I am a VFR, private pilot although I have been inactive for several years due to hearing loss.
I have been a member of the aero modeling community for over 50 years, starting with control line and single channel RC.
During this time I have left and re-entered this rewarding hobby several times, but for the last several years I have been involved in the more advanced UAV and FPV areas of the hobby.
Our hobby has always had an exceptional safety record, given the millions of RC model aircraft flights and the relatively few serious incidents.
It seems to me that the FAA should be looking to us for guidance rather than seeking to bring our hobby to its knees.
The AMA has certainly had a major role in keeping our activity and us as safe as it has and yet your recent "Notice of an interpretation concerning model aircraft" appears to go against that.
You are removing from their capable and very safety oriented guidance and support the entire set of criteria which we have been successfully operating under.
It also seems to me you are taking on a completely unenforceable set of interpretations which will leave virtually all of the existing model airplane pilots in the unenviable position of suddenly finding themselves in the position of at various times now flying what has come to be by your interpretation an unauthorized UAS in NAS airspace and thus under your immediate jurisdiction.
For instance, in the course of normal RC airplane flying, it is perfectly common to occasionally lose sight of your airplane or air vehicle momentarily behind a tree or some other obstruction.
By the strict interpretation you have made for "visual line of sight" and your interpretation of violating any of the "rules" you have established, this vehicle would immediately become an unauthorized UAS violating NAS airspace and subject to immediate legal action by you.
Another area of ambiguity is you taking responsibility for model airplane ground accidents, traditionally this has been subject to normal civil and criminal law, and NAS airspace interference has been interpreted as a model airplane interfering with manned aircraft. It seems to me that is they way it should remain unless you really want to take on the thousands of inconsequential model aircraft crashes that occur every year.
In fact your current interpretations and proposed "rules" completely countermand the very thing that Congress ordered you to not do.
If a model airplane is interfering with an aircraft or airport operations, that is your concern, if it crashes into my neighbors rose bush it is not and should not be your concern. (For your own sake's you really need to realize this).
You are overreaching and reinterpreting your own laws and rules to draw the conclusions you have.
As for banning FPV goggles based on a narrow and unsupported by any other body anywhere reinterpretation of "Visual Line Of Sight" to suit your own ill advised desires.
You are the ones that "interpreted" (decided - made up) that no obstruction at all must be between the operators eyes and the airplane and then defined binoculars and FPV goggles as obstructions.
What you have not listed are sunglasses and even eye glasses or contact lens's, surely they are just as significant an obstruction as binoculars (which actually aid, not hinder your vision).
Of course, there are the FPV goggles which you are clearly bent on banning.
Certainly in some sense they do obstruct line of sight, but consider the alternative which you are not banning and in fact can't ban, flying FPV with a monitor.
To use a monitor, the operator must divert their eyes (voluntarily) from the plane to see the monitor, but since it is their choice when and how (and LOS remains unobstructed), you cannot simply ban this.
The reality is this is a less safe mode of FPV flight because the monitors are an intrinsically less satisfactory mode of FPV flying, they provide less visual detail and are subject to external effects (Sun shining on the screen and other distractions).
The immersive aspect of goggle based FPV flying with the extreme wide angle cameras that are used is what actually makes them safer, in fact, even safer than normal ground based RC flight.
FPV goggles can be discarded in a second and regaining orientation to see the plane is a learned skill, like our other piloting skills, it is not simply a hazard to be banned.
The AMA helps us get the training we need to learn how to do that kind of task successfully and safely.
It is much easier to see and avoid hazards around you with the goggles than either with a "monitor screen" or even than flying normal ground referenced RC.
You are, in fact, contributing to a less safe flying environment in the future rather than to increased safety as would seem to be your primary mandate.
You would be so much better off simply establishing the AMA standards for safe and reasonable flight and then establishing penalties for interfering with your NAS operations.
Gary R. McCray
An excellent "response" to the FAA from fellow DIYDrones member Brian Mahaney
To whom it may concern,
Science, technology, engineering, math (STEM): as a nation, The United States has made it a goal to promote these fields in order to remain competitive in the world. No other single force has promoted this goal more than the model aircraft hobby. We, as a nation, have not seen this many individuals drawn to technology with so much passion in decades. In recent years, this hobby has encouraged individuals of all ages to pursue knowledge about electronics, programming, radio communications, math, avionics, aerodynamics, propulsion, and many other technical aspects of the field.
Promotion of these technologies through model aircraft is not restricted to The United States. This is a world wide phenomenon. Great advances and innovations are happening in government, universities, and garages around the world. But there are places where the progress is slow: places where government is stifling the free flow of advancement. And now, in the freest place on earth, misguided and uneducated government is threatening to stifle innovation and thus cripple the ability of The United States to compete in an area that much of the world will quickly surpass us.
The FAA's recent Interpretation of the Special Rule for Model Aircraft is grossly over-restrictive. If this is an indication of the agency's direction on this topic, The United States is in serious trouble for the future, and those who do not think so greatly underestimate the impact that this technology is having and will have on the future. We do not want to lag behind in this area. We need individuals educated and experienced in these areas as time goes on.
If we allow relative freedom of individuals to experiment and innovate, we will produce generations of people with “natural” abilities in the STEM fields. If we stamp out experimentation by nearly all individuals, we will fall behind technologically. It is that simple. Orville and Wilbur Wright, and many others who contributed to aviation in its infancy, would not have been able to make the progress that they did in such a restrictive environment.
Fear seems to be the driving force for the FAA. If preservation of safety is the primary goal, a little education on the topic will show that flying FPV, with on-board stabilization, and return to launch capability is actually much safer than traditional third person flight. It increases situational awareness. It does not decrease it. It introduces redundant safety measures that traditional models never had.
I respectively ask that those in leadership work to preserve the freedom that allows innovation and advancement such as that which is currently taking place in The United States. Please reconsider this highly restrictive direction that we seem to be taking.