Aviation Rule Making Committee report [Archive]

Quandumphone

May 13, 2009, 11:45 PM

Some pretty crazy weight and operating area restrictions in there if I read it right. Not bad for the boondocks testing flights but pretty bad for an average sized camera ship wanting to operate in populated areas. I guess they want to rely on the waiver process pretty heavily.

I have to go back and read it again but I think a Private Pilots License should be acceptable in lieu of any sUAS required operators certificate. It seemed that wording was a bit weak but maybe I'm wrong. They're using a lot of the same reliance on written and general operating procedures for see and avoid that a private pilot is required for and shouldn't need repeating. I didn't see any distinction between fixed a rotary wing but I might have missed that.

I also thought that the AMA commenting against the "model aircraft not operated in accordance with accepted set of standards" hobbyist was a bit of a conflict of interest. They have a monetary stake in that requirement and should have stayed silent regarding it.

I thought it was a good idea to essentially allow testing and indirect commercial operations at what appears to be club sites with permission. Problem is, I don't think it is currently allowed by AMA to do fully autonomous flights. So that provision is a little useless unless the AMA changes policy except for regular R/C demo flights and non autonomus model testing.

rich smith

May 14, 2009, 09:38 AM

This link is to a 74 page report date 1 April 2009 by the
Small Unmanned Aircraft System Aviation Rulemaking Committee

April Fool!

CenTexFlyer

May 15, 2009, 12:02 AM

April Fool!

OH! How I wish it were so!

rich smith

May 15, 2009, 08:58 AM

To me the recommendations appear totally reasonable and no surprises. Hobby (Group I) UAVs: line of sight, 400' alt, 30 knots, 4.4lb, 3 miles from airport, no certificate required. I've built and flown close to 2 dozen UAV all under 1lb and only issue is had to go above 400' in order to deal with piss poor GPS altitude accuracy. I'm willing to either add barometer or keeps things the same and risk cheapie plane.

The only ones who will complain are those wanting to fly large and dangerous aircraft in risky situations. Reminds me of the ultralight/sport debacle few years ago. The big whiners were those who abused original part 95 training exemption and wanted to joyride with girlfriends in overweight overpowered "fatties" with no intention of instructing. Personally I was glad to see the FAA clamp down.

EddieHaskell

May 17, 2009, 11:24 AM

To me the recommendations appear totally reasonable and no surprises. Hobby (Group I) UAVs: line of sight, 400' alt, 30 knots, 4.4lb, 3 miles from airport, no certificate required.

I guess you didn't notice that autopilots ( Auto Flight Management ) are not allowed in Group I. In addition, Group I requires System Certification ( sect. 9.4 ) before it can be used. In fact all of the catagories require certification ( sect. 20 ) If you read section 20, you'll realize that certification is intended for companies that manufacture sUAS ( ready to fly small UAVs ).

Model Aircraft ( sect. 3 ) requires "direct control from the pilot" ( ie. no autopilot ). 3.2.5 "Model Aircraft are limited to unaided VLOS".

Sounds to me like this is the end of ( legal ) amatuer UAVs.

patrickegan

May 17, 2009, 11:57 AM

It is the end! No amateur, no hobby, no nothing and it was buttressed with uncertified (untested) open source autopilots being flown in the NAS. The last day of the ARC they all let me twist in the wind (with the exception of Fred Marks FMA). I made some friends that day :rolleyes:

I called BS on the whole hobby thing and so did the AMA but, first and foremost they were there to advocate for their membership.

My take on the 10+ months of fun.

http://www.rcapa.net/forums/blog.php?u=7

airmcn_3

May 17, 2009, 12:32 PM

patrickegan

May 17, 2009, 12:35 PM

No hobby uav/uas

jetblackaircra

May 17, 2009, 12:44 PM

It is the end! No amateur, no hobby, no nothing

The way I read the ARC suggestions, it doesn't say anything about hobby sUAS. It says the recommendations are for civil (commercial) sUAS. In the first paragraph of the forward is says that.

Also, I reread subpart A for model aircraft. The way I read it, they are excluding hobbyists from the rest of the recommendations. Only sections 2 and 3 apply to hobbyists. These sections basically say that you have to be in direct control. Direct control does not appear in the definitions, so as long as you are in visual line of sight, and are in direct control...

I get the feeling they want the FAA to be a little more specific than AC 91-57 but it sounds like they're not wanting to keep hobbyists from flying, but they do want you within line of sight and they do want you to be able to make maneuvering commands directly at all times. Not, just send it a couple of miles away using only onboard sensors to fly. Seems reasonable to me. If you want to fly out of line of sight and autonomously, you've got to certify it.

You guys have a problem with that? Seems perfectly resonable.

patrickegan

May 17, 2009, 01:02 PM

No, if you want to fly "in" line of sight autonomously, you've got to certify it. there is "no" beyond VLOS. :(

matttay

May 17, 2009, 01:47 PM

To me the recommendations appear totally reasonable and no surprises. Hobby (Group I) UAVs

This isn't hobby, though, this April 1 paper is for commercial isn't it?

Hobby is ambiguous as ever. AC 91-57 has the 400' AGL ceiling that is broken hourly at every field in the country. AMA adds to that and prevents autopilots I think.

So, if you are a hobbyist flying UAV, you are outside of your AMA coverage, but probably clean from FAA perspective if you stay under 400'. I don't think LOS is required from FAA.

Of course, regardless of the rules, if you crash into the ground and kill someone or bring down a manned aircraft, then what the rules state will be of little consequence.

I'm in agreement with you on the "lighter is better". If you are lighter than a bird, and made of something like foam, then the chances of you hurting something in the air or on the ground is very, very remote.

I'd not mind if hobbyists were clamped down on a bit. I don't like the idea of someone with nearly zero assets to their name (aka "nothing to lose") building a 6 pound monster with a gas engine and trying to fly waypoints to populated places unseen without a lot of engineering rigor and concern for life and property. Not sure how to prevent this, though, given the enforcement staff on hand.

patrickegan

May 17, 2009, 03:05 PM

Its for everything unmanned under 55lbs, regardless of anything else.

Gary Mortimer

May 17, 2009, 03:28 PM

Was the 87 knots to fend off kinetic energy incidents??

Guess not having a turbine onboard helps with that.

It does all smack of protection for the big boys making the gear.

But with ever more daring FPV video on YouTube and a ceaseless stream of look how high I went posts appearing. All during the ARC process I bet it was very hard sat at the table defending model aircraft flyers, not just UAS.

I expect we will get something similar in Europe, but am holding out for the fact that the UK CAA are already making provision for commercial aerial photography.

Something which seems to have been completely missed in this arguement.

You might get your UAS certified in the USA but as I read it you will not be permitted to use it for hire and reward.

I'm sure sense will prevail.

Especially if all the AMA members that ever aspire to have a turbine aircraft or fly competition cross country gliding competitons get their act together and petition. Oh and the handful of UAS types.

matttay

May 17, 2009, 03:47 PM

Patrick, are you sure? Where is the text that say says this applies to everything unmanned (including RC hobby) under 55 pounds?

If you are right, then a hobbyist flying small UAV with autopilot is in violation of this rule. And everyone flying a regular RC plane faster than 100 MPH is in violation of this rule? And regular RC flights now require an observer?

jetblackaircra

May 17, 2009, 06:22 PM

Patrick,

Nowhere in the document does it say that you cannot fly for hobby an autonomous aircraft within line of sight of which you have direct control of as well. It says,

"Model Aircraft: A sUAS used by hobbyists and flown within visual line-of-sight under
direct control from the pilot, which can navigate the airspace, and which is manufactured or
assembled, and operated for the purposes of sport, recreation and/or competition."

Nowhere in the document does it define "direct control". However, they do define:

Auto Flight Management: Pilot-in-Command (PIC) is able to maintain stable flight without
constant direct intervention. To at least some degree, control surface movements result from
sensors and software automation on-board the aircraft.

AND

Manual Flight Control: PIC is able to directly control the aircraft such that control inputs
made at the Control Station are translated directly into corresponding control surface
positions. Augmentations which help maintain flight stability are permitted.

I feel it could be argued that if the pilot is able to switch between modes he is able to maintain "direct control". If they meant absolutely no autonomous flight, why didn't they say "no auto flight management".

patrickegan

May 17, 2009, 06:56 PM

airmcn_3

May 17, 2009, 07:15 PM

patrickegan

May 17, 2009, 07:32 PM

From what I've heard end of 2011 early 2012 (maybe never???) It is going through the SRM process (no friends here but, I've offered help), then out for NPRM and comment.

airmcn_3

May 17, 2009, 07:35 PM

From what I've heard end of 2011 early 2012 (maybe never???) It is going through the SRM process (no friends here but, I've offered help), then out for NPRM and comment.

Good to hear we still have some time. Thank you for taking the time and effort to try and help out the hobby.

Chris

matttay

May 17, 2009, 08:48 PM

I was on the ARC, I fought against it for 10 months. Read the AMA safety guidelines, if you're an unaffiliated RC flyer, you're getting less. Believe me, they don't want autopilots or anything else that is automated.

If you aren't AMA, then you are covered by 3.x "Model Aircraft Not Operated in Accordance with Accepted Set of Standards"

3.3 (1) has a 55 pound limit, (5) is a 400' AGL, (6) says you can operate with 3 nm of airport, but you must be <2 pounds and <60 MPH.

Thus, these guidelines appear to replicate AC91-57, and where they clamp down, they are reasonable and sane.

I'm with JetBlackAircraft, reading this doesn't appear to prohibit hobbyists from UAV development.

Note specifically they call out under manual flight control " Augmentations which help maintain flight stability are permitted." This can be read very broadly to mean an FMA or an autopilot. If they were worried about autopilot, then in 65 pages of text you'd think they would specifically state that hobbyists may not ever use autopilots.

Please cite the text that prohibits a hobbyist from flying a UAV under LOS conditions.

c_matt92

May 17, 2009, 08:55 PM

I understand the problems that you guys have with this. I agree that there needs to be provisions for low altitude, close range hobby UAS's, but at least something is finally being done. As both a hobbiest and someone that is interested in being able to use these on a commercial bases in the not to distant future, I am glad to see that they finally decided to actually act on the UAV issue. I believe that before things are "wrote in stone", there will be provisions for hobbiests, but every one of you has to admit that many of the people out there (not necessarily those on here but others) will do very idiotic things with a UAV if they aren't regulated with them. They will fly as far as they can, over huge cities, and end up killing someone if they aren't watched. The way the FCC is right now, they wouldn't be able to watch this, either. Hence the harsh restrictions. Not saying that this is the best, just the reasons that I see for these regulations and I can understand them.

patrickegan

May 17, 2009, 10:04 PM

Matt,
Read Sec. 1. (definitions) for model aircraft. Any other questions call them up. :)

jett
Sec 9.3 (1) Manual Flight Control :)

airmcn_3

May 17, 2009, 10:45 PM

Matt,
Read Sec. 1. (definitions) for model aircraft. Any other questions call them up. :)

jett
Sec 9.3 (1) Manual Flight Control :)

Sec. 1. Definitions

Model Aircraft: A sUAS used by hobbyists and flown within visual line-of-sight under
direct control from the pilot, which can navigate the airspace, and which is manufactured or
assembled, and operated for the purposes of sport, recreation and/or competition.

Going to have to call them on this one, I can think of a few arguments as I am sure many can.....

9.3

Manual Flight Control: Group I SUAS must be capable of only manual flight
control, ensuring that PIC control inputs made in the Control Station are translated directly into corresponding control surface positions. !

RATIONALE: The idea for Group I aircraft were that they are operated
like a Model Aircraft for compensation and hire. Model Aircraft are not
generally operated in any other manner than manual flight control. Such a system is likely to be less complex and thus easier for a non-license PIC
to operate.
For operations requiring other than manual flight control (i.e., auto flight
management) would thus have to be operated as Group II.

ALTERNATIVE VIEW: Group I sUAS should be allowed to utilize
simple auto flight management systems as long as manual flight control
can be assured.

ALTERNATIVE RATIONALE: Technology has progressed to such a
state that to preclude the use of simple auto flight management is
unnecessarily restrictive. Consensus standards could be written to define
such systems and the mechanisms to test and verify their performance.

Pretty cut and dry on where they want to go with this. I like the ALTERNATIVE VIEW if I had an option.....

matttay

May 17, 2009, 10:51 PM

Read Sec. 1. (definitions) for model aircraft. Any other questions call them up.

Model aircraft, as defined, permits "direct control".

As jetblackaircraft notes, "direct control" is not defined. If I'm watching my UAV, and it's flying to a waypoint I've programmed, and I can abort that operation in 100 mS and resort to manual flight, then I'm in direct control.

If you want to get literal, then direct control means me moving a control surface with my finger. As it is, there are countless, literally, entities, including several microprocessors that are processing the signal in countless ways, between me and the actual control surface. Since they haven't defined the level of processing, I'm assuming all processing is permitted.

If, instead of Direct Control, they substitute Manual Flight Control, then I still read that as an autopilot being permitted.

If they define Direct Control to mean Manual Flight Control MINUS stability augmentations, then I'd be a bit worried.

It's a simple clarification for them to make at this point.

jetblackaircra

May 17, 2009, 11:03 PM

Agreed.

And the hobbyist aircraft do not fall under group 1 anyway. they are completely seperate. the 5 groups only apply to commercial....

either way, what I've been saying all along is still true. There will be an NPRM that will come out. It will most likely be worded similarly to this document. We will ALL have a chance then to give input. We MUST ALL give input to try to get them to realize there is no reason to keep hobbyists from using autopilots.

Anyway, no point getting all heated now... lets all go out and fly sUAS's with autopilots as a hobby while we can.

patrickegan

May 17, 2009, 11:13 PM

Its called denial.

matttay

May 17, 2009, 11:19 PM

RATIONALE: The idea for Group I aircraft were that they are operated
like a Model Aircraft for compensation and hire. Model Aircraft are not
generally operated in any other manner than manual flight control. Such a system is likely to be less complex and thus easier for a non-license PIC
to operate.
For operations requiring other than manual flight control (i.e., auto flight
management) would thus have to be operated as Group II.

OK, this is pretty unambiguous, but it conflicts with their other statement about flight stabilization being OK. However, things like Return Home in the event of lost radio contact is smart no matter what, and it will be part of a basic RC plane in the very near future. The DIY drones folks are demonstrating what can be done for super cheap.

The should have a definition for direct control and auto flight management. As written, I'd consider heading hold and alt hold to be flight stabilization (which is OK), but hitting waypoints to be "auto flight management". However, Return Home I'd not consider part of auto flight management

PS If alt and heading hold is OK, why is turning criminal? What is their concern with "auto flight management" if the pilot can regain control in a few hundred milliseconds?

Their statement here is circular: Model Aircraft don't generally have flight control, and thus anything with flight control isn't a Model Aircraft.

patrickegan

May 17, 2009, 11:31 PM

The DIY drones folks are demonstrating what can be done for super cheap. Yes, but certified is another story. Those of us who are proponents agree that it can be done safely and that RTL is flyaway protection. The vendors had nothing to say in the way of support for us using them.

mlbco

May 18, 2009, 01:46 AM

Sec. 1. Definitions

Model Aircraft: A sUAS used by hobbyists and flown within visual line-of-sight under
direct control from the pilot, which can navigate the airspace, and which is manufactured or
assembled, and operated for the purposes of sport, recreation and/or competition.

I already wrote to the AMA mentioning that this definition excludes free flight models and that they would no longer be considered Model Aircraft. If you're looking for a "wedge" to force the FAA and AMA to consider amateur UAVs as model aircraft, the free flight category is the way to go. The AMA already supports uncontrolled models in the NAS (i.e. free flight) and looking at the AMA safety code I can't find anything that prevents me from flying a 55 lb free flight. When the AMA and FAA come to terms with this omission there should be some leeway left to insert the idea of an autonomous model with the possibility of direct manual control.

Steve

patrickegan

May 18, 2009, 01:49 AM

Anything is possible but... I have very little support as far as uncertified autopilots go.

p.s. glad to see MLB make it up to Beale :)

jetblackaircra

May 18, 2009, 02:34 AM

The free flight comment is a very good point. Bottom line is that this is the first time in recent history that the FAA has come out with an entirely new set of rules (other than light sport aircraft) and so there will be a period of transition in which there are rules in place which are excessive. The idea is that we should all do what we can to comply, but also focus our efforts on making it clear to the FAA what the public consensus is through the appropriate channels. (NPRM).

I go back to what I said months ago. I think we should all start to formulate a response to the NPRM based on what is said in the ARC recommendations. If we all submit the same response to the FAA they will pay attention. We should concentrate on making sure that we all know the correct way to respond to the NPRM and that we all have the same comments. That gives the best chance of getting our ideas heard and making a difference.

Patrick, since you are affiliated with an organization which holds some weight, I leave it up to someone like you to organize such an undertaking. I have some experience responding to NPRMs having worked for Cessna/McCauley. I'm willing to provide some input in the form of sample letters with formatting, etc. But, the first thing is to get a list of people interested in doing this.

Anyone?

Gary Mortimer

May 18, 2009, 05:15 AM

Join RCAPA and the AMA if your not already.

Get the representatives there to fight your corner.

Come to the table with clear defined rational messages.

Make sure people like the free flight crowd know they might be affected.

Seems like the FAA is taking the chance to get lots through under the mantle of sorting out UAS. Hoping that other disciplines won't notice.

Its amazing isn't it, you would sort of hope that the FAA would be full of little boys and girls that grew up making models and would have some insight.

You have a different president now, maybe that will mean a different attitude to this development stifling rule making from the administration.

Failing all that book your tickets to Australia, maybe Europe, certainly Africa oh and China probably wants you!!

rich smith

May 18, 2009, 07:56 AM

IMO these issues are really not important to those interested in actual hobby operation. The FAA has virtually no enforcement ability in the real world. Unless you are making big bucks, building UAVs way outside the amateur realm (i.e. over a pound or two etc.), or quaking in your boots over AMA coverage, then nothing to be concerned about.

If you are careless/foolish and complaints issued they may investigate but, even then, unlikely to do anything. Typically a civil case if anything. This has been the situation with literally thousands of ultralight incidents where they take one look at the "flying clothes line", get back in the black SUV, and drive away. As the true UL guys say, "Just Fly".

jetblackaircra

May 18, 2009, 09:28 AM

Good point I suppose, but at the same time, it would suck to get busted and fined just because your airplane accidentally crashed into a senators car or something stupid like that. Might as well try to make the rules make sense when you have the chance to change them.

CenTexFlyer

May 18, 2009, 09:36 AM

If you are careless/foolish and complaints issued they may investigate but, even then, unlikely to do anything. Typically a civil case if anything.

Woof! I guess ol' rich has never sat in the hot seat during an FAA "investigation"! Talk about a dog pile! They have lawyers sitting in so that every infraction (FAR) they can come up with can be determined to be civil or criminal. Not fun!

..... and we haven't even gotten into "willful intent"......

rich smith

May 18, 2009, 09:46 AM

Woof! I guess ol' rich has never sat in the hot seat during an FAA "investigation"! Talk about a dog pile! They have lawyers sitting in so that every infraction (FAR) they can come up with can be determined to be civil or criminal. Not fun!
..... and we haven't even gotten into "willful intent"......

True. Never been in that position and curious what you did to get there. But my point is unlikely it gets to that state of affairs. After personally being present at several crashes involving "illegal eagles" and hearing of hundreds on Yahoo UL groups not one case of fine or other action. Not one.

(Note to self: do not crash into senators car. Even with my 14oz foamie UAV.)

patrickegan

May 18, 2009, 09:55 AM

The idea is to do up a cheat sheet of grievances for use by the sUAS stakeholders. :)

rich smith

May 18, 2009, 10:26 AM

...

rich smith

May 18, 2009, 10:28 AM

I think we should all start to formulate a response to the NPRM based on what is said in the ARC recommendations. If we all submit the same response to the FAA they will pay attention.

Like they did with LSA, right? LOL!

I am glad we got guys like Patrick in there making noise for us. Problem is the FAA tend to listen to the money. In this case it seems like AMA and a couple mfg are only input. FAA don't seems too interested in "the public". How does it go? "The FAA has reviewed your comments and find it is not in the FAAs best interest at this time to...." or something like that.

The only improvement I see to this document, as mentioned, is make the Alternative Views less alternative and more justifiable. But I'm only a hobbyist. :eek:

patrickegan

May 18, 2009, 10:33 AM

There are parts of the documents they didn’t post. More opposing views, a section on LTA and some things for consideration in the future. Money talks here and those with the money are at the forefront of the issue.

Gary Mortimer

May 18, 2009, 01:26 PM

Oh and best you start containing this crowd.

http://www.youtube.com/watch?v=rXrXckTZ8ZY

Is it any wonder regulation is required

Thankfully I have never had to sit on the 13th floor of the CAA over here for a meeting with no biscuits, but I know a couple of people that have.

One very good friend of mine filed an incident report for something that really was nothing and nobody was hurt. But once the CAA starts it plays hard. He ended up with a suspended sentance!! Remember he filed the first report that landed himself in trouble!! Just imagine if they came to you.

No I'm not going to say what for.

Once the rules are in place its simple money for the FAA!

Just look at all the evidence on the OSD

jetblackaircra

May 18, 2009, 04:07 PM

Sweet video :-) But their artificial horizon sucks. Over estimates bank angle the whole time.

reznikvova

May 18, 2009, 04:56 PM

Sweet video :-) But their artificial horizon sucks. Over estimates bank angle the whole time.

Not a perfect install of OSD AHI, is the problem.

http://vimeo.com/4418321

Sean_M_2007

May 18, 2009, 10:50 PM

Thank you Patrick for all the time and effort you put into the ARC. It takes a lot of dedication to fight an uphill battle.

This post turned out to be longer than I expected, so I put some section labels in to break it up.

Commercial Applications:
The ARC recommendations appear to do a good job of enabling initial operation of commercial UAVs to fly in the National Airspace System without conflict with manned aircraft. This is important for developing and testing UAVs, which I have heard is quite difficult to do under current regulations. However, the 1 statute mile distance restriction and the 1200ft AGL altitude restriction severely limit the commercial applications. You can get a low altitude aerial view of the ground around where you are flying from, but that's it. Even doing something like taking aerial imagery of a farm field might require you to land and move in order to image the entire field.

Training and Certification:
I think the pilot and aircraft certification requirements do a lot for enhancing safety and awareness. The trouble is, if the commercial opportunities under these regulations are very limited, will enough people be willing to invest in establishing the training and certification programs needed to carry out these regulations? Now, people might invest in these training and certification programs anyway because they anticipate the FAA will open up more of the NAS to UAVs in the future, but the FAA would have to make it clear that this is the direction they are headed in.

UAS Regulations Beyond sUAS:
Along those lines, I'm curious if the FAA has a committee for proposing regulations for larger UAVs? Most of the commercial applications for UAVs might fall under these regulations, if they were to be proposed. If the FAA is not currently working on regulations for larger UAVs, then it will be many years before UAVs can fly beyond line of sight since it will be at least 2 years before any sUAS regulations go into effect.

Repairs and Modifications:
I think this is an area that may need more attention. I would think a significant number of businesses would purchase certified UAV airframes, and then modify them to install their own sensor package. More guidelines and/or oversight may be needed. This doesn't have to be more rules and restrictions. They could give the owner a lot of leeway to make modifications, but also make them ultimately responsible for the safety of the aircraft.

Model Aircraft:
I'm not sure the restrictions on turbines is warranted. The document says many members of the ARC were concerned about the safety of turbines, but is there any data to back this up?

Education:
COMMENTARY: It is important that manufacturers of Model Aircraft
are able to test fly their aircraft as they do today without having to adhere
to sUAS regulations. In order to give educational institutions (e.g.,
universities) the flexibility to provide "hands on" instruction and training
to students preparing for careers in the UAS and aviation industries they
are allowed to fly these systems under the requirements for Model
Aircraft. For consistency, manufacturers who develop sUAS that are
functionally similar to Model Aircraft, are allowed to test at a location
following a community-based and FAA-accepted program.
This quote is from the commentary on section 2.1. The sentence in bold seems to suggest universities should be able to fly model aircraft that have auto flight management. After all, how can we expect to prepare for a career in the UAS industry if the aircraft doesn't have an autopilot? Now if universities can fly model aircraft with autopilots, why can't anyone do the same as long as they follow the rules?

What about the AUVSI UAS competition? Where would this fall under the proposed sUAS regulations?

patrickegan

May 19, 2009, 12:51 AM

It is one big convoluted mess. I for one am not willing to accept vendor store fronting through universities.

Re: certification
Most of this will be done through standards groups like ASTM and RTCA. No one has any idea what it will look like, but I'll tell you it will be difficult for a dude in his garage to prove safety out to E-06 (with or without a strait face.) Flying out to a mile and 1200' will be in remote area's with position reporting and other costly stipulations.

You're welcome :)

fnev

May 19, 2009, 03:49 AM

Well… I am from the generation that doesn’t like regulations… But I work for the aerospace industry. So, I do understand the need for regulations especially when it comes to flying objects. I can appreciate that air traffic and safety might be a hard concept for a lot of people to understand. Why not take the car and the road as a reference?

We all (I hope) drive a car and therefore use the “civilian road and highway system”. Let say that a group of individuals for hobby play with unmanned mini vehicles; they do have to test them. They are a serious bunch and do their testing and “playing” on remote “unused” roads when monitoring carefully incoming traffic; so far, so god.

Now, some of them realize that this could lead to a lucrative business as these “little” wonder can do a similar job than some of their “manned” counterpart. BUT they have to operate on a “road space” that is used by a lot of “normal” users.

Firstly in order to operate on the “civilian road and highway system” they will need to have their vehicle to be registered and to do so follow some “regulations” like crash tests, stability, reliability… Then they will have to follow the “rules” that every “civilian road and highway system” user has to comply with. And last they will need to get sort of a driver’s license to prove their abilities to cope with all the above.

How would you feel as a “regular” driver and “civilian road and highway” user if you started realizing that these operators are getting more and more in “YOUR SPACE”? How would you react if you realized that they do NOT follow or obey the same rules that are imposed on you and your car/vehicle? How would you accept the fact that the “vehicles” they are putting along your car on the “civilian road and highway system” are not subject for a minimum roadworthy regulation/check?

I am ready to bet that some of the most vocal people on these forums about freedom to operate their “UAS” would be the most vocal against these operators encroaching on “THEIR” “road and highway system”…

Now, granted that the regulations/rules have to be fair and realistic. You do not regulate a couple of pounds unmanned foamy flying at a model airfield as you would for a several dozen of pounds small aircraft flying autonomously out of sight for several hours above populated areas… Furthermore, the regulators should be very careful for NOT hampering studies and research in this field as pretty much everybody agree: THIS IS THE FUTURE OF THE AIRCRAFT INDUSTRY.

EddieHaskell

May 19, 2009, 09:24 AM

It is the end! No amateur, no hobby, no nothing and it was buttressed with uncertified (untested) open source autopilots being flown in the NAS.

I agree...the open source autopilots undoubtedly added to the arguments for tighter regulation by the ARC members. The large commercial companies represented at the ARC also have a business interest in regulating commercial sUAS, they would like to restrict the competition from smaller companies. All Groups outlined by the ARC require certification and that's the FAA's real control (when these get turned into FARs). Certification requirements will set the threshold for which company can afford to pay for the testing and paperwork to get a sUAS certified.

1) The Groups listed in the ARC apply to commercial UAV systems, not hobby use. These groups have additonal limitations such as certification and operator licensing as well as operational limitations ( 1/4 mile & 400AGL ).

2) Hobby use: the AMA rules (ARC sect 2) are pretty clear: (RADIO CONTROL rule 10) "the operator ..shall control it during the entire flight" (ie. no autopilot ).

3) Hobby use: (ARC 3.2.5) "Model Aircraft are limited to unaided VLOS operations" (ie. no autopilot ).

The FAA's defines sUAS as "small unmanned aircraft" which includes hobby and commercial.

airmcn_3

May 19, 2009, 11:40 AM

I agree...the open source autopilots undoubtedly added to the arguments for tighter regulation by the ARC members. The large commercial companies represented at the ARC also have a business interest in regulating commercial sUAS, they would like to restrict the competition from smaller companies. All Groups outlined by the ARC require certification and that's the FAA's real control (when these get turned into FARs). Certification requirements will set the threshold for which company can afford to pay for the testing and paperwork to get a sUAS certified.

1) The Groups listed in the ARC apply to commercial UAV systems, not hobby use. These groups have additonal limitations such as certification and operator licensing as well as operational limitations ( 1/4 mile & 400AGL ).

2) Hobby use: the AMA rules (ARC sect 2) are pretty clear: (RADIO CONTROL rule 10) "the operator ..shall control it during the entire flight" (ie. no autopilot ).

3) Hobby use: (ARC 3.2.5) "Model Aircraft are limited to unaided VLOS operations" (ie. no autopilot ).

The FAA's defines sUAS as "small unmanned aircraft" which includes hobby and commercial.

You show me anywhere that says "No Autopilot" and I will agree with you. This is just another example of how poor the wording of the ARC is and how each individual seems to take it differently.

Funny how many try and add their own words to the document.

Too many holes, until this is rectified apparently we are going to continue to see argument between modelers.

Well either way we roughly have 1.5years to enjoy ourselves with our hobby UAV before we have some serious regulations better get out and enjoy.

mlbco

May 19, 2009, 11:48 AM

I received a response from the AMA regarding my comments on the rule making committee's report and listed below are my comments and the AMA's response. It looks like their just sending out form letters at the moment. The AMA's suggestion to not contact local government officials is interesting: "... if needed, will let you know when and where to make your voice heard."

Personally, I think now is the time to make sure the AMA hears our voices. In the FAA's eyes they are the institution of choice for representing modelers and it would be very helpful to get the AMA to explicitly include autonomous aircraft under the definition of model aircraft, so long as the aircraft is in visual range and direct control can be engaged at any time.

Steve
----------------

My letter to the AMA:

The AMA's current recommendation is to define model aircraft as follows:

"Model Aircraft: A sUAS used by hobbyists and flown within visual line-of-sight under direct control from the pilot, which can navigate the airspace, and which is manufactured or assembled, and operated for the purposes of sport, recreation and/or competition."

This is flawed because it neglects free flight aircraft which are not under direct control of the pilot. Under current AMA rules a 55lb free flight may be operated as a free flight model (according to my interpretation of the rules). The AMA must make recommendations consistent with uncontrolled aircraft operations, such as free flight models.

I would personally like to see the AMA accept aircraft with autopilots as model airplanes if they meet the AMA safety guidelines for RC models and have the ability to be taken over with manual control at any moment. Such models would be restricted to visual LOS operations. Including autopilot and free flight aircraft does not reduce safety and represents the broad interests of AMA members while upholding the AMA charter to promote educational and scientific advancement within the hobby.

Sincerely,

Steve Morris
AMA #98482

AMA Response:

Tue May 19 2009 11:15AM by JCHERRY@MODELAIRCRAFT.ORG
Thank you for your comments. The recommendations document posted by the FAA is a rough set of guidelines that were drafted for the purpose of creating a starting point. These are not laws and are a long way (years) from being finalized. If you are concerned about some of the conditions stated in section 3 of the document, simply put, section 2.1 states that is you are flying under an accepted set of standards (such as AMA) then you will be exempt from the rules in section 3.0.

For the past year, we (AMA) have been working closely with the FAA to formulate these standards and will continue our pursuit to keep our flying privileges intact.

You do not need to make any contacts with your governmental representatives at this time. We are months away from public input. We will keep you informed as the process proceeds and, if needed, will let you know when and where to make your voice heard.

Best regards,
Jim

Gary Evans

May 19, 2009, 11:53 AM

You show me anywhere that says "No Autopilot" and I will agree with you.

DEFINITIONS SECTION
Model Aircraft: A sUAS used by hobbyists and flown within visual line-of-sight under direct control from the pilot, which can navigate the airspace, and which is manufactured or assembled, and operated for the purposes of sport, recreation and/or competition.

mlbco

May 19, 2009, 11:58 AM

For those who think that the AMA wants to include UAVs in the definition of a model aircraft, please check out this thread:

http://www.rcgroups.com/forums/showthread.php?t=1029868

The FAI is already taking steps to define anything that can navigate waypoints as a UAV and therefore not a model aircraft. This effort was supported by the AMA appointed FAI representative, Dave Brown (former AMA president). I think this is the clearest indication of the AMA's intent on this matter and that is why it is important to write to the AMA ASAP and express your opinions. Listed below are the conclusions of the FAI working group on this matter. Notice their recommendation to re-define model aircraft to exclude UAV's.

Steve
--------------------

Conclusions

1. The Working Group recommend that UAVs and autonomous flight have no place in

model aircraft flying within CIAM

2 This recommendation requires a revised definition of model aircraft

3 Action must be taken about the existing records in the F8 Autonomous Flight category:

a) for CIAM to recognise these flights as special achievements

b) to retain the records as historical superceded records

c) to endeavour to have the records transferred to the relevant UAV category

4 Consequential changes to the Sporting Code record section.

airmcn_3

May 19, 2009, 12:18 PM

DEFINITIONS SECTION
Model Aircraft: A sUAS used by hobbyists and flown within visual line-of-sight under direct control from the pilot, which can navigate the airspace, and which is manufactured or assembled, and operated for the purposes of sport, recreation and/or competition.

This has been talked about earlier in this thread. Find definition of direct control because I can directly control by bird from the GCS at any time during the flight, I also can take control via RC transmission at any given time via two different options.

Again, poor wording is the issue here. It’s entirely too vague...

Gary Evans

May 19, 2009, 12:30 PM

This has been talked about earlier in this thread. Find definition of direct control because I can directly control by bird from the GCS at any time during the flight, I also can take control via RC transmission at any given time via two different options.

Again, poor wording is the issue here. It’s entirely too vague...

It seems pretty clear to me and I don't think there is any misunderstanding the intent. If the plane had an autopilot but it was never turned on you would be fine.
My guess would be that there are some model negative types reading these boards who would be more than willing to firm up any required wording in the NPRM. Maybe we should make a list for them.

patrickegan

May 19, 2009, 12:45 PM

read in the type 1, 9.3 (1) Manual flight control:..

airmcn_3

May 19, 2009, 01:20 PM

read in the type 1, 9.3 (1) Manual flight control:..

Got ya! Thanks.

(1) Manual Flight Control: Group I SUAS must be capable of only manual flight
control, ensuring that PIC control inputs made in the Control Station are translateddirectly into corresponding control surface positions.

I like the alternative view.....

ALTERNATIVE VIEW: Group I sUAS should be allowed to utilize
simple auto flight management systems as long as manual flight control
can be assured.

patrickegan

May 19, 2009, 01:24 PM

This represents a poison pill for the small manufacturer and the 3nm for the small business guy. Sewed up tight!

I'm sure it will be in section 3 as the non affiliated RC will get less then on the AMA field.

Who do you think came up with the black dot's and alternative views?

airmcn_3

May 19, 2009, 02:31 PM

patrickegan

May 19, 2009, 02:53 PM

airmcn_3

May 19, 2009, 03:30 PM

Model stuff that was pro, Rich, Fred and myself. The pro commercial stuff Fred and myself, and when I say myself I mean with the help of RCAPA. Those were fall backs from the RCAPA proposed guidelines. The anti stuff commercial was MITRE mainly, but manned guys too.

The manned guys went nuts on me during the last meeting. :(

Thanks Patrick, I am sorry to hear they were so rude. We really do appreciate you taking the time to deal with these types of issues.

I guess it will be a while until we have an opportunity to re-voice our opinions, I hope we can rally together and submit a consistent tune....

Chris

patrickegan

May 19, 2009, 04:17 PM

It wasn't that they weren't rude, we were just out numbered and the vendors just sat back and let it happen.

You're welcome :)

rich smith

May 19, 2009, 05:04 PM

(1) Manual Flight Control: Group I SUAS must be capable of only manual flight control, ensuring that PIC control inputs made in the Control Station are translateddirectly into corresponding control surface positions.

It seems crystal clear to me. "CAPABLE" being the key word. Every UAV I've seen is capable of "only manual flight". "Capable of only manual flight" does not mean the same thing as "only capable of manual flight".

Also what does SUAS stand for? It looks like some gloom and doom types here aren't so good at interpreting english.

Also beware of wolves in sheep clothing. We learned a lesson with Sport that not everyone who seems to be on your side actually is (EAA). And I can't imagine depending on the AMA who has been nothing but hostile to UAV since the beginning. No great friend of small electric parkflyers either.