialog and debate raised in this thread is how you hone an argument (and hopefully as a byproduct, goals and direction). Obviously someone will have to take the lead, and cull the ideas into an actionable focus, but I would hope the dialogue is what will help shape that focus. So perhaps the time spent hearing ideas is valuable?
Sadly, I do agree with what you and Old Man have said. It seems to be a game stacked against the little guy - and without some big $ it seems very unlikely that that little guy will be able to help steer the course in any meaningful way. Without sounding defeatist, I will also say that making an effort - ANY effort, will perhaps provide a small amount of comfort by way of "at least we tried." I accept it's a very small conciliation. But in my experience, although bitter sweet, I've personally always felt some small bit of comfort after at least making the effort for something I had a passion for, regardless of whether I failed to achieve my intended goals or not.
So what would you two suggest as the best, realistic course of action?
you keep mentioning that we can't agree here, and although I realize that time is an issue, it seems to me that the dialog and debate raised in this thread is how you hone an argument (and hopefully as a byproduct, goals and direction). Obviously someone will have to take the lead, and cull the ideas into an actionable focus, but I would hope the dialogue is what will help shape that focus. So perhaps the time spent hearing ideas is valuable?
Sadly, I do agree with what you and Old Man have said. It seems to be a game stacked against the little guy - and without some big $ it seems very unlikely that that little guy will be able to help steer the course in any meaningful way. Without sounding defeatist, I will also say that making an effort - ANY effort, will perhaps provide a small amount of comfort by way of "at least we tried." I accept it's a very small conciliation. But in my experience, although bitter sweet, I've personally always felt some small bit of comfort after at least making the effort for something I had a passion for, regardless of whether I failed to achieve my intended goals or not.
So what would you two suggest as the best, realistic course of action?
Bartman
Welcome to MultiRotorForums.com!!
Chuck,
it almost seems like you recognize the problem but are accepting defeat in advance. time and funding is not available to address the commercial sUAS sub-group but what is and what can be done in the short term?
as a union pilot I've tried to lobby a large group for support and it's very hard. giving people info to write their own letters doesn't work (the AMA is trying to do this, we'll see how many letters it generates, I'm skeptical). Trying to get enough people to show up on any given day for a protest doesn't work. what works is a link with the opportunity to vote and it's got to be as quick/easy as possible. online petitions do the most you can ask for in a short amount of time and there is the potential to get news coverage if it pops fast and hard.
fwiw, the marine in mexico, as unfortunate as the situation is, isn't the same situation and the petition process shouldn't be compared just because he's still in jail.
Bartman
Welcome to MultiRotorForums.com!!
i'm going to get this petition up today. it won't be complicated because it doesn't have to be. someone should do the following
1. list the websites where the petition needs to be mentioned
2. mine email addresses for industry groups that would be interested in contributing to the petition drive
3. mine facebook group pages that should be hit with the petition notice
4. mine email addresses for national news companies and circulate a release stating the presence of the petition at the whitehouse.gov site.
5. everyone should be prepared to send the petition link to their entire email contact list
6. i'll send the link to the entire multirotorforums.com member list (almost 15,000 members!!)
7. someone should be ready to ask all relevant websites to ask that they also send the petition link to their entire membership lists
8. anything that will increase response numbers
9. anything that will increase response numbers
10. anything that will increase response numbers
1. list the websites where the petition needs to be mentioned
2. mine email addresses for industry groups that would be interested in contributing to the petition drive
3. mine facebook group pages that should be hit with the petition notice
4. mine email addresses for national news companies and circulate a release stating the presence of the petition at the whitehouse.gov site.
5. everyone should be prepared to send the petition link to their entire email contact list
6. i'll send the link to the entire multirotorforums.com member list (almost 15,000 members!!)
7. someone should be ready to ask all relevant websites to ask that they also send the petition link to their entire membership lists
8. anything that will increase response numbers
9. anything that will increase response numbers
10. anything that will increase response numbers
I sure have appreciated the insight and knowledge coming from members who've posted on this thread. Chuck, you know you are not alone in your frustration. Knowing just how to respond is not easy.
No doubt a PAC/Professional Association specifically representing sUAS Commercial Aerial Photographers (sUAS CAP) could make a difference. I just wonder how many of us there really are that would be willing to pay $100 to $250 annually to belong to such an organization and what are the real numbers that we'd need. Is it 20,000? That would be great but if the number is that large, I wonder if we'd come close. Additionally, it would take a couple of individuals with a tremendous amount of time and motivation to make it happen.
I found your post about the potential cost of commercial certification for small sUAS to be very informative as well. Having worked as a professional in aviation, I am aware of the costs that airworthiness certifications can add to any product. On this point, I could not agree more. If sUAS Commercial AP is to exists on a level that small operators can afford, we MUST have some separation from the UAS entities that plan to operate large vehicles in the NAS.
I have suggested before a position paper? Something we could put our heads together and try to agree on. Maybe a PAC would come out of it or maybe it would just be something tangible that we could start floating out to other organizations that would perhaps endorse it. It might end up being as ineffective as a bunch of signatures on a petition but could inspire thought and consideration of the real needs of an industry we'd like to help forge.
The standards of the British sUAS rules have been brought up a lot. Are they something we could/should use as a model? Do you think the FAA is considering small operators at all in their rule development? I wonder if they're looking at those standards? The list of corporations sure doesn't make one believe so, as many have pointed out.
I think we need some critical distinctions which would separate this class/category of commercial operation from others that the FAA is charged to regulate.
Would these work:
Operations never to exceed 400 feet
Aircraft gross weight not to exceed 22 1bs/10 kg (half the weight of a small UAS as defined by the FAA) Maybe we call it vsUAS – very small Unmanned Aircraft System ;-)
No remotely detachable payloads
Must be remain in VLOS of the Operator
There may be other parameters that, by definition, would limit our operations and create a real distinction from the UAS operations that would be certified at a wholly different level.
I wanted to come back to your discussion about certifications and cost. Obviously, Airworthiness Certifications are directed at design, quality control and risk management in the name of safety. From what I can tell as a relative novice in this field, there are few of us, if any, who can assure the FAA or anyone else that our 15 lb MR won't fall out of the sky. It even happens to the military for all the money they spend. Certified components might help but could make the aircraft cost prohibitive.
What is the status of ballistically deployed parachutes for this type of equipment? Is this something we could integrate into our MR at a commercial level that would give the FAA a reasonable assurance should an un-certified flight controller fail, that the aircraft could be instantly disabled and float to the ground?
No doubt a PAC/Professional Association specifically representing sUAS Commercial Aerial Photographers (sUAS CAP) could make a difference. I just wonder how many of us there really are that would be willing to pay $100 to $250 annually to belong to such an organization and what are the real numbers that we'd need. Is it 20,000? That would be great but if the number is that large, I wonder if we'd come close. Additionally, it would take a couple of individuals with a tremendous amount of time and motivation to make it happen.
I found your post about the potential cost of commercial certification for small sUAS to be very informative as well. Having worked as a professional in aviation, I am aware of the costs that airworthiness certifications can add to any product. On this point, I could not agree more. If sUAS Commercial AP is to exists on a level that small operators can afford, we MUST have some separation from the UAS entities that plan to operate large vehicles in the NAS.
I have suggested before a position paper? Something we could put our heads together and try to agree on. Maybe a PAC would come out of it or maybe it would just be something tangible that we could start floating out to other organizations that would perhaps endorse it. It might end up being as ineffective as a bunch of signatures on a petition but could inspire thought and consideration of the real needs of an industry we'd like to help forge.
The standards of the British sUAS rules have been brought up a lot. Are they something we could/should use as a model? Do you think the FAA is considering small operators at all in their rule development? I wonder if they're looking at those standards? The list of corporations sure doesn't make one believe so, as many have pointed out.
I think we need some critical distinctions which would separate this class/category of commercial operation from others that the FAA is charged to regulate.
Would these work:
Operations never to exceed 400 feet
Aircraft gross weight not to exceed 22 1bs/10 kg (half the weight of a small UAS as defined by the FAA) Maybe we call it vsUAS – very small Unmanned Aircraft System ;-)
No remotely detachable payloads
Must be remain in VLOS of the Operator
There may be other parameters that, by definition, would limit our operations and create a real distinction from the UAS operations that would be certified at a wholly different level.
I wanted to come back to your discussion about certifications and cost. Obviously, Airworthiness Certifications are directed at design, quality control and risk management in the name of safety. From what I can tell as a relative novice in this field, there are few of us, if any, who can assure the FAA or anyone else that our 15 lb MR won't fall out of the sky. It even happens to the military for all the money they spend. Certified components might help but could make the aircraft cost prohibitive.
What is the status of ballistically deployed parachutes for this type of equipment? Is this something we could integrate into our MR at a commercial level that would give the FAA a reasonable assurance should an un-certified flight controller fail, that the aircraft could be instantly disabled and float to the ground?
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Bartman
Welcome to MultiRotorForums.com!!
not to be a **** but, at this point, please discuss sUAS certification options in another thread. thank you (sorry!)!
Bart, Would you mind sharing the contents of your petition for comments from the group before posting it?
I wonder if we wouldn't be better served to draft a Position Paper that defines and details our wants and needs so that we have something that in essence, supports the petition and provides some detailed background and basis for individuals or groups that may wish to join/support the cause.
Motopreserve
Drone Enthusiast
#3: I can mine facebook for the related/appropriate group pages. I have a decent start on it - and can certainly find more. Of course I will also get the word out via email, blog sites etc as well.
Bartman
Welcome to MultiRotorForums.com!!
Thanks Scott!
@dmetz, a position paper will take much longer to write but it's something that will be a follow up exercise to the petition. i've got another domain name, www.understandingsuas.com that I may try to fire up in the coming days to post relevant info in support of the petition.
@dmetz, a position paper will take much longer to write but it's something that will be a follow up exercise to the petition. i've got another domain name, www.understandingsuas.com that I may try to fire up in the coming days to post relevant info in support of the petition.
Motopreserve
Drone Enthusiast
I'm thinking that I can also reach out to some of the podcasts that broadcast regularly to see if they might do a mention on-air.
Bartman
Welcome to MultiRotorForums.com!!
TITLE of the petition
[h=4]WE PETITION THE OBAMA ADMINISTRATION TO: Compel the FAA to adopt the UK's commercial sUAS standards immediately[/h]
BODY of the petition (800 word limit)
Small Unmanned Aerial Systems (sUAS or "drones") are already providing valuable services safely and for-hire to a wide range of industries (real estate, agriculture, public safety, etc)
The FAA's present interpretation (FAA-2014-0396) shouldn't seek to indirectly regulate commercial sUAS operations by better defining hobby usage
Commercial sUAS operators should be managed by an sUAS member-operator interest group to be overseen by the FAA
Peripheral issues such as privacy can and should be handled at the local/municipal level
Therefore, the FAA should adopt the UK commercial sUAS standards immediately so as to preserve the benefit of safe and low-cost sUAS aerial services for the tens of thousands of small business people that are already operating and employing them
[h=4]WE PETITION THE OBAMA ADMINISTRATION TO: Compel the FAA to adopt the UK's commercial sUAS standards immediately[/h]
BODY of the petition (800 word limit)
Small Unmanned Aerial Systems (sUAS or "drones") are already providing valuable services safely and for-hire to a wide range of industries (real estate, agriculture, public safety, etc)
The FAA's present interpretation (FAA-2014-0396) shouldn't seek to indirectly regulate commercial sUAS operations by better defining hobby usage
Commercial sUAS operators should be managed by an sUAS member-operator interest group to be overseen by the FAA
Peripheral issues such as privacy can and should be handled at the local/municipal level
Therefore, the FAA should adopt the UK commercial sUAS standards immediately so as to preserve the benefit of safe and low-cost sUAS aerial services for the tens of thousands of small business people that are already operating and employing them
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