New Proposed Interim Rules Commercial Use


Old Man

Active Member
Some of what I read in that is not good and definitely was not part of the 107 NPRM document.
 

Hexacrafter

Manufacturer
I have been watching this entire process very closely from the beginning and have had several conversations with a couple of FAA officials and the question that is still unclear to me is the UAS Aeronautical Knowledge Test. Many are speculating that this will be the same test currently required for the PPL, and schools are already running and many are rushing out to ground school.
BUT... from what I read, the FAA is to DEVELOP a new test specific to UAS...... so is it possible that those that are jumping at the PPL test and Ground School will need to take a different test?
From my point of view, this seems to make sense as the MAJORITY of questions on the PPL Aeronautical Knowledge Test have absolutely NOTHING to do with UAS.
It is more logical, that a test would be tailored to ensure that the "UAS Operator" would know about the rules, regulations and restrictions related specifically to UAS.
I cannot wait until someone can provide a clarification of what the UAS Aeronautical Knowledge Test will actually become, but when you read the available information about what is being proposed in the ACT, it seems to indicate a NEW specialized Test.
 


Old Man

Active Member
Everything in the NPRM pointed at a new knowledge test for sUAS operators. I read every bit of that thing and there were several references to the areas of knowledge, which not nearly as extensive as the PPL written. My thoughts just have a lot of people doing what most of the industry has been doing for some time now, extracting as much money as they can from people that can't charge for their work, before of after they get fleeced by these outfits. I even have a local airport operator asking me how he might start making some money of a "training" program, and he has not ever flown a multirotor..
 

jfro

Aerial Fun
I also read the full proposal a few months back. I thought it was a good start. Since then I see movement that suggest what old man is suggesting. Trying not to think the worst of our system, but seeing Amazon and others strong arm themselves into getting what they want and some of the language (I just skimming this new one) in this document, but it is worrisome. Keeping my fingers crossed the FAA holds true to their original ideas as I thought it was a good start. This is going to be a fast moving issue and some adaption will most likely be called for, but they need to just start with the basics of which I thought they did a good job on the first proposal.
 

Among other concerns, I'm wondering just how much will all this cost?

I now see the following requirements:
• Written Exam (pre-exam classes too?)
• Flight test
• Aircraft Inspection
• Registration of aircraft

All these requirements will no doubt come with a fee attached. Plus, for those of us with multiple MR's and multiple pilots, these fees will be multiplied.

Anyone care to offer any estimates?


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jfro

Aerial Fun
In the FAA proposed rules, I thought you'd have to go somewhere to take the test, but all the educational material would be available on line for those who like to self school as most is already available for the pilots information that we will need and they were going to be the new material quickly. At least that's how I interpreted it. I don't recall their being a flight test, but maybe my memory bank is faulty.
 

jfro - It is this part of the doc :

‘‘(iii) has demonstrated the ability to
fly the aircraft in accordance with the op-
erating restrictions set forth in subsection
1(c)."

That led me to believe that we would need to take a flight test. But maybe I am interpreting this incorrectly?
 

Old Man

Active Member
In the FAA's Part 107 NPRM there was no reference to an operator's flight test, only a written one. The language use in the NPRM was suggestive of a new written test more appropriate to the tasks a line of sight sUAS operator would be involved with. There was no reference to aircraft certification, only aircraft registrations. The estimated cost for operators to conform to new commercial operator certifications was roughly $260.00 or so. Test fee, aircraft registration, operator background check. There was no mention of anything other than medical self certification by the operator.

What Jfro posted is clearly something new, created by someone that appears to be functioning outside of the FAA structure. If at the legislative level as it appears there could be some significant hurdles in front of us yet again that go above and beyond what was referenced in the NPRM. The average operator out there will not be able to afford aircraft certification as it was referenced the Jfro's link. The center mentioned is a major test and certification lab that uses ASTM and other standards for certification. There is no one single part that is marketed at our level that has been certified to those levels. In reality, there is not one thing that has been certified as meeting some international or nationally recognized mechanical, structural, or electrical engineering or FAA-PMA standard at all.

Some of this stuff were things I was aware of being promoted by the big league players for their aerospace/military grade BLOS operations, with most of that extremely long distance. There's no possible way we can afford that playground. If all the rules are designed to meet those levels of equipment and operator certification we are dead in the water. We absolutely must have a tiered system that defines size, distance, equipment, and operator classifications that leaves room for the small guy.
 


Old Man

Active Member
Based upon what was related in the article I think we just found out who was behind the text of the bill Jfro posted.
 

jfro

Aerial Fun
In the FAA's Part 107 NPRM there was no reference to an operator's flight test, only a written one. The language use in the NPRM was suggestive of a new written test more appropriate to the tasks a line of sight sUAS operator would be involved with. There was no reference to aircraft certification, only aircraft registrations. The estimated cost for operators to conform to new commercial operator certifications was roughly $260.00 or so. Test fee, aircraft registration, operator background check. There was no mention of anything other than medical self certification by the operator.

What Jfro posted is clearly something new, created by someone that appears to be functioning outside of the FAA structure. If at the legislative level as it appears there could be some significant hurdles in front of us yet again that go above and beyond what was referenced in the NPRM. The average operator out there will not be able to afford aircraft certification as it was referenced the Jfro's link. The center mentioned is a major test and certification lab that uses ASTM and other standards for certification. There is no one single part that is marketed at our level that has been certified to those levels. In reality, there is not one thing that has been certified as meeting some international or nationally recognized mechanical, structural, or electrical engineering or FAA-PMA standard at all.

Some of this stuff were things I was aware of being promoted by the big league players for their aerospace/military grade BLOS operations, with most of that extremely long distance. There's no possible way we can afford that playground. If all the rules are designed to meet those levels of equipment and operator certification we are dead in the water. We absolutely must have a tiered system that defines size, distance, equipment, and operator classifications that leaves room for the small guy.


I thought the original article I linked made it clear that Sen Booker (sp) was one of two senators launching this.

Ol M an, thank your for your post. Your post of the initial FAA proposals what I understood when I read the FAA document. While I didn't understand some of Bookers proposed legislation, I had the gut feeling it was big boy promoted and this legislation would most likely put the cost of doing business out of the reach of most businesses or at least more time consuming & more expensive.

I started getting worried that big money was pushing back HARD when I saw Amazon was getting an exemption to test their delivery system. Then this article really bothered me.

There's a very interesting video I saw this week that EVERYBODY should watch, spred, and discuss with their friends. It was based on a Princeton study I just found and quickly skimmed & believe this is the study the video links to. The article link is here.

http://scholar.princeton.edu/sites/...testing_theories_of_american_politics.doc.pdf

And the video link is here.


It's more depressing than I thought and I'm already pretty pessimistic about our politicians in regards to them doing any thing for the people as opposed to special interests groups that are backed by big money.

This video puts into 2 graphs which should be absolutely clear what the Princeton article found in it's research. Proposed legislation like Cory Booker's vs what the FAA has proposed will be an interesting effort to watch and potentially pretty devastating to not just us as a group of multirotor flyers, but also possibly just another of a long continuing policy of monied interests setting the table for their own benefit at the expense of us, the American people.

I recommend you all watch this, like all 10 people that are reading this thread. I'm retired so not sure how much this effects me, but for those who want to get into business with their multirotors, if this goes through, 95% of the people flying today will more than likely be shut out. As an old duo signing team said, and the beat goes on, la di da di da.
 
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Old Man

Active Member
I sat through a couple long Power Point presentations put on by people that are participating members of the FAA ARC committee and also employed at higher levels of the corporate aerospace group. They were "closed" meetings intended for educating aerospace "insiders" as to the direction the government was being directed to take, including equipment and operator certification requirements. Considerable time was devoted to system test certification processes, the facility that would be in charge of the testing, documentation requirements, and discussions about current frequency congestion in the U.S. Part of what was presented in your copy of the proposed bill aligned closely with what was presented in those meetings.

I can't relate specific meeting content because of legal agreements but the short version is we all better pray that Part 107 becomes law, and does so very quickly. Corporate aerospace bought the government officials that will be writing and enacting UAS law quite some time ago and what we do is not included in their plan. Some of the government working committees developing new law are chaired by aerospace leadership. Consider where their loyalties are. They are not altruistic people, and for the most part do not understand the operation of what they preside over. They are business people first and foremost, with corporate revenues their only interest. They only speak the language of money.
 

Wow. That's a pretty scary assessment. Do we know, specifically, who is spearheading these legislative efforts? Because I really do think it could benefit us to form some kind of writing campaign to appeal to these individuals and at least alert them to our presence and our needs as small business owners in this new industry. How this could be accomplished, I'm not sure. But if we want ANY of this to go our way, we need to have a voice in the process. Otherwise we really have no right to ***** about anything.
 

Old Man

Active Member
I don't think the leadership of Lockheed, General Atomics, Boeing, Northrup, Amazon, and a few others will be all that interested in what you have to say. Last year alone Boeing provided about $20 million to political action committees for both parties and numerous lobbyists. The other aerospace giants did similar. Politicians are not driving the government, corporate money is. Our government is bought and sold daily and the evidence of this is blatant. This is not a political statement, just simple fact. If you want to correct the problem the action starts by reviewing voting records of Congressional members and responding in kind at the voting booth.
 

jfro

Aerial Fun
I don't think the leadership of Lockheed, General Atomics, Boeing, Northrup, Amazon, and a few others will be all that interested in what you have to say. Last year alone Boeing provided about $20 million to political action committees for both parties and numerous lobbyists. The other aerospace giants did similar. Politicians are not driving the government, corporate money is. Our government is bought and sold daily and the evidence of this is blatant. This is not a political statement, just simple fact. If you want to correct the problem the action starts by reviewing voting records of Congressional members and responding in kind at the voting booth.


Post #13 proves the point of money is driving our laws. Watch 5 minutes of the video. This has been going on for decades, long before the Supreme court ruled that corporations are like people and have the same rights. Both Parties.
 

Old Man

Active Member
I'm with you all the way. Thanks for the video. I wish he would have named the study for deep reference purposes.


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