John Collins
En-Route
I submitted the following comment to the NPRM:
Small UAS NPRM will cause mid airs
- Thread starter John Collins
- Start date
RyanShort1
Final Approach
Seems like it would need to be more like 4-5 miles to protect the glideslope in case of a navigation or communications systems failure on board the drone, and we've already seen guys do stuff like this:
https://www.youtube.com/watch?v=FOdl-NDv3NE
I was flying in that same airspace that same day and only a few hours difference.
Of course the problem with that is that places like the Metroplex are the places where these people want to use UAVs the most. If you couldn't fly a drone within 5 miles of an airport in Dallas, you'd be pretty limited where you could fly. Maybe in VFR conditions only and a strobe on the drone?
Ryan
Last edited:
Howard Wilson
Line Up and Wait
Maybe kids should be allowed to ride their 'Big Wheels' in the street......
Checkout_my_Six
Touchdown! Greaser!
and ban all birds near airports.....in class G airspace or otherwise.
and ban all birds near airports.....in class G airspace or otherwise.
Silly comment.
Birds cannot be regulated; and, birds actually try to see and avoid (usually successfully).
35 AoA
Pattern Altitude
when I lived in MS, our weirdo neighbors would let their kids (barely tall enough to see over the steering wheel) drive their ATV around the cul-de-sac and it was about 36 hours before they plowed into my roommates car, broadside. I might have been annoyed, but they always kept our fridge/freezer stocked with venison that they trucked out from hunts in said SUV so we let it slide
RyanShort1
Final Approach
I don't think the fears are overplayed. Model rockets go straight up and back down pretty much. Pretty small window of hitting one. Usually a thin / lightweight bit of cardboard that doesn't really have that much energy. Personally not very worried about it even if a rocket went through the prop arc.
MUCH larger window to hit a drone orbiting around a site, or doing what you see in the video I posted. You multiply what's already happening by 50 or so and it's bound to happen.
John Collins
En-Route
Seems like it would need to be more like 4-5 miles to protect the glideslope in case of a navigation or communications systems failure on board the drone, and we've already seen guys do stuff like this:
https://www.youtube.com/watch?v=FOdl-NDv3NE
I was flying in that same airspace that same day and only a few hours difference.
Of course the problem with that is that places like the Metroplex are the places where these people want to use UAVs the most. If you couldn't fly a drone within 5 miles of an airport in Dallas, you'd be pretty limited where you could fly. Maybe in VFR conditions only and a strobe on the drone?
Ryan
Make your comment to the NPRM, I made mine.
KSCessnaDriver
Pattern Altitude
I was 10 years old and had one that would do 3000 ft no sweat.
That said, I don't think that these small UAS are a big deal.
RyanShort1
Final Approach
I've been working on it.
RyanShort1
Final Approach
My comment:
I am a commercial pilot, flight instructor, and aerial photographer. As a result, I have several ways in which I interact with the National Airspace System that will likely intersect with the proposed rules.
It is my belief that most UAS interactions that will cause conflict will occur in two areas. The first area is locations with dense urban populations and the second area is agricultural areas.
I believe that if UAS are to be regulated, there need to be modifications to the rules in at least three areas: Conditions of flight, visibility, and communications requirements.
Regarding conditions of flight as a commercial / instrument rated pilot, I am concerned that the proposed restriction to daylight hours for UAS should also be modified to include specific vertical VFR weather minimums. Instrument rated-pilots on IFR flight plans are given "safe zones" for instrument approaches. These zones may take them down as low as 2-300 feet while on an approach on either end of the runways. The NPRM allowance of UAS within five miles of an airport is is well within an area of potential hazard if a UAS lost communications or had a control system failure. A conflict at low level with an aircraft on an instrument approach during daylight IFR conditions would be at a very vulnerable time for any pilot, especially if a critical aircraft component was damaged or an upset condition occurred. In addition, a sizeable number of the airports where an instrument approach may be made are airports where there is no control tower, or any reasonable means of alerting a pilot to potential danger from a UAS failure.
Regarding visibility. As an aerial photographer, I probably spend more time over dense urban areas than many pilots. We are always mindful of the rules regarding 1000' minimum altitudes over the highest obstacle within a 2000' radius and the requirement to have enough altitude to make an emergency landing without undue hazard to persons or property on the surface. Small UAVs, with their different composition will be more hazardous than birds or balloons to these types of operations. Typically, a balloon sized-object that is below the horizon can be spotted with reasonable distance to see and avoid. Birds are harder to spot, but they also typically do not climb into the path of an aircraft. I have seen UAS in flight before. Small recreational R/C model aircraft are typically easier to see because their pilots often paint them bright colors and fly them in predictable locations. A commercial UAS on the the other hand is likely to be even harder to spot than a bird, balloon, or R/C aircraft because of it's nature. Quadcopters and hexcopters blend into the surroundings of an urban environment very well and are capable of being much harder to spot do to their ability to move very slowly or even hover. They are also capable of climbing directly into the flight path of an aircraft that cannot see them below the area obstructed by the nose. I believe that there should be at minimum a high-visibility scheme requirement, ideally, a strobe requirement as well.
Regarding communications. I see two areas of serious concern here in a couple of scenarios:
First, if there is a UAS being used in an agricultural field, there needs to be a way to coordinate with local aerial applicators (spray planes, helicopters) or with someone who can give aerial applicators a heads up warning of their location and use. Aerial applicators typically fly at low-level en-route to their fields and cross numerous fields in transit. Unannounced UAV use may pose a significant hazard to them even with the three-mile visibility limit as a low-flying aircraft may not be visible over the treeline.
Second, there needs to be a way to quickly alert controllers in urban areas such as Dallas or Houston of the loss of control of a UAS and there needs to be no penalty for such self-reporting in order to make it something that an operator does quickly and without hesitation.
Third, there needs to be a way for a UAS operator in the area around a Class E instrument approach area to quickly alert someone, somehow of a UAS system failure that would endanger any aircraft making an instrument approach to that airport.
Thank you for looking at my comments. I am not against the use of UAS, but I believe that it will need to be done responsibly.
I am a commercial pilot, flight instructor, and aerial photographer. As a result, I have several ways in which I interact with the National Airspace System that will likely intersect with the proposed rules.
It is my belief that most UAS interactions that will cause conflict will occur in two areas. The first area is locations with dense urban populations and the second area is agricultural areas.
I believe that if UAS are to be regulated, there need to be modifications to the rules in at least three areas: Conditions of flight, visibility, and communications requirements.
Regarding conditions of flight as a commercial / instrument rated pilot, I am concerned that the proposed restriction to daylight hours for UAS should also be modified to include specific vertical VFR weather minimums. Instrument rated-pilots on IFR flight plans are given "safe zones" for instrument approaches. These zones may take them down as low as 2-300 feet while on an approach on either end of the runways. The NPRM allowance of UAS within five miles of an airport is is well within an area of potential hazard if a UAS lost communications or had a control system failure. A conflict at low level with an aircraft on an instrument approach during daylight IFR conditions would be at a very vulnerable time for any pilot, especially if a critical aircraft component was damaged or an upset condition occurred. In addition, a sizeable number of the airports where an instrument approach may be made are airports where there is no control tower, or any reasonable means of alerting a pilot to potential danger from a UAS failure.
Regarding visibility. As an aerial photographer, I probably spend more time over dense urban areas than many pilots. We are always mindful of the rules regarding 1000' minimum altitudes over the highest obstacle within a 2000' radius and the requirement to have enough altitude to make an emergency landing without undue hazard to persons or property on the surface. Small UAVs, with their different composition will be more hazardous than birds or balloons to these types of operations. Typically, a balloon sized-object that is below the horizon can be spotted with reasonable distance to see and avoid. Birds are harder to spot, but they also typically do not climb into the path of an aircraft. I have seen UAS in flight before. Small recreational R/C model aircraft are typically easier to see because their pilots often paint them bright colors and fly them in predictable locations. A commercial UAS on the the other hand is likely to be even harder to spot than a bird, balloon, or R/C aircraft because of it's nature. Quadcopters and hexcopters blend into the surroundings of an urban environment very well and are capable of being much harder to spot do to their ability to move very slowly or even hover. They are also capable of climbing directly into the flight path of an aircraft that cannot see them below the area obstructed by the nose. I believe that there should be at minimum a high-visibility scheme requirement, ideally, a strobe requirement as well.
Regarding communications. I see two areas of serious concern here in a couple of scenarios:
First, if there is a UAS being used in an agricultural field, there needs to be a way to coordinate with local aerial applicators (spray planes, helicopters) or with someone who can give aerial applicators a heads up warning of their location and use. Aerial applicators typically fly at low-level en-route to their fields and cross numerous fields in transit. Unannounced UAV use may pose a significant hazard to them even with the three-mile visibility limit as a low-flying aircraft may not be visible over the treeline.
Second, there needs to be a way to quickly alert controllers in urban areas such as Dallas or Houston of the loss of control of a UAS and there needs to be no penalty for such self-reporting in order to make it something that an operator does quickly and without hesitation.
Third, there needs to be a way for a UAS operator in the area around a Class E instrument approach area to quickly alert someone, somehow of a UAS system failure that would endanger any aircraft making an instrument approach to that airport.
Thank you for looking at my comments. I am not against the use of UAS, but I believe that it will need to be done responsibly.