From AMA Today December 2010 (electronic newsletter)
Update on FAA
The FAA process to create regulation for the operation of small unmanned aircraft systems (sUAS) in the national airspace continues to move forward. There's been a lot of speculation about what will be contained in the sUAS proposed rule that is scheduled to be released as a notice of proposed rulemaking (NPRM) sometime in June 2011.
The NPRM will contain proposed regulation that will most likely have some impact on model aviation. The FAA is prohibited by law from disclosing the exact language in the NPRM until it's released in the Federal Register. However, we have been able to determine, in a generic sense, what some of the proposed language might be. The Aviation Rulemaking Committee’s report submitted to the FAA in 2009 indentifies many of the sUAS issues under consideration; however the specific recommendations in the report may or may not be reflected in the final rule. We know that the NPRM will most likely address things like how high, how fast, and where a model aircraft may fly. We know that the FAA has drawn a hard line between recreational use and commercial use.
AMA is continuing to work with the Unmanned Aircraft Program Office (UAPO) within the FAA and is in contact with the UAPO on a weekly, if not daily basis. Over the past 90 days there have been five face-to-face meetings with AMA and the UAPO staff. AMA’s internal workgroup, consisting of members with a diverse and knowledgeable model aviation background meet by conference call weekly and continues to develop standards that will eventually be submitted to the FAA for adoption that will allow modelers who follow these standards additional latitude from the rule. The foundation of our standards has always been the National Model Aviation Safety Code and its supporting documents including our Turbine Waiver Program and our Large Model aircraft Program. Recently a member of the UAPO office has been regularly attending these calls.
We're fighting a tough battle between keeping our members informed and not painting an overly tenuous picture of the future of model aviation. Not knowing exactly what will be in the proposed rule makes this a difficult challenge. And we're still working through some issues today that may be satisfactorily resolved before the NPRM is released. At the same time we need to make sure our members are aware, engaged, and prepared to react, if necessary, when the time is right.
The FAA has been invited to the AMA Expo in January. They have accepted. Our intent is to hold a roundtable Q&A session to help clarify a number of issues. This roundtable will be open to those in attendance and will also be taped and posted online. The Expo will also signal the beginning of an increased awareness campaign to keep the model aviation community as informed as possible as we move into 2011 and the eventual release of the NPRM.
– Dave Mathewson AMA President
Comments
I know its way too much to ask for,
A hobby size sUAS Class up to 5 kg all up weight with a max battery or fuel weight of 2 kg. This larger class allows a realistic sized 2 kg payload for scientific, aerodynamic & long duration surveys. FAA could tier the required downlink data: PICVSAA,TM with hobby grade Transponder above 400' with appropriate FailSafe actions based on desired range out to 20 miles and altitude up to 3000' in non-populated areas: deserts, dry lakes or over large private property: western cattle ranches, farms or agriculture lands.
Trappy and others have demonstrated most of these capabilities, an affordable hobby class transponder standard will need to be developed by FAA.
Airframe, Pilot & Range Safety Observer certification programs, similar to high power rocketry, where certified Mentors oversee and approve new pilots and airframes to next sub-tier by system and pilot demonstrations each sub-tier increasing in range and altitude.
Range Safety Observers and AirFrame Inspectors will require extended certification levels after receiving certified sUAS Pilot status. Mandatory insurance is required as you start Pilot certification program. With reduced rates upon graduation and after maintaining a good safety record.
The AMA will have to embrace FPV and autonomous systems whether they like it or not if they make themselves the pseudo-government agency they want to be. If they don't they are setting themselves up for a class action lawsuit.
I do not think anyone but a few understand the ramifications of what the AMA is trying to do...not even the AMA.
Fair question. I think there are a number of reasons why the sUAS w/ autopilot community should at least be aware of what's going on between the AMA and FAA. First, the simple use of the term "sUAS" is an issue. Until very recently, sUAS, to me, meant a small aircraft capable of autonomous flight. At some point along the way it became all-inclusive. Now it applies to RC model airplanes with or without autopilots, FPV aircraft and perhaps others (e.g. free flight). That's kind of a shame, in my opinion, because it muddies the waters. In any case, the AMA seems to have embraced the term and, by design, default or misunderstanding, brought sUASs w/ autopilots under their umbrella of discussion.
Second, I'm sure that many, if not most, hobbyists in the U.S. who are currently, or want to be, flying DIY Drones, are current AMA members and would like to openly fly their planes at AMA club fields. For many of us, I think, AMA fields are our only option for flying model aircraft of any kind. When I finally build my own sUAS, I would like to be able to fly it at my AMA field.
Finally, I think the AMA, if it is to be a proactive and relevant organization promoting the technological development of model aircraft, should embrace new technologies like airborne telemetry, FPV and autopilots and strive to work them into their programs (can't think of better term at the moment).
What is the purpose of a waypoint capable sUAS if it must remain in the line of sight. You may as well fly it manually. Does anybody actually agree that 1500 foot radius is a generous offering or that it actually requires an onboard autopilot?
I understand the wisdom of section 4 of the ARC recommendations related to suas. There are a lot of professionals out there that will be wanting to use very capable airframes, that whole ball of wax from Class I and up is handled consistently and appropriately.
I believe that a Class 0 can be defined, for those that truly want to play suas, with the freedoms currently enjoyed. Not only would I define it with an extremely light weight, 500 grams, and low speed, But actually require onboard real time video telemetry in this class so that the pilot in command can take over. I'm talking about a 1 pound airframe full up. Loss of r/c link, loss of video link, etc, would require a failsafe.
I'd be willing to follow all of the requirements including obtaining a pilot license and everything as mentioned in section 4. I'd be willing to keep it non commercial and keeping it under 400 feet and all of the other restrictions except for LOS. The size and weight and speed of a Class 0, along with the requirement of PICVSAA capability on board, should be enough to allow for the only class of airframe permitted to go beyond LOS. I would argue that it would be the safest class of model in any airspace. I further request that standard pilot insurance covers this and only this type of suas, Class 0, not the ama or anyone else. I don't want to be stuck at an ama field to fly my precious airplane while some knuckleheads are doing 3D aerobatics with their 0.90 sized copters.
A Class 0 airframe would probably attract most suas flyers willing to get the license and pay the insurance.
Instead of 2.2kg airframes stuck at ama fields, you would fly 500 grams out in a non-populated area of your choice. With a pilot's licence, proper insurance, uav training and etc, the Class 0 pilot could be trusted to be an suas team by himself. Class 0 would answer to the FAA.
Ok, ok, you're thinking he doesn't understand how things work, they'll never go with that, I'm just amazed that no one else ever brings up the obvious safety that on board video telemetry provides.
If you really want to keep playing sUAS drop that term FPV otherwise you will go down with them.
I believe the AMA are fully aware of whats coming in March, it set in stone and your all not going to like it.
Dump the AMA crud in section 2 and get the FAA to expand section 3 to include FPV with an observer. Sadly, the FAa thinks the AMA speaks for everyone in the hobby and puts their 140K members over everyone else.
I don't fly commercial and don't want to be forced to join any private organization. I don't have to join the NRA to hunt, why should I have to join the AMA to fly a model airplane?
The AMA does not want the added liability that sUAS and FPV operators will bring to their fields so can we honestly expect them to go to bat for us with the FAA. Unfortunately as a community we missed the boat with the sUAS Arc back in 2008 and our next best chance is to make some kind of impact when this is opened up to public input next year (we hope). Until then I think we need to discuss some common objectives and a strategy we can apply to make some kind of impact on the process.
(1) Prescribed safety program entailing oversight, assessment, risk mitigation, and
accident/incident reporting.
(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.
(6) Educational programming that assures participants are provided relevant safety
information and validates the learning process.
(7) Educational programming that addresses essential piloting issues
(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:
. Cooperation with other modelers
. Applicable altitude restrictions
. Emergency Procedures (e.g., Fire, First Aid)
My concern is that section 2 could allow the AMA to have no restrictions what-so-ever. That would make the AMA a money making, loophole, monopoly. Far too much temptation amd power for a bunch of amateurs pretending to be experts. No wonder they wanted to eliminate section 3, you would have to join the AMA to fly an airhog in your backyard if that happened.
I would have more respect for the AMA if they fought for a less restrictive section 3 for everyone and elimination of section 2. That would have been the proper thing for an NPO that says they are protecting "model aviation" for eveyone. I am ashamed to be a member, but change can only come from within.
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