[Dick3310]

All,

Everyone needs to read and comment on the UAV NPRM.

As written it is very dangerous to aircraft at uncontrolled airports. You can find the NPRM on regulations.gov. Search for docket 2015.03544. It has comment links. Page 84+ discusses airspace. Page 183+ is the airspace proposed rule.

The NPRM would prohibit UAV's in controlled airspace which is A, B, C, D and "surface Es" without ATC approval. UAV activities are allowed in G without any notice what so ever. You may be meeting a 55 pound, 100 MPH object right over your airport.

In a collision the UAV has a financial interest. You as a pilot have potentially a life or death issue. The FAA thinks see and avoid is sufficient when potentially neither party can see the other. The UAV because of perspective and the aircraft can't see because of the UAV's small size.

The issue is many, actually most airports are uncontrolled and are in Class G. For example in my state of Colorado there are 76 public use airports. Nineteen are B, C, D or surface E's. The remaining 57 are in Class G.

When you look at the sectionals surface Es have the thin dashed magenta lines. Surface Es are designated by the Feds in Order 7400. The designation is usually because of air carrier operations or multiple instrument approaches.

I believe UAVs have a useful place in our society, just not over public use airports because of safety. Not sure why the alphabet organizations thought this was a reasonable first step.

My suggestion would be that all public use airports become surface E's but you may have other thoughts.

Dick Sunderland

 

[rmartingt]

I've been working on a lengthy set of comments on the rule, and this is one of the issues I'm mentioning. The current 5 mile rule for R/C aircraft is maybe a bit much for very low altitude operations, but I wouldn't want quadcopters floating around in the traffic pattern or over the ramp of a crowded airport, either.

From a wider perspective, I think most of the rule as proposed is unworkable and impractical. The technology is so widespread and so easy to get (local gas stations are selling camera-equipped helicopters now) that, rather than spend all the money and effort on getting the UAV operator's license and doing all the paperwork, everyone but the highest-profile commercial operators are just going to bypass the rule. I mean, really--a 10lb hexcopter needing a freaking N-number? Contrary to the FAA's apparent assertions, small UAVs and manned aircraft are not the same.

In short, it violates the principle of "never issue an order that won't be followed and that you can't enforce".

 

[jnmeade]

When you comment, you might want to consider using the term UAS (unmanned aircraft system) or sUAS (small Unmanned Aircraft System) or UV (unmanned aircraft), as those are terms the FAA uses. That way, you and they are talking on exactly the same frequency and there is no chance they may misinterpret what device you are talking about.

I am not interested in any more surface E's, as that restricts operations such as my Champ in some weather conditions.

 

[Bill Boyd]

The technology is so widespread and so easy to get (local gas stations are selling camera-equipped helicopters now) that, rather than spend all the money and effort on getting the UAV operator's license and doing all the paperwork, everyone but the highest-profile commercial operators are just going to bypass the rule.

Because licensure and regulation worked SO WELL for citizen's band radio in the 70's, right? You can buy them in gas stations and truck stops, too.

The public will disregard this just as they do with "Breaker breaker one nine," and the spillover will denigrate the safety and enjoyment of general aviation just as disregard for the regs and general slovenliness of Children's Band have sullied amateur radio.

Be ready.

-Stormy

 

[jnmeade]

You may well be right about the notion that the FAA can not enforce the proposed rule if enacted. That should be considered.
In following sUAS in the news, the recent FAA violation actions I've read of were based on notices and complaints by the public. As this word gets out, every person who every was a chronic complainer of airplanes on final approach to a runway will be the very type who will start complaining of sUAS flying around. My point is, more of the public, especially those concerned about privacy, may start complaining.
AS to enforcement, that is indded an issue, it seems to me. The FAA put out a document recently talking about how they would work like local law enforcement agencies. My first reaction was that a few LEOs might think this is fun, but the vast majority of LEOs will probably want nothing to do with this kind of case. What is in it for them? More jobs, no more money, dubious public image, etc.
Several years ago I had sUAS advocates tell me on more than one occassion that they saw this as like the CB craze in the 70's. So many CBs were operated illegally that the FCC gave in and came up with a blanket license arrangement. sUAS advocates think the FAA will roll over, too. Maybe they will. Maybe an sUAS will go through a passenger jet engine and cause damage resulting in publiciity. Indeed, it's hard to predict how this will turn out. Enforcement is an issue.
I strongly agree that each of us should provide thoughtful, articulated and well supported comments to the NPRM.