NPRM proposes changes to 14 CFR 91.113 for Drone operations

Daleandee

Daleandee

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Dale Andee
avbrief.com

New Rules Would Give Drones Right of Way Under Some Circumstances - AvBrief.com

New NPRM would change right-of-way rules, allowing drones priority over some crewed aircraft in low-altitude airspace.
avbrief.com avbrief.com

"In all other airspace within the Part 108 operating regime of 400 feet AGL and below, a drone would have the right of way over manned aircraft not broadcasting a (ADS-B) signal." :oops:

If you'd like to comment: https://www.federalregister.gov/doc...ystems-beyond-visual-line-of-sight-operations
 
I looked at the NPRM.

All I see is this: "UAS operating under part 108 would be required to yield right of way to traffic broadcasting their position using Automatic Dependent Surveillance-Broadcast (ADS-B) Out equipment."

I think the issue is more of detecting capability rather than "yield to the drone that you can't even see". The drone might not be able to detect an aircraft that doesn't broadcast ADS-B out.

I still think the NPRM could use a bit of clarification.
 
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Lindberg said:
Do they not broadcast ADS-B? If not, then they might have to yield to UAS in certain, limited areas.
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Some do, but likely not all. I'm also not sure how having ADS-B matters much for real-time drone operations, unless the operator has a real-time ADS-B-in receiver, *and has ground reception for ADS-B at that location*. Using internet ADS-B is inadequate for avoidance. This basically seems like an airspace give-away to Walmart, Amazon, etc.
 
This is my comment here and the one I submitted:

I read the proposed rule to mean: The less maneuverable, more visible aircraft must yield to a nearly invisible, more maneuverable non-ADS-B broadcasting drone?

That is the reverse of the current standard see-and-avoid rules.

Beyond the specific issues of the danger to crop dusters and helicopters, my home field and many, many others are in agricultural areas. Many such airfields directly border agriculture fields. More and more drones are being use to monitor agriculture.

In my case, only a two-lane road separates the southern end of my home runway from an active growing field. Nearly the entire final approach leg is flown below 400 AGL over agriculture fields. The road is so close, we have to watch for semi-trailers when landing. Now I'll be required to see and avoid a potential drone on its mission to determine if the field is ready for harvest? While I am concentrating on landing.

Pilots and passengers will be hurt if this proposed rule becomes final.

I will not comment on the likely aviation experience of the author(s) of this proposed rule.
 
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My 10 cent understanding of this new Part 108, it is really tailored for the Walmart and Amazon's of the word. The certification requirements are more akin to Part 121/135 level operations and would be more expensive and onerous to the average drone operator, even the professional ag drone operators.

The way it has been described to me, is that these high end drone delivery operations would essentially get a block of airspace, almost like a TFR, that is stood up during operations. Those blocks would be at lower altitudes, and avoid airports, helipads, and approach zones to both. Manned aircraft will be expected to avoid said airspace, which except for helicopter and crop dusters we probably wouldn't be in anyway.

One of my initial thoughts based on that information, which may be incorrect, is that our maps are about to get crowded with all this new Special Use airspace. It will become useless noise that will be ignored, much like the 10,000+ tower and obstruction NOTAMs we get in every briefing.

I also question the business case for drone delivery. One problem is noise. Even the smallest drone these days sounds like an angry mosquito. Multiple that by 100, the public isn't going to be happy. Another problem is potential theft or loss of product. What will happen when today's porch pirates start taking swipes at these drones? The other issue I see is liability. One of these drones has a failure that crashes into someone's house or car, breaks a window, or potentially injures someone, I'm sure insurance underwriters are going to love this one.

Or maybe I'm just getting old...

Stay off my lawn!
 
Jeff Oslick said:
Some do, but likely not all. I'm also not sure how having ADS-B matters much for real-time drone operations, unless the operator has a real-time ADS-B-in receiver, *and has ground reception for ADS-B at that location*. Using internet ADS-B is inadequate for avoidance. This basically seems like an airspace give-away to Walmart, Amazon, etc.
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Drones operating under this rule would be required to avoid aircraft broadcasting ADSB. There's A LOT more detail, including reasoning, in the nprm than in the scarebait article.
 
I wonder how many comments they'll get from people responding to AOPA/EAA's existence-justifying rage-bait articles versus people responding to the actual proposed rules.
 
Lindberg said:
Drones operating under this rule would be required to avoid aircraft broadcasting ADSB.
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Quoting myself on this:
AV8R_87 said:
All I see is this: "UAS operating under part 108 would be required to yield right of way to traffic broadcasting their position using Automatic Dependent Surveillance-Broadcast (ADS-B) Out equipment."
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To me this reads like they won't have to yield to a non ADS-B aircraft. Yet there are words in the rule about implementing other aircraft detection methods.
I'd rather have the NPRM say "yield to traffic broadcasting their position or detected through other sensors".
 
This implies every drone will have ADS-B In functionality.
 
Domenick said:
This implies every drone will have ADS-B In functionality.
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Part 108 is not Part 107, which are the rules i fly. Part 108, if you haven't read the summaries, is BLVOS - Beyond Line of Sight. That's the Amazon money talking. Even for Part 107, there are 2 categories based on weight, and both require continuous visual observation with the eyes, not any type of monitor.
 
Jeff Oslick said:
How in the #$!% does this work with crop dusters and helicopters?
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There are drone crop dusters these days...huge buggers (200+ pounds) with 10 gal tank, and huge price tags - an easy $35,000. The big fields still use the airplanes but the small fields and wierd areas, the drones are very useful. Saw one demonstrated this summer at the CAP drone camp.
 
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