The "Reality" of Commercial UAV Use?

Old Man

Active Member
A lot of extremely good, and equally valid points have been brought up in the preceding posts, demonstration the many facets of what we are facing. With 45 years as an avid RC fixed wing modeler in genres from RC gliders to gas engine 3d giant scale, 10 years in the military grade UAV industry, and about a year in multi rotors, I can state FPV isn't much of an issue but the altitude limits are. You can't perform manyvertical maneuvers without breaking 400' AGL flying giant scale RC, and RC glider thermal duration and Free Flight activity is effectively eliminated. So it's more than just FPV video at stake here.

Full scale manned aviation has airspace right of way regardless of the altitude being flown. That's the rules, has been the rules, and the FAA made them a long time ago. The FAA is in all likelihood not going to alter that way it has been doing things for the last 50 years. They will simply force anyone new coming into airspace activity to comply with the rules as they already are. The FAA will simply define a new niche for them to fit into. There is no such thing as personal, private airspace. The FAA owns all of it, everywhere inside the U.S., the moment something breaks contact with terra firma. I was involved in some extensive legal activity years back where that fact was made quite clear. If manned aviation breaks the law and flies below the 500' unpopulated airspace rule, they still have the right of way. There have already been numerous publicized events where unmanned "toys" have gotten quite close to passenger airliners. Several reports of MR type aircraft have been made near approach and departure corridors at airports. There have been several, meaning more than 5, collisions between sUAS and military aircraft in the air and on the ground overseas. War zones and military airport in Europe.

That we will be stuck with line of sight rules is pretty much a given unless we are flying a "certificated" aircraft using approved avionics suites and telemetry ground stations. I've been employed by one of the companies doing this inside U.S. airspace for quite some time. From their perspective it would be better if RC modeling activities went away, and the rules being generated regarding equipment will to a large extent help make that happen unless we become very, very loud in an organized manner. We'll probably have to promote our own vision of an altitude limit, along with specific areas where higher activities could be conducted. I hate to say it but FPV using goggles will likely not be permitted, with or without a spotter. There have already been far too many publicized examples demonstrating how people cannot be trusted to obey even basic safety rules. I can go to a minimum of three You Tube videos right now that depict MR's well above 5,000' AGL, and search for numerous posts in different forums where people have done similar repeatedly, some above 18,000' AGL Once you get in a cloud flight safety issues expand significantly. Manned aviation is only being advised of tracked aircraft to maintain separation, and models of any type without a transponder are invisible to air traffic control. An MR's through the wind screen or into a turbine will be killing someone in the manned aircraft.

So we have issues of our own making. By "our own" I refer to those that buy and fly without any sense of responsibility. Those that believe they can do whatever they want, whenever they want without regard to anyone or anything else. Generally those people are fairly young but the fact is many are not so young they they haven't learned right from wrong. We will only correct these issues through organization. Some limits will have to be placed upon who can purchase what and from where based upon product quality. The importers must take some responsibility and not sell to anyone that has not first become informed of rules, regulations, and personal responsibilities/liability. Some will have to made examples of for the point to get across, which is what the "Trappy" person is to the FAA. He will be the example from which all others will learn the wrath of the federal government and the FAA.

So how do we fix it? As much as I don't like the AMA and how it works in some areas it's still an organized body with about 160,000 members we can use. If enough MR operators join we'd develop a much stronger voice in policies and procedure. If we started our own organization such could act as a leveraging group within a larger body such as the AMA. It would be nice if we could approach groups like the Arplane Owners and Pilots Association and SHOW them how we are doing all we can to prevent being a threat to pilot and passenger safety. Same with Airline Pilots Association. Unfortunately our group has done pretty much the opposite, which is something needing immediate correction. Another issue we have with manned aviation is the fact our operational methods absolutely threaten some of their livelihoods. We have a similar problem with ground based camera crews.

We have some pretty serious issus in front of us and it will take some reaching out to people that may not like what they hear. Some of what I like to call "kiddie forums" will react with pure venom simply because they are filled with extremely immature people possessing a sense of entitlement and overwhelming need for instant gratification. Those same people are largely the ones responsible for the situations we are facing now.
 
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econfly

Member
It's a legitimately tough situation. Not to throw any interests under the bus, but I can understand the unacceptable risks associated with RC pilots flying out of line-of-sight and especially at high altitudes. That's just Russian roulette, and counting on lots of empty air to avoid a collision. I still think private property and a reasonable ceiling could solve just about all of the real or imagined problems, but that assumes sensible government and sensible operators (i.e., it will never happen).
 


Old Man

Active Member
That growth continued will be much of the support we need to enable continuing what we do. I'd recommend joining the AMA if not already a member.

AMA#388446
 

dmetz

Member
A lot of extremely good, and equally valid points have been brought up in the preceding posts, demonstration the many facets of what we are facing. With 45 years as an avid RC fixed wing modeler in genres from RC gliders to gas engine 3d giant scale, 10 years in the military grade UAV industry, and about a year in multi rotors, I can state FPV isn't much of an issue but the altitude limits are. You can't perform manyvertical maneuvers without breaking 400' AGL flying giant scale RC, and RC glider thermal duration and Free Flight activity is effectively eliminated. So it's more than just FPV video at stake here.

Full scale manned aviation has airspace right of way regardless of the altitude being flown. That's the rules, has been the rules, and the FAA made them a long time ago. The FAA is in all likelihood not going to alter that way it has been doing things for the last 50 years. They will simply force anyone new coming into airspace activity to comply with the rules as they already are. The FAA will simply define a new niche for them to fit into. There is no such thing as personal, private airspace. The FAA owns all of it, everywhere inside the U.S., the moment something breaks contact with terra firma. I was involved in some extensive legal activity years back where that fact was made quite clear. If manned aviation breaks the law and flies below the 500' unpopulated airspace rule, they still have the right of way. There have already been numerous publicized events where unmanned "toys" have gotten quite close to passenger airliners. Several reports of MR type aircraft have been made near approach and departure corridors at airports. There have been several, meaning more than 5, collisions between sUAS and military aircraft in the air and on the ground overseas. War zones and military airport in Europe.

That we will be stuck with line of sight rules is pretty much a given unless we are flying a "certificated" aircraft using approved avionics suites and telemetry ground stations. I've been employed by one of the companies doing this inside U.S. airspace for quite some time. From their perspective it would be better if RC modeling activities went away, and the rules being generated regarding equipment will to a large extent help make that happen unless we become very, very loud in an organized manner. We'll probably have to promote our own vision of an altitude limit, along with specific areas where higher activities could be conducted. I hate to say it but FPV using goggles will likely not be permitted, with or without a spotter. There have already been far too many publicized examples demonstrating how people cannot be trusted to obey even basic safety rules. I can go to a minimum of three You Tube videos right now that depict MR's well above 5,000' AGL, and search for numerous posts in different forums where people have done similar repeatedly, some above 18,000' AGL Once you get in a cloud flight safety issues expand significantly. Manned aviation is only being advised of tracked aircraft to maintain separation, and models of any type without a transponder are invisible to air traffic control. An MR's through the wind screen or into a turbine will be killing someone in the manned aircraft.

So we have issues of our own making. By "our own" I refer to those that buy and fly without any sense of responsibility. Those that believe they can do whatever they want, whenever they want without regard to anyone or anything else. Generally those people are fairly young but the fact is many are not so young they they haven't learned right from wrong. We will only correct these issues through organization. Some limits will have to be placed upon who can purchase what and from where based upon product quality. The importers must take some responsibility and not sell to anyone that has not first become informed of rules, regulations, and personal responsibilities/liability. Some will have to made examples of for the point to get across, which is what the "Trappy" person is to the FAA. He will be the example from which all others will learn the wrath of the federal government and the FAA.

So how do we fix it? As much as I don't like the AMA and how it works in some areas it's still an organized body with about 160,000 members we can use. If enough MR operators join we'd develop a much stronger voice in policies and procedure. If we started our own organization such could act as a leveraging group within a larger body such as the AMA. It would be nice if we could approach groups like the Arplane Owners and Pilots Association and SHOW them how we are doing all we can to prevent being a threat to pilot and passenger safety. Same with Airline Pilots Association. Unfortunately our group has done pretty much the opposite, which is something needing immediate correction. Another issue we have with manned aviation is the fact our operational methods absolutely threaten some of their livelihoods. We have a similar problem with ground based camera crews.

We have some pretty serious issus in front of us and it will take some reaching out to people that may not like what they hear. Some of what I like to call "kiddie forums" will react with pure venom simply because they are filled with extremely immature people possessing a sense of entitlement and overwhelming need for instant gratification. Those same people are largely the ones responsible for the situations we are facing now.

I think you've summed it up quite well here old man. Its going to take some well thought out position papers and propositions to influence the FAA on these points. We desperately need more rules unfortunately (not less) that can specifically define how and where someone can operate a small commercial MR venture. Other countries have done it. Perhaps we should be looking at those current laws and lobbying for what might work best in the US. I'd love to see a good template/model that might define what (reasonable) parameters and requirements for certification would exist for commercial use of UAS say under 10Kg or 7Kg or whatever that number should be to distinguish this commercial operator from someone like the military. Maybe there needs to be a fundamental use specification as well. For instance, as an aerial photographer/videographer, I personally have no interest in being able to carry and deliver packages or other dynamically separable payloads.

Does anyone know of any template document or position paper like this that currently exists?
 

Ronan

Member
My only issue is with this way of approaching the 'problem', is we are doing the FAA's job, but not only that, i have seen, first hand, when people gather to work on items like that for any big corporation/government, it usually goes straight in a filing cabinet since it offends them that we are doing their job.

We have to be very careful with this.
 

Old Man

Active Member
As one who works for a big corporation doing government work, the worst of both worlds, I could not agree more. You forgot the part where everything has to be presented in a manner that permits those in higher positions to be able to take credit for the work. Sorry, that's a rant for another time and place...
 


As an aside, and less relevant for this forum, I wonder how RC airplane guys see this issue. I'm fine keeping it under a short ceiling (400 feet, etc.) because I'm flying multis and just want to do photo/video work. The guys with the RC planes and jets would probably like (need?) more room.

I have flown RC for about 20 years. I flew sailplanes and I can tell you that they were way above 400 ft.
We did it with total disregard for general aviation and it was stupid.
Today's model jets flown at AMA sanctioned fields and meets have the same 400' restriction as everyone else. 400' is the limit. It's a regulation set forth by the FAA and that is it.
It's nice to get that high view of everything but it is what it is and until it changes we should live with it.
I don't see the 400' FL limit ever changing but you FPV guys need to show responsibility that will help you in the fight to get those Regs changed or amended.
They have already banned National Parks in the US and that just plain stinks. They are some of the most fantastic and beautiful areas we have but a few uneducated individuals made the loudest noise and now we are banned. Responsible actions can help our cause. Irresponsibility can only damage it further.
 

dmetz

Member
My only issue is with this way of approaching the 'problem', is we are doing the FAA's job, but not only that, i have seen, first hand, when people gather to work on items like that for any big corporation/government, it usually goes straight in a filing cabinet since it offends them that we are doing their job.

We have to be very careful with this.

Hi Ronan. Very true BUT, having come from government, and having some understanding of the rule making process, it is by public comment and position papers, typically with the clout of some larger organization wherein these opinions and propositions are heard. That is EXACTLY what this period of public comment is intended for. Those that say the FAA cannot make law are miss-informed. These agencies are charged by statute to create Federal "Rules" which do, in fact, constitute law.

I think where the FAA got into trouble with the courts in their recent RC operator vs FAA ruling (paraphrasing here); it is that they did not have sufficient definitions and delineation's in "rule" to allow the court to sustain their assertion. I have no doubt that the current language on the table gives the FAA just what they need to avoid any future embarrassment in the court system. In so doing, they do not leave any doors open for a reasonable certification for "simple" commercial use of MR. That is too bad and I wish we could strategically work to change or amend this proposal.
 

Av8Chuck

Member
Hi Ronan. Very true BUT, having come from government, and having some understanding of the rule making process, it is by public comment and position papers, typically with the clout of some larger organization wherein these opinions and propositions are heard. That is EXACTLY what this period of public comment is intended for. Those that say the FAA cannot make law are miss-informed. These agencies are charged by statute to create Federal "Rules" which do, in fact, constitute law.

I think where the FAA got into trouble with the courts in their recent RC operator vs FAA ruling (paraphrasing here); it is that they did not have sufficient definitions and delineation's in "rule" to allow the court to sustain their assertion. I have no doubt that the current language on the table gives the FAA just what they need to avoid any future embarrassment in the court system. In so doing, they do not leave any doors open for a reasonable certification for "simple" commercial use of MR. That is too bad and I wish we could strategically work to change or amend this proposal.


Any position papers from individuals is pointless. By the time the FAA starts the public comment period the rules have already been written by lobbyists and "Industry Experts," the comments will just be used to ratify the rules.

If we want to make a difference we'd better create a political action committee like AOPA that has attorney's that can add some teeth to any position papers and defend any onerous action taken by the FAA. Everyone should comment but if your hoping that it will have much if any effect your probably going to be disappointed.

Like it or not, the recent passage of the healthcare bill is an example of the power of lobbyists to influence policy and is systemic. The FAA is doing exactly the same thing and if we don't have representation at those negotiations all the comments in the world will not make a difference.
 

Old Man

Active Member
Actually, we do have some representation but we have under utilized the asset. The AMA (Academy of Model Aeronautics) got deeply involved in the sUAS rule making process back in 2007. They had to request to be included in the discussions with UAS industry leaders and the FAA, and were permitted on what might be viewed as a "listen only" basis, but they did get involved. Though not having a voice in the process they were at least able to obtain information to pass along for others to act upon. From that point forward they've so far spent a bit over $1 million lobbying Congress and the FAA. Considering they work off o $58.00/year membership with only 160,000 members that quite a bit of additional expenditures for an organization that until 2007 had not been all the involved in government lobbying.

By under utilization I refer to the likelihood that most currently flying MR operators have never heard of the AMA, making most of their hobby purchases via the internet and off shore vendors, neither of which make any mention of hobby organizations, safe operating rules, or other beneficial information that would better serve the MR operator group. For the most part the majority of AMA info getting to the public is being dispersed by the Roswell Flight Test group, which is not, IMO, anywhere close to the best possible means of disseminating information for anything aside from FPV activity. So most of the AMA members are there because of their previous associations with other forms of RC flying activity, including competition, which is impacted by this latest advisory. Those RC groups formed special interest groups (SIG's) to promote specific agendas relative to their group activities within the AMA. At this time MR's do not have a SIG, nor is there a significant membership declared as dedicated to MR flying. At this time there is discussion within the AMA to provide a segment in their monthly magazine one every other month. Activities like RC helicopters, RC Scale, RC Aerobatics, and Control Line flying have columns that run monthly, which should be an indication of perceived level of public interest in multirotors. I believe the activity to be considerably higher than what is now represented within the AMA, but without membership numbers to support that claim there is no way for the AMA to provide an accurate estimate and supportive representation. OTH, the AMA has shown itself to be supportive of FPV flying activities, albeit with some reasonable restrictions.

So we have a lobbying forum available to us but we have to join up in large numbers in short order to make effective use of it. A few commercial MR cinema have already petitioned the FAA but it is clear their focus is primarily on their activities, not FPV or hobbyists in general. This is to be expected since they are revenue generating. Our MR vendors need to become united at some level to make their voices heard as well since they take in sales and business taxes that count towards the only thing that really matters to government, which is money.

No, I'm not pimping the AMA just to pimp the AMA. If there was a better solution I'd be all over it.
 

dmetz

Member
Any position papers from individuals is pointless. By the time the FAA starts the public comment period the rules have already been written by lobbyists and "Industry Experts," the comments will just be used to ratify the rules.

If we want to make a difference we'd better create a political action committee like AOPA that has attorney's that can add some teeth to any position papers and defend any onerous action taken by the FAA. Everyone should comment but if your hoping that it will have much if any effect your probably going to be disappointed.

Like it or not, the recent passage of the healthcare bill is an example of the power of lobbyists to influence policy and is systemic. The FAA is doing exactly the same thing and if we don't have representation at those negotiations all the comments in the world will not make a difference.

Agreed AV8Chuck. Generally speaking, the FAA may have already received the input they wish to receive and yes, lobbyist from organizations and industry experts will wield the most influence. That said, a comment period is for comments so I'm not totally sure that input at this point, is pointless. A PAC would help. I'm just concerned that nothing exists in anything I've read to certify a small commercial operator with a definitive scope of operation.

You seem knowledgeable and informed. Do you have any suggestions?

Old Man...I appreciate your insight on the AMA. I am not a member but tomorrow I will be. Anything else that we can do folks? If its too late or if public comment does not matter, than it somewhat feels like we are wasting our words.

Someone mentioned petitions that may be circulating; any links and what do they purport/propose? Is it something that can even be palatable to the FAA?
 

Av8Chuck

Member
You raise some great points, part of the trouble is that the AMA is more about the hobby, not the profession. The fact that the AMA was only permitted a "listen only" basis kind of supports my claim that the FAA does not take the comment period seriously. Even if everyone who flew MR's joined the AMA that wouldn't guarantee a seat at the table. We need a PAC that's more like AOPA, it would be great if AOPA would take up the cause.

We need attorney's. I've argued that as individuals we have no voice in this debate, many on these forums think this only effects people wanting to do AP professionally but I think that since its difficult to differentiate a hobbyist flying a camera and someone getting paid for AP that the FAA will just ban all camera's from RC's period, including FPV.

Maybe the AMA would have enough credibility to get AOPA to provide the resources to defend our right for commercial AP?

 

Actually, we do have some representation but we have under utilized the asset. The AMA (Academy of Model Aeronautics) got deeply involved in the sUAS rule making process back in 2007. They had to request to be included in the discussions with UAS industry leaders and the FAA, and were permitted on what might be viewed as a "listen only" basis, but they did get involved. Though not having a voice in the process they were at least able to obtain information ,,,,,,,,,,,,,,,,,,
,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,So we have a lobbying forum available ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
No, I'm not pimping the AMA just to pimp the AMA. If there was a better solution I'd be all over it.

Actually they are the only voice we have and my friends, it's far better than nothing. When you think about it, you are getting an advocate for the price of a battery. The AMA has rules and regulations also but having been a member for 15 years or more they are rules you can live with and you get the insurance too.
 

Old Man

Active Member
Actually they are the only voice we have and my friends, it's far better than nothing. When you think about it, you are getting an advocate for the price of a battery. The AMA has rules and regulations also but having been a member for 15 years or more they are rules you can live with and you get the insurance too.

During the formative period of the rule making it was pretty much the heavy iron commercial sUAS and UAS industry, along with the Airplane Owners and Pilots Association and Airline Transport Association that was doing the talking. This is why I'm on record as saying they want the small guy locked out in order to monopolize the market. The company I work for had a person sitting on that development board, along with the original founder of the company. Thankfully at least modeling was allowed to be present and listen or the fight would be far more uphill than it is.

At this point, what is essentially a notice of proposed rule making period, our voices DO make a difference. This is where the AMA has the ability to continue positioning Congress people to show favor on our position. It worked once before not that long ago with the AMA getting Congress to put the restriction against rules on RC modeling by the FAA. The fact this rule has suddenly been ignored by the FAA has some heavy connotations, one of them being the massive amount of publicized activities that are detrimental to aviation safety probably the most causal. The AMA is the "national organization" the FAA references in their document for rules and guidelines so we still have the opportunity to save some of the day.

I don't know what to do about the commercial side of what we do, generally because I've never thought for a second the FAA would let people fly for hire without a Commercial Pilot certificate. I think we've deluded ourselves if we thought otherwise. However, it is during the current situation where group lobbying to permit specific activities for hire at altitudes AGL well below what is safe for a faster moving manned aircraft, or manned helicopter, could be presented. The FAA has rules for aircraft separation that call out 1,000 feet of vertical separation in IFR conditions and 500' of vertical separation in VFR conditions. Since there is the 500' AGL separation from persons or structures restriction, and most of the time a manned aircraft floor of 500' AGL, we have an opportunity to obtain airspace use under 500' AGL IF we call out a manned/unmanned separation buffer zone. Personally I see that at somewhere between 250" and 300' AGL. I thought they were quite gracious to permit only a 100' buffer before between models and full scale. Gracious considering how difficult they usually are.

So I believe (hope) the comment period will be productive if used correctly. To sit back and do nothing because we think it has no impact assures that nothing can be done in our favor. To make comments calling out specific bullet points covering what we would like to have provides something to reference. The AMA has put up some letter/contact guidelines that we may find useful in either the crrent formatting or after a little modification. Doing something is always better than doing nothing. Forums such as this and similar are not viewed by the officials we need to sway, so we have to take the water to the horse.
 
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Old Man

Active Member

Maybe the AMA would have enough credibility to get AOPA to provide the resources to defend our right for commercial AP?


Chuck,

Private aviation has been on a massive decline since 1989. 9/11 and the recession made that situation even worse. I'm a member of that group as well. Point being AOPA has been trying to figure out for years how to get more people interested in flying private aircraft in order to boost their declining membership. As a commercial pilot and sUAS operator familiar with both sides of the fence I suggested quite some time ago that AOPA make contact with all the sUAS candidates that were going to be coming home from the wars soon as strong candidates for under taking flight lessons. Since most companies require sUAS trainees to obtain a Class III aviation medical AOPA was aware of who those people were and how to contact them. Manned aviation despises the thought of unmanned aircraft even though most of the commercial flights are almost fully automated. To a large extent the pilot is along for the ride and to input data into the auto pilot. So the private flying community believes we are a threat to their safety and integrating us into the airspace would likely cause them to bear some financial expenditures to assure all aircraft were equipped with transponders, TCAS, and two way communications. Something they are not required to do now unless they fly in specific airspace. The airline transport pilots believe we are a threat to their livelihoods, and to some extent we are as unmanned operators, so they don't want us around either.

We shot ourselves in both feet by calling our aircraft UAV's and drones. That tied us tightly to the unmanned aircraft types that actually will be causing aircraft owners and airline pilots to spend money and lose income. Had a distinction been made to separate us from them what we are dealing with now might have been delayed a little. The Phantom has not helped anyone at all. That damn thing has been a slow acting poison for all that we do. And not really all that slow in getting us into this mess.

We won't get any help from AOPA and ALPA.
 
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dmetz

Member
Chuck,

Private aviation has been on a massive decline since 1989. 9/11 and the recession made that situation even worse. I'm a member of that group as well. Point being AOPA has been trying to figure out for years how to get more people interested in flying private aircraft in order to boost their declining membership. As a commercial pilot and sUAS operator familiar with both sides of the fence I suggested quite some time ago that AOPA make contact with all the sUAS candidates that were going to be coming home from the wars soon as strong candidates for under taking flight lessons. Since most companies require sUAS trainees to obtain a Class III aviation medical AOPA was aware of who those people were and how to contact them. Manned aviation despises the thought of unmanned aircraft even though most of the commercial flights are almost fully automated. To a large extent the pilot is along for the ride and to input data into the auto pilot. So the private flying community believes we are a threat to their safety and integrating us into the airspace would likely cause them to bear some financial expenditures to assure all aircraft were equipped with transponders, TCAS, and two way communications. Something they are not required to do now unless they fly in specific airspace. The airline transport pilots believe we are a threat to their livelihoods, and to some extent we are as unmanned operators, so they don't want us around either.

We shot ourselves in both feet by calling our aircraft UAV's and drones. That tied us tightly to the unmanned aircraft types that actually will be causing aircraft owners and airline pilots to spend money and lose income. Had a distinction been made to separate us from them what we are dealing with now might have been delayed a little. The Phantom has not helped anyone at all. That damn thing has been a slow acting poison for all that we do. And not really all that slow in getting us into this mess.

We won't get any help from AOPA and ALPA.

I have a similar notion regarding AOPA involvement in the current MR challenge. I was a member for 20 years but let my membership lapse. I somewhat doubt their interest in this and, as Old Man so eloquently put it above, suspect the AOPA and its members could see UAS and in particular, commercially operated UAS, as a threat to safety and livelihood.
 

We shot ourselves in both feet by calling our aircraft UAV's and drones.

I've said that all along. Builders, flyers and even some manufacturers seem to believe for some reason that the word Drone is a more attractive term and somehow elevates them above the common radio controlled model.
Drones are always equated with Hellfire missiles and spy missions and have very negative connotations. The media just can't wait to get its hands on a good, juicy "Drone" story.
By definition we do fly drones but the general public and politicians can't make a distinction between our craft and the dreaded "Drone".
 

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