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Thread: Proposed regulations for 3-pound "micro" drones

  1. #1
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    Proposed regulations for 3-pound "micro" drones

    On behalf of a client we filed a proposed rule for 3-pound drones (UA) and supported it with a safety study. We literally wrote the entire regulation for the FAA. I would be interested in your comments.

    Below is a link to the entire Petition for Rulemaking, but the text of the proposed regulation is Attachment A at the back, and the safety study is Attachment C.

    Thank you.

    http://www.kramerlevin.com/files/upl...Rulemaking.pdf

  2. #2
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    Seems like good common sense except for the part about not being allowed to operate over private property. That seems a bit extreme when so little public land is left available to us.

  3. #3
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    Most of it is very common sense. I don't really agree with the statement below...

    No person may operate a micro unmanned aircraft except between the hours of

    sunrise and sunset
    The FAA... "We're not happy till your not happy." Since 1958 =P

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    Quote Originally Posted by Grimm Reaper Racing View Post
    Most of it is very common sense. I don't really agree with the statement below...

    No person may operate a micro unmanned aircraft except between the hours of

    sunrise and sunset

    LOS


    Wayne
    Everybody loves a bunny.

  5. #5
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    Quote Originally Posted by Channel 1 View Post
    LOS


    Wayne
    Lights.

    -Alex
    If it is broken, fix it. if it isn't broken, I'll soon fix that.

    [url]videoaerialsystems.com[/url] - Performance video piloting

  6. #6
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    A couple of thoughts --
    -- Unless I'm misreading this, 107.13 (b) and (c) seem to be in conflict. (b) requires "prior authorization from the ATC facility having jurisdiction over that airspace" while (c) requires "
    prior written authorization from that airport’s management." So, if someone wants to fly within 5 miles of a Class D airport, they need written permission from the airport manager, but only verbal permission from ATC? What if they get one but not the other? Do they need to get this once, or every time they fly?
    -- Related to (c) above, there are lots of airports marked on sectionals that are only used sporadically (I'm thinking specifically of a section of a farmer's land that may be used three or four times a year for aerial application operations). Seems rather restrictive and open to the capricious whim of the farmer or whomever to deny permission because he's in a bad mood. Any chance of requiring a denial to be based on some legitimate safety concern?
    -- I notice that 107.13(d) maintains the prohibition on flying under goggles. Is it your assumption then that this ship has sailed and there's no point in arguing this any further?

    Thanks for doing this!
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    Quote Originally Posted by IBCrazy View Post
    Lights.

    -Alex

    Think LOS unaided by devices other than prescription glasses.


    Lighting is in the proposed rule, but only for extending LOS into twilight, not a biggie in the lower 48 but up in Alaska it matters.


    Whence nighttime and full darkness sets in, depth/distance perception becomes a problem without the normal visual references afforded by LOS, more so from the ground looking up versus the sky looking down.


    Wayne
    Everybody loves a bunny.

  8. #8
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    Quote Originally Posted by PDXDave View Post
    I notice that 107.13(d) maintains the prohibition on flying under goggles. Is it your assumption then that this ship has sailed and there's no point in arguing this any further?

    Thanks for doing this!

    I wouldn't say under goggles has sailed, but if those who wish to do so legally and if the industry that supplies them wishes to stay in business, they both need to stand behind and push this framework, then once it's codified into rule, work on creating an exemption for such activities.


    Right now the FAA is playing fast and loose pulling so called rules out of their arse, get regulations like this in place and lines are drawn, then with a baseline set, start shimming the finer points in.


    Wayne
    Last edited by Channel 1; 23rd January 2015 at 06:24 PM.
    Everybody loves a bunny.

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    These rules seem to target rotorcraft and severely restrict fixed wing operations. However, I don't like many things I read:

    I do not agree with 107.9 at all. Lighted UAS at night are LESS of a hazard to aircraft as ones operated in the daytime. I have done many night flights some with FLIR cameras, others with CCD cameras. Night flights are very safe so long as the aircraft is lit up. You can see it for several miles.

    I would also like to propose for 107.13 that the 5 mile statute be reduced to 3 miles as in the AMA safety code. Many of these airports are grass runway airports and there is little (if any) daily traffic through them.

    107.13 (d) - Makes FPV behind objects (such as trees) illegal. With technology getting better, the FPV systems can punch through objects with ease. Also, if behind a structure, you are out of airspace that other aircraft would use. I think we should simply leave the distance at 1/2 mile.

    107.17 - Ground speed of 40 knots is terribly slow for an airplane. One of my employees has a 3 oz RTF Biplane (I forget what it is called) that goes 50 knots... and it's a micro scale plane.

    107.19 (b) - Perhaps this should be a special test specifically for micro UAS and not the same as those piloting full-scale aircraft. Remember that an Ultralight (249lbs) does not have a speed limit, nor does it require ANY certification. We're talking RC toys here.

    Other than that, it looks ok to me.

    -Alex
    If it is broken, fix it. if it isn't broken, I'll soon fix that.

    [url]videoaerialsystems.com[/url] - Performance video piloting

  10. #10
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    Quote Originally Posted by Channel 1 View Post
    Think LOS unaided by devices other than prescription glasses.


    Lighting is in the proposed rule, but only for extending LOS into twilight, not a biggie in the lower 48 but up in Alaska it matters.


    Whence nighttime and full darkness sets in, depth/distance perception becomes a problem without the normal visual references afforded by LOS, more so from the ground looking up versus the sky looking down.


    Wayne
    You never flew with a FLIR camera have you? Or even a good night time black/white starlight camera? Night flying is just like daytime with the proper equipment. We do LOS night flights all the time. We just run lights inside our wings for orientation. Works great.

    Then there's HugeOne. He has a headlight on his airplane that is 10X stronger than my headlights on my car. It looks like broad daylight through the camera even at 1/4 power.

    -Alex
    If it is broken, fix it. if it isn't broken, I'll soon fix that.

    [url]videoaerialsystems.com[/url] - Performance video piloting

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