Detailed analysis of FAA's NPRM on sUAS

Discussion in 'Announcements' started by Andy Johnson-Laird, Mar 2, 2015.

  1. Andy Johnson-Laird

    Andy Johnson-Laird Administrator
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    If you are interested, my detailed analysis in the form of my 100+ page comments on the NPRM are now on-line at http://www.regulations.gov/#!documentDetail;D=FAA-2015-0150-0182

    In fairness, my comments are only about 60 pages, the rest is inclusion of text from the NPRM.

    I would urge everyone with a vested interest to post comments regardless of whether you agree with me. The FAA is obligated to review the comments and we, as a group, can have an effect on the final rules.

    To make a comment, go to http://www.regulations.gov/#!docketDetail;D=FAA-2015-0150 and click on "Comment Now" to the right of the "Operation and Certification of Small Unmanned Aircraft Systems" (the first document you'll see listed).

    There are guidelines on making comments at http://www.regulations.gov/docs/Tips_For_Submitting_Effective_Comments.pdf

    When you click on Comment Now you can you can either type your comments into a window, or prepare them offline and copy and paste them into a window (limit of 5,000 characters), or, for longer comments, post them as an attachment as, say, a PDF file.

    You can either submit comments anonymously or with your contact information.

    Thanks
    Andy
     
  2. Jeff Scholl

    Jeff Scholl Distributor

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    "268. From my own personal experience, I can assert that the FAAs description is bogus."

    Now that's funny...

    Jeff
     
  3. Andy Johnson-Laird

    Andy Johnson-Laird Administrator
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    Bonus points for Mr. Scholl for even getting to paragraph 268 on page 78. :)

    Anyone else think the FAA's right to describe landing a Cinestar like this: "in the two-joystick control station example provided above, the operator could land a small unmanned rotorcraft simply by pressing the altitude joystick down until the rotorcraft descends to the ground."

    Note: "small" means < 55 lbs..

    KEERRRRRUNCH....oh yeah, that must be how we land....sorry about your Red Epic and the MōVI.... :rolleyes:

    Andy.
     
  4. Paul conto

    Paul conto Member

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    Andy, I'm only about a quarter of the way through your write up, reding it as I ride the metro around town, but I got to where your saying companies need to start publishing so sort of maintenance Manual. Well DJI has "started" with the inspire, they have a very basic one they call a maintenance manual but it's more of a pre-flight checklist. Not really a manual but at least it's a start.
     
  5. Andy Johnson-Laird

    Andy Johnson-Laird Administrator
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    Good to know, Paul. Thanks for the information.
    It's just that the NPRM is clearly proposing that sUAS "operators" have to maintain the aircraft -- which is tough to do armed only with a checklist.

    Obviously if you've constructed the aircraft from a kit (e.g. a Cinestar), then you have a lot of the necessary knowhow to maintain it, but with the Inspire 1 I would imagine it's going to be a bit harder. With manned aircraft there is at least a pilot's operating handbook (POH), and there are Airframe and Power Plant (A&P) mechanics who can maintain the aircraft using aircraft manufacturers' maintenance manuals.

    My comments were triggered by the fact that the FAA's NPRM was assuming facts about what sUAS vendors were currently doing -- but I had a sneaking suspicion they were viewing the copter world through manned-aviation glasses!

    Let me know if you have further questions or comments -- and be sure to make your own comments too!

    Thanks
    Andy.
     

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