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Author Topic: FAA Rules Applicability for CL  (Read 2448 times)

Online Peter in Fairfax, VA

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FAA Rules Applicability for CL
« on: June 02, 2019, 02:27:40 PM »
Already, I've seen correspondence the FAA has sent stating the requirements to register and label drones does not apply to control line models.  Further, NVCL has spoken with the FAA, resulting in the FAA informing us that the FAA does not consider CL a threat they regulate.  The general thinking is that the FAA is no more interested in CL than they are in beach kites.

Are any clubs finding their CL fields influenced by any thought that FAA drone rules apply to CL?

thanks,

Peter


Online BillP

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Re: FAA Rules Applicability for CL
« Reply #1 on: June 02, 2019, 03:07:02 PM »
Already, I've seen correspondence the FAA has sent stating the requirements to register and label drones does not apply to control line models.  Further, NVCL has spoken with the FAA, resulting in the FAA informing us that the FAA does not consider CL a threat they regulate.  The general thinking is that the FAA is no more interested in CL than they are in beach kites.

Are any clubs finding their CL fields influenced by any thought that FAA drone rules apply to CL?

thanks,

Peter


What written info from the FAA have you seen? I phoned the FAA some time go and different reps said different things...such as CL has to register and CL doesn't have to register. I picked the answer i liked but have no idea which is fact and which is fiction.
Bill P.

Offline Brett Buck

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Re: FAA Rules Applicability for CL
« Reply #2 on: June 02, 2019, 04:39:43 PM »
Already, I've seen correspondence the FAA has sent stating the requirements to register and label drones does not apply to control line models.  Further, NVCL has spoken with the FAA, resulting in the FAA informing us that the FAA does not consider CL a threat they regulate.  The general thinking is that the FAA is no more interested in CL than they are in beach kites.

Are any clubs finding their CL fields influenced by any thought that FAA drone rules apply to CL?

   I just got something from the AMA about "Letters of Agreement" and how they are going to track it. The first information I got is that the AMA wants us to follow it and there is no distinction made about the types of models.

    Brett

Offline BillLee

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Re: FAA Rules Applicability for CL
« Reply #3 on: June 02, 2019, 04:42:09 PM »
   I just got something from the AMA about "Letters of Agreement" and how they are going to track it. The first information I got is that the AMA wants us to follow it and there is no distinction made about the types of models.

    Brett
As usual!  HB~>
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Online BillP

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Re: FAA Rules Applicability for CL
« Reply #4 on: June 02, 2019, 06:16:06 PM »
 They may still  be pushing the deal where flyers don't have to register if they are members of a "community" organization or some wording like that...and the official community organization is the AMA. 
Bill P.

Offline Brett Buck

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Re: FAA Rules Applicability for CL
« Reply #5 on: June 03, 2019, 01:13:40 AM »
They may still  be pushing the deal where flyers don't have to register if they are members of a "community" organization or some wording like that...and the official community organization is the AMA.

  That's still probably the AMA plan, but no one seems to be paying any attention to them - which is entirely unsurprising. 

   To elaborate from earlier, the Letter of Agreement is supposedly required between a club and the air traffic control tower, if a site falls within controlled airspace. This is reasonable for RC models, but absurd for CL. Of course, despite the years of assertions by the AMA, they make no distinction at all between forms of modeling. So I was asked to fill out some AMA survey form about out letter of agreement with the Napa airport, which I have yet to do and probably won't.

     Brett

Offline Bob Heywood

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Re: FAA Rules Applicability for CL
« Reply #6 on: June 03, 2019, 06:17:01 AM »
Below is a recent email exchange between Tyler Dobbs and myself concerning this issue:

Robert,

Happy to answer your questions.

How exactly is outdoor Free Flight impacted? Do all of the rules, including registration and identification apply? How do I keep my competition Free Flight aero model below 400 ft. AGL?

-   AMA has always maintained that FF models cannot navigate the airspace and therefor do not meet the definition of an unmanned aircraft system.  We do not believe that registration and other requirements for UAS apply to this type of aircraft. Will law enforcement understand the difference if they approach a FF club, probably not.

-   We will be creating letters of agreement for our sites in Class G airspace in the coming days, which will allow our clubs to operate at altitudes above 400’.  It may be in your best interest to go through the LOA process to ensure that your flights above 400’ can continue without issue.  An email will be sent to all club presidents and contacts in Class G airspace towards the end of next week on how to begin this process. 

How exactly is outdoor Control Line impacted? Do all of the rules, including registration and identification apply?

-   AMA maintains that Control Line does not meet the definition of an unmanned aircraft system, due to the fact there is something attached to the aircraft that allows for direct intervention of its operation. We do not believe that registration and other requirements for UAS apply to this type of aircraft. Will law enforcement understand the difference if they approach a CL club, maybe due to the attachment to the operator but not a guarantee.   

Why have we been ignored?

-   We have asked the FAA numerous times if our understanding that FF and CL are exempt under current UAS regulations and they have verbally agreed.  When we ask for these assurances in writing they are hesitant.  That being said, with other countries recently exempting CL they may now be willing to follow. 

I understand your frustration of operating in a gray area and not being able to get a straight forward respond.  We will continue to ask the FAA for something in writing, but we are approaching this issue with caution.  We don’t want to the FAA to punt to the safest response and include two disciplines that we feel are extremely safe and fall outside of the definition of UAS.   

Best regards,
Tyler Dobbs l Government Affairs Director
Academy of Model Aeronautics
5161 E Memorial Drive
Muncie, IN 47302
(800)435-9262   -   (765)287-1256 ext. 235   -   Fax (765)289-4248


Near as I can tell, until if or when there is a formal written exemption, C/L aero models fall under the definition of a Unmanned Aircraft according to Federal Law.

I doubt that the FAA really cares. I believe that since most of us fly at established sites and have good working relationships at the local level we are in good shape.

There was an incident with one of our club members where some malcontent decided to cause trouble and called a control tower to report drone activity in the area. Some underlings from the airport came by to see what was going on. They had never seen a C/L model in their life. They also were not aware that a C/L site was near the airport, never mind that it had been there since the very early 1960's. After some protracted discussion they went away and left our guy alone. This has all been sorted out to our satisfaction with airport management.
« Last Edit: June 03, 2019, 11:11:03 AM by Bob Heywood »
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Offline Tim Wescott

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Re: FAA Rules Applicability for CL
« Reply #7 on: June 03, 2019, 10:41:16 AM »
  That's still probably the AMA plan, but no one seems to be paying any attention to them - which is entirely unsurprising. 

I'll post a link if I run across it again (unlikely, alas), but I ran across an article from the drone community that was more or less "Why can't we get commercial licenses yet?" and the answer was "those RC guys have a Really Powerful lobby".

I guess that the drone community wants every "drone" to have a $1000, 1-pound tracking system installed.  That may have an affect on how our CL planes fly.

So I think that someone is paying attention.
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Online Peter in Fairfax, VA

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Re: FAA Rules Applicability for CL
« Reply #8 on: June 03, 2019, 11:20:30 AM »
I did speak at length with the AMA today.  The people at AMA do understand what CL is.  AMA is asking the FAA for CL to be formally described as not UAS, just as the UK and Canada have put CL into their codes and regulations.  The present situation is that individual FAA people explain orally that CL planes are not a threat, and do not classify as UAS.  Getting that instruction into writing is in the works, though not at the top of the FAA to-do list.

Peter

Offline Mike Scholtes

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Re: FAA Rules Applicability for CL
« Reply #9 on: June 03, 2019, 03:27:33 PM »
Al Hieger in LA reports that on May 27 a contingent of FAA reps showed up at the Jet Rally (which I assume is RC) to monitor the event for compliance. They apparently issued a permit for the event to proceed. However in view of this enforcement activity one of the prime CL sites in LA has been shut down voluntarily by the users in an exercise of caution while they try to get a Letter of Agreement from the nearby Van Nuys ATC center.

My own suggestion is that all clubs within controlled Class D airspace get realistic about the situation and submit a request for a LOA from the relevant ATC center (or centers if you fly in a congested area with multiple controlled airports). This would be Oakland for my Alameda club, Napa for the Napa site, and probably at least one Sacramento tower for the Davis-Woodland site.

I would not risk confiscation of my model and flying equipment, and possibly Federal regulatory violation charges, for want of seeking a LOA from the FAA. Regulatory charges are no joke. Anyone who thinks this can be laughed off is kidding themselves.

Offline Dave Hull

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Re: FAA Rules Applicability for CL
« Reply #10 on: June 04, 2019, 09:46:07 PM »
Mike,

I am the President of the Valley Circle Burners, whose home field is Apollo 11 Field in the San Fernando Valley. Al is our club Secretary and newsletter editor. I have been working on this issue since the day after the R/C jet rally, which was a sanctioned AMA event and allowed to be continued under a FAA-granted waiver while they observed. There are a lot of things going on here, and a lot of misinformation being spread via the internet and facebook. Some of it is probably the result of a good deal of anger...which has yet to help the situation.

While Al may have said the grounding is voluntary for the control line flyers, who have multiple circles across the parking lot from the R/C flying area, I would disagree with that assessment. First, the new Section 349 regulations are in place (see attachment below), and as far as I can tell became effective immediately. Second, the entire extent of Apollo 11 Field is inside Class D airspace, which the FAA has the responsibility to control. Class D goes from zero feet AGL to 2,500 feet. Third, from my search, no written approval for flying models could be found. Historical precedent is not sufficient. The AMA is requiring clubs to input their field status (Lat/Long) and any ATC agreements by June 16th. A bit late to get paperwork in place to avoid being grounded. And while the AMA has a draft of their desired LOA form (you can access on the AMA website), the FAA is still working on their version. I have not heard a due date for that document. In the meantime, the FAA posted a sign on the entrance to the overall flying area, along with the applicable United States Code. It does not seem to make an exception for control line.

What appears to be different about Apollo 11 Field situation is that the FAA groups (VNY ATC, FSDO, sUAS directorate, special agents from the DOT, etc. and I kid you not, the California Highway Patrol) used this as a test case. When specifically asked if control line planes were exempted, one FAA person responded that they were unmanned aircraft and therefore regulated. Until this issue is resolved, each field that is affected is operating only with the goodwill of local ATC personnel and their personal interpretation of the regulations.

One good piece of advice we received from an AMA leader was that anyone with an FAA license, whether a pilot's license or an A&P license, should probably not try flying control line without the signed LOA. Too much skin in the game.

If someone needs specific details, send me a private message and I will respond if I can.

Dave "McSlow" Hull
Valley Circle Burners
« Last Edit: June 04, 2019, 10:08:49 PM by Dave Hull »

Offline Reptoid

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Re: FAA Rules Applicability for CL
« Reply #11 on: June 04, 2019, 11:31:09 PM »
Apparently we have morons on both sides of the AMA vs FAA discussion. Perhaps we need to redefine Controline as "Powered Kites" limited to 70' lines. Since the maximum altitude with a really tall pilot would be under 80' and there are hard structures like buildings taller than that in said airspace it should be a non-issue. Lumping Controline together with Drones, free-flight, RC aircraft (both FPV and Line of sight) capable of high altitude flight is beyond ludicrous. R%%%%
Regards,
       Don
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Offline Mike Scholtes

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Re: FAA Rules Applicability for CL
« Reply #12 on: June 04, 2019, 11:33:28 PM »
Dave, I sent you a PM on this subject.

Regards, Mike Scholtes

Offline Dave Hull

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Re: FAA Rules Applicability for CL
« Reply #13 on: June 05, 2019, 01:08:32 AM »
Replied.

Dave Hull

Offline Dave Hull

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Re: FAA Rules Applicability for CL
« Reply #14 on: June 05, 2019, 01:30:36 AM »
Don,

You may want to check out the FAA rules regarding kites before you run down that rabbit hole very far….

I'm still looking for a current/official copy of the regulations, but here’s what I think it says:

S101.13 Operating limitations.
   (a) Except as provided in paragraph (b) of this section, no person may operate a moored balloon or kite --
      (1) Less than 500 feet from the base of any cloud;
      (2) More than 500 feet above the surface of the earth;
      (3) From an area where the ground visibility is less than 3 miles; or
      (4) Within five miles of the boundary of any airport.

In other words, attempting to redefine control line airplanes as kites does not appear to relax any requirements at all. And, the FAA does not consider kites as kids toys to be ignored as irrelevant. Rather, they think they are sufficiently hazardous under certain conditions that they have long regulated them.

Dave

Offline Reptoid

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Re: FAA Rules Applicability for CL
« Reply #15 on: June 05, 2019, 09:48:47 AM »
Don,

You may want to check out the FAA rules regarding kites before you run down that rabbit hole very far….

I'm still looking for a current/official copy of the regulations, but here’s what I think it says:

S101.13 Operating limitations.
   (a) Except as provided in paragraph (b) of this section, no person may operate a moored balloon or kite --
      (1) Less than 500 feet from the base of any cloud;
      (2) More than 500 feet above the surface of the earth;
      (3) From an area where the ground visibility is less than 3 miles; or
      (4) Within five miles of the boundary of any airport.

In other words, attempting to redefine control line airplanes as kites does not appear to relax any requirements at all. And, the FAA does not consider kites as kids toys to be ignored as irrelevant. Rather, they think they are sufficiently hazardous under certain conditions that they have long regulated them.

Dave
I'm not going down any rabbit hole. I'm quite aware of the FAA regs on kites. Just pointing out that regulating CL airplanes lumped in with untethered aircraft is ludicrous.
Regards,
       Don
       AMA # 3882

Offline Dave Hull

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Re: FAA Rules Applicability for CL
« Reply #16 on: June 05, 2019, 12:33:15 PM »
Don,

I agree that they have nothing like the same risks and liabilities and that they should have separate treatment by the FAA. As control line models.

Currently, we are moving that direction, but at a glacial rate. I made a run at this way back in 2011 because things were not looking good at that time. Since then, we have inched forward in one area: the VIP movement TRFs now differentiate control line planes from the larger group of models (ie. R/C and drones); and, apparently other countries aviation regulations are starting to make a distinction.

Our barrier to progress is that control line isn't the FAA's biggest problem (no surprise there!)--and therefore we are somewhere near the bottom of their agenda.

Dave

Offline Reptoid

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Re: FAA Rules Applicability for CL
« Reply #17 on: June 05, 2019, 05:35:08 PM »


Our barrier to progress is that control line isn't the FAA's biggest problem (no surprise there!)--and therefore we are somewhere near the bottom of their agenda.

Dave
[/quote]
This is exactly why with the correct approach, this would never have been an issue. Not only is control line not their biggest problem: it was never their problem at all. The AMA tried to fight the FAA with a "one bomb war": not how you win a fight with any Gov agency. You have to pick small winable battles. The FAA is reacting to fears and concerns for manned aircraft safety and National security (as they should). It would have been easy initially to show them that control line was a unique and separate part of aircraft modeling  and a threat to neither and therefor not on their agenda at all.
   For those who fly R/C: I'm not throwing anyone under the bus, I'm just saying each category has it's own unique issues to be resolved with the FAA. Control line should never have been on their Radar (pun intended)
Regards,
       Don
       AMA # 3882

Offline Dave Hull

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Re: FAA Rules Applicability for CL
« Reply #18 on: June 05, 2019, 05:50:57 PM »
Don,

I completely understand your points. As I said, I made a run at this back in 2011. The letter below was my starting point. And, as noted, the progress has been minimal and that has come at a glacial pace.

Dave

_______________________

4/20/2011
Mr. Rich Hanson,

   Thank you for your liaison efforts on behalf of model aviation with the FAA regulatory process. I would like to know if current discussions have specifically included the differences in the types of model aviation, and their differing relevance to the national airspace and to national security?

1.   It appears that current FAA/TFR language specifically excludes indoor models from the standard restriction. This is certainly logical, but it also establishes a precedent of (a) review of a specific activity for reasonableness; and (b) tailoring of otherwise all-encompassing language.

2.   A logical extension that follows from (1) above is that control line models also have highly restricted flight capability, ie. they are constrained to less than an 80 foot radius hemisphere under AMA rules, and by custom, practice, and facilities. In fact, second only to indoor modeling, control line modeling would seem to have the least potential for both airspace conflicts and security concerns. Further, it is highly unlikely that any threat detection methods currently used would be cluttered by control line activities. (No false alarm issues.) From a ground enforcement standpoint, all an observer has to do is notice that the plane is connected to the pilot by wires and flying in a circle, to know that it is not either free flight or remotely piloted.

3.   As a further point of comparison, I didn’t note a no-fly restriction on kites within the TFR, an activity which would seem more similar to control line flying. But prior rulemaking by the FAA acknowledged that kite flying is more of a hazard to full size aviation than control line flying. This is borne out by the prior regulations restricting kites within a 2 mile radius of an airport to less than 500 feet of line and to a maximum weight of 5 lb.  Finally, there are very, very few control line planes weighing over 5 lb and probably none over 8-10 lb.

4.   It is not my purpose to create a wedge issue between modeling groups, but rather, to help educate the regulators about the differences in scope between the various modeling activities, and on that basis begin a progressive roll back of what seem to be excessively restrictive regulations.  In fact, I worry that if the AMA takes an overly cautious approach and groups all modeling activities together, that tailoring will not take place; that partial relief will not be granted; that all of modeling (except indoor) will be treated as if we fly with turbines with speed potential of over 200 mph, at gross weights over 10 lbs, with augmented stability systems, with telemetry and with onboard camera/guidance systems.

The above issues are of particular importance here in the Los Angeles area, since the two major flying sites (practically the only flying sites) lie within the restricted zones created whenever VIPs fly into Los Angeles International Airport. This seems to occur fairly frequently—and always unexpectedly. Worse, if we have a contest scheduled we can’t simply switch from one field to the other because they are both closed down by the same TFR.

I appreciate the AMA’s involvement in this process on behalf of the membership, and look forward to your response.

David Hull
AMA 48643
Valley Circle Burners member
Southern California Air Racers, AMA Club #4641
National Control Line Racing Association, Southwest District Representative




Offline Brett Buck

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Re: FAA Rules Applicability for CL
« Reply #19 on: June 08, 2019, 12:44:34 PM »
On this topic, our "club" (such as it is...) pursued a letter of agreement separately from the AMA process, and as of yesterday at about 11 AM, the relevant FAA personnel at the Napa ATC are completely satisfied that we are good to continue as is. They were very well informed, knew exactly what we were talking about, and granted permission to continue as we have been, no notification or additional authorization required. It is their opinion that CL is exempt from any notification requirements, at least in our case, since it does not use a "ground control station".

    The AMA has been strong-arming us on this "survey", to the point that the AMA AVP called me today on the topic. I am weighing our options on the AMA approach to letters of agreement, since I don't trust them to represent our interests. But a very interesting bit of information came out of that - that the AMA is seemingly pursuing a "master letter of agreement" with the FAA, apparently a blanket LOA for everyone. This is not too surprising  - and also the reason I am hesitant to throw in my lot with the AMA. This appears to be another one-size-fits-all solution by the AMA, effectively an end run to try to re-institute the effect of the Special Rule for Model Aircraft, without having to pass any legislation to that effect.

   A second very interesting insight is that now the AMA seems to have realized that drones are a threat, and that "Amazon and Google are trying to take our airspace away!". Last horse finally crosses the line!  Our AMA AVP stated to me that "the AMA has nothing to do with drones, they are our competitors for airspace".  That despite intermingling the two, arguing strongly that they should all be lumped together for the last 3+years in every single utterance, and even putting a f*cking drone on the 2019 sticker!   I think they are just now seeing the effect I predicted - they figured the AMA was an 800-lb gorilla. Unfortunately gorillas are on the endangered species list.   The drone manufacturers and large delivery companies are going to crush them like the small-town rubes they are.

We seem to have a perfectly satisfactory situation with regard to the Napa site as it, with the correct people working directly for the FAA fully informed and in approval of our operations. What I am concerned with the AMA approach is that they will try to come up with a blanket agreement that is geared to a generic RC site, with notification requirements, and a bunch of absurd restrictions that do not apply or cannot be complied with. In particular I don't want us in an FAA database as a generic club, to then be "inspected" for compliance with our airman's certificate and transponder function, when that (inevitably) becomes a requirement. I expect the AMA to mindless lump everything together, in fact, they said more-or-less that in an email to me last week, they DO NOT WANT TO MAKE DISTINCTIONS for FF or CL, all model airplanes are the same and should have the same legal requirements.

   Note the same thing from Dobbs above, when combined with these new revelations from our AVP, makes it clear that they are trying to shovel us into a generic solution.

    For CL-only site operators, I would advise extreme caution when dealing with the AMA and participating in their plan, because I think it is clear that they do not care at all about our special requirements

    Brett

p.s. I think I will probably attempt to query the AMA on several topics, not to get their stated position or stock answers, but to see if I can elicit any  unintended revelations or insights. I will report back if I find anything interesting.

Offline John Rist

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Re: FAA Rules Applicability for CL
« Reply #20 on: June 08, 2019, 02:13:19 PM »
Their is a lot of control line flying at the AMA flying sight.  IE. the up coming AMA NATS.   How does all this fit into this discussion?
John Rist
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Offline Dave Hull

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Re: FAA Rules Applicability for CL
« Reply #21 on: June 08, 2019, 02:53:27 PM »
John,

The AMA site should be no different than any other...except that maybe as a large site and near a smaller airport there would be a willingness to hold a discussion. And, perhaps they do not have any on-going antagonistic activities.

The philosophy at the AMA continues to be that control line does not have an RF link, and no "ground station" and therefore does not meet the definition of an "unmanned airborne system."  If we can't get that in writing soon, we should submit a request to the FAA for an Letter of Interpretation. That comes out of their legal department, I believe. I have mentioned this to several AMA representatives. (Tyler Dobbs, AVP Jim Mohan)

To Brett's point, his local FAA appear to have made this distinction and granted (verbal?) approval. We have one field like this for our club. Our main field, however has been shut down, with the FAA--including representatives from the sUAS directorate based in D.C.--apparently stating (or not overruling) the statement that control line planes are "unmanned aircraft."

People have said that the AMA site is within a 5 statute mile radius of Delaware County airport which would make it Class D airspace when the tower is in operation. I measure slightly greater than this at 5.75 mi. using on-line tools and the definition as the center of the airport geographical area. Someone should do this measurement more carefully, and possibly determine that all AMA control line circles are outside the 5 sm radius and therefore a non-problem.

However, if it is within the 5 sm, it means that they have a zero AGL to 2,500 ft flight restriction--unless they have ATC approval. That approval could come in the form of a written LOA, but it would not have to, at the discretion of ATC.

Without this, you could fly and simply hope that no enforcement actions will occur. It would be the pilot's risk, not the AMA. The FAA out here seemed much more interested in sanctioned AMA events than informal sport flying. I do not understand the reason for that, so take from it what you will.


Dave Hull
Valley Circle Burners, Los Angeles CA

Offline Frank Imbriaco

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Re: FAA Rules Applicability for CL
« Reply #22 on: June 08, 2019, 03:04:29 PM »
Perry:
FYI :
The FAA and CIA(combined)have shut down a controline stunt  meet here on the the East coast two years in a row (2017 and 18). The venue is an R/C field that is roughly 5 miles from Trump's summer get a way ( Bedminster, NJ ).
 Despite assurances that there would be no R/C activity, when the President is in town we are s.o.l.

Offline Brett Buck

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Re: FAA Rules Applicability for CL
« Reply #23 on: June 08, 2019, 04:29:19 PM »

The philosophy at the AMA continues to be that control line does not have an RF link, and no "ground station" and therefore does not meet the definition of an "unmanned airborne system."  If we can't get that in writing soon, we should submit a request to the FAA for an Letter of Interpretation. That comes out of their legal department, I believe. I have mentioned this to several AMA representatives. (Tyler Dobbs, AVP Jim Mohan)

   I have made the same point to the AMA (at the time, Budreau and Hanson) and as recently as last week. I keep getting mealy-mouth responses, they sort of say that yes, they should pursue it, but so far no action. I agree that this must be *written down* in some FAA document that we can reference. Budreau at one time implied a vague threat, a sort of "be careful what you wish for..." sort of threat, for me and others pushing the point.

   BTW, I think all those on the rule-making side agree that  the wording specifically says "ground control station" and they mean RC and FPV,  so I think the AMA and the FAA regulators would agree with our premise. However, that distinction is not universal with every FAA official, and until you can actually quite a paragraph to them specifically excluding it, it's catch and catch can as far as how it will be enforced.

    Brett

Offline Bob Heywood

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Re: FAA Rules Applicability for CL
« Reply #24 on: June 08, 2019, 06:15:35 PM »
John,

The AMA site should be no different than any other...except that maybe as a large site and near a smaller airport there would be a willingness to hold a discussion. And, perhaps they do not have any on-going antagonistic activities.

The philosophy at the AMA continues to be that control line does not have an RF link, and no "ground station" and therefore does not meet the definition of an "unmanned airborne system."  If we can't get that in writing soon, we should submit a request to the FAA for an Letter of Interpretation. That comes out of their legal department, I believe. I have mentioned this to several AMA representatives. (Tyler Dobbs, AVP Jim Mohan)

To Brett's point, his local FAA appear to have made this distinction and granted (verbal?) approval. We have one field like this for our club. Our main field, however has been shut down, with the FAA--including representatives from the sUAS directorate based in D.C.--apparently stating (or not overruling) the statement that control line planes are "unmanned aircraft."

People have said that the AMA site is within a 5 statute mile radius of Delaware County airport which would make it Class D airspace when the tower is in operation. I measure slightly greater than this at 5.75 mi. using on-line tools and the definition as the center of the airport geographical area. Someone should do this measurement more carefully, and possibly determine that all AMA control line circles are outside the 5 sm radius and therefore a non-problem.

However, if it is within the 5 sm, it means that they have a zero AGL to 2,500 ft flight restriction--unless they have ATC approval. That approval could come in the form of a written LOA, but it would not have to, at the discretion of ATC.

Without this, you could fly and simply hope that no enforcement actions will occur. It would be the pilot's risk, not the AMA. The FAA out here seemed much more interested in sanctioned AMA events than informal sport flying. I do not understand the reason for that, so take from it what you will.


Dave Hull
Valley Circle Burners, Los Angeles CA

According to the FAA airport finder web link provided by AMA, the AMA site is completely outside of the Class D airspace for Delaware County Regional airport. The airspace zone crosses north of E. Memorial Dr about 1 mile west of Hwy 35.

https://www.arcgis.com/apps/webappviewer/index.html?id=9c2e4406710048e19806ebf6a06754ad
"Clockwise Forever..."

Offline Dave Hull

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Re: FAA Rules Applicability for CL
« Reply #25 on: June 08, 2019, 06:25:22 PM »
Bob,

Thanks for looking that up. So now John has a definitive answer. We should all move to Muncie so that we can fly control line in uncontrolled airspace. At least between May and November, right?

Dave

Offline Bob Heywood

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Re: FAA Rules Applicability for CL
« Reply #26 on: June 08, 2019, 06:31:30 PM »
   I have made the same point to the AMA (at the time, Budreau and Hanson) and as recently as last week. I keep getting mealy-mouth responses, they sort of say that yes, they should pursue it, but so far no action. I agree that this must be *written down* in some FAA document that we can reference. Budreau at one time implied a vague threat, a sort of "be careful what you wish for..." sort of threat, for me and others pushing the point.

   BTW, I think all those on the rule-making side agree that  the wording specifically says "ground control station" and they mean RC and FPV,  so I think the AMA and the FAA regulators would agree with our premise. However, that distinction is not universal with every FAA official, and until you can actually quite a paragraph to them specifically excluding it, it's catch and catch can as far as how it will be enforced.

    Brett

It may be worth starting with the definitions stated in the law:

(8) UNMANNED AIRCRAFT.—The term ‘‘unmanned aircraft’’
means an aircraft that is operated without the possibility of
direct human intervention from within or on the aircraft.

(9) UNMANNED AIRCRAFT SYSTEM.—The term ‘‘unmanned
aircraft system’’ means an unmanned aircraft and associated
elements (including communication links and the components
that control the unmanned aircraft) that are required for the
pilot in command to operate safely and efficiently in the
national airspace system.

Applicability.
49 USC 40101


Clearly, our planes fly in the air and we stand on the ground.

Nothing is said that specifically relates to any given technology. It can be argued that C/L uses a mechanical communication link.

So, until there is an official statement to the contrary, I'm operating on the basis that a C/L aero model is a UAS as defined by Federal law.
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Online Dan McEntee

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Re: FAA Rules Applicability for CL
« Reply #27 on: June 08, 2019, 07:49:49 PM »
It may be worth starting with the definitions stated in the law:

(8) UNMANNED AIRCRAFT.—The term ‘‘unmanned aircraft’’
means an aircraft that is operated without the possibility of
direct human intervention from within or on the aircraft.

(9) UNMANNED AIRCRAFT SYSTEM.—The term ‘‘unmanned
aircraft system’’ means an unmanned aircraft and associated
elements (including communication links and the components
that control the unmanned aircraft) that are required for the
pilot in command to operate safely and efficiently in the
national airspace system.

Applicability.
49 USC 40101


Clearly, our planes fly in the air and we stand on the ground.

Nothing is said that specifically relates to any given technology. It can be argued that C/L uses a mechanical communication link.

So, until there is an official statement to the contrary, I'm operating on the basis that a C/L aero model is a UAS as defined by Federal law.

       Hi Bob;
   Well, the way I would interpret the law, C/L models are NOT UAS aircraft. The flight path is controlled by the bell crank, which is within the aircraft. The law does not say that the pilot has to be with in the aircraft. We are directly connected to the mechanism and manually and physically control the flight path, and by the pilot standing on the ground, we are not navigating the airspace. Like a lot of government regulations, lots of gray areas to explore, as typical.
    With eth weather this year and flooding, we are NOT getting much flying done here in St. Louis anyway. I just tried to sneak in a couple flights at a local mall lot that is closing, and as the tank was running out, a sudden rain squall sprung up out of no where. Came from the east of all places. Prevailing winds here are west to east! I got soaked. I just wonder why Mother Nature is so mad at us here!
    Type at you later,
    Dan McEntee
AMA 28784
EAA  1038824
AMA 480405 (American Motorcyclist Association)

Offline Brett Buck

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And yet more....
« Reply #28 on: June 10, 2019, 09:42:18 AM »
A predicted, the "AMA Survey" is not a survey at all, but the input information for what will apparently be a "form LOA" that the AMA plans on sending to the FAA directly. This is the latest, and my response:



On Jun 10, 2019, at 6:57 AM, Hannah Giese <hannahg@modelaircraft.org> wrote:

Hi Brett,

Thank you for reaching out to us. Since you are pursuing a letter of agreement with the NAPA ATC personnel directly, it is up to you if you would like to submit the online form to keep for records. When we receive these forms, we check the information within our system and then send the LOA  off to the FAA. From there, they will contact the ATC on the LOA. Feel free to reach out to the AMA government affairs team with any questions or concerns.

Thank you!

Hannah Giese | Government Affairs Representative
Academy of Model Aeronautics
5161 East Memorial Drive Muncie IN 47302
hannahg@modelaircraft.org
765.287.1256 x227


  Hannah - this is a rather alarming bit of information. As of Saturday morning, when I was contacted by my AVP by phone on this topic, this was a “survey” on the topic of flying sites so that options for approaching the LOA process might be discussed.   

   Now, we find that it is not actually a survey, but that the AMA wants to generate an LOA for us, without us having any input to it? The same AMA that has repeatedly told us that they did not want to “muddy the waters” by discussing CL models, or, at other times, claiming that CL models are not a UAS and are exempt? If we are exempt and not a UAS, then why does the AMA want to generate (what I expect to be) a form letter LOA or us?

   Nowhere in the previous discussions with the AMA did is say anything about automatically generating a LOA for us, sending it to the FAA for us, and then having the FAA and ATC agree to it. This appears that that the AMA is attempting to cut us out of the loop. What will the letter say? Are *we*, the site operators, party to this agreement, or was the plan to present it to us afterwards as a fait accompli?

 Lack of clear discussion and information on this “plan” has been characteristic of the AMA approach from the start.

 As I told then AMA government relations team last week, and our AMA AVP on Saturday morning, we are weighing our options on the topic of the survey. We have not decided what our path should be. Now you can see why we were so concerned about it.

To be honest with you, we predicted that this would be the AMA approach many months ago, and were concerned that the AMA would follow the plan you seem to be referring to. That’s why we are reticent to fill out the so-called “survey", without knowing the details, and what would be done “on our behalf”.

With this new and disturbing revelation on AMA LOAs, I would like to see a fully delineated and clearly stated plan on what the AMA is doing with regard to this, including:

What will the LOA say?

What does the LOA say about CL models specifically? Will the LOA be specifically geared to CL?

What does the AMA consider different between “not a UAS” CL/FF models, “are a UAS” RC models, and “are a UAS” FPV models?

How do these differences jibe with previous statements from the AMA? I note that apparently the AMA position on drones has radically shifted, our previous position was that “drones are our future” and the AMA went to the point of putting a quadcopter on the 2019 AMA sticker. As of Saturday morning, apparently, now “drones are trying to steal our rights” and Amazon and Google are our mortal enemies. I have seen no AMA statements to this fact, before I was told this by our AMA AVP Saturday morning on the phone. This appears to be an abrupt about face - and now, far too late to have any useful effect on regulation.

  I would also note that we have a very nearby (same public park about 100 yards away) RC field. We and our club have nothing to do with that site, our site is a single CL circle in John F. Kennedy park. I presume that the AMA has also been in contact with those site operators separately, but please confirm that. They probably *do* need a separate LOA and the AMA “form letter” LOA may well suffice.


    Brett

Offline Larry Renger

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Re: FAA Rules Applicability for CL
« Reply #29 on: June 10, 2019, 01:47:13 PM »
What about GSSC which is ON an airport?
Think S.M.A.L.L. y'all and, it's all good, CL, FF and RC!

DesignMan

BTW, Dracula Sucks!

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Offline Dave Hull

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Re: FAA Rules Applicability for CL
« Reply #30 on: June 10, 2019, 03:45:18 PM »
Larry,

Same airspace rules would apply regardless of airport property boundaries. I'd sure like to hear about any arrangements that GSSC may have.

Dave

Offline Brett Buck

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Re: FAA Rules Applicability for CL
« Reply #31 on: June 10, 2019, 05:21:51 PM »
Larry,

Same airspace rules would apply regardless of airport property boundaries. I'd sure like to hear about any arrangements that GSSC may have.

Dave

    At this time, the only requirement is to have an agreement with the relevant ATC, which they presumably have.

What I have discovered in the responses from the AMA as recently as a few hours ago is that:

They had pursued a 'blanket" LOA that effectively recreates the Special Rule for Model Aircraft, but this effort was rejected by the FAA. Of course they didn't tell any of us about that, but that would have been a fairly positive development, compared to what they are actually doing instead.

They now have a different agreement with the FAA, to send all the responding site operator's current information to the FAA, the FAA will create a LOA and pass the information along to the relevant ATC. That's what the really want in the survey questions - it's not really a survey, it's filling in information to feed to the FAA.  Of course, what will almost certainly happen is that the FAA will create a form letter with whatever restrictions they choose, have no distinction as to what you are actually doing or what type of models you are flying, and then impose that as directive on the local ATC, you sign or you are out of business. You will note that it doesn't ask what type of models will be flown, I think that is no accident, because they are not planning on considering that.   There was also another implied threat, basically, if you don't go along now, you may be at the end of the line when it comes to getting your privileges granted. Effectively they are using the FAA to strong-arm us into signing the AMA's agreement, which is why they haven't told anyone that was what they were attempting to do.

   They also told me two fundamentally contradictory statements about LOAs in the space of 4 hours, and 4 unique and distinct interpretations, but this is hardly a new experience.

     Brett

Online Mike Griffin

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Re: FAA Rules Applicability for CL
« Reply #32 on: June 10, 2019, 09:23:48 PM »
I never dreamed that flying a CL model plane would ever get this complicated. 

Mike
It's too bad that stupid doesn't hurt

Offline Paul Walker

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Re: FAA Rules Applicability for CL
« Reply #33 on: June 11, 2019, 01:00:11 PM »
Glad I don't live under class D airspace!

Nobody has bothered me under the uncontrolled airport I have my flying field under.

Online Fredvon4

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Re: FAA Rules Applicability for CL
« Reply #34 on: June 11, 2019, 02:26:02 PM »
I have been a Amatuer Radio operator for some decades now and full well understand how NON ELECTED (FCC) bureaucrats operate in our government

So  in 2010 and 2011 there were quite a few very severe DRONE vs Emergency services incidents* my ears perked up and I bet myself the DOT / FAA was going to get a call from Congress to "DO SOMETHING"....just like school shootings...the knee jerk was going to be ineffective and absolutely pure pandering

True to my insider experience the US Congress DEMANDED the DOT FAA "do something" and they did
Same time US Congress made a carve out for Hobby Airplane use....

I have read every word written on this subject since November 2011

When the DOT/FAA made their final New Rule Making I was actually impressed at the lengths they went to argue against honoring the Congressional carve out...their citations of LAW and Mandates make sense....from a what we are chartered to do POV.....They are chartered to Protect the National Air Space and wee given BROAD powers to do so......The congressional carve out for Recreational Hobby focused Aero Flight contradicts the DOT/FAA Charter

Lawyers are pretty well educated and savvy to write fairly concisely

* most notably a severe fire in southern California where NEWS Drones were invading the event airspace that required the Local air control to suspend all AERO flight operations in the area for over 48 hours....causing loss of property and life..... fact is you want to check

This was NOT the first incident but it did gain Press and Thus Congress attention....History and facts...the 112Th congress TOLD DOT/FAA "FIX THIS NOW!!!!!!!!"

DOT/FAA as a non elected entity may NOT make ruling withOUT public input... I was there and in 2012 WE Control Line respondents were less than 1/3rd for the total 4700 respondents.... MOST were lawyers for entities like AMAZON and TARGET who have a BIG DOG in this HUNT

and quite frankly as a slogged through the 4700 comments trying desperately to see a good Brett Buck ( his is exceptional BTW) well written and thoughtful comment.... well I was disappointed

and my disappointment was NOT displaced...we failed to make OUR case..... so here we are 7 years later and scratching our asses wondering what the hell.....

My observation is 50 years of dumbing down the populace has worked
No one ( ok very few) has/have the ability to communicate effectively
We continue to elect ineffective and corrupt leaders (congress and AMA)

One would think that some $25,000~$250,000 AMA bucks could create a all expenses paid holiday for 50 congress members to be wined and dined at Muncie and SEE what we do, how we do it  and the fun and recreation, as well as the revenues experienced....

I am absolutely astounded that NOWHERE in our cadre do we have a insider that could make this happen

Wayne La Pierre and the AMA president can both go suck eggs for all I care they are both too corrupt to look out properly for their members....

"A good scare teaches more than good advice"

Fred von Gortler IV

Offline Ty Marcucci

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Re: FAA Rules Applicability for CL
« Reply #35 on: June 11, 2019, 05:35:42 PM »
The sad part is they don't seem to understand we do NOT use National Airspace nor controlled airspace, ever. Where my club flys there are light standards, a stadium and hundreds of tall pines that are ALL higher than we fly, ie 80 feet. We are in the middle of the city, and FAA regs state that an aircraft cannot go lower than 2,500 feet over occupied areas, without special clearance. Even
then they are not going into  our area.  Has anyone taken some high "muckey muck" by the  hand to a flying session and shown them just what we do.  As stated, a quick trip to the CL part of the NATS might open some eyes.  Actually knowing the low intelligence running loose in DC, we might all end up in a gulag. ???
Ty Marcucci

Offline Brett Buck

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Re: FAA Rules Applicability for CL
« Reply #36 on: June 12, 2019, 10:39:21 AM »
I have been a Amatuer Radio operator for some decades now and full well understand how NON ELECTED (FCC) bureaucrats operate in our government

So  in 2010 and 2011 there were quite a few very severe DRONE vs Emergency services incidents* my ears perked up and I bet myself the DOT / FAA was going to get a call from Congress to "DO SOMETHING"....just like school shootings...the knee jerk was going to be ineffective and absolutely pure pandering

True to my insider experience the US Congress DEMANDED the DOT FAA "do something" and they did
Same time US Congress made a carve out for Hobby Airplane use....

I have read every word written on this subject since November 2011

When the DOT/FAA made their final New Rule Making I was actually impressed at the lengths they went to argue against honoring the Congressional carve out...their citations of LAW and Mandates make sense....from a what we are chartered to do POV.....They are chartered to Protect the National Air Space and wee given BROAD powers to do so......The congressional carve out for Recreational Hobby focused Aero Flight contradicts the DOT/FAA Charter

Lawyers are pretty well educated and savvy to write fairly concisely

* most notably a severe fire in southern California where NEWS Drones were invading the event airspace that required the Local air control to suspend all AERO flight operations in the area for over 48 hours....causing loss of property and life..... fact is you want to check

This was NOT the first incident but it did gain Press and Thus Congress attention....History and facts...the 112Th congress TOLD DOT/FAA "FIX THIS NOW!!!!!!!!"

DOT/FAA as a non elected entity may NOT make ruling withOUT public input... I was there and in 2012 WE Control Line respondents were less than 1/3rd for the total 4700 respondents.... MOST were lawyers for entities like AMAZON and TARGET who have a BIG DOG in this HUNT

and quite frankly as a slogged through the 4700 comments trying desperately to see a good Brett Buck ( his is exceptional BTW) well written and thoughtful comment.... well I was disappointed

and my disappointment was NOT displaced...we failed to make OUR case..... so here we are 7 years later and scratching our asses wondering what the hell.....

    I did comment on that, but, that effort was a dead end. Drones were ALWAYS going to be regulated, that was an immutable truth, because of exactly the sort of incidents you note.

    The real problem actually started with RC FPV, those predated the widespread appearance of quadcopter drones. I think this was a little later than the time frame you mention, but the public *hates* drone misuse, and within months of drones becoming a "thing", there were national commercials where people were being threatened by swarms of delivery drones.

     This is a problem for us because of how the AMA has dealt with the situation. They figured the Special Rule for Model Aircraft would protect them, and therefore, they could chase the drone crowd - more specifically, the drone advertiser crowd. They, being the only established CBO, could offer protection under the Special Rule, everyone does whatever they feel like as long as they stick their AMA number on it. This was an utterly delusional notion, but they stuck to it like glue, to the point of sticking a quadcopter on our 2019 official AMA sticker.

    This all started to fall apart and the plan became obviously unworkable in about 2015  - to anyone but the AMA Government Relations Team, (Hanson and Budreau) - and they started emitting desperate pleas for assistance ("write your congressman!") to try to save their vision. Most of this was laughable and completely unsupportable. I was (as stated here) unwilling to participate in the level of falsehood they requested. Since then, everything has proceeded along entirely predictable lines.

 The AMA has used their supposed "influence" to sidle up to the FAA. As of yesterday afternoon, I intepret their comments on the topic of flying site LOAs as them having teamed up with the FAA to ensure that only AMA-affiliated actions will be considered, no matter if the relevant ATC and the site operators are perfectly compliant and agreeable. They are cancelling, for instance, the existing agreements - in our case, with the Napa  Regional Airport FAA reps, which took about 10 minutes to achieve - with their own registration plan, in which the FAA in Washington will direct the ATCs to follow a form letter that the FAA/Washington and the AMA has already negotiated "on our behalf". Doesn't matter what you are doing, that everyone understood perfectly well that there was no issue.

  Note also that in this latest, there is a strong-arm tactic. The "survey" they want you to fill out is not a survey. It's an application for a LOA, despite the fact that it is referred to repeatedly as a "survey" or "questionnaire". They are taking the information from the "survey", forwarding it to the FAA, the FAA will generate the LOA, send it to the local ATC, you get *nothing* aside from what the AMA and FAA have negotiated - note the past tense. It took quite a while for me to gain this admission, they said 4 different misleading or contradictory things about it before they actually told the truth. Of course you don't have to do it, the general public can do the same process. But the AMA had worked it so that they are first in line, so an individual sites *might be shut down for many months or years* awaiting all the AMA agreements to be made.

     You might be tempted to say, as they did, that this is an example of the AMA working on your behalf. OK, CL-only site operators, fill out the survey. Where is the check box for putting "CL-Only, no UAS operation permitted"? Oh, there isn't one? Even though all concerned recognize that CL is "not a UAS" because, by law, it does not use a "ground control station"? And is therefore, by all agreement and black-letter law, *is not subject to FAA regulation*?

   What do you suppose the pre-negotiated, already extant, secret AMA/FAA LOA is going to say about CL?  Jack-sh*t, that's what.

  One belated note- I think they have finally grasped the stupidity of their baseline plan, and now I have statements from the AMA that "drones/Amazon is trying to steal your right to fly!!!!!!" Nitwits, that ship sailed as soon as "drones were our future", 5 years ago.

     Brett

Online Fredvon4

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Re: FAA Rules Applicability for CL
« Reply #37 on: June 12, 2019, 12:06:56 PM »
Please excuse my inarticulate writing.... on my second stroke and using a pencil to hunt n peck the keys

This situation is very serious for some reasons I doubt many of our cadre can understand

Un Elected entities ---DOING CONGRESSIONAL constitutional responsibilities----- are bad mojo IMO.....

I can argue easily AGAINST HUD/Homeland Defense/ FCC/ DOT-FAA/  and a lot of other "we are afraid of the consequences" Bureaucratic entities

Yes Virginia--- I do understand how a National FCC is necessary......as a elected congressional committee...not a un elected bunch of bureaucrats with too broad a power base and NO congressman willing to properly limit and oversee their activity........

If you are spun up about Control Line vs the government .....You might be totally frustrated to be a firm (AS WRITTEN) 2nd Amendment or 1st amendment believer..(constitutional ....is sez "shall NOT be infringed") black n white with a f......ing period...IN FACT THE WAY THEY WROTE IT...ZERO AMBIGUITY......ok ---I know a few of you zealots here think that I, at 63 and retired Army, should NOT OWN an AR-15 (so called assault rifle).... well screw you cupcake.... I think you need to turn in all IC engines as they are polluters

As a AERO hobby recreational citizen...we are ALL NOW subject to Felony Convictions because the AMA lies to us about Control Line being exempt....

CATEGORICALLY C/L IS NOT F.....ing EXEMPT ----and we all are ONE Zelous Police person away from losing all voting and gun ownership rights

This is not hyperbole...tis a fact....you live in a recreational or medical state for Pot and you do use it---- you are now a Federal Felon and IF/when prosecuted you will no longer be able to legally vote or OWN/USE any firearm...Period ......and in the USA you can not petition any court to get YOUR RIGHTS BACK...

This same insane condition exists if you fly airplanes in the national airspace withOUT authorization and compliance with the DOT/FAA rules....that currently DO NOT EXEMPT any thing over a certain size and weight

BTW...a few facts....
Written and codified law trumps whatever the hell some GS-7 servant opines....THIS means the phone conversation or e-mail means nothing.....it is an opinion with zero binding impact on the organization who employs the person
That servent is non elected and YOU can not sue him for false information
There is a lot of case law and precedent that the government uses to convict it's citizens....tried every year
SO....If you don't fully understand my rambling.....
Stop smoking dope
Do not use Amateur radio equipment to jam or harass legitimate FCC licenses or sations... the loss of Bucks, equipment, and jail time ...and then now loss full citizenship rights is pretty severe
Get a DOT/FAA LICENSE for you or your aircraft
If near any restricted airspace...get a MOA LOA and comply with any NOTAM


"A good scare teaches more than good advice"

Fred von Gortler IV

Offline Bob Heywood

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Re: FAA Rules Applicability for CL
« Reply #38 on: June 12, 2019, 12:57:00 PM »
Unfortunately Fred, when two (or more) black & white things crash into each other you end up with a gray mess. Such is life.
"Clockwise Forever..."

Offline Brett Buck

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Re: FAA Rules Applicability for CL
« Reply #39 on: June 12, 2019, 03:06:28 PM »

CATEGORICALLY C/L IS NOT F.....ing EXEMPT ----and we all are ONE Zelous Police person away from losing all voting and gun ownership rights

This is not hyperbole...tis a fact..


  Not quite. In fact (and the actual wording has been published here) is that what is subject to regulation are "unmanned aerial systems". This is defined as a system for navigating in the air, that uses a ground control station. We do not have a ground control station, therefore are not an ummanned aerial system, and not subject to regulation. RC (traditional and FPV) *do* use a ground control station, and *are* subject to regulation. FF - not a UAS.

   This is clear and agreed to by all at the rulemaking level. Where this falls away is in the guidance given to everyone regarding the law, which has been unclear, misleading, ambiguous, despite universal agreement at the regulatory level. Nowhere is a "ground control station" defined clearly for the layman, maybe your control handle is a "ground control system" or not, depending on who you talk to. This is the danger area, depending on who cares about it at any moment, you can get in some sort of trouble. It's probably defensible based on the wording of the regulation, but that won't keep you out of court.

   This is, largely, the AMA's doing, they made no real attempt to clarify this at any level, because they did not want to "muddy the waters" as Budreau put it to me and others, by attempting to draw distinctions between categories of modeling, or worse, modeling and the hordes of drone idiots. This was a conscious decision on their part, despite almost everyone else predicting exactly how it was all going to work right down the line. to be honest I am not even sure they don't want someone to get in trouble, so that they can attempt to generate a precedent

   Brett

Offline Gary Dowler

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Re: FAA Rules Applicability for CL
« Reply #40 on: June 12, 2019, 05:38:14 PM »
Brett said      " to be honest I am not even sure they don't want someone to get in trouble, so that they can attempt to generate a precedent "

This is a legitimate concern!

Gary
Profanity is the crutch of the illiterate mind

Offline Brett Buck

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Re: FAA Rules Applicability for CL
« Reply #41 on: June 12, 2019, 09:35:16 PM »
I would note that this (admittedly trivial) case is how totalitarianism works, on a day to day basis, even with democratic voting. Nearly everything is made illegal, to the point that a regular citizen cannot go through life without committing crimes, or violations of some sort, probably multiple violations. Then, anyone in a position of authority is then able to effectively control behavior on a whim, by deciding which violations they will pursue, and which they will not. Doesn't matter what you do, if someone wants to make your life miserable or control you, they can decide to charge you with any one or more of your multiple violations, entirely at their own initiative. You see variants on this at all levels, with the inevitable little Hitlers.

   Oh, wait, you didn't know that stepping in the endangered red-bellied ant was a violation? Well, can't let ignorance of the law be an excuse. Besides, it's in codicil GG of the EPA Regulatory statutes, paragraph 110, subparagraph Q and P, plain as day, black and white.

  In this situation, the AMA is also behaving this way. They don't care if the issue gets f*cked up, as long as they are the ones doing the f*cking. And they are more than willing to take actions that make it impossible to act without following their rules. In this case, they have negotiated - in secret - with the FAA "on your behalf", and if you don't go along with their questionnaire, er, survey, er, data-gathering activity, er, rigid LOA agreement plan, they have made it impossible for you to pursue it yourself.

   Or rather, not impossible, but (to quote) "The FAA has agreed to work on this process with AMA before moving on to the thousands of other fixed sites submitted by JROTC, parks, other possible CBOs, and schools around the country.  If AMA clubs have not submitted their information by June 16, they will possibly be but at the back of the processing line.   . So, the message is, do it like they have already negotiated,  or you might be left out in the cold.

   Nice site you have there, it would be a shame if something happened to it...

    Brett

Online Fredvon4

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Re: FAA Rules Applicability for CL
« Reply #42 on: June 13, 2019, 11:50:39 AM »
I wrote back in 2012 that I only fly Control Line models----in/on our county sports complex....

I, and only I, are the total of all model airplane kids in this county.....There might be a dozen local citizens yearly that buy RC and seek a venue to learn and fly....That is done 2 or 3 counties to the east at the only local RC Club

My Sheriff's office and Town Police Departments received pamphlets from DOT/FAA on the new rules way back around 2012.....

OH what the hell....from the posts, I get the impression no one (OK very few)  takes me seriously about YOUR/OUR constitutional rights and how fragile they are based on NON ELECTED RULE MAKERS.......Schumer, Pelosi, and Sanders should scare the hell out of all of us....IMO....AOC is an anomaly that will die....I hope
"A good scare teaches more than good advice"

Fred von Gortler IV

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Re: FAA Rules Applicability for CL
« Reply #43 on: June 14, 2019, 06:05:08 AM »
Nothing has really changed since this license stuff started.  Appears to me the AMA wants to be an unofficial private sector "arm" of the FAA so everyone flying any model will have to be an AMA member.  That's my take from their "community" organization wording. Any category outside of that realm (CL) isn't going to get their support. 
Bill P.

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Re: FAA Rules Applicability for CL
« Reply #44 on: June 14, 2019, 04:11:35 PM »
On a practical level, on or after June 16 what will happen at the fields?  If no LOA, will someone from the airport or control towers shut down the field?  If I show up to fly and it is not posted, am I breaking the law?  I am flying at an airport with a prior agreement and so far, nothing has been said.
Fred
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Offline 944_Jim

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Re: FAA Rules Applicability for CL
« Reply #45 on: June 14, 2019, 06:48:53 PM »
What is a community-based organization please?

One hundred percent of the control line fliers in my community fly at a local church lot. It is somewhat isolated, and the loosely organized fliers all live in the same community, and share the same ideas concerning flying safety and respect for our hosts/community.
Does this make us community-based?

Offline Dave Hull

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Re: FAA Rules Applicability for CL
« Reply #46 on: June 15, 2019, 12:52:36 AM »
Fredwood,

It looks like the data is being continuously dumped from the AMA database into the FAA database. You can get on the FAA site and go into the drone rules area (trust me) and find an embedded link that will get you to both an Excel file listing the sites, and a map of the USA with gridded airspace. Locations with a blue dot are supposed to be cleared to fly.

For example, for the "fixed" flying site (ie. what we think of as traditional model flying parks) at Whittier Narrows has been uploaded and marked with the club names and a blue dot. Presumably the altitude restriction in the grid is the requirement, else, these would probably be hung up waiting for detailed work on a LOA. For those control line circles, they have a 200 ft ceiling, so there would not appear to be any restriction. Note that some grids have a 50 ft restriction. The grids are tapered in altitude based on distance from the runway and channeled such that normal arrival and departure paths have more restrictive model ceilings.

Be sure you check this map if your field is in Class D airspace. There are errors in it! The R/C club at Whittier must have given the street address and not the field coordinates. This put them into an adjacent grid and knocked 50 feet off their ceiling. Control line got 200 ft and R/C got 150 ft.  Oops!

I keep telling folks that if the Gulfstreams departing overtop our location at Sepulveda Basin were to fly thru our circle at, say 80 feet, they’ve got a much bigger problem than worrying about whether we have a mid-air.

Porsche Jim,

You can read what the FAA thinks is a CBO in the same area of the FAA website. They specifically leave room for more that just the AMA. They ain’t got a lock on that designation. If you wanted to be a CBO, you probably could be if you got organized and submitted yourselves as such. It would likely be a pain.

Dave Hull
Valley Circle Burners (grounded)
San Fernando Valley, CA

https://www.faa.gov/uas/recreational_fliers/

http://udds-faa.opendata.arcgis.com/


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