pepper
Member
sooooo..... maybe we have some people with larger pocket books helping out.... http://www.hklaw.com/casestudies/out-in-front-on-drone-litigation/
Representation for Commercial sUAS
- Thread starter filmfly
- Start date
Old Man
Active Member
Good, feedback, harsh or soft it doesn't matter, it's feed back. That was exactly what I was trying to elicit.
I wrote the proposal without any input from anyone. At the time everyone was complaining but nobody was presenting alternatives. For the most part, they still aren't. This is what I meant when I mentioned that if we do and say nothing we'll get what someone else proposed in our absence.
Str8 up and Ronan, thanks for your input. When I wrote that I failed to consider distances for building/structure inspections. I routinely violate my own written standards when doing the same kind of work. Revision is necessary, but we learn from things like this, right?
Some expansion on "why" for things in the proposal. Much of what it contains we already do, or should do, in knowing our equipment, tracking our batteries, establishing inspection and maintenance practices, etc. The FAA will most certainly require some kind of equipment and operators manuals for everything we use and do. That's already been established in the Part 333 waiver process. So those items are to establish clarity and a formal "to do" list more than to lay out anything new. Most already do this stuff they just don't document them.
As for medical certificates, 1/3 of a day at an AME's (Aviation Medical Examiner) office and $120.00 or so usually takes care of that requirement. Yes, there are background checks associated with an aviation medical now. Thank the hijackers from 9/11 for that one. The Class III aviation medical is virtually the same qualifications required of a truck driver to obtain/maintain their commercial driver's license. Class II aviation medical is a bit tougher. Have a good ticker and marginally better eyesight. Correctable to 20-20 of course. The FAA does have a hard on for diabetics and people with high blood pressure though. They have to jump through a few more hoops. People that have problems with drugs and alcohol will also run into problems. Remember, we're dealing with the FAA, an organization that certifies pilots and establishes medical standards under which they must qualify. As a simple RC modeler that isn't an issue but as a commercial operator we're almost certainly going to be subjected to pilot medical standards. That was part of ARC and National Airspace discussions going back as far as 2007, and why the corporate operators quickly adopted medical certification standards.
Remember, those flying for hire are not flying for fun and games, and will always be held to a higher standard. However, the standard is open for definition at the moment. A Class III will likely end up the standard. Bear in mind, they could force anyone that flies for hire to become a Commercial Pilot. I'll take a medical certificate over having to go whole hog with a Commercial ticket any day of the week. Anyone got about a year or so and $15,000.00-$20,000.00 they want to toss out the window? I would prefer than no multirotor opertor be forced to have a full scale Pilot's licence but they've already mandated that in the 333 waiver process. Perhaps that will go away. I hope so.
Passing a Private Pilot written test. Yep, a PITA for sure, but another item the corporate players have already established with the FAA as being a qualifier to operate inside the National Airspace System (NAS). Will we go that high, fast, or far? Not in my life time but do we think the FAA with establish a separate knowledge standard for commercial operators just because they are small fry? My guess is no. OTH, some or many will at some point end up flying "missions" that could pose a conflict with aircraft such as helicopters. Remember that in Class G airspace a full scale operator only has to maintain specific separation distances from persons or structures. In angular measure that distance in feet is only about 1,400, or just over 1/4 mile. When not around a person or structure they only need to fly high enough to make a safe landing in the event a power unit failed. So if they were going fast enough that altitude in Class G airspace could be just clearing the ground. They could zoom for altitude in an engine failed, just as is done at the Reno Air Races during an in flight emergency.
Those were wild examples but the purpose was to show that what many don't know could in fact cause some pretty serious issues later. Having some fundamental aeronautical knowledge also works to our benefit in that we learn what all pilots are supposed to do is certain situations. We see them, they see us, what both are supposed to do is already established in the regulations. Who has right of way? Let's be clear, manned aviation will always have the right of way and passing the test standards assures the FAA we are well aware of that.
The big thing is that we want to assure we have a place in the NAS. We will be subjected to regulations, what those will be is not yet published. But to go in the door with nothing to counter with is pure folly. We won't have time to go back and forth after the NPRM is released and the comment clock starts ticking. Each of us has needs and desires that may well be unique to your particular operation or function. Put them on the table and let's see how those needs could be incorporated into a counter proposal. What I wrote is wide open to modification but it demonstrated to the FAA that we truly want to play in their airspace, believe in flight safety, understand that we'll have to, at least at some level, think like a pilot, and have a general understanding of the rules that everyone else has to play by. None of it is cast in concrete.
So please, let's have some more complaints, grousing, and suggestions and clarification. That's how we'll get to where we need to be.
I wrote the proposal without any input from anyone. At the time everyone was complaining but nobody was presenting alternatives. For the most part, they still aren't. This is what I meant when I mentioned that if we do and say nothing we'll get what someone else proposed in our absence.
Str8 up and Ronan, thanks for your input. When I wrote that I failed to consider distances for building/structure inspections. I routinely violate my own written standards when doing the same kind of work. Revision is necessary, but we learn from things like this, right?
Some expansion on "why" for things in the proposal. Much of what it contains we already do, or should do, in knowing our equipment, tracking our batteries, establishing inspection and maintenance practices, etc. The FAA will most certainly require some kind of equipment and operators manuals for everything we use and do. That's already been established in the Part 333 waiver process. So those items are to establish clarity and a formal "to do" list more than to lay out anything new. Most already do this stuff they just don't document them.
As for medical certificates, 1/3 of a day at an AME's (Aviation Medical Examiner) office and $120.00 or so usually takes care of that requirement. Yes, there are background checks associated with an aviation medical now. Thank the hijackers from 9/11 for that one. The Class III aviation medical is virtually the same qualifications required of a truck driver to obtain/maintain their commercial driver's license. Class II aviation medical is a bit tougher. Have a good ticker and marginally better eyesight. Correctable to 20-20 of course. The FAA does have a hard on for diabetics and people with high blood pressure though. They have to jump through a few more hoops. People that have problems with drugs and alcohol will also run into problems. Remember, we're dealing with the FAA, an organization that certifies pilots and establishes medical standards under which they must qualify. As a simple RC modeler that isn't an issue but as a commercial operator we're almost certainly going to be subjected to pilot medical standards. That was part of ARC and National Airspace discussions going back as far as 2007, and why the corporate operators quickly adopted medical certification standards.
Remember, those flying for hire are not flying for fun and games, and will always be held to a higher standard. However, the standard is open for definition at the moment. A Class III will likely end up the standard. Bear in mind, they could force anyone that flies for hire to become a Commercial Pilot. I'll take a medical certificate over having to go whole hog with a Commercial ticket any day of the week. Anyone got about a year or so and $15,000.00-$20,000.00 they want to toss out the window? I would prefer than no multirotor opertor be forced to have a full scale Pilot's licence but they've already mandated that in the 333 waiver process. Perhaps that will go away. I hope so.
Passing a Private Pilot written test. Yep, a PITA for sure, but another item the corporate players have already established with the FAA as being a qualifier to operate inside the National Airspace System (NAS). Will we go that high, fast, or far? Not in my life time but do we think the FAA with establish a separate knowledge standard for commercial operators just because they are small fry? My guess is no. OTH, some or many will at some point end up flying "missions" that could pose a conflict with aircraft such as helicopters. Remember that in Class G airspace a full scale operator only has to maintain specific separation distances from persons or structures. In angular measure that distance in feet is only about 1,400, or just over 1/4 mile. When not around a person or structure they only need to fly high enough to make a safe landing in the event a power unit failed. So if they were going fast enough that altitude in Class G airspace could be just clearing the ground. They could zoom for altitude in an engine failed, just as is done at the Reno Air Races during an in flight emergency.
Those were wild examples but the purpose was to show that what many don't know could in fact cause some pretty serious issues later. Having some fundamental aeronautical knowledge also works to our benefit in that we learn what all pilots are supposed to do is certain situations. We see them, they see us, what both are supposed to do is already established in the regulations. Who has right of way? Let's be clear, manned aviation will always have the right of way and passing the test standards assures the FAA we are well aware of that.
The big thing is that we want to assure we have a place in the NAS. We will be subjected to regulations, what those will be is not yet published. But to go in the door with nothing to counter with is pure folly. We won't have time to go back and forth after the NPRM is released and the comment clock starts ticking. Each of us has needs and desires that may well be unique to your particular operation or function. Put them on the table and let's see how those needs could be incorporated into a counter proposal. What I wrote is wide open to modification but it demonstrated to the FAA that we truly want to play in their airspace, believe in flight safety, understand that we'll have to, at least at some level, think like a pilot, and have a general understanding of the rules that everyone else has to play by. None of it is cast in concrete.
So please, let's have some more complaints, grousing, and suggestions and clarification. That's how we'll get to where we need to be.
Old Man
Active Member
FYI, I bought my first plane in 1990 for less than $13K. Today's heavy lifters with a gimbal cost more than that.
A medical runs around $100.00.
There are 3 ways to pass the PP written test.
- Buy the books for about $40.00 or so and study, study, study until you feel ready to take the test, Take the test at a lot of different locations but your local airport and flight school will be a good source for location info. You have to pay to take the test with any of the methods. Figure another $100.00 or so.
- Pay a flight instructor to give you ground schooling. Really expensive and time consuming. You still have to buy the books and pay the testing fee.
- Purchase an accelerated training course. You're essentially memorizing the multiple choice possibilities on the written test Most forget everything the memorized within a few days of passing the test. Runs several hundred dollars, and you still have to pay the testing fee. You can do this in in a week or less. you should still buy the books for later reference
Bartman
Welcome to MultiRotorForums.com!!
a lot of local flight schools will have group ground-school programs that are less expensive than one-on-one and you'll still get the instructor endorsement to sit for the test.
Old Man
Active Member
I was bouncing around on a search today and found a couple things that might prove useful if the need arises. The first is an FAA listing of all the test centers in the U.S. I'd call any of them that fit your locale before driving out there. https://www.faa.gov/pilots/testing/
Second is a home study course, a bit pricey but you can do it on your own time and provides all the books and study material to go all the way through the Private flight test should one decide to go all the way. http://www.kingschools.com/ground-s...&scu=GAWCORP&gclid=CNDDtcjZq8ICFUeEfgodKJwAww
One could also Google King Schools and obtain some of the individual courses for less at Amazon. Google Private Pilot ground school for even more selections.
There's a lot of different course curriculum out there but many requires that the individual attends classes at their location which can hammer a personal and work schedule. I hope things don't go to such burdensome requirements but at least we all have options in the manner we would have to get things done.
Second is a home study course, a bit pricey but you can do it on your own time and provides all the books and study material to go all the way through the Private flight test should one decide to go all the way. http://www.kingschools.com/ground-s...&scu=GAWCORP&gclid=CNDDtcjZq8ICFUeEfgodKJwAww
One could also Google King Schools and obtain some of the individual courses for less at Amazon. Google Private Pilot ground school for even more selections.
There's a lot of different course curriculum out there but many requires that the individual attends classes at their location which can hammer a personal and work schedule. I hope things don't go to such burdensome requirements but at least we all have options in the manner we would have to get things done.
Old Man
Active Member
Looks like someone is finally getting the message.
http://thehill.com/policy/transportation/226176-house-to-hold-drone-hearing
http://thehill.com/policy/transportation/226176-house-to-hold-drone-hearing
kloner
Aerial DP
I used the sportys faa knowledge test study buddy app to prep, 70% of the questions were exactly what was on the test,,,, the other 30% were related to stuff i had studied but worded different. I personally can't just learn form books very well, i had to see what they were talking about and that's what going to a vfr ground school like local flying clubs offer.
With the FAA releasing there new rule set for public comment supposedly within the end of the year, you are all a bit late to the party. There doing it all as we discuss this. If you want to make a difference at this point will be to "public comment" on there rule set when you see them in a positive moving way, not to just ***** but to give reasons that makes people think about why what is good or bad in it. For those to understand the mindset without meeting them, think IRS, FBI, etc mentality and how if they ask a question, you give a reasonable answer and they move on to the next question and listen to you. Start rambling and not making since they move on to the next comment and your ignored.
With the FAA releasing there new rule set for public comment supposedly within the end of the year, you are all a bit late to the party. There doing it all as we discuss this. If you want to make a difference at this point will be to "public comment" on there rule set when you see them in a positive moving way, not to just ***** but to give reasons that makes people think about why what is good or bad in it. For those to understand the mindset without meeting them, think IRS, FBI, etc mentality and how if they ask a question, you give a reasonable answer and they move on to the next question and listen to you. Start rambling and not making since they move on to the next comment and your ignored.
pepper
Member
positive thinking !! agreed! we all gripe on forums but I'm sure that if we were in person with the FAA, it would be different. seeing that kloner is getting his pilots license, and has already went through the sUAV/FAA issues, may be a strong indication on what the FAA is going to want.
is there a link to comment on what the FAA is discussing?
is there a link to comment on what the FAA is discussing?
kloner
Aerial DP
It's all internal and with those uav integration groups right now, then it'll be posted on regulations.gov for public comment, then the faa will take the serious comments that show either why or why not the sections will work not work and explain there way out. Anybody that's ever talked to an faa administrator would understand. I had last heard it's suppose to be up there before 1-1-2015..... i can tell you there a pain to work with right now cause there super busy attempting to meet that deadline. And they probably want to take the holiday/new year off so i'd expect to hear something very very soon. It WILL make national headline news so unless you live under a rock, your gonna hear all about it on the new/media outlets
Late to the party? Really? You geniuses have pretty much made sure the party is all but over.
Am I the only one that thinks that the MPAA and these exempted companies basically did nothing but make the entire regulatory situation 10 times worse?
By using proprietary manuals as a group, they have gone directly against the very spirit of all anti-trust legislation. Then they agreed to provisions, that in several cases are currently not possible to comply with, much less make no practical sense whatsoever. Commercial operations that could have been performed at a reasonable cost would have to be quadrupled in order to meet what this group has agreed to. All in great haste and greed to gain some competitive advantage. How Pathetic. They have not done the industry or anyone else any favors here. Transport Canada just released a set of very practical guidelines for commercial operations that are very well balanced. Here in the US we have a large association making back door deals to lock out any competition. You should be ashamed.
Am I the only one that thinks that the MPAA and these exempted companies basically did nothing but make the entire regulatory situation 10 times worse?
By using proprietary manuals as a group, they have gone directly against the very spirit of all anti-trust legislation. Then they agreed to provisions, that in several cases are currently not possible to comply with, much less make no practical sense whatsoever. Commercial operations that could have been performed at a reasonable cost would have to be quadrupled in order to meet what this group has agreed to. All in great haste and greed to gain some competitive advantage. How Pathetic. They have not done the industry or anyone else any favors here. Transport Canada just released a set of very practical guidelines for commercial operations that are very well balanced. Here in the US we have a large association making back door deals to lock out any competition. You should be ashamed.
Av8Chuck
Member
Finally, someone willing to talk about the"why" the regulations should be what they're going to be rather than "what" the regulations should be. Its an issue of process and the issue becomes much more interesting if we discuss the process. Kloner, and the others represented by the MPAA are working within the guidelines of the already existing process, the one that certifies full size aircraft for example, and clearly that top down, one sized fits all regulatory process is not going to work well in this situation. However, no matter how much we might disagree with that process its not OK to rail against Kloner and the MPAA's effort to find what they consider to be a solution to this issue. Its nice to think that we might be able to effect change in the overall process but these companies are trying to work within the already existing system to make sUAS legal. You can't fault them for that. They did not create this mess, the FAA did.
Don't get me wrong, I agree with the sentiment of your message but lets not shoot the messenger, Kloner has always helped this community and he is in an important position to help us by providing us with examples of what works as well as what doesn't, and we need to be able to trust him and he, us, and that trust will be hard to find if we level accusations at one another.
Do you have a link to the recently enacted guidelines?
http://www.tc.gc.ca/eng/civilaviation/standards/general-recavi-uav-2265.htm?WT.mc_id=1zfhj#safety
Kloner seems like a nice guy but that is not the point. Smart people don't try to drive a square peg into a round hole. The MPAA and these companies in no way had yours or my interests in mind when they headed down this path. The sole intent was to create a monopoly for aerial filming. I made no accusations, only observations that are all valid.
Kloner seems like a nice guy but that is not the point. Smart people don't try to drive a square peg into a round hole. The MPAA and these companies in no way had yours or my interests in mind when they headed down this path. The sole intent was to create a monopoly for aerial filming. I made no accusations, only observations that are all valid.
Av8Chuck
Member
The FAA don't have a clue the shape of their hole and they won't know until they pull their head out of it. And we can't seem to agree on the shape of our peg. The MPAA is a trade organization and they did exactly what they should have, represent their members. AOPA is doing the same for pilots and the AMA for modelers, so who represents the interests of small sUAS businesses?
Keep in mind that most of the revenue generated for sUAS small businesses will not come from those who just want to fly them but more likely those that will benefit from the services they provide like realtors, farmers and firemen for example. Part of the problem we have is that carpenters, electricians, and mechanics all have trade organizations and use screw drivers [for example] to solve different problems, but there's no trade organization for the tool.
Keep in mind that most of the revenue generated for sUAS small businesses will not come from those who just want to fly them but more likely those that will benefit from the services they provide like realtors, farmers and firemen for example. Part of the problem we have is that carpenters, electricians, and mechanics all have trade organizations and use screw drivers [for example] to solve different problems, but there's no trade organization for the tool.
kloner
Aerial DP
The motion picture industry is all about driving down costs with competition and i garuntee you we in no way shut the door behind us. I heard theres a bunch of exemptions getting ready to be granted in the next week or two. I'm anxious to see if they include for aerial filming or what.A bunch of power companies are coming up, disney will have something soon. Were not the only ones agreeing that what there asking for pros with really big helis doing risky work should need. I think we would all agree that the little guys should be considered a no brainer to just be careful and good luck where the larger riskier helis need some sort of level of safety. Honestly i never would have nor did we bring up any pilot license, hence why i have exemption and can't even fly yet.
scotth
Member
It would be nice to see some additional 333 exemption petitions approved that discount your view, but have you ever dealt with the FAA on similar issues? It is a royal pain in the rear. Try getting a 135 certificate.. it can take years. Or a field approval on a simple part replacement in a certificated airplane. Forget it. I spent thousands with a DER once to get approval to put a simple hole through a non-structural portion of a Jet Ranger in order to run some camera cables. All common sense stuff, but no. Or more to your point, look at companies that have spent huge amounts of money on engineering and legal fees in order to get an STC approved with the FAA. That STC isn't for the rest of the aviation public to glom on to.. it's intellectual property. I see the legal fees and time spent by the first 7 companies on developing policies and procedures that satisfy the FAA as something that shouldn't be available to the public either.
But yes.. why are there no others having been approved yet? That's a good question. But there is a downside to getting the exemption. You've seen the requirements.. they are incredibly restrictive. I would guess that anyone getting the exemption automatically cuts themselves out of a good percentage of the work they used to do... since they're now on the FAA radar.. because they can't meet the requirements in many of the gigs. On the gamble that bigger ticket film shoots will come their way.
My 2c.
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