Originally Posted by Desertrat

Awesome!

Thanks for the input. Maybe segregate Legacy LOS Model Aviation somehow? Or you think it's defined enough to eliminate it all together?

Originally Posted by Judge

Most of that language only applies to aircraft systems that will want to use the first method of compliance. For model airplanes which are most likely not going to do anything but the third means of compliance (flying at a FRIA), the amateur built language does not apply.

So if we follow that logic, then FRIA's become a permanent fixture for LOS modeling and section XV would have to be revised - or modeling goes away? (IMO the latter is not likely).

Originally Posted by AKNick

Thanks for the input. Maybe segregate Legacy LOS Model Aviation somehow? Or you think it's defined enough to eliminate it all together?

I think it is defined enough to eliminate. For example - the new rule specifically requires remote ID for craft that have the ability to autonomously navigate from point to point, while allowing some autonomous safety features such as "return to home" to be allowed on craft flown LOS in a FRIA without remote ID.

Originally Posted by Desertrat

I think it is defined enough to eliminate. For example - the new rule specifically requires remote ID for craft that have the ability to autonomously navigate from point to point, while allowing some autonomous safety features such as "return to home" to be allowed on craft flown LOS in a FRIA without remote ID.

I suppose what's more important attempting to free up the uncontrolled airspace, and allow FRIA sites to be created and developed for the future.
I wish FG had a strike through text option.

Originally Posted by AKNick

I suppose what's more important attempting to free up the uncontrolled airspace, and allow FRIA sites to be created and developed for the future.
I wish FG had a strike through text option.

Agreed and agreed. There used to be one.

Originally Posted by tazx100

Im flying what ive got when I want and how I want.

Exactly

IMHO, the distinction that we need to get the FAA to recognize is that we fly only line of sight (LOS), without full autonomous capability. Really nothing else matters to get a carve out for traditional R/C flying.

The NPRM is written for and about fully autonomous Beyond LOS (BLOS) flying. It ignores how we fly to our detriment. The NPRM is potentially an end to our sport as we know it.

Comments to the FAA need to address the NPRM issues point by point, be backed up by data, and present unique substantive arguments. The FAA does not consider the quantity of responses, so form letters essentially count as one unique response. This means we need to get creative to get the outcome we need.

I've started a thread on RC Groups in the Advocacy section titled " Let's fight the FAA Model RID NPRM! ". This thread is intended to be a place to contribute positive, actionable ideas about fighting to save our sport. We have some worthwhile ideas coming out, and of course a few of the " throw in the towel" negative characters trying to keep us real.

Please join us there if you feel you can contribute in a positive way!
Paul

Originally Posted by AKNick

Can we summarize what we are going to ask of our leadership to see changed or revised? The regulations offer an unrealistic buffer, maybe we can change the stipulations proposed or already in place. I'm hoping this might be more helpful to me and others when they approach their/our leadership.
We can create a educated list here. Add to it?? Copy/Paste?


Amateur Recreational LOS UAS:
Should be allowed to fly in (class G airspace?) above and beyond 400 feet from the user. Maybe this may need a spotter, Remote ID, or flying within FRIA. 400 foot geofence is hindering aeromodelers to safely fly and maneuver their model aircraft.


FRIA Flying sites:
Should be encouraged to be continually developed and supported. Threatening to remove these flying sites by not allowing them to do so will eliminate a safe location for Amateur Recreational UAS to operate in a designated safe environment.


Remote ID:
Should not be required in direct LOS in class G "Uncontrolled" airspace.
Attempting to integrate existing technology with remote ID within three years (with a registration plan) is inadequate. The technology isn't currently available for all systems via update. ADS-B by 2020 took a decade after all.


Definitions:
Amateur Recreational LOS UAS - Should separate fixed wing and multi-rotor. The FAA's proposal seems to always give examples of Multi-rotors. It's apparent that multi rotors not with direct LOS are the target to regulate, not fixed wing LOS. This is not clearly defined as the operating procedures are different and if they are grouped together will directly negatively affect fixed wing LOS recreational UAS operators.


Concerns:
Un-nessicary Over-Regulation. While the FAA needs to regulate the controlled airspace, and create laws for new technology - It is restricting existing legacy recreational UAS as a minority. There needs to be more clarity and segregation from the rise in drone/UAS technology that protects the minority of legacy recreational model aircraft.
Taking away flying sites (FRIA's) by not allowing new development is destroying a way of educating and inspiring young aviators. Pilots and Technicians are retiring faster than the industry can refill it.


Please add to this. Try to be short and concise - no novels about your thoughts please. References are highly encouraged.

I like this and I'm trying to get some notes together for my comments and letters. My goal is to be levelhead, clear, and concise so that the proper message is sent.

Also, where is the 400' limit from the pilot?

This is what really troubles me because in reality unless you are flying something that is under the .55 lbs. limit, this in my mind decreases safety.

Furthermore I fly at a field with Class E aerospace from 700' to 1200' and we have had zero instances of interfering with aircraft landing at the airport a few miles away. On a few occassions, local pilots have buzzed our field while someone was flying and our members have always yielded the right of way. In my opinion, flying Line of Sight has always been very safe to full scale aviaiton and I have only advocated remote ID on airfraft that will operated beyond LOS.

Originally Posted by AKNick

C
Definitions:
Amateur Recreational LOS UAS - Should separate fixed wing and multi-rotor. The FAA's proposal seems to always give examples of Multi-rotors. It's apparent that multi rotors not with direct LOS are the target to regulate, not fixed wing LOS. This is not clearly defined as the operating procedures are different and if they are grouped together will directly negatively affect fixed wing LOS recreational UAS operators.

Problem is right here you already divided us and excluded major segments of the hobby. There is no mention of single rotor RC helis. And FPV racing quads have more in common with us than with people who fly autonomous DJI camera drones.


We HAVE to stay together and we HAVE to come up with responses that promote and protect all segments of the hobby. This is the same "its not us its them" thinking I see on Helifreak where smack heli guys say 400 ft is no problem because they only fly at treetop level. And the same thing at RCGroups where all the park foamy guys want to blame it on gas planes.


We CANT let ourselves be divided. We have to bring all segments:

• Fixed wing sport (glow/elec/gas)
• park foamies
• electrics
• giant gas acro
• IMAC
• Pattern
• scale
• turbine jets and EDFs
• sailplanes, winch, DLG, ELG, slope, etc
• 3D helicopters
• scale helicopters
• FPV racing quads
• Free flight
• control line
• etc
• etc
• etc

Everyone.

Well said. No segment of this hobby can survive on its own so we all have to stick together for more reasons than one.

Originally Posted by jharkin

Problem is right here you already divided us and excluded major segments of the hobby. There is no mention of single rotor RC helis. And FPV racing quads have more in common with us than with people who fly autonomous DJI camera drones.


We HAVE to stay together and we HAVE to come up with responses that promote and protect all segments of the hobby. This is the same "its not us its them" thinking I see on Helifreak where smack heli guys say 400 ft is no problem because they only fly at treetop level. And the same thing at RCGroups where all the park foamy guys want to blame it on gas planes.


We CANT let ourselves be divided. We have to bring all segments:

• Fixed wing sport (glow/elec/gas)
• park foamies
• electrics
• giant gas acro
• scale
• turbine jets and EDFs
• sailplanes, winch, DLG, ELG, slope, etc
• 3D helicopters
• scale helicopters
• FPV racing quads
• Free flight
• control line
• etc
• etc
• etc

Everyone.

FWIW I suggest people take the time to at least read the actual proposed rule itself, Part 89. It starts on page 283 of the NPRM.

The parts that apply to most models are:

89.120 Unmanned aircraft systems without remote identification

Subpart C—FAA-Recognized Identification Areas (89.201 - 89.230)

Most of the rest of the rule only applies to aircraft systems WITH remote ID, either the standard or limited. For model aircraft sUAS that are operated at a FRIA none of the build requirements or other requirements stated in sections other than what I note above apply.

I've seen long threads talking about build rules, data transmission, etc. Bottom line is if you are fly a model airplane at a FRIA none of that applies. And this is their first pass. I am willing to bet the proposed final rule will look very different.

Originally Posted by Judge

FWIW I suggest people take the time to at least read the actual proposed rule itself, Part 89. It starts on page 283 of the NPRM.

The parts that apply to most models are:

89.120 Unmanned aircraft systems without remote identification

Subpart C—FAA-Recognized Identification Areas (89.201 - 89.230)

Most of the rest of the rule only applies to aircraft systems WITH remote ID, either the standard or limited. For model aircraft sUAS that are operated at a FRIA none of the build requirements or other requirements stated in sections other than what I note above apply.

I've seen long threads talking about build rules, data transmission, etc. Bottom line is if you are fly a model airplane at a FRIA none of that applies. And this is their first pass. I am willing to bet the proposed final rule will look very different.

Great point. I think most folks are hanging their opinion on the limited time scope of the FRIA. I tend to think the rules are contradictory and there will have to be some give either on the nature of RID installation in legacy, proximity flown amateur built craft or the FRIA will have to become more flexible and long term - the way it is written today doesnt make any sense. Even the FAA recognizes aviation didnt get where it is today without a robust amateur modeling community.

Here is a list of every Senator and Congressman we need to focus our efforts on. All are on the relevant committees with jurisdiction over the FAA. I say we ignore the rest of congress. It does not matter if these are your local representatives or not. They still are supposed to not only work for their constituents but the American people (insert cynical laugh here).

These are the Senators currently on The Subcommittee on Aviation and Space

Jurisdiction[edit]
has jurisdiction over technology, engineering, astronautical and aeronautical research and development; national and civil space policy; civil aviation research, development, and demonstration, and aviation safety and protection of consumers. The subcommittee conducts oversight on the National Aeronautics and Space Administration (NASA), Federal Aviation Administration (FAA), and the civil aviation and civil space policy functions of the Department of Transportation, Department of Commerce, and National Space Council within the Executive Office of the President.[1]

Members, 116th Congress

Ted Cruz, Texas, Chairman
John Thune, South Dakota
Roy Blunt, Missouri
Jerry Moran, Kansas
Cory Gardner, Colorado
Marsha Blackburn, Tennessee
Shelley Moore Capito, West Virginia
Mike Lee, Utah
Kyrsten Sinema, Arizona
Brian Schatz, Hawaii
Tom Udall, New Mexico
Gary Peters, Michigan
Tammy Duckworth, Illinois
Jon Tester, Montana
Jacky Rosen, Nevada

These are the Congressmen on The Subcommittee on Aviation

Jurisdiction[edit]
The Subcommittee on Aviation has jurisdiction over all aspects of civil aviation, including safety, infrastructure, labor, commerce, and international issues. All programs of the Federal Aviation Administration (FAA) except for research activities, are within the purview of the Subcommittee.
The Aviation Subcommittee is also traditionally the lead subcommittee with jurisdiction over the National Transportation Safety Board (NTSB), the federal agency responsible for investigating civil aviation accidents and other transportation accidents. The Essential Air Service program, which ensures commercial air service to smaller communities, the war risk insurance program, which provides insurance coverage for commercial flights to high-risk parts of the world, the National Mediation Board (NMB), and passenger and cargo commercial space transportation also fall within the purview of the Aviation Subcommittee.

Members, 116th Congress[edit]

Rick Larsen, Washington, Chair
André Carson, Indiana
Stacey Plaskett, U.S. Virgin Islands
Stephen Lynch, Massachusetts
Eleanor Holmes Norton, District of Columbia
Dan Lipinski, Illinois
Steve Cohen, Tennessee
Hank Johnson, Georgia
Dina Titus, Nevada
Julia Brownley, California
Anthony Brown, Maryland
Greg Stanton, Arizona
Colin Allred, Texas
Chuy García, Illinois
Eddie Bernice Johnson, Texas
Sean Patrick Maloney, New York
Donald Payne, New Jersey
Sharice Davids, Kansas
Angie Craig, Minnesota
Grace Napolitano, California
Salud Carbajal, California
Garret Graves, Louisiana
Don Young, Alaska
Daniel Webster, Florida
Thomas Massie, Kentucky
Scott Perry, Pennsylvania
Rob Woodall, Georgia
John Katko, New York
David Rouzer, North Carolina
Lloyd Smucker, Pennsylvania
Paul Mitchell, Michigan
Brian Mast, Florida
Mike Gallagher, Wisconsin
Brian Fitzpatrick, Pennsylvania
Troy Balderson, Ohio
Ross Spano, Florida
Pete Stauber, Minnesota
************************************************** ******
Now is the time to organize. We want to engage congress and the relevant parties during the proposed rule comment phase. We want to apply as much pressures as possible during this period while the FAA is open to input. Sadly we won’t get everything, we may accomplish nothing but the latter will most certainly hold true if we as a community do nothing.
The 10 key changes in the language I see that will have the most benefit to all are
1. The ability to change locations of existing approve FRIA sites should a club need to relocate.
2. The ability for additional FRIA sites to be approved in the future.
3. The ability to establish a FRIA site on private land that is not associated with a CBO but agrees to follow their safety guidelines.
4. The ability to grant permission for temporary FRIA sites to hold special events and competitions. Especially within controlled airspace. Think municipal airports and jet events.
5. FRIA boundary sizes propitiate to the size of the respective site and overfly area.
6. Ceilings greater than 400ft with in FRIA airspace.
7. Any park designated as a recreational flying location by municipalities granted FRIA status with no CBO requirement.
8. No RID requirements for any traditional model aircraft or FPV as long as they are operating within FRIA zone.
10. FRIA zones would be marked on sectionals just like a tower or any other obstacle with a higher designated altitude to fly over, well beyond our operational ceiling. We are not talking a lot of space here they can simply fly around us jeez ;-)

Bhodi, well said and researched. I wonder if the AMA or someone will build one of the auto link fill in the blank letter writing web pages that other organizations like the NRA use. They do seem to be effective.

Originally Posted by Festivus

Bhodi, well said and researched. I wonder if the AMA or someone will build one of the auto link fill in the blank letter writing web pages that other organizations like the NRA use. They do seem to be effective.

They have done so in the recent alls to action so I suspect they will do the same thing here.

Having said that, getting a large number of unique comments generally has greater impact than cooking cutter template comments, but they are better than nothing.