Highlights of the FPVFC’s Public Comments to the FAA

Responses to, “Safe and Secure Operations of Small UAS”

Stand-off distances.  The FAA asked for comments on an appropriate, required stand-off distance to fly Small UAS.  The FPVFC response was for Category 1, no stand-off distance should be required and for Categories 2 and 3, no stand-off distance should be required.  Instead, the kinetic energy limitations of 11 ft-lbs and 25 ft-lbs for Category 2 and 3 should provide sufficient safe operations.

Altitude, Airspeed and other Performance Limitations.  The FAA requested comments about establishing additional performance limitations.  The FPVFC responded the FAA should eliminate the maximum allowable speed of 87 knots for Category 2 and 3 SUAS under Part 107 as the kinetic energy limitations provide sufficient regulation.  For Category 1 SUAS, a speed limit of 87 knots is reasonable. In addition, FPVC requested no speed limit for recreational SUAS as the repeal of section 336, creates a gap of speed limits in SUAS regulations.

Unmanned Traffic Management (UTM) Operations.  The FAA requested public comments for SUAS Unmanned Traffic Management (UTM).  FPVFC recommended that any SUAS flying at a designated flying field should be excluded from UTM.  The FPVC recommends for recreational UAS and Category 1 SUAS operating under Part 107, LAANC should be used and no UTM should be required.  The FPVFC recommends Category 2 and 3 SUAS operate under a UTM.

Payload Restrictions.  The FAA requested public comment about rules on SUAS payloads.  The FPVFC responded that Hobbyists, Category 1, 2 and 3 UAS should all be able to carry a video camera without restrictions.  

Small UAS critical system design requirements.  The FAA requested public comment on any technology requirements for commercial SUAS operations beyond visual line of sight.  The FPVFC responded that BVLOS of a Hobbyist SUAS and Category 1 SUAS should require GPS with coordinates transmitted to the remote pilot and no redundancy of equipment should be required.  For Category 2 and 3, FPVFC recommends a Return to Home capability as a requirement.


Responses to, “SUAS Operations over People”

In the proposed rules, the FAA states anyone building or modifying a Small UAS is by definition a manufacturer.  There will be numerous requirements for a Small UAS manufacturer including gaining approval by the FAA to fly the SUAS as well as logs of changes, etc.  much like the requirements for manned aircraft. FPVFC requested the FAA waive the definition of manufacturer for SUAS which are intended for recreational use.

In a similar topic, the proposed rule states adding a camera to an existing SUAS renders the SUAS non-compliant with safety regulations and therefore not eligible to fly over people or at night.  The FPVFC requests the FAA waive this requirement for SUAS intended for recreational use.

The FAA proposes three Category of commercial SUAS:

Category 1

  • < 0.55 lbs AUW including cargo.

  • Props may be exposed.

  • May operate over people and at night with 107 certificate

Category 2

  • > 0.55 lbs

  • Limit of 11 ft-lbs of kinetic energy ref Section IV.B.4

  • No exposed props (no exposed rotating parts)

  • Manufacturer FAA certification required

  • May operate over people and at night with 107 certificate

Category 3

  • Limit of 25 ft-lbs of kinetic energy

  • No exposed props (no exposed rotating parts)

  • May not operate over people if the craft has a FAA-identified safety defect

  • Manufacturer FAA certification required

  • No operations over people.  If transiting through an area with people, no hovering

These categories are important to the FPV community if the FAA eventually determines all SUAS should fall into one of these categories.

The FPVFC’s response to this section was to copy text developed by, “Inside Unmanned Systems” where the authors dug into University research performed for the FAA where the FAA used a highly conservative interpretation of energy thresholds for category 2 and 3.  The statement copied and submitted to the FAA follows:

“The kinetic energy transfer figures in § 107.115 Category 2 operations (b) (1) (i) and § 107.120 Category 3 operations (b) (1) (i) are extremely conservative and will cripple the commercial UAS industry if adopted. The FAA should wait for the public release of the Task A14 Ground Collision Severity Study to allow the public and manufacturers to review the findings and make a public comment on the draft NPRM before proceeding. Valuable data will be available shortly that could guide the FAA and the public in addressing meaningful comments to the draft NPRM.

The FAA should remove § 107.105 Prohibition on operations over moving vehicles. No small UAS qualified for operations over people in category one, two and three would cause injury from collisions to occupants in moving vehicles. The FAA should not consider ground vehicle driver reaction to a small UAS collision. Collision with flying objects is a well-known driving hazard that all licenced drivers should be trained to encounter. Failure to remove § 107.105 will make the commercial UAS industry non-viable in this country. It is difficult to envision commercial UAS tasks that do not involve flying over moving vehicles in some manner.”

First Person View Freedom Coalition Announces Non-Profit Launch

Leading FPV pilot advocacy group receives 501(C)(3) approval and will seek Community Based Organization (CBO) status from FAA

New York - April 3, 2019 The First Person View Freedom Coalition (FPVFC), today announced its official launch as a non-profit organization, with a mission to advocate for the rights of Unmanned Aircraft Systems (UAS) FPV aircraft pilots within the U.S. to fly safely in the National Airspace. The FPV Freedom Coalition fosters the freedoms of recreational FPV pilots, and enhances the community’s culture through defined public safety guidelines and effective educational resources while protecting the privilege to access abundant airspace.

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The Federal Aviation Administration (FAA) recognizes Community Based Organizations (CBO) that represent segments of model aircraft pilots to help the FAA educate and shape National Airspace (NAS) regulations. The FAA requires CBOs to be 501(c)(3), non-profit organizations. The FPVFC incorporated in late 2018 and with its 501(c)(3) status will continue working with the FAA and are now able to seek CBO status.

“With the dramatic growth of drones and emerging industry regulations, we recognized that recreational drone pilots needed an advocate with the FAA. We created the FPVFC with the mission to foster the freedoms of recreational FPV pilots and help define safety guidelines and effective educational resources to protect access to abundant airspace,” said Chad Kapper, CEO Rotor Riot and CEO and Board Chair, FPVFC.

“The variety and adoption of drones across multiple industries is expanding every day. With the advent of innovative on-board hardware and software, we see a great opportunity to increase safety and accountability for commercial and recreational drones, as well as ensure the data and privacy of FPV pilots is kept absolutely secure. One of the efforts I hope to see with FPVFC is the advancement of universal industry standards so improved security becomes more pervasive across the board,” Jeff Thompson, CEO of Red Cat and FPVFC Board member.

To learn more and understand how to participate and help maintain flying privileges for the FPV pilot community visit http://fpvfc.org For questions, please contact Dave Messina, President, FPVFC at dmessina(at)FPVFC(dot)com or (914) 646-5258.

About First Person View Freedom Coalition
The FPV Freedom Coalition is a non-profit organization created to advocate for recreational FPV pilots through education and safety guidelines to protect the community’s access to ample airspace. Through this, the coalition protects the ability of FPV pilots to fly and to do so safely, armed with the knowledge that they need to interact with the general public in a positive and respectful way. Together, the coalition seeks to unite the community into a single voice through which its concerns and needs can be heard. For more information visit http://fpvfc.org.

FPV Freedom Coalition Launch FAQ

Q1:  How does the FPVFC relate to the AMA?
A1:  FPVFC is a separate organization from the Academy of Model Aeronautics (AMA) with a number of common objectives.  The AMA has agreed to collaborate with FPVFC through open communication on regulatory issues, messaging and safety.

Q2:  I’ve read in the AMA magazine that they represent all recreational models including drones (sUAS) with the FAA.  Why did you see the need to create the FPVFC?
A2:  FPV pilots fly at a variety of locations.  That aspect of FPV dictates the need for a focus to ensure FAA regulations support flight beyond designated, permanent sites.

Q3:  Why do we need a FPV Knowledge Exam in addition to the FAA’s Part 107 Exam?
A3:  Assuming we gain FAA approval, our FPVFC Knowledge Exam would be less comprehensive than a FAA Part 107 and it would provide the FPV Pilot the privilege of recreational flight.  It is also a requirement for flight once Section 349 from the FAA Reauthorization act of 2018 goes live.

Q4: Why do you think you can get the FAA to accept any of your recommendations?
A4:  The FAA is required to listen to the public and they have created rules for groups to be able to provide input on rules and regulations.  The FPVFC has done what the FAA requires so we may represent a group. Specifically, in order to represent a group to the FAA, the FAA requires the group to be a Community Based Organization.  To be a CBO, the organization must be a non-profit organization. The FPVFC is now a non-profit organization.

Q5:  Who are the individuals behind FPVFC?  Is there a manufacturer’s agenda in the FPVFC?
A5:  The FPVFC is an independent non-stock corporation operating as a 501(c)(3) non-profit.  The current board of directors have a background of FPV industry, global corporate technology, retail industry and deep FPV experience.

Q6:  Our air space is free why do we need any regulations for drones (recreational sUAS)?
A6:  In the United States of America, the airspace is regulated by the FAA.  Flying in the National Airspace is a privilege, like driving a car anywhere in the USA requires a driver’s license and is a privilege (not a right), the same ideas apply to our national airspace.

Q7: I heard the FAA legislation in 2018 repealed all the recreational regulations.  What happened to the exemption for model aircraft? Are there new rules?
A7:  The 2018 FAA Reauthorization Act passed a number of mandates the FAA must now implement.  Within those mandates was the repeal of section 336, the model aircraft exemption. Until the FAA establishes the new rules under Section 349 of the FAA Reauthorization Act of 2018, FPV pilots are required to comply with the current rules, for example, Section 336.

Q8:  If I’m a member of FPVFC, do I still need to register with the FAA?
A8:  If you fly a FPV aircraft which weighs more than 250 grams, you need to register with the FAA.  This registration is the pilot, not each aircraft. The FPVFC is a private, non-profit organization.  There is no requirement to become a member of the FPVFC; however, there is a requirement to fly under the safety guidelines of a CBO.  The FPVFC will advocate for FPV pilots with the FAA.

Q9:  Other than working with the FAA, what will the FPVFC do for FPV Pilots?
A9:  In addition to advocating for FPV Pilot rights with the FAA, the FPVFC is working to provide insurance to recreational FPV Pilots, provide and promote its FPVFC Safety Guidelines, create a Knowledge Exam for FPV recreational pilots and more.

Q10:  Will FPVFC be at FPV events so we may meet the FPVFC team?
A10:  Depending on the success of our fundraising, yes.

Q11:  Will the FPVFC be recommending LAANC applications?
A11:  Yes. The FPVFC will reflect the views of the FPV community and its members and will make recommendations to guide newcomers to the hobby.

Q12:  Can the FPVFC help me understand how I may fly legally around the USA?
A12:  The FPVFC will work to provide understandable interpretations of FAA regulations through it’s weekly Town Halls as well as resource documents on the FPVFC website.

Q13:  Will the FPVFC provide insurance for my drone?
A13:  It is the intent of the FPVFC to provide drone insurance for recreational use within the USA.

Q14:  How much does the FPVFC membership cost?
A14:  Annual adult membership is $40 and annual youth membership is $20.

Press Release to DroneLife.com

The FPV Freedom Coalition is still evaluating the full impact of HR302 on the recreational FPV hobbyists, as the most important details have yet to be released by the FAA. They have deadlines, ranging from 60 to 270 days, to produce and publish further policy. For example, they have 180 days to define the knowledge test as well as publish an Advisory Circular describing CBO designation/application.

Although Section 336, Special Rule for Model Aircraft, has been repealed by the FAA Reauthorization Act of 2018, we feel the existing regulation remains in force until struck from the Federal Register. During this transition period, the FAA will phase in new regulation over the next 270 days and may wait to remove 336 until Section 349 is formally implemented.

We will continue to evaluate and interpret the new regulations for the community. Reactions from the community have been mixed so far as they gain the knowledge to understand just what is happening. Overall, we see no "show-stopping" issues but there is plenty of work ahead for us. We view aspects of this bill as a well-thought-out invitation to groups just like the FPV Freedom Coalition, inviting us to get involved and lend our expertise in ensuring the safety of the national airspace. This is a goal we share with the FAA and, more importantly, we eagerly accept the challenge.

DroneLife.com

Response to HR 302 Passing in the Senate

As most know at this point, the Senate has passed HR 302. The next stop is the White House to the desk of President Trump. Now is the time to get your letter to the president written and submitted so the voice of the FPV community can be heard. These are your skies, that should be free to use, to explore, and to enjoy. Protect that right!

While this may be seen as many as a setback, this does not mean that all is lost. We as a community need to come together and keep pushing forward. There are many areas in the FAA Reauthorization Act that have been left for the FAA to put to committee, develop guidelines, and to overall hammer out the details. We need to be the voices in their ear that help to shape those guidelines.

The FPV Freedom Coalition is still developing at a fast pace. We are determined to represent the FPV pilot, and to help raise the volume of your voice and to protect your access to the skies. We will continue to push, to fight, to shout, and to work with the community, the government, and the public to bring our hobby out from the shadows and into the light. We need your help to do that though, because through you, our mission comes full circle.

Our ask of the FPV community is simple…. Write your letters to the President, let him know why this is important to you. Share your stories, share your love of the hobby. Keep shouting from the rooftops if you have to, we are listening. Keep innovating, keep pushing your skills to the next level. Most importantly, keep flying!

We will keep you updated as more information comes out, so stay tuned.

We have a great, immersive, and educational hobby. Help us fight for that. Join the FPV Freedom Coalition!