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HomeAircraftHelicopterMain Discussion › Please go comment on FAA's Special Rule's
06-26-2014 07:03 PM  4 years agoPost 21
revmix

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NJ

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laywers and judges
for hobbyist no need to worry about them

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06-26-2014 07:44 PM  4 years agoPost 22
marked23

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Lynnwood, WA

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These are my comments:
The hobby model aircraft industry includes domestic companies that develop hobby model aircraft for sale. From reading the Section 336 statutory requirements "The aircraft is flown strictly for hobby or recreational use;" Such companies could not test-fly products under development without falling under regulation of 14 CFR Part 91, because paid employees flying a prototype hobby model aircraft under development could not meet the "strictly for hobby or recreational use" clause.

Additionally, the hobby model aircraft industry includes "sponsored pilots" who perform demonstration flights at sanctioned events. In most cases, these sponsored pilots receive some compensation for their involvement. This compensation may be as small as receipt of free product, or as large as a paycheck. The compensation isn't strictly for the flight demonstration, but flight demonstration is included in the duties of this kind of representative.

I'm sure it is not the intent of the FAA to extinguish domestic hobby aircraft development, or to prevent sponsored representatives from performing demonstration flights. However, as "Interpretation of the Special Rule for Model Aircraft" currently reads, this will be the effect. Domestic companies may seek other options rather than wonder if their operations will be someday regulated under Part 91.

If they could know now, what those Part 91 rules might look like, then at least they could have an understanding about their status. As this reads now, it places model aircraft operations that do not meet the statutory requirements of section 366 in a legal limbo.

---

The "line of sight" rule mentions "an operator could not rely on another person to satisfy the visual line of sight requirement." However the nationwide community-based organization's safety rules already require that the person wearing the "first person view" goggles is only acting as a co-pilot to the actual operator. The nationwide community-based organization's safety rules already require the operator (acting as pilot-in-command) to maintain line-of-sight at all times. This operator/co-pilot arrangement is facilitated by a hobby industry standard dual-control system where the operator (pilot-in-command) holds a dead-man switch to temporarily enable the controls of the co-pilot.

Footnote 2 ignores this distinction. It would be helpful if the FAA would acknowledge and comment on this specific scenario. This is important because the current nationwide community-based organization's safety rules are misrepresented, on this point, by the language in "Interpretation of the Special Rule for Model Aircraft."

I believe the dual-control with pilot-in-command arrangement is sufficient to meet the public safety requirements for hobby model aircraft. I urge the FAA to consider this arrangement as a practical solution to ensure public safety while still allowing hobby model aircraft participants to enjoy first-person-view flying.

Thank you for reading my comments.

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06-28-2014 03:17 PM  4 years agoPost 23
Steve Graham

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Denver, CO

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Thats a good example of a well thought out response. While the initial impulse to send a note like "**** off you ****ing ****s. Who the **** do you think you are? I'm going to find out where you live and fly my model through your living room bay window. You can have my model when you pry it from my cold dead hands" might feel good it's not likely to do much good in the long run.

Very large numbers of tax paying and voting citizens using logic to express their concerns to both the FAA and their representatives are what's going to get us relief. Fortunately the FAA's position on this matter is so ill conceived that doing so doesn't really take much effort.

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06-29-2014 02:43 AM  4 years agoPost 24
marked23

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Lynnwood, WA

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Yes. While I was writing it, I had to fight the urge to include some insulting snark. But I kept at the front of my mind, "What kind of language would cause me to stop reading the message and skip to the next one?"

I tried to avoid any language that would cause them to ignore the message.

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06-29-2014 03:10 AM  4 years agoPost 25
drdot

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So. California, Orange County.

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fwiw...

Writing does no good....I would bet money most go unread, as there is no consequence to the FAA....The only hope we have is through elected officials..They actually may have some skin in the game...Agencys never deal in dialogue...only edict.

John.

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06-29-2014 03:22 AM  4 years agoPost 26
don s

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Chesapeake, VA

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The FAA is taking the law's definition of model aircraft literally.

Blame congress (and AMA) perhaps?

E820, Raptor G4N, X50F/E, E620, Forza 450, and some planks.

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06-29-2014 12:49 PM  4 years agoPost 27
rpat

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Weirton, W. Va.

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Well didn't congress already pass a law telling other agencies to keep their hands off of the model RC hobbyists.
You guys can do all of the writing that you want and all that you are going to get out of it is hand cramps.
drdot has it nailed. You are dealing with a government right now that is one step away from being a dictatorship, and some of us know what that means and some of don't.

trex 700fbl cal30,minititan,, trx600fbl,trex250,logo 500,Velocity N2

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06-29-2014 05:04 PM  4 years agoPost 28
unclejane

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santa fe, NM, USA

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I agree. I'm not even an anti-govt. conspiracy theorist and even I have accepted that FPV "model aircraft" are no longer "model aircraft" and will be specifically regulated as something else ("UAS" probably). And that nothing, even metaphysical intervention, will force FAA from this position ever. It's over and done. Let's put our comments in and forget about it.

Also, now that the AMA rule is dead and gone forever I can finally criticize it lol.. In fact, I've never liked it - it effectively requires an FPV model aircraft to have a crew of 2 which is way way overkill for a model airplane. A crew of that number is only required for quite large and complicated aircraft in full scale. But for a little multi or helicopter, a crew of 2 is kind of ridiculous. It also implies that an FPV operator can never achieve the level of competence to fly solo and unaided by a second crew member. In my experience, this is not the case at all - I can (well, I could) demonstrate an end-to-end/spoolup to spooldown, completely unaided FPV flight with my trex 800 or any of my multis to prove this.

I would support a simple spotter requirement, but I don't think that's in the cards for us.

We'll just have to see in a few years when the actual NPRM is released and we can see what we're going to have to deal with.

LS

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06-29-2014 08:46 PM  4 years agoPost 29
TMoore

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Cookeville, TN

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This is one of the problems that I have with FPV; what if the downlink takes a dump and all of a sudden you are way out there and you have to start flying line of sight? You yourself admit you suck at LOS so now your machine is a long way out, you have no idea what the orientation and you are not sure where it is spatially because up until that point you have been flying in a hood and you don't have 100% positive control....This is why it's supposed to be a 2 man operation. By your own admission you are a danger.

TM

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AMA SECTION 336 = Good
Drones = EVIL

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06-29-2014 09:13 PM  4 years agoPost 30
Heli_Splatter

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USA

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Multis not so dumb any more.
Excuse me... Have you heard of "Return to home?" and "Intelligent Orientation Control (IOC)"?

I don't care what orientation it is... I pull the stick back towards myself and it flys to me... Stick right moves right, stick left moves left. It takes a bit to get used to this mode of flying, but you can transition quickly if you want to.

If I want I can hit "Return to Home" or shut off the transmitter, and the multirotor with go up 20meters +/- and return to the launch point.

Of course I am talking about DJI Naza M/Phanton capabilities. Other controllers may have more or less the same features available. It is up to the operator to buy, install, and properly operate the equipment.

I do not consider myself a danger to anyone as I do not fly over people and property that I am not allowed to fly over. It is an evolving technology, and I hope we can talk the FAA into allowing some form of hobby FPV use. The idiots posting videos on the internet are not helping.

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06-29-2014 10:55 PM  4 years agoPost 31
TMoore

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Cookeville, TN

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Heli_splatter, I own a DJ550 and I'm well aware of how they operate but regarding those, they fail too. What I was talking about was unclejane using a T800 with FPV goggles not MR's.

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06-30-2014 12:29 AM  4 years agoPost 32
Heli_Splatter

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USA

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Everything can and will fail. It is just that a lot is being done to prevent those failures from becoming far worse.

Systems are available for helis too. We have to learn the operating ranges and stay within those ranges.

What we need is a repeater that we can install on a glider that we can bounce our command/control and FPV video off of.

At some point in time, we are going to be using cell phones to control our aircraft. I am surprise we have not seen it yet.

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06-30-2014 01:32 AM  4 years agoPost 33
unclejane

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santa fe, NM, USA

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This is one of the problems that I have with FPV; what if the downlink takes a dump and all of a sudden you are way out there and you have to start flying line of sight? You yourself admit you suck at LOS so now your machine is a long way out, you have no idea what the orientation and you are not sure where it is spatially because up until that point you have been flying in a hood and you don't have 100% positive control....This is why it's supposed to be a 2 man operation. By your own admission you are a danger.
What happens when you lose your r/c link? I don't need to go over that for you, you are already aware of what happens.

Aviation in all of its forms is a risk. And we take that risk according to the benefit received. But here you're judging my risk - depending on a video downlink - as greater than yours - depending on an r/c link - without any other supporting information. Namely, you don't know my flying habits, any precautions I take to ensure I fly safely, or even if my equipment is reliable. Do you even fly FPV? helicopter FPV?

Notice that I could jump to the same conclusions about you and you would probably respond the way I am right now.

This is topical in fact, because this is what FAA has done to FPV in its interpretation in a manner of speaking. It's jumped to the conclusion that FPV can't be done safely even at the current state of the art, but with no data in hand about whether it's a hazard or not.

That's how these myths get started and why we end up in the spots we end up in.

LS

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06-30-2014 01:38 AM  4 years agoPost 34
unclejane

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santa fe, NM, USA

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Heli_splatter, I own a DJ550 and I'm well aware of how they operate but regarding those, they fail too. What I was talking about was unclejane using a T800 with FPV goggles not MR's.
Have you ever FPVd your 550 in a 30 mph wind? Have you done the same FPV with a trex 800 in a 30 mph wind? Which one is safer?

LS

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06-30-2014 02:34 AM  4 years agoPost 35
TMoore

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Cookeville, TN

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What happens when you lose your r/c link? I don't need to go over that for you, you are already aware of what happens.
Aviation in all of its forms is a risk. And we take that risk according to the benefit received. But here you're judging my risk - depending on a video downlink - as greater than yours - depending on an r/c link - without any other supporting information. Namely, you don't know my flying habits, any precautions I take to ensure I fly safely, or even if my equipment is reliable. Do you even fly FPV? helicopter FPV?
Notice that I could jump to the same conclusions about you and you would probably respond the way I am right now.
This is topical in fact, because this is what FAA has done to FPV in its interpretation in a manner of speaking. It's jumped to the conclusion that FPV can't be done safely even at the current state of the art, but with no data in hand about whether it's a hazard or not.
That's how these myths get started and why we end up in the spots we end up in.
Your words not mine. You're the one that's been saying that you were more comfortable with FPV than LOS and I'm just taking you at face value. All I know is that if you are under the hood and the FPV link dies; if you are out of LOS what happens? That's why the AMA wants a spotter. Argue with that all you want but if you were at an event and doing FPV and I was the CD I would ground you without a spotter.

We all expect our radio equipment to fail at one time or another, that's a given but what we don't want to happen is for the machine to go completely out of control beyond LOS and that seldom happens but it does happen. FPV adds another big variable to the game.

TM

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AMA SECTION 336 = Good
Drones = EVIL

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06-30-2014 04:05 AM  4 years agoPost 36
unclejane

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santa fe, NM, USA

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Your words not mine. You're the one that's been saying that you were more comfortable with FPV than LOS and I'm just taking you at face value. All I know is that if you are under the hood and the FPV link dies; if you are out of LOS what happens?
My response is, if you get disoriented as a LOS pilot what happens? If the aircraft gets too far away before you regain your orientation, what happens?

You have a problem with FPV, but you don't seem to have a problem with losing an aircraft while LOS. At least, not in principle. That strikes me as a double-standard that you haven't justified.

Again, do you fly FPV? Have you ever flown a helicopter FPV?
That's why the AMA wants a spotter. Argue with that all you want but if you were at an event and doing FPV and I was the CD I would ground you without a spotter.
A spotter I'm ok with. But I don't like the FPV pilot being ultimately subordinate to another LOS pilot via the buddy-box requirement as per the AMA requirement. In my view, the FPV pilot is at least as able as, and in fact in many ways more able, than the LOS pilot. The FPV pilot should be able to act as "PIC" without being tethered to a LOS pilot.
We all expect our radio equipment to fail at one time or another, that's a given but what we don't want to happen is for the machine to go completely out of control beyond LOS and that seldom happens but it does happen. FPV adds another big variable to the game.
I agree that it adds another variable, but I disagree that it only adds more hazards. That's what you seem to be suggesting and in my experience, that's incorrect.

LS

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06-30-2014 04:21 AM  4 years agoPost 37
TMoore

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Cookeville, TN

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My response is, if you get disoriented as a LOS pilot what happens? If the aircraft gets too far away before you regain your orientation, what happens?
You have a problem with FPV, but you don't seem to have a problem with losing an aircraft while LOS. At least, not in principle. That strikes me as a double-standard that you haven't justified.
Again, do you fly FPV? Have you ever flown a helicopter FPV?
Losing orientation due to distance is one thing but not knowing where the heli is spatially once you pop out from under the hood is why you need a spotter and I'm fine with the FPV pilot being the slave on the buddy box. LOS should be the master. Yes I have flown both an airplane, a helicopter and a multi rotor on FPV. I'm very much ambivalent to the FPV. I don't care one way or the other but the FAA seems to. Between the MR's, FPV and camera ships our hobby is being threatened.

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AMA SECTION 336 = Good
Drones = EVIL

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06-30-2014 04:46 AM  4 years agoPost 38
unclejane

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santa fe, NM, USA

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Losing orientation due to distance is one thing but not knowing where the heli is spatially once you pop out from under the hood is why you need a spotter and I'm fine with the FPV pilot being the slave on the buddy box.
We see this differently, then. Being spatially unaware because you lost orientation while LOS vs being spatially unaware because of a lost video downlink are both being spatially unaware to me. They're both equally dangerous conditions.

Losing the video downlink, however, is a significantly less likely hazard than losing orientation while LOS - the latter has happened to all of us and we know how distressingly common it is.

This doesn't happen to the FPV pilot.

The former (loss of video link) has not happened to me yet.
LOS should be the master. Yes I have flown both an airplane, a helicopter and a multi rotor on FPV. I'm very much ambivalent to the FPV.
It is my opinion that, if you flew FPV to a level of proficiency, your fears about it probably wouldn't be what they are now. I have done this and now recognize that FPV has certain advantages over LOS, such that the "tether" is unnecessary. That's just my opinion, however it is based on a lot of experience with flying FPV.
I don't care one way or the other but the FAA seems to. Between the MR's, FPV and camera ships our hobby is being threatened.
No, line of sight is fully protected and good to go. FAA hasn't touched LOS and that mode hasn't undergone any changes. The commercial use issue will affect you, but not anything having to do with the way you control the plane.

FPV and commercial ops are what the FAA are targeting specifically.

LS

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06-30-2014 04:50 AM  4 years agoPost 39
revmix

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NJ

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FoolishPaperVictory
paper plane Judge
lawlessness r/c hobby
Special Rule or bust

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06-30-2014 05:01 AM  4 years agoPost 40
aceisback

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Terre Haute, IN

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Excuse me... Have you heard of "Return to home?" and "Intelligent Orientation Control (IOC)"?
I am just starting to get into FPV flying, so this issue is of interest to me.

As far as RTH and IOC are concerned, try using that if you have flown behind a 7+ story building or structure or are flying in or under a low structure such as a tunnel, parking garage, etc. Both are useless if RC or FPV link fails in these scenarios and you cannot see the aircraft.

People are flying these things in places they should not be just for the glory of creating a cool video. Unfortunately, thanks to these people, I can see why the FAA wants to regulate these things.

In other hobbies such as guns and go-karts, you don't go into the middle of downtown and start shooting for the hell of it, and you don't race your go-karts down a busy highway. If this is a hobby, we need to fly them where it is safe and appropriate, not just anywhere we want to.

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