|May 27, 2011, 12:57 AM|
Escondido, CA USA
Joined Jan 2001
Thank you, Daemon, for that carefully considered response to my safety while I pursue my living flying full-size airplanes, sometimes with paying passengers along with family and friends. I won't mention myself as I know I don't matter at all in the overall scheme of things. It makes me positively relieved to know your line of reasoning preserves me from any concern how someone flying a model up to 27 miles away has complete control over his situation because not only can he and/or his spotter see the model and what it's doing but can also at the same time see me and will be able to take any actions as required to prevent a collision, especially above clouds. This greatly enhances my feelings that beyond line of sight is only a metaphor and is not intended to define what really is taking place. It's good to know safety is in the top paradigm of those kind of FPV operations as shown by all who have the eyesight to see what a six-foot wingspan airplane is doing at that range regardless of altitude. Or even at seven miles. It's also extremely comforting to know those operating systems aboard the model are replaced at their expected half-life to guarantee there cannot be any technical failures at any point of the model's flight/route. Similar to my experiences flying full-size of never having an engine fail, spew oil all over the left wing, hydraulic or electrical failures, brake or control system failures or any of that over 40 years. It's just as comforting to know the airplane operator is constantly reviewing his actions to ensure the safety of others by not pulling any stupid stunts like flying low along a road with cars on it or flying through a tunnel or diving toward an in-use bridge. Why, that's just like my FAA-required check flights I take every so often. Well, maybe not with flying through a tunnel as the airplane I fly won't fit, but you know what I mean. It's becoming obvious to me how those who fly FPV only nearby so they can track what their airplane is doing need to expand their horizons. And if those people point out how they believe long-distance flight of their models may not be appealing to them because of percieved safety matters, just print this thread or at least this post and show it to them right at the flying field. Be certain to point out the one who wrote this is an active commercial pilot. Then, I'm certain, they can drop any concerns of how their actions may affect others just like they can drop yesterday's newspapers. Including any dark stinky stuff wrapped inside those papers.
|May 27, 2011, 03:59 AM|
Care to provide the actual odds of collision between a full scale aircraft, and a small
model aircraft operating at random altitudes and courses in class E or G airspace?
The odds can and *have* been calculated.
Once known, compare that with the odds of above mentioned life threatening
engine failures, hydraulic failures, electrical failures, control system failures,
instrument failures, ATC mistakes, lightning, icing, clear air turbulence, heart attack..
etc.. If it were 1,000 times less likely than any of those, or 10k or a million, would
it matter to you? Where would you draw the line? Somewhere between
being struck by lightning in clear air and struck by a meteorite (both have non-zero odds).
To talk rationally about this subject, you have to start with the true odds of
occurrence and work with the industry standard benchmarks of failure and risk analysis.
Otherwise, we're basing our decisions, as I contended earlier, on either no science or
bad science.. + fear.
Part of this is a matter of perspective. To a full scale pilot the sky is full of aircraft.
But keep in mind full scale aircraft are forced to fly from the same fixed locations, to the
same fixed locations, usually following either narrowly defined, or at least relatively
predictable flight corridors and often holding standard flight levels. All of which
ultimately concentrates them in specific parts of the sky and *increases* the odds
of close encounters and potential collisions significantly. Full scale aircraft see
each other a lot, because of that. The relative randomness of FPV flights, free to
launch and fly far from airports and known flight corridors and altitudes (which many
of us make a very conscious effort to do when flying beyond VLOS), makes them
much less likely to encounter full scale aircraft, by literally several orders of magnitude.
This takes a potential collision event that already has minuscule odds of occurrence and
makes it virtually impossible (statistically speaking).
Somewhere in this discussion someone will inevitably bring up bird strikes as an
example of something small which collides with full scale aircraft, and which
do occur fairly regularly. But let's start with the fact that
there's an estimated 60 billion birds in the US, a large percentage of them are on the
wing some part of every single day, they are concentrated near water, which also happens to
be where humans choose to build cities and airports, and we find that the vast majority of bird
strikes occur relatively close to airports where the aircraft traffic is concentrated, and
generally at low altitudes where the birds are concentrated. Even when occasionally
encountered during cruise phase we're usually talking about flying into flocks of hundreds of migrating
birds at a time before a collision occurs. Yes it's a real risk that has to be taken seriously, but a
few hundred amateur FPV aircraft in the US, flying once or twice a week usually in class G airspace,
usually far from airports, and only very rarely high up, is not at all comparable to dealing with
60 billion birds all over the sky and all the other compounding factors that bring planes
and birds into the same airspace.
Another way to frame this discussion to see why we're upset at what is happening to us
is to turn the tables.
Let's say I was the FAA crafting regulations for full scale aircraft and my concern
was the safety of people on the ground. I know that there's a non-zero chance
of a full scale aircraft crashing into a populated area. In fact, I know that
it has already happened. It happens every year or two, and people are killed.
Do I outlaw full scale aircraft flying over populated areas entirely? It hasn't happened, and won't ever.
Do I outlaw full scale aircraft flying over unpopulated areas? Obviously ridiculous.
Do I outlaw operation of any specific class of full scale aircraft if an accident occurs? No.
Do I make different rules and licensing requirements for big heavy commercial aircraft, and smaller
lighter ones like sport class, ultralights, paragliders, and hang gliders and take into account
where in the sky it's safe to operate? Of course. The regulations should adapt to the
realities of the situation and there are places where it's considered safe to operate
lightweight aircraft with minimal or no licensing requirements. That's a reasonable approach.
That's not what amateur FPV is facing. We fly 2-3 lb chunks of foam, usually in lightly or
unpopulated areas and the new sUAS regulations could make amateur FPV in uncontrolled airspace
almost totally illegal as we know it, and the remaining operating requirements more onerous than
those needed to operate a sport class plane, ultralight, HG or PG.
That's irrational, and "unnecessary regulation".
I fully understand the need to regulate commercial operators. They *want*
to operate over heavily populated areas. They *want* to share the NAS with
full scale aircraft in the airspace they currently operate. The vast majority of amateur FPV pilots
are not going out of their way to do either one, and they don't represent
a credible danger to you, for the reasons outlined above.
|May 27, 2011, 08:28 AM|
Joined Nov 2006
Get the philosophical deck chairs all lined up quick because it appears the freedom ship FPV Titanic has got a big problem.
And then there are some differant slants on this. Interestingly enough a guy on another channel is waging a one man battle against AMA which is ok I guess until you understand the reasoning. Since AMA does allow autonomous systems and limit all FPV to LOS with RC buddy box he reasons we would be better off under the FAA's wing. I can only imagine that he has not read the proposed sUAS regulations or thinks maybe they will provide a special get out of jail free card for people to fly autonomously with no rules. Hope springs eternal!
|May 27, 2011, 10:07 AM|
United States, NY, Cortland
Joined Sep 2010
|May 27, 2011, 10:20 AM|
The public comment NPRM is a sham. The FAA is under no legal or moral obligation to change one word in the SFAR and I seriously doubt they will. I will see the head of the UAPO office in a couple of weeks and will be in a forum where I can ask questions so...
|May 27, 2011, 04:03 PM|
|May 27, 2011, 04:04 PM|
|May 27, 2011, 04:18 PM|
Joined Nov 2006
Ground effect machines would seem to be an exception but thet are not considered by FAA to be aircraft.
|May 28, 2011, 01:31 AM|
Escondido, CA USA
Joined Jan 2001
So it's a numbers game. I was not a math major so I'll ask for assistance here.
Let's say I have a bottle of absolutely pure distilled water with a capacity of sixty billion parts. You are thirsty. I pour out a glass of that water and give it to you and say "By the way, there is one part rat poison in that sixty billion parts of otherwise distilled water. Here you are." Would you drink it? How about a hundred parts rat poison in those sixty billion? Maybe 1/100th part rat poison. Entropy aside, how much rat poison in your glass are you willing to accept so you can drink it? How many more obstacles to a safe completion of someone's flight are you willing to provide? That's a dumb question.
From my point of view, I should be able to expect someone else to see how what his actions are could interfere with anothers' pursuit of a possibility of completing his flight without BLOS interruption, because you know better. Doesn't matter how many birds there are out there, one can do you in as easily as a dozen. I saw that happen when an Air California 737 picked up a single seagull in the right engine just after rotation. Bird went in, engine guts ejected out. Did the gull place himself in that situation knowing the possible results? Do radio antennas/guy wires snicker in the fog, waiting patiently for someone to snag them?
I can handle ATC mistakes, and have so far corrected for them
I know where most migratory routes are if they are in some form of NOTAM, charting, AFD or the like
I've had my share of equipment failures and I was the first to know about them as well as the only one on board who could deal with them real-time at the scene
I have yet to fly into terrain or have a mountain jump up in front of me
All stupid examples because not one of those things are planned. Planned for, but not planned out to endanger my flight. None of those things are intentionally set up in the air--they simply exist. FPV-BLOS is intentional, flown by someone who knows there are more airplanes out there and goes anyway while claiming it's mostly safe because nothing has happened yet. Sort of like what the CAA (pre-FAA) said until the Grand Canyon collision--in the Fifties, was it? That one time is the reason why the ATC system exists today. And you are saying what's one more danger? Get over it? Overblown fear of the unknown? untrusting? uninformed of what the probabilities are? I wonder what would go through your mind if you were the one the model hit. "OK, that was my one chance, I made it so now I'm fine." The other guy, yeah, that's too bad.
Oh, I get it, it's all about risk management, is it not? Well then, we could add more risks to flying full-size until someone says OK, that's enough, let's don't push any more of that. Sort of like playing Russian roulette with a gun having room for only one round compared to one with sixty billion rounds. How many times will you try that before saying "nuts to this"?
I also love the reasoning of "we only do this over unpopulated areas away from towns and cities". Where do you think full size airplanes spend most of their cross-country time? "But jets fly way too high for me to threaten them." Many light airplanes fly much lower than that, from a couple thousand feet on up based on what the pilot is doing. "We do this only at low altitudes." Like the low altitudes available when flying on top of a cloud deck? "Well, it's only scattered layers, no more." I'd have to disagree from the videos I've seen. Besides, you can see right through/around those scattered clouds, right? "That's what the spotter is for." Right.
Actually, I don't really care how you operate FPV/BLOS flight as long as you can provide the same level of separation I currently have with other airplanes. In other words, do your thing but don't add more danger to me while you do. With no on-board pilot flying the BLOS model but relying on the narrow view of the camera, compared to wider view the average human has, how do you propose to accomplish that?
|May 28, 2011, 03:25 AM|
Do you realize that *you* actually do this all the time? There exists almost every
type of toxin in various sources of water and food you regularly drink and eat every day.
It *is* measured in parts per billion or parts per million and it *is* absolutely a numbers
game. If the numbers are small enough then it's considered safe for human
consumption, otherwise not. There's no perfectly safe food or drink. Our water and
food (and air) contains small levels of toxins such as arsenic, mercury, lead, aluminum,
cadmium, thallium, nickel, chromium 6 and various radioactive substances.
the reasons I outlined earlier.
astronomically small. Smaller than the risks from many other human caused activities you
do have control over but don't currently worry about, that all have a non-zero
chance of occurring.
the same thunderstorm at 21,000 feet.
you want to believe that or not. If you truly wanted zero risk to your person
and family from aviation accidents, you would not be a pilot. In fact you would
have to push to outlaw all aviation because a full scale aircraft could crash on top of
you while you're on the ground. You can't logically argue that one human initiated risk
with low but non-zero odds is totally acceptable while another is totally
unacceptable despite the the latter having significantly *lower* odds than the
former. That's why it's important to actually know what the odds are and
regulate accordingly. Adding more full scale aircraft to the sky (FAA forecasts there
to be 50,000 more aircraft in US skies by 2030) constrained to depart and arrive at the same destinations
as today is a significantly greater risk to you as a pilot, than adding a relatively small number of small
foam amateur piloted sUAS to lightly trafficked areas of the same sky.
airspace are say 1 in 100 billion then we're talking 1 bullet in 100 billion empty
chambers, versus the bird strike case of 60 billion rounds out of 100 billion chambers.
you and I and everyone else on this planet knowingly/purposely take risks with odds much
much much worse than that every day. The problem is we (collectively as humans)
are really bad at assessing and prioritizing which risks are the ones that are most likely
to affect or even kill us and which ones are not. Some examples. Quoted from http://reason.com/archives/2006/08/1...-be-terrorized
"So, according to the National Safety Council this means your one-year odds of dying in a car accident is about one out of 6500. Therefore your lifetime probability (6500 ÷ 78 years life expectancy) of dying in a motor accident are about one in 83.
What about your chances of dying in an airplane crash? A one-year risk of one in 400,000 and one in 5,000 lifetime risk. What about walking across the street? A one-year risk of one in 48,500 and a lifetime risk of one in 625. Drowning? A one-year risk of one in 88,000 and a one in 1100 lifetime risk. In a fire? About the same risk as drowning. Murder? A one-year risk of one in 16,500 and a lifetime risk of one in 210. What about falling? Essentially the same as being murdered."
The rest of that article is well worth reading, and is about the realities of risk analysis.
Their point is, that adding an additional risk to your life of say 1 in a million,
is insignificant compared to all the others you knowingly accept. My point
is the same, but the odds are even smaller by several orders of magnitude.
and vertical air space. A VFR piloted plane can choose to fly around in what they
might consider to be random airspace, but they're still ultimately constrained by the
fact that they have to take-off and land at airports, and that statistically limits
the airspace in which they'll actually be found most of the time. And the
reality is most VFR pilots simply don't choose to fly around randomly so they're found
in the same narrow corridors. As an FPV pilot it's easy enough to simply go
somewhere else, which we do.
and IFR flights aren't vectored through cloud decks at altitudes low enough to reach
with FPV planes unless relatively close to airports, which is why we don't fly close airports.
When FPV pilots go cloud chasing they're usually purposely skimming the top edge of the
clouds themselves which is basically a no-man's land for full scale aircraft. There's
nothing interesting for an FPV pilot 1000 ft or more above a cloud.
And whether you believe this or not, someone flying an electric FPV plane 10-20 miles
from an airport doesn't generally choose to burn through their entire battery pack to
climb to a cloud deck at 15,000 feet AGL where there could be IFR flights transiting
those clouds. They wait until the clouds are low and relatively easy to reach
so they can spend more time playing in them.
VFR flight corridors at non-standard altitudes, thereby lowering the odds of us being
in the same part of the sky to astronomically small levels.
BTW, it's not like see or sense-and-avoid is the end-all-be-all of collision avoidance
either. In the Grand Canyon mid-air they were both forced to fly VFR and knew it was
their responsibility to watch for other planes, but still didn't see each other in time.
A couple years ago here, a Cirrus SR22 flying in *known* heavily populated
but uncontrolled airspace over a populated area collided with a sailplane on tow.
The Cirrus pilot did not see the tow plane or the sailplane, which together
represented a pretty huge visual target in the sky. I'm not saying it's useless. Just
that it's still just a numbers game and I advocate reducing the odds in a different way
that is no less effective.
|May 28, 2011, 05:42 AM|
So let's talk numbers (long post)
OK, so let's talk numbers. The statement was made that " If the true odds of collision in class G airspace are say 1 in 100 billion", then a number of extrapolations and relations were made. Some context may be instructive on this number. The FAA (and other civil aviation agencies) have stated on a number of occasions that the analytical incident probability of occurrence they are looking for sUAS is between 10E-6 and 10E-9 (one in one million to one in one billion operating sorties/hours) (Patrick Egan, catch me here if I am going off course). Turns out the general aviation accident rate has been hovering around 6 in one hundred thousand hours (6 x 10E-5) so they are not meeting their desired numbers there for GA.
A group wanting to launch a weather balloon carrying a glider did some pretty fair calculations along these lines. See this site: http://members.shaw.ca/sonde/risks.htm Their numbers for what appears to be a relatively busy General Aviation area turned out to be about one in 600,000 sorties. The calculations seem fairly reasonable and are WAY less than the number suggested up top.
If you take a look at the first table attached out of MIL-STD-882E, this gives you some practical values to compare these numbers to. Note the fleet/inventory numbers, since that is what we are interested in. The second table gives an idea of what the generally accepted consequence levels are for this document. Note that the levels may not be suitable for the civilian sector. Now take a look at the third table. It is a risk assessment matrix that combines both the probability and the consequence. This is how the government (and everybody else, really) evaluates risk. So if you want to minimize risk, one way would be to mandate that all FPV flying be done with < 4.0 lb. foam pusher aircraft that fly less than 35 MPH. Then control where they can fly and how high. Now THAT would reduce risk by controlling the probability and the consequence.
So where am I going with this? If you are going to talk numbers, then use validated numbers calculated how the target audience calculates them. Then you might get somewhere with the only people that count right now, the FAA.
My experience dealing with government organizations like the FAA (especially the FAA) is that they only respect solid analytical results to be the basis for any rulings they may make. And those results have to come from sound methodologies have to be based on solid, provable data on encounters and failure rates. That is always the hard part. As an aside, MIT does a great deal of the ground work for these types of regulations for the FAA.
Strictly as an OBTW, take a look at the original ARC document and the model aircraft section. If you think the projected flight limits being mentioned with the AMA involved are "draconian", without the AMA involved it would be far, far worse whether FPV or sailplanes, or turbines or just plane sport fliers.
A couple of final points:
All the calculations aside, it will only take one really bad midair between a model aircraft and a full scale and the roof will come crashing down on everyone. It already has started around here because of the FAA ARC. The mile square mowed grass Navy Outlying Landing Fields we used to fly sailplanes on now have a hard ceiling of 400 ft, making them useless.
And for those who say that the FAA cannot possibly enforce the upcoming regulations, they won't have to. When someone flying outside of the approved parameters crashes into something on the ground and damages something/injures someone or has a midair out side the field limits doing the same, the LAWYERS will enforce the regulations by taking every thing of value from the offender as soon as they take one look at the regs. And they will......
|May 28, 2011, 10:55 PM|
I think they said about a foot off the ground.
Did anyone read this?
These dudes don't play a square game...
|May 29, 2011, 12:55 AM|
They are forced to fly to and from the same fixed locations and naturally
concentrate in specific corridors.
"This leaves a chance per daylight hour of intersecting a small randomly placed aerial object at 1 in 300,000 flight hours, assuming no effort at all is made to avoid airports, practice areas, or traditional waypoints.
But GA mid-airs overwhelmingly occur in clear daylight, in the vicinity of airports, and either in the approach path to landing, or at the discrete altitudes light aircraft often fly at (1000', 1500', 2000', etc). In addition, flight tracks generally begin and end at an airport or common waypoints. These facts tell us that by actively avoiding GA airports and practice areas, the risk can be brought substantially below the above value."
They ultimately come to the same conclusion that I said above (and I've never seen this
specific report before). That to lower the risks significantly you simply move away from the
high traffic areas, which we generally already do.
BTW, they reference the MIT study, but their link is broken. Here's a working link.
Notice that in their mid-air collision risk analysis, once you move away
from highly traffic'ed areas the odds do drop into the 1x10-9 to 1x10-10 range and even less.
Look at all that blue and white area of the first map on page 15.
It really is not that hard to know where full scale aircraft operate
the most, and avoid those areas. It would not be impossible to create regulations
which say to do that, or present different rules for flying in lightly trafficked areas
as currently exist for various types of ultralight/HG/PG aircraft.
light model aircraft crash on top of or into things all the time, and little or no harm is
done and operators are rarely sued to their ruin.
|May 31, 2011, 12:37 AM|
Escondido, CA USA
Joined Jan 2001
Actually, you missed some things, Daemon. Paint the model a flourescent color. Equip the model and file before departure so separation other than VFR methods can be used. Don't let anyone, regardless of size, divert from the planned route, filed or not, regardless of reason, so they won't be away from published Victor airways, waypoints of any kind or other known locations. Don't know what to suggest about some of the ideas upcoming in the near future such as GPS direct (actually already routine in some places) or the satellite-based traffic separation systems, allowing routing/route deviations for whatever reason, based on current, real-time known traffic loading. Anywhere.
This has been fun and educational but I feel I should add, this coming from my five-year involvement as a part of the Experimental Department with a well-known GA manufacturer in research, development and certification: Remember the FAA will ask you, not to prove or to example or to show them anything. They will ask you to demonstrate to them why this or that is a good idea so it can be acceptable to the Administrator. If it's OK to quote another thread where I posted it, it will be much better to offer the FAA an idea in lieu of a rebuttal about how to handle this.
To drop from the flight levels to model levels, if there is an incident/accident involving a BLOS model in the meantime, especially if it involves a fatality, I would expect the FAA, if not the general public's uninformed response to be "That's all, folks", and lump all models operated in any way under the steamroller.
Maybe it's time to invest in an indoor micro/flyable airplane, just in case
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