My Reccomendation to the FAA

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My Reccomendation to the FAA

Post  Admin on Mon Jan 31, 2011 8:34 pm

A copy of what I believe to be reasonable regulation of recreational sUAS systems

Comprehensive Set of Recommendations
for recreational sUAS Regulatory Development

Recommended Changes to
Subpart A. sections 2. and 3.

Subpart A. Recreational SUAS

Eliminate section 2 in its entirety as there is no CBO that has any guidelines that are backed with any scientific, statistical or legal documentation, investigation or rationale. Further there is no CBO that has any oversight to provide compliance nor to prevent corruption or favoritism. As an example, the AMA is little more than an insurance middleman and publisher that has a poor safety history for its members as their own insurance documents will attest with an average of 60 incidents per year averaging $30,000 in damages per incident. The AMA has no documentation to demonstrate any research involved in their rule making. Rather it appears that many of the AMA’s rules are created at the whim of influential members to receive special privileges (IE: the recent rule allowing massive metal blades). All this section would do is grant special privileges to a small minority of recreational SUAS operators and/or be used as tool to increase the profits of the AMA by forcing millions of safe non-members to join the AMA to continue to use their vehicles safely.

3. Recreational SUAS

3.1 Applicability
The following general requirements and limitations apply to RECREATIONAL SUAS, which are operated by hobbyists for the sole purpose of sport, recreation, and/or competition.

3.2 General Requirements
(1) RECREATIONAL SUAS shall be flown in open spaces and in a manner that does not endanger the life and property of others.
(2) RECREATIONAL SUAS shall yield the right of way to all manned aircraft.
(3) RECREATIONAL SUAS shall not interfere with operations and traffic patterns at airports, heliports, and seaplane bases.
(4) RECREATIONAL SUAS shall not be operated at locations where RECREATIONAL SUAS activities are prohibited.
(5) RECREATIONAL SUAS are limited to unaided visual line-of-sight operations. The RECREATIONAL SUAS pilot must be able to see the aircraft throughout the entire flight well enough to maintain control, know its location, and watch the airspace it is operating in for other air traffic. Unaided visual line-of-sight does not preclude the use of prescribed corrective lenses.
(6) RECREATIONAL SUAS shall be designed, equipped, maintained and/or operated in a manner in which the aircraft remains within the intended area of flight during all operations.
(7) RECREATIONAL SUAS pilots may not intentionally drop any object from a RECREATIONAL SUAS that creates a hazard to persons or property.
(8 ) RECREATIONAL SUAS shall be operated in a manner that respects property rights and avoids the direct overflight of individuals, vessels, vehicles, or structures.
(9) RECREATIONAL SUAS shall not be operated in a careless or reckless manner.
(10) RECREATIONAL SUAS pilots shall not operate their aircraft while under the influence of alcohol or while using any drug that affects the person’s faculties in any way contrary to safety.
(11) DELETE – there is no evidence that metal propellers are a safety hazard.
(12) RECREATIONAL SUAS shall not use gaseous boosts.
(13) RECREATIONAL SUAS shall not use fuels containing tetranitronmethane or hydrazine.
(14) RECREATIONAL SUAS shall not use turbine-powered engines that have not been approved by the FAA as a propulsion source.

3.3 General Limitations
(1) RECREATIONAL SUAS shall not exceed 55 pounds (lbs).
(2) RECREATIONAL SUAS shall remain clear of clouds.
(3) RECREATIONAL SUAS will not operate in Class B airspace without the written permission of the ATC authority.
(4) RECREATIONAL SUAS shall not be operated within 3 NM miles of an airport, heliport, or seaplane base without the written permission of the ATC authority.
(5) RECREATIONAL SUAS shall operate in close proximity to the ground, at or below 400 feet above ground level (AGL), and shall at all times remain below and well clear of all manned aircraft. Except in class G airspace and other FAA designated areas where operations will be limited to 1200 feet above ground level (ADL).
(6) Notwithstanding the above limitations, RECREATIONAL SUAS weighing less than or equal to two lbs incapable of reaching speeds greater than 60 miles per hour (mph) (52 knots), and powered by electric motor or mechanical stored energy (e.g., rubber-band powered) may operate within 3 NM of a military or public-use airport or heliport; if they remain a safe distance from the airport or heliport, remain well clear of all manned aircraft, and remain below 400. AGL.
(7) RECREATIONAL SUAS will not be flown at an airspeed that would cause the aircraft to inadvertently leave the prescribed maneuvering area.
(8 ) RECREATIONAL SUAS cannot launch pyrotechnic devices which explode or burn

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