Discussion FAA ARC Group stuff for Models!

[rojos]

Much more for UAVs, but this should get your attention! This is not in concrete yet.

Steve

April 1, 2009
Page 3
Subpart A. Model Aircraft
2. Model Aircraft Operated in Accordance with
FAA Accepted Standards
2.1 Applicability
Model Aircraft operations that are conducted in accordance with an FAA accepted set of
standards established and administered by a community based association as discussed in
Section 2.2, shall otherwise be exempt from the requirements of any Special Federal
Airworthiness Regulation (SFAR) that results from this recommendation as long as they are
operated by:
• Hobbyist for the sole purpose of sport, recreation and/or competition under the
conditions of such an FAA accepted program
• Manufacturers which are flight testing aircraft intended to be operated for the sole
purpose of sport, recreation, and/or competition and they are tested at an approved
field as defined by and in accordance with an FAA accepted program with the
approval of the community-based association responsible for the location
• Educational institutions and/or students for the sole purpose of education or research
and they are operated at an approved field as defined by and in accordance with an
FAA accepted program with the approval of the community-based association
responsible for the location
• Manufacturers which are flight testing aircraft intended to be operated for other than
sport, recreation, and/or competition and they are tested at an approved field as
defined by and in accordance with an FAA accepted program with the approval of the
community-based association responsible for the location
RATIONALE: Reflects FAA’s concept of regulating model aviation by
exempting Model Aircraft from regulation. Under this approach, modelers
participating within an aeromodeling structure/organization such as the
Academy of Model Aeronautics (AMA) may operate their Model Aircraft
in accordance with an accepted set of standards and operating
procedures. Based on a more rigorous attention to safety, risk assessment,
and risk mitigation, the accepted standards may provide greater latitude
in the Model Aircraft operations. Modelers not participating in the
additional safety programming established in an accepted set of standards
shall comply with the requirements of Section 3.
April 1, 2009
Page 4
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.
2.2 Accepted Model Aircraft Standards and Procedures
Accepted Model Aircraft Standards and Procedures may be established and administered by
a community-based association. An accepted set of standards shall be based upon accepted
and recognized safety principles and will include but not be limited to the following:
RATIONALE: Community based organizations, such as the AMA, that
have credibility within the Model Aircraft community and that have an
established safety record and have demonstrated the ability to influence
participant compliance shall be afforded the opportunity to establish a set
of safety standards that are more comprehensive than the requirements
and limitations given for non participating modelers, and use these
standards as an alternative means of compliance with any regulations
which may results from these recommendations. Since such standards are
more comprehensive, operations under such standards shall allow for a
broad spectrum of operations and greater latitude in the AMA operations.
(1) Prescribed safety program entailing oversight, assessment, risk mitigation, and
accident/incident reporting.
(2) General safety guidelines and operating principles.
(3) Operating guidelines specific to the location and to the type, size, performance, and
propulsion of the various Model Aircraft.
(4) Comprehensive programming addressing Model Aircraft having non standard
weight, or identified as having unusual propulsion types or extraordinary flight
characteristics.
(5) Programming to facilitate Model Aircraft events, competition, national and
international record attempts, gatherings, and Model Aircraft demonstrations and
exhibitions.
(6) Educational programming that assures participants are provided relevant safety
information and validates the learning process.
(7) Educational programming that addresses essential piloting issues including:
• Recognition and avoidance of manned aircraft
• Safe operation near spectators and other non participants
April 1, 2009
Page 5
• Safe and cooperative operation with other modelers
• Transitioning to higher performance and more complex models
(8) Methodology for establishing and designating dedicated Model Aircraft flying sites
providing:
• Guidelines for flying site location, configuration and design layout applicable to
its intended use and the type(s) of Model Aircraft flown, and which ensures
Model Aircraft operations do not interfere with manned flight operations
• Safety guidelines that ensure the safety of the public and provide adequate
separation of persons and property from the Model Aircraft operations
• Guidelines for coordinating and reviewing operating policies and procedures
with the airspace controlling authority for those flying sites located within
controlled airspace
• Guidelines for coordinating and reviewing operating policies and procedures
with the airport and applicable airspace control authority for those flying sites
located within 3 NM of a military or public-use airport, heliport, or seaplane
base.
• Guidelines for establishing and disseminating flying site operating procedures,
limitations and safety guidelines including the following:
– Hours of Operation
– Flying site operating procedures
– Frequency control procedures (if applicable)
– Traffic pattern and flight operations
– Cooperation with other modelers
– Applicable altitude restrictions
– Applicable No-Fly zones and operating area limits
– Flight line and pit area safety procedures
– Spectator and public access policies
– Emergency Procedures (e.g., Fire, First Aid)
3. Model Aircraft Not Operated in Accordance with
Accepted Set of Standards !
3.1 Applicability !
The following general requirements and limitations apply to Model Aircraft which are not
operated in accordance with an FAA accepted set of standards, but are operated by hobbyists
for the sole purpose of sport, recreation, and/or competition.
April 1, 2009
Page 6
ALTERNATIVE VIEW: Eliminate Section 3.0 in its entirety.
ALTERNATIVE RATIONALE: AMA believes this approach is flawed in
that it fails to recognize the substantial diversity of the hobby, establishes
unrealistic and unenforceable restrictions, and leaves absent a safety
surveillance program to oversee the activities of those modelers who
choose not to participate in a formal aeromodeling structure/organization
More importantly, as a baseline set of standards, these limitations have
the inherent potential of imposing a devastating impact on the
aeromodeling activity and the hobby industry.
3.2 General Requirements !
(1) Model Aircraft shall be flown in open spaces and in a manner that does not
endanger the life and property of others.
(2) Model Aircraft shall yield the right of way to all manned aircraft.
(3) Model Aircraft shall not interfere with operations and traffic patterns at airports,
heliports, and seaplane bases.
(4) Model Aircraft shall not be operated at locations where Model Aircraft activities
are prohibited.
(5) Model Aircraft are limited to unaided visual line-of-sight operations. The Model
Aircraft pilot must be able to see the aircraft throughout the entire flight well
enough to maintain control, know its location, and watch the airspace it is operating
in for other air traffic. Unaided visual line-of-sight does not preclude the use of
prescribed corrective lenses.
(6) Model Aircraft shall be designed, equipped, maintained and/or operated in a
manner in which the aircraft remains within the intended area of flight during all
operations.
(7) Model Aircraft pilots may not intentionally drop any object from a Model Aircraft
that creates a hazard to persons or property.
(8) Model Aircraft shall be operated in a manner that respects property rights and
avoids the direct overflight of individuals, vessels, vehicles, or structures.
(9) Model Aircraft shall not be operated in a careless or reckless manner.
(10) Model Aircraft pilots shall not operate their aircraft while under the influence of
alcohol or while using any drug that affects the person’s faculties in any way
contrary to safety.
(11) Model fixed-wing and rotorcraft aircraft shall not use metal-blade propellers.
(12) Model Aircraft shall not use gaseous boosts.
(13) Model Aircraft shall not use fuels containing tetranitronmethane or hydrazine.
(14) Model Aircraft shall not use turbine-powered engines (e.g., turbo-fan, turbo-jet) as
a propulsion source. !
April 1, 2009
Page 7
RATIONALE: Turbine powered aircraft are perceived by many members
of the sUAS Aviation Rulemaking Committee (ARC) as being a higher
risk.
ALTERNATIVE VIEW: Eliminate the limitation.
ALTERNATIVE RATIONALE: The blanket prohibition of turbine
engines does not take into consideration the various and diverse turbine
engines currently produced and impose an unjustified economic impact on
the hobby industry.
3.3 General Limitations !
(1) Model Aircraft shall not exceed 55 pounds (lbs).
(2) Model Aircraft shall remain clear of clouds.
(3) Model Aircraft will not operate in Class B airspace without the permission of the
ATC authority.
(4) Model Aircraft shall not be operated within 3 NM miles of an airport, heliport, or
seaplane base without the permission of the ATC authority or airport manager.
(5) Model Aircraft shall operate in close proximity to the ground, at or below
400 feet (’) above ground level (AGL), and shall at all times remain below and well
clear of all manned aircraft. !
RATIONALE: By keeping Model Aircraft at or below 400’ encounters
with manned aircraft are reduced. This recommended general limitation
is consistent with the current Model Aircraft guidance contained in
AC91-57.
ALTERNATIVE VIEW: Replace (5) with the following:
Model Aircraft shall operate in close proximity to the ground, shall stay at
or below 400’ AGL when within 3 NM of an airport, and shall at all times
remain below and well clear of all manned aircraft.
ALTERNATIVE RATIONALE: Though it is agreed that there needs to
be some altitude limit on the modelers that are not participating in a
structured safety program such as AMA’s, AMA also knows from their
experience that creating a hard and fast across the board altitude limit,
such as 400’ is unnecessarily restrictive, unrealistic, and arguably poses a
greater risk to personnel on the ground. AMA’s experience has shown that
the greatest risk to other participants in the NAS and perhaps the only
significant risk posed by model aviation is when Model Aircraft are
operated within three miles of an airport. The language in the
ATERNATIVE VIEW mirrors the current guidelines in the AMA Safety
Code.
(6) Notwithstanding the above limitations, Model Aircraft weighing less than or equal
to two lbs incapable of reaching speeds greater than 60 miles per hour (mph)
(52 knots), and powered by electric motor or mechanical stored energy (e.g.,
April 1, 2009
Page 8
rubber-band powered) may operate within 3 NM of a military or public-use airport
or heliport; if they remain a safe distance from the airport or heliport, remain well
clear of all manned aircraft, and remain below 400’ AGL.
RATIONALE for the above limitations:
(1) Currently accepted domestic weight limit and has international
precedent as well.
(2) Is consistent with the concept of visual line-of-sight (VLOS).
(3) Class B is positive control. All aircraft are required to operate on a
clearance. Gaining permission from ATC is equivalent to receiving a
clearance.
(4) Model Aircraft permitted to operate within 3 NM of the airport will be
provided applicable operating limitations.
(5) 400’ is appropriate for Model Aircraft operations in Class C airspace
without coordinating with ATC and is consistent with the intention of
current domestic policy and with the UK, CASA, and Canada.
(6) This is consistent with the guidelines currently established by
AC91-57.
(7) Makes a blanket exception for models weighing two lbs or less. This
is an appropriate allowance for “Park Flier” and “toy” type models
and allows them to use parks and small fields closer to airports.
(7) Model Aircraft will not be flown at an airspeed that would cause the aircraft to
inadvertently leave the prescribed maneuvering area. !
RATIONALE: The pilot will be responsible for limiting their speed so
that they can remain within the prescribed maneuvering area.
ALTERNATIVE VIEW: Replace (7) with the following:
Model Aircraft cannot be operated at airspeeds which exceed 100 mph
(87 knots).
ALTERNATIVE RATIONALE: Restricting the speed of Model Aircraft
not participating in an FAA-accepted safety program will mean that highperformance
aircraft will not be operated by individuals that are not
being scrutinized by their peers. Eliminating high-performance aircraft
will also help to ensure that the operator will be able to keep their aircraft
within the defined operational area (line-of-sight and below 400’ AGL).
Limiting the speed also will reduce the likelihood of turbine powered
aircraft being operated without the guidance of an FAA-accepted safety
program. Turbine powered aircraft are perceived by many members of
the ARC as being a higher risk.
(8) Model Aircraft cannot launch pyrotechnic devices which explode or burn.
April 1, 2009
Page 9
(9) Excluding take-off and landing, no powered Model Aircraft may be flown closer
than 25 feet to any individual, except for the pilot and the pilots helper located at
the flight line.

[Dr. Sandy Frank]

YES the AMA is working for US !!!

RICH HANSON is appreciated for helping get this done...

THANK YOU "RICH"!!

and the AMA EC for getting it done...!

[mongo]

did you actually read section 3, sandy?????

there is no "working for us" in that section, if you are talking about modelers in general, and not just ama members.

[littlecrankshaft]

"ALTERNATIVE VIEW: Eliminate Section 3.0 in its entirety."
I agree with that view

[BillM]

Since the actions listed in the report are those initiated by the AMA I would view this as the AMA looking out for the membership.
I would agree with Dr Frank that this is indeed the AMA "working for us".
The members dues support the AMA's efforts with governmental agencies. It is done primarily for the benefit of those who support the opganization-the dues paying members.

BM

[Pinecone]

FAA will have to have SOME descriptive/restrictive/limitations.

[fhhuber506771]

Note the proposed 100 mph max airspeed for "unregulated" models.

Thats going to stomp on a lot of toes...

[mongo]

well bill:
this dues paying member does not think that the ama is doing a very good job looking out for this members interest at all.
so again, they are not doing a good job for "us" at all.
i would very much prefer for the ama to just keep it's mouth shut and it fingers out of what the FAA is doing.

[Lightnin]

Mongo,

Have you ever participated in state or federal government or found out the hard way the quickest way to get regulations you can't live with? The way you end up in that situation is by sticking your head in the sand.

The only way you avoid restrictions you can't live with is being involved in the process which is exactly what AMA is doing. I know this from hard learned experience as a person who has prepared arguments to go before an EPA science advisory council and more.

"A man who feels he is an island will find himself always alone"

BRAVO AMA

[Warningshot]

Originally Posted by BillM

Since the actions listed in the report are those initiated by the AMA I would view this as the AMA looking out for the membership.
I would agree with Dr Frank that this is indeed the AMA "working for us".
The members dues support the AMA's efforts with governmental agencies. It is done primarily for the benefit of those who support the opganization-the dues paying members.

BM

If section three is done away with I have a question. Where will non AMA
flyers be able to fly?

[BillM]

warningshot
Same place you are flying now.

BM

[BillM]

I really don't believe that most people understand what is being stated here.

BM

[Dr. Sandy Frank]

Originally Posted by Lightnin

Mongo,

Have you ever participated in state or federal government or found out the hard way the quickest way to get regulations you can't live with? The way you end up in that situation is by sticking your head in the sand.

The only way you avoid restrictions you can't live with is being involved in the process which is exactly what AMA is doing. I know this from hard learned experience as a person who has prepared arguments to go before an EPA science advisory council and more.

"A man who feels he is an island will find himself always alone"

BRAVO AMA

"""The only way you avoid restrictions you can't live with is being involved in the process which is exactly what AMA is doing."""

It is amazing how Darwinnian selection has allowed some to thrive
over the years...

oh well....

[fhhuber506771]

Originally Posted by Dr. Sandy Frank

"""The only way you avoid restrictions you can't live with is being involved in the process which is exactly what AMA is doing."""

It is amazing how Darwinnian selection has allowed some to thrive
over the years...

oh well....

Darwin was a nutcase... just look at Jerry Springer guests. If evolution worked they couldn't happen.

[mongo]

amen FH

and yes, i have been involved in state level regulation making, and some federal.
what i am amazed at, is, how little input the ama has asked us, it's members for in this process that has been ongoing for well over a year. any of you ever get asked what yoiu thought would be a good stance to present to the feds in this action?