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Comments requested: FAA's ANPRM for Safe & Secure Operations of UAS
360 14 2019-3-29
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Cetacean
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ACADEMY OF MODEL AERONAUTICS                                                     

                                                     The largest model aviation association in the world!
Dear AMA members (& US DJI Hobbyists),
Model aviation needs your help to ensure future regulations do not place unnecessary burdens on our community.  Last month, the FAA issued an advanced notice of proposed rulemaking (ANPRM) regarding the safe and secure operations of small unmanned aircraft systems (UAS). In this ANPRM, the FAA is currently seeking comments on potential new rulemaking for operational and performance restrictions on UAS, including model aircraft. Some of the parameters being considered include altitude, airspeed,  stand-off distances and unmanned aircraft traffic management.
AMA has long held that the hobby of model aviation has introduced no new risk into the airspace, and therefore should not be subject to any new regulations. AMA is in the process of submitting comments to the FAA to this effect, urging the agency to take into consideration the existing safety guidelines for modelers and the differences between model aircraft and commercial drones – the FAA cannot and should not take a one-size-fits-all approach to regulating them.   
  
It is critical that we voice our support for the hobby by submitting a comment to the Federal Register regarding this ANPRM. Click here to submit a comment or visit www.regulations.gov and search for Docket No. FAA – 2018 - 1086; Notice No. 18-08. Below you'll find a suggested template for comments, which you can customize with your personal story and then copy and paste into the comment field on the Federal Register website. The current deadline for submitting comments is 11:59 pm on April 15, 2019.   
  
Rulemaking is a lengthy process but rest assured that AMA will continue to advocate for our members and keep you informed as it progresses.  As always, thank you for your continued support, and please reach out with any further questions or concerns at [url=]amagov@modelaircraft.org[/url].  
  
Thank you,
AMA Government Affairs

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Template Comment for AMA Members: ANPRM Safe and Secure Operations
  
I am writing in response to the FAA's advanced notice of proposed rulemaking on the safe and secure operations of small unmanned aircraft systems (UAS), including model aircraft. My position is simple: model aviation has introduced no new risk into the airspace, and therefore should not be subject to new regulations.
  
[Insert personal introduction details such as: I am a member of the Academy of Model Aeronautics (AMA) and have been flying model aircraft safely and responsibly for XX years. I am also a model aircraft club officer/educator/designer, etc. I love to fly XX because...]  
  
As the FAA considers new rules for UAS, I urge the agency to take into consideration the existing safety guidelines for modelers and account for the fact that model aircraft and commercial drones are not the same – the FAA cannot and should not take a one-size-fits-all approach to regulations. Not only would that approach run counter to the long-standing principles guiding both manned and unmanned aviation regulations, but it would also place an unnecessary burden on hobbyists like me who have been  flying model aircraft for recreational and educational purposes safely for many years.   
  
Hobbyists who fly model aircraft do not need to be included in new rules for drone operators because we already follow our own proven set of safety guidelines, often at remote fixed flying site locations.  All AMA members fly according to the organization's safety code, which has been recognized by Congress as an effective means for managing the modeling community. Our existing safety guidelines work – and there's no reason to add new rules.  
  
For example, AMA members always fly within visual line of sight of their aircraft, which allows model aircraft pilots to see and avoid anything that may be flying nearby. Also, AMA members must maintain a 25-foot distance between their aircraft and any individuals whenever they are flying. At competitions and events, spectators are required to stay behind a well-defined line, typically 50-100 feet away from the flight line where pilots are operating models, depending on the size of the event and  aircraft.   
  
Advanced drones, however, have created the possibility for new risk, and that's why AMA has supported giving the FAA the authority it needs over sophisticated drones with advanced capabilities, such as those designed for sustained and controlled navigation beyond visual line of sight.  The FAA could use the presence of a navigational system that utilizes multiple waypoints as a means of differentiation between model aircraft and sophisticated drones.   
  
New restrictions on model aviation could have a detrimental impact on long-standing model aviation events and competitions that support local charities and non-profits. Beyond curtailing events and harming charities, new rules would have a chilling effect on youth involvement in the hobby and stifle the benefits of utilizing model aviation in STEM education, ultimately hindering efforts to attract youth to the aviation industry.  
  
Again, I urge you to consider model aviation hobbyists separately from operators flying sophisticated drones as you work on new rules for UAS. Not all model aircraft and drones are the same, so the FAA cannot simply take a one-size-fits-all approach.  
  
Respectfully,
[Name]
[City, State]
2019-3-29
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Mark The Droner
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Thanks for posting
2019-3-30
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DJI Stephen
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Hello and good day Cetacean. Thank you for posting and for sharing this informative information. Great work and thank you for your valued support.
2019-3-30
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Cetacean
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Aloha Mark,

     Yeah, we have to watch these government guys closely!  But, AMA does a good job at that!  Good hearing from you!

Aloha and Drone On!
2019-3-30
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Cetacean
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DJI Stephen Posted at 3-30 07:19
Hello and good day Cetacean. Thank you for posting and for sharing this informative information. Great work and thank you for your valued support.

Aloha Stephen,

     Over here we say, "We stay coming, you stay going, what!"  (An ode to confusion!)  Maybe we will one day figure it out!  

     Mahlo for monitoring it!

Aloha and Drone On!
2019-3-30
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DJI Stephen
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Cetacean Posted at 3-30 15:56
Aloha Stephen,

     Over here we say, "We stay coming, you stay going, what!"  (An ode to confusion!)  Maybe we will one day figure it out!  

You are very much welcome Cetacean. Have a safe and happy flying always.
2019-3-31
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Mark Weiss
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Seeing as the regulatory burdens on UAS ownership are likely to become large in the very near future, now might be a good time to sell, before the market is flooded with used drones from people who cannot deal with the barriers to entry, such as a full licensing scheme (as Australia just passed to law).
2019-3-31
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Cetacean
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Mark Weiss Posted at 3-31 14:46
Seeing as the regulatory burdens on UAS ownership are likely to become large in the very near future, now might be a good time to sell, before the market is flooded with used drones from people who cannot deal with the barriers to entry, such as a full licensing scheme (as Australia just passed to law).

Aloha Mark,

     Hey, do not give up so easy.  I am trying to get the FAA to authorize a third category of UAV use besides hobbyist and commercial - community service.

     There is plenty room for improvement.  Remember way back a couple years ago when those two lawsuits forced the FAA to change what they were doing in two different areas?  It can happen again.  The airspace of the United States has to be used fairly and equitably.  It takes time, but it can happen.

Aloha and Drone On!
2019-3-31
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Mark Weiss
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Prior to July 1913, the airwaves were free to use by all. Then in July of that year, the government stole the airwaves from the people and licensed them back to big corporations like RCA and NBC.
As with any new technology, including the internet, eventually the government will take it away from us and license it back to those with deep pockets.
2019-4-3
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Cetacean
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Mark Weiss Posted at 4-3 06:09
Prior to July 1913, the airwaves were free to use by all. Then in July of that year, the government stole the airwaves from the people and licensed them back to big corporations like RCA and NBC.
As with any new technology, including the internet, eventually the government will take it away from us and license it back to those with deep pockets.

Aloha Mark,

     Now the Dems are in control of the House and working on ways to redistribute that which was stolen from the people.  Write letters and emails and VOTE.  We need to get these problems solved!

     If you write a little bit at a time, but constantly, it gets things done.

Aloha and Drone On!
2019-4-3
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Mark Weiss
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Cetacean Posted at 4-3 22:54
Aloha Mark,

     Now the Dems are in control of the House and working on ways to redistribute that which was stolen from the people.  Write letters and emails and VOTE.  We need to get these problems solved!

The Dems want redistribution of wealth and a police state. Neither party will return the airwaves to the people. It's hopeless. We've got people running the country who don't even know which bathroom to use. :/
2019-4-8
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Cetacean
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Mark Weiss Posted at 4-8 16:46
The Dems want redistribution of wealth and a police state. Neither party will return the airwaves to the people. It's hopeless. We've got people running the country who don't even know which bathroom to use. :/

Aloha Mark,

     I thought you were talking about net neutrality?  Hey I just want the health care I already payed for.  And as for wealth, I like the tax structure of the late fifties and sixties.  Our economy was booming back then.  All the businesses are having hard times right now.  My Brother-in-Law is having a real hard time, he has manufacturing in China and warehousing in California, getting hit from all sides.

Aloha and Drone On!
2019-4-9
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Alvaro L
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I hope that EASA does something similar, I would chip in. For instance, make manufacturers to publish failure modes of their products, meaning the exact chain of events that could lead to a certain hardware failure. Also payload software and command and control software layers should become separated and the later should become full proof resistant to software crashes.
2019-4-9
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Cetacean
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Alvaro L Posted at 4-9 12:16
I hope that EASA does something similar, I would chip in. For instance, make manufacturers to publish failure modes of their products, meaning the exact chain of events that could lead to a certain hardware failure. Also payload software and command and control software layers should become separated and the later should become full proof resistant to software crashes.

Aloha Alvaro,

     Well, I am way too old to be alive when that ever happens.  Too much competition between businesses and not enough benevolent government.

Aloha and Drone On!
2019-4-11
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Mark Weiss
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Cetacean Posted at 4-9 03:40
Aloha Mark,

     I thought you were talking about net neutrality?  Hey I just want the health care I already payed for.  And as for wealth, I like the tax structure of the late fifties and sixties.  Our economy was booming back then.  All the businesses are having hard times right now.  My Brother-in-Law is having a real hard time, he has manufacturing in China and warehousing in California, getting hit from all sides.

Nah, "neutrality" is a political term in the context of the battle between freeloaders like Netflix and true neutrality, such as the opposite of Fascistbook.

Everything in nature, every new discovery is free, until government decides that it can leverage it to its advantage by regulating it.
2019-4-13
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