Overview of Small UAS Notice of Proposed Rule making
1650 27 2015-9-17
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snathla
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Don't like what's being proposed

http://www.faa.gov/regulations_p ... 15_sUAS_Summary.pdf
2015-9-17
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frank320
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Holy crap. With those rules, we be reduced to flying "tethered kites"... you will be able to fly tethered kites higher, further and with infinitely less restrictions and liabilities.

Definitely a step backwards. Can we tell the FAA to "go fly a kite"? punt intended...
2015-9-17
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precisionair
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I honestly think this is a good thing.  If you have a 333 (and are serious about this becoming a real deal) then most of these stipulations are already in effect... BUT, with current 333 exemptions it requires pilots to hold at minimum a sports license.  That is expensive and time consuming to get!  With this new test it will be a simple test to pass and re-test every 24 months , hopefully without having to go to sport.  Not sure why the stipulations would ever limit someone's ability to fly.  I am curious which rules make it more difficult? Don't fly over people? VLOS??  If people were doing these things already then we wouldn't have all the stink in the media about UAS.

Brad
2015-9-17
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ibdronin
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@precisionair - I apologize and don't want to come off rude but you are dead wrong. This will actually hurt the consumers making purchases on drones. It will damage the business of drone makers.


This is also just a proposal and doesn't mean  it's going to pass. It will not help and will cripple those that aren't professionals. I doubt this will pass but you never know.

This is how stupid the FAA can be. Maximum altitude of 500 feet above ground level? Minimum weather visibility of 3 miles from control? No one here can see for example an inspire 1 at 3 miles from home location without visual assistance and 500 ft  above for that matter. Unrealistic, and this would also interfere with actual airlines and this my friends can and will cause catastrophic incidents. In their proposal they stated no visual assistance. This is just wrong!
What are the current laws that are in effect at this time? For example an old fart like me wanting to fly on his land to check on livestock?
Please give me the intel it would be appreciated.



2015-9-17
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sultangris01
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It says you must maintain visual line of sight, and it went interfere with actual airlines, they fly much higher than 500 feet except for when taking off or landing which is why you can't fly near airports. Anyway even if a place did hit an inspire or phantom size drone it wouldn't do Jack shit to the plane. Birds have more mass than plastic drones and planes hit thousands of them every year without any catastrophic incidents.
2015-9-17
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ibdronin
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Well.. where I live we have crop dusters for example that do fly below 500 ft and even under 100 ft. Believe it or not an inspire 1 for example can take down a jet engine. Birds do this all the time. But with that said
I still do not agree with the FAA proposal at all. It is ridiculous!

Does anyone here know the actual law for flying R/C? Which is what we truly are flying. We aren't sitting at a base station in Nevada trying to take out the bad guys over in the middle east.
2015-9-17
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frank320
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This could also be a gaming/negotiating tactic from the FAA and authorities. i.e come up with an initial draft that looks draconian and is completely restrictive, like above, scare the crap out of everyone, then proceed to "revise" the above draft to something less restrictive and hope people say "whew, at least the latest revision is not as bad as the original one", and threaten to go back to the first original draft if people don't accept...
2015-9-18
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ibdronin
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@frank320 you could be correct. ;)
2015-9-18
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stan
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No flying at night, that's ridiculous!
2015-9-18
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precisionair
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@ibdronin I can understand your point of view as a consumer, and yes I agree it probably does not help consumers, but please try to remember I am coming from the respect of the aerial professional, not consumer, I should have made that more clear.  So, I can see your point that this is a bad deal for consumers, and I would ask the FAA to limit their regulation on recreational product, for professionals though, I am sticking to my original argument that this is a good thing.  Seems like the VLOS rule is the most limiting of all and surely you can see it has righteous tones to it, maybe just a bit overbearing.  Fly over your pasture without VLOS? Sure go ahead, whats the worst that can happen?  Fly over downtown with lots of people gathering at events? I say get permission first and keep a close eye on the bird, only trouble ahead!

Brad
2015-9-18
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jaharrell
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Has anyone here actually successfully gone through the FAAs 333 process?
I inquired at the Riverside, CA FAA office but the staff there were not able to give me any useful information other than that the whole UAS issue was under review.
My understanding is that currently one may not legally use a UAS for any commercial purpose without having gone through the 333 process and that, by some interpretations, the 333 process must be done for each job. Obviously this would be burdensome.
There is no requirement in the purposed rules for an Airworthiness Certificate but each UAS would have to be registered and marked. So it seems that an aspiring commercial UAS pilot must make two applications one for the commercial use and one for the registration of each UAS.
I know that there are photographers offering, even advertising, their aerial photography services is anyone doing this legally? I have been turning down jobs because I have a Commercial Pilot Certificate and I don’t want to jeopardize it.
2015-9-18
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precisionair
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jaharrell@aol.c Posted at 2015-9-18 21:54
Has anyone here actually successfully gone through the FAAs 333 process?
I inquired at the Riverside ...

Yes I have gone through the 333 process and it isn't that bad really.  It takes forever (at least mine did) and you can get an exemption from the airworthiness requirements due to the size of the craft.  Per job is not necessary as the 333 is set in more broad terms for the type of job (agriculture, real estate, etc).  Just make sure to list everything you can think of, because you don't want to get a job offer and it fall within a different category!!  

If you want my advice, go on the FAA website and start there, it will have much more information than your local office, and you can actually browse through 333's that have been accepted.

https://www.faa.gov/uas/legislat ... n-Air-Inc-11762.pdf

here is mine, from beginning to end, hope this helps!

Brad

2015-9-18
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jaharrell
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frank320 Posted at 2015-9-18 16:28
This could also be a gaming/negotiating tactic from the FAA and authorities. i.e come up with an ini ...

I doubt that the FAA sees this proposal as an opening gambit from which they intend to negotiate. Any movement is likely to be more restrictive than less restrictive.
2015-9-18
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precisionair
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jaharrell@aol.c Posted at 2015-9-18 22:00
I doubt that the FAA sees this proposal as an opening gambit from which they intend to negotiate.  ...

I agree, this is the Gov we are talking about, why negotiate when you can just dictate?

Saves time and effort if you ask me....

Brad
2015-9-18
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ibdronin
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precisionair Posted at 2015-9-18 21:58
Yes I have gone through the 333 process and it isn't that bad really.  It takes forever (at least  ...

From my understanding in what I am reading is that this is more leaning toward commercial use and not
personal. For example, I plan to use my inspire 1 on a thousand acres of land that I own to use for our livestock count to assist in herding the sheep and to give me something to do when my wife kicks me out of the house while she is cleaning and or her friends are over playing bridge.  
2015-9-18
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precisionair
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ibdronin Posted at 2015-9-18 22:14
From my understanding in what I am reading is that this is more leaning toward commercial use and  ...

I envy your flying time!!!
2015-9-18
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eaglecook
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Check out the last bullet point under the operational restrictions:

Proposes a microUAS option that would allow operations in Class G airspace, over people not involved in the operation, provided the operator certifies he or she has the requisite aeronautical knowledge to perform

This basically means that we would be able to fly Inspires and Phantoms over people if we certify that we have the knowledge to preform a safe flight.

The change from 333 to make a visual observer optional is a good thing for the most part. I'll still use one, but I can think of times that I may want to fly without one.

The restrictions on the other classes of airspace are just common sense.

Once again, the change from 400ft max to 500 ft max is a good thing.

The major flaw I can see with this is that it doesn't specify if these rules are for all UAV use or commercial use only, and that one would need to be vetted by the TSA... a notoriously poorly run branch of the government.

My thought is that it is at least leaning in the right direction. We have to remember that these rules are put in place for ALL operators.. not everyone uses common sense or flies with regard to others. The FAA is just trying to protect the general public from the few flaming idiots that spoil things for the rest of us.
2015-9-18
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jaharrell
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precisionair Posted at 2015-9-18 21:58
Yes I have gone through the 333 process and it isn't that bad really.  It takes forever (at least  ...


Thank you Brad

The conditions under which you must operate are not too burdensome.
If I understood correctly the PIC must have a current BFR and have a VO when conducting operations. It sounds like the PIC and the VO could use radios to maintain contact. You I1 has an N number?
In the world of aviation the manufacturer provides a clear operator’s manual with the preflight checklist which is something that DJI has not done or if they have I have not seen it.
Now that the FAA is granting these authorizations it seems to me that DJI should be publishing the appropriate documentation (electronically) for the I1 which would mean that it might need to be reissued for significant firmware changes and that the PIC would be required to have it in his possession while conducting operations.
2015-9-19
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GB44
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I think that the US FAA have missed an opportunity to harmonise with the UK regs and create an internationally accepted ICAO regulations for all UAV operations.  I know Australia are currently looking into recognition of foreign trained UAV Pilots such as the BNUC-S certification in the UK, which is a step in the right direction for synergy and Pilot qualifications. Indeed the BNUC-S system run by EuroUSC is I beleive now accepted in most of Europe, Singapore, China and if Australia eventually chose to accept this qualification also, that will be a good portion of intertnational aviation authorities that will recognised this UAV Pilot qualification and provide some reciprocal acceptance of Pilot qualifications in line with the principal of ICAO for Pilots operating in foreign countries.

Looking briefly at the proposed FAA regulations in the link above,  I don't see what the fuss is about.  The proposals are similar to UK regulations and as PaulKerry outlines above, visual line of sight has to be accepted as the safest way to fly these aircraft.  I can't see them accepting the Inspire as a micro aircraft either.

The other issue I noted was that increasing the max altitude to 500 feet means that you could be at the same altitude as a small aircrafts minimum height agl.  The idea in the UK was that a max altitude of 400 feet for UAVs gives a 100feet separation between the different aircraft as a margin of safety and in reality 400 feet/120m is probably as high as you need to be safely.

2015-9-19
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precisionair
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You know, I would take the 400 foot argument with a grain of salt, and be very careful!  While we are 'allowed' to go to 400, I was out flying today and was buzzed by a helicopter flying around 250 (seemed like a lifeline vehicle).  Just because we are allowed to go to 400 doesn't mean no one else can come down to our level.  Just saying be careful out there!

Brad
2015-9-20
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wingingit
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jaharrell@aol.c Posted at 2015-9-19 09:46
Thank you Brad

The conditions under which you must operate are not too burdensome.

Brad is right about the 333 exemption process not being difficult jharrel.  And I'm not sure when he sent his petition in, but they now have a "summary grant" process where as long as you are only asking for exemptions that have previously been granted you should be approved in around 60 days versus the 120 days most people waited out earlier in the program.  I'm still waiting on mine to be approved, but I stuck with the basics on what I wanted exemptions from and didn't ask for anything that hadn't already been approved for someone, so I'm hoping mine will be close to the 60 days for approval.

What you're basically doing is submitting a request to exempt your UAS from certain FARs that a UAS just cannot comply with.  For example the "N" numbers on an aircraft are required by FAR to be a certain size.  So one of the exemptions you ask for is an exemption to use smaller lettering for your N-numbers.  Another one is the requirement for certain manuals and documents to be onboard an aircraft for each flight.  So you request an exemption to have the required operating documents on hand and located at the launch point for each flight since they won't fit inside the UAS.  I think you said you are a commercial pilot, so you know what Operating Specifications (Ops Specs) are.  Your approval basically becomes your Ops Specs and spell out what you can and cannot do commercially with your UAS for all of your commercial operations.  It's a one time approval; you don't apply for an exemption for each of your jobs.  One example where you would have to reapply is if you want to use a different UAS.  Say you currently use a Phantom 3 but think you might start using an S-1000 at some point; go ahead and include both the Phantom 3 and S-1000 in your original request.

https://www.faa.gov/uas/legislative_programs/section_333/

If you decide to go through the 333 process that page has a ton of resources.  Towards the bottom of the page is a link to all of the previously approved requests.  If you go through those you will have a pretty good feel for how to put your request together.  And if your local FAA folks are as unhelpful as you said, call Jeff Riff at the Houston office.  He's very up to date on all of this and very helpful.  He's the one who gave me the tip on including more than one UAS if you think you might upgrade equipment later.      
2015-9-20
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PeteGould
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wingingit Posted at 2015-9-21 02:19
Brad is right about the 333 exemption process not being difficult jharrel.  And I'm not sure when h ...

One of the major problems with the current 333 exemptions is that almost everyone who gets one is violating one of its basic terms: that you fly no closer than 500' to any person, vehicle or structure not involved in the operation unless you have constructed a protective barrier to prevent an accident.  Unless you're on a thousand-acre farm, you are almost certainly within 500' of an uninvolved person, vehicle or structure at some time during your flight.  500' is a significant distance - much more so than most people seem to realize.
2015-9-20
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wingingit
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PeteGould Posted at 2015-9-21 01:39
One of the major problems with the current 333 exemptions is that almost everyone who gets one is  ...

I'm definitely not a big fan of the FAA, but I almost feel for them a little.  This technology is accelerating at an exponential pace and they don't have the budget to do much at all about it right now.  What should be going on is numerous meetings with recreational and commercial users and the companies that build and sell; working towards a well thought out approach that takes everyone's concerns into account and realistically addresses situations like the one you point out.
What I'm afraid is going to happen is something big like an airliner sucking a UAS into one of its engines on short final.  Nobody dies, but that's going to be big news.  So then our illustrious clowns in Washington DC drag the FAA Administrator into a hearing, yell and scream about how the FAA should have been way ahead of this, and once the cameras are turned off they throw a bunch of money at the FAA to "fix this problem!"  I can only imagine how draconian the regulations that came out of that scenario would be.   
2015-9-21
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Machoman
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ibdronin Posted at 2015-9-18 08:50
@precisionair - I apologize and don't want to come off rude but you are dead wrong. This will actual ...

If drone makers would limit their unter USD 3000,- drones to 100m radius+alt there would be no need for such regulations. Its the cheap drones the masses can afford which destroy everything and need regulations.

Just think 1% of population has a drone. If you are on a mountain you cannot make a picture anymore without having a drone in it. Make a video? Not anymore - how you get the drones out of them?

And imagine some stupids (you have known them in school but now they are adults and allowed to buy drones which fly 3miles and 1500ft high at 40 miles speed) are just with you on the mountain and there are 5 drones flying around. Sure at least 2 will collide.

The manufactorers want the masses and are all making drones with specifications like above unter USD 1000,- - look at the Phantom3 Standard - this drone forces governments to make such regulations!

The planned regulations are for a scenario there are always anywhere several drones in the sky because every fool can afford it. And though I hate regulations because I am intelligent enough to fly safe without them and ignore government I understand why they must do this.
2015-9-21
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Machoman
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Its almost the same as the EU proposal.

Seems the will make this in all countries. However EU defines "pilot qualification" as

"It is not the intention to create a licence, but merely to develop learning objectives or an e-learning tool. Alternatively, the education provided at model-flying associations could be accepted as equivalent."
2015-9-21
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teamnest1
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interesting
2015-9-21
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PeteGould
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Machoman Posted at 2015-9-21 07:33
The planned regulations are for a scenario there are always anywhere several drones in the sky because every fool can afford it.

Perhaps so.  But if the governments pass rules making drones useless for video and film production, there is going to be a lot of pushback.
2015-9-21
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alan
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I live in the DC area. Last week I was on a group bike ride and one of the guys told me he was with the FBI as an investigator for the FAA to help develop the rules. I didn't press him much on the subject but he said the delay in making rules was from so many factors they are trying to figure out... they expect 700,000 drones to be sold in the US this year. They are very worried about flights over nuclear power plants... but he didn't go into detail why. (Surveillance for a ground attack or for actually attacking with drones?)  A nuclear power plant seems pretty solidly made to me and I can't imagine a drone carrying enough explosive to damage it.  Other terrorist scenarios are likely worrisome too. Hobbyists are certainly a major concern due to their numbers ... flying over crowds, stadiums, forest fires, near airports, etc.  

It seems to me that setting up some rules, tests and permitting for commercial users would be the easy part that they could start on while they try to figure the rest out. We're really not the problem.
2015-9-22
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