Paraphrasing the e-mail from USHPA (copied below), drones will be given the right of way over all aircraft in the airspace below 500 feet AGL, except those equipped with ADS-B or TABS, under the latest recommendation from the Aviation Rulemaking
Committee for Unmanned Aircraft Systems operating Beyond Visual Line Of Sight. I'm posting this here in case some RAS readers were not aware of the proposal and want to submit comments regarding this proposal to the FAA (at 9-FAA-UAS-BVLOS@faa.gov)
before the August 2, 2022 deadline.

Below is a copy of the e-mail. The links are very long so I'll copy them at the end

Hello USHPA Members,

The Aviation Rulemaking Committee for Unmanned Aircraft Systems operating Beyond Visual Line Of Sight (UAS BVLOS ARC) has released its final report containing specific recommendations to the FAA for changes to 14 CFR Part 91 (FAR Part 91). A copy of the
ARC report is available here. https://4xe68.r.a.d.sendibm1.com/mk/cl/f/WfVXyRioVqRy5agDyAnwj08tP3vTFrgZ0f1hvFccQYQoOL-_sPYfzPIzDfoaYAcEGjdugYjX9hoL8h7ngWTQNcwbRQTZ3zJYlFAhCbOOAwUP6msDuoeY_-L8C19YOx7E92uMg_
7bjLH3blc4fv6a3E5f5oLmlqvRaHtRiajxM8eT0jUUrNszPKC1gU59duQRyv7h4tb8vPJqpF5Y0RGi_OjNMoyC4liOMablB0kDKQzzJPxqZm68DcHcLi33u0yIHLph9N2pjryqpvtx-kGSBYd551RrEH6lUUmRZO-eVsHofQ1XpSYOReisxq8TQYX4-RY-4oSWU1H43Q

The FAA is accepting comments on the ARC report until August 2nd. Comments must be submitted by email to this email address: 9-FAA-UAS-BVLOS@faa.gov

The USHPA National Coordinating Committee has studied the report and developed a response that has been submitted to the FAA. A copy of the USHPA response can be found here.

The EAA and other air sports organizations have also submitted comments, which can be read here:

Experimental Aircraft Assn.
US Powered Paragliding Assn.
Balloon Federation of America


The primary objection that all of these responses have in common to the ARC Report recommendations is to the specific recommendations that would give UAS (drones) right of way over all aircraft in the airspace below 500 feet AGL except those equipped
with ADS-B or TABS. Responders from air sports organizations whose members regularly use this airspace, i.e. hang glider and paraglider pilots, hot air balloon pilots, powered parachute pilots, paramotor pilots, etc, are unanimous in their judgement that
this recommendation is unworkable and grossly inconsistent with safety.

USHPA members are invited to study the documents at the links provided, and to submit a response to the FAA if they so desire. Note that the deadline for submission is August 2nd, and that only submissions by email to the email address given above will
be accepted.

Best Regards,

USHPA National Coordinating Committee

Here are the links:

A copy of the ARC report is available here: https://4xe68.r.a.d.sendibm1.com/mk/cl/f/WfVXyRioVqRy5agDyAnwj08tP3vTFrgZ0f1hvFccQYQoOL-_sPYfzPIzDfoaYAcEGjdugYjX9hoL8h7ngWTQNcwbRQTZ3zJYlFAhCbOOAwUP6msDuoeY_-L8C19YOx7E92uMg_
7bjLH3blc4fv6a3E5f5oLmlqvRaHtRiajxM8eT0jUUrNszPKC1gU59duQRyv7h4tb8vPJqpF5Y0RGi_OjNMoyC4liOMablB0kDKQzzJPxqZm68DcHcLi33u0yIHLph9N2pjryqpvtx-kGSBYd551RrEH6lUUmRZO-eVsHofQ1XpSYOReisxq8TQYX4-RY-4oSWU1H43Q
A copy of the USHPA response can be found here: https://4xe68.r.a.d.sendibm1.com/mk/cl/f/EPwgaIWR843QZLi_HAzVKM4qbt-f8ZB5MYeJSnrxyYjkMnpqYlXCS_pFkL_p-85KCwGpn1e3qXNqOSdaVqLcn0pfgN1dDP4gzc-mJKAQHnOcpQrGZq1m8zIWcRu6KiiPmm0xtPohshj9Jg28aNNTUB_ODx6DT_
3KV4LtHa6LeZS0ww06UE7x5FvxM-5sTv9HzCrZKTu8uhasBuMbbFQoP4JvU8k1a7WZaerBaiWhnCAon6kq
Experimental Aircraft Assn response: https://4xe68.r.a.d.sendibm1.com/mk/cl/f/ng-GUTebA8Qq0AYDQmNh-5sR7_AOYhQQFqpXivJrTD-XOxu14YFP4mKTx0uJ15s-IPuZm5bJF4eqr9zp28DHVZ6vSlS54A43yx7hpxVglOftCDfb3GFZiSGLvvI3CpLZ3KqYQZgc9x1KZmPode9cOzlqHfWERb1uOLjy_
SvE80KRyP0GEna_r2D5_hkuFg3ys3JxaDwCTxx8CsrvBNBisInV94U2Uy3o0nyINqMJ-11i_jan
US Powered Paragliding Assn response: https://4xe68.r.a.d.sendibm1.com/mk/cl/f/fSjyNdubAFvLO8lD5XK0ouOyZRehjomOpRgPwgDdVC-Cmuddme_2RioWOMAd4urD-hWLGp2Ej4NE-i8fQjtxYoGGdXaVSiToEJlX2KshriKCzI14Lx7PkfpD9w99FyWKXaJHwb139o3dRHIn5KlU0KV0vEb_
knsa0UPZknhnERw1BH6md5Q5FaPr8i1VNBUbiDCuqMFRFqWMhzxZTNymqxHK_I3PGbRncYqxKH_gw0J_udvb
Balloon Federation of America response: https://4xe68.r.a.d.sendibm1.com/mk/cl/f/N-MRyFDZNQgcCf6inOrCjpePRbaL4lP4mjMq-8MTeSczJBgooiYwh4fZDeRQq8izVvtJYBUrE7RpCaBwqoO53FeP8pq4yIo5oVeUSVar9IOTVC1fQZsZQZ27WuDAyIGjaAA8-
3bZuygHR7RJLRbm7hRFhMcBQphMwzm4ohj9HXsnp0z1VsQ2WcmZvIQmkbNDZ-fQ9G36Tyor4LVBMfHB0pUGxJM3g43-Rwkj8nR1auzC9mG0

--- SoupGate-Win32 v1.05
* Origin: fsxNet Usenet Gateway (21:1/5)

Thank you Nico. I'll send my email opposing drones right now.

--- SoupGate-Win32 v1.05
* Origin: fsxNet Usenet Gateway (21:1/5)

On Sunday, July 31, 2022 at 5:52:06 PM UTC-4, Nicolas Bennet wrote:

Paraphrasing the e-mail from USHPA (copied below), drones will be given the right of way over all aircraft in the airspace below 500 feet AGL, except those equipped with ADS-B or TABS, under the latest recommendation from the Aviation Rulemaking

Committee for Unmanned Aircraft Systems operating Beyond Visual Line Of Sight. I'm posting this here in case some RAS readers were not aware of the proposal and want to submit comments regarding this proposal to the FAA (at 9-FAA-U...@faa.gov) before the
August 2, 2022 deadline.

Below is a copy of the e-mail. The links are very long so I'll copy them at the end

Hello USHPA Members,

The Aviation Rulemaking Committee for Unmanned Aircraft Systems operating Beyond Visual Line Of Sight (UAS BVLOS ARC) has released its final report containing specific recommendations to the FAA for changes to 14 CFR Part 91 (FAR Part 91). A copy of

the ARC report is available here. https://4xe68.r.a.d.sendibm1.com/mk/cl/f/WfVXyRioVqRy5agDyAnwj08tP3vTFrgZ0f1hvFccQYQoOL-_sPYfzPIzDfoaYAcEGjdugYjX9hoL8h7ngWTQNcwbRQTZ3zJYlFAhCbOOAwUP6msDuoeY_-L8C19YOx7E92uMg_
7bjLH3blc4fv6a3E5f5oLmlqvRaHtRiajxM8eT0jUUrNszPKC1gU59duQRyv7h4tb8vPJqpF5Y0RGi_OjNMoyC4liOMablB0kDKQzzJPxqZm68DcHcLi33u0yIHLph9N2pjryqpvtx-kGSBYd551RrEH6lUUmRZO-eVsHofQ1XpSYOReisxq8TQYX4-RY-4oSWU1H43Q

The FAA is accepting comments on the ARC report until August 2nd. Comments must be submitted by email to this email address: 9-FAA-U...@faa.gov

The USHPA National Coordinating Committee has studied the report and developed a response that has been submitted to the FAA. A copy of the USHPA response can be found here.

The EAA and other air sports organizations have also submitted comments, which can be read here:

Experimental Aircraft Assn.
US Powered Paragliding Assn.
Balloon Federation of America

The primary objection that all of these responses have in common to the ARC Report recommendations is to the specific recommendations that would give UAS (drones) right of way over all aircraft in the airspace below 500 feet AGL except those equipped

with ADS-B or TABS. Responders from air sports organizations whose members regularly use this airspace, i.e. hang glider and paraglider pilots, hot air balloon pilots, powered parachute pilots, paramotor pilots, etc, are unanimous in their judgement that
this recommendation is unworkable and grossly inconsistent with safety.

USHPA members are invited to study the documents at the links provided, and to submit a response to the FAA if they so desire. Note that the deadline for submission is August 2nd, and that only submissions by email to the email address given above will

be accepted.

Best Regards,

USHPA National Coordinating Committee

Here are the links:

A copy of the ARC report is available here: https://4xe68.r.a.d.sendibm1.com/mk/cl/f/WfVXyRioVqRy5agDyAnwj08tP3vTFrgZ0f1hvFccQYQoOL-_sPYfzPIzDfoaYAcEGjdugYjX9hoL8h7ngWTQNcwbRQTZ3zJYlFAhCbOOAwUP6msDuoeY_-L8C19YOx7E92uMg_

7bjLH3blc4fv6a3E5f5oLmlqvRaHtRiajxM8eT0jUUrNszPKC1gU59duQRyv7h4tb8vPJqpF5Y0RGi_OjNMoyC4liOMablB0kDKQzzJPxqZm68DcHcLi33u0yIHLph9N2pjryqpvtx-kGSBYd551RrEH6lUUmRZO-eVsHofQ1XpSYOReisxq8TQYX4-RY-4oSWU1H43Q

A copy of the USHPA response can be found here: https://4xe68.r.a.d.sendibm1.com/mk/cl/f/EPwgaIWR843QZLi_HAzVKM4qbt-f8ZB5MYeJSnrxyYjkMnpqYlXCS_pFkL_p-85KCwGpn1e3qXNqOSdaVqLcn0pfgN1dDP4gzc-mJKAQHnOcpQrGZq1m8zIWcRu6KiiPmm0xtPohshj9Jg28aNNTUB_ODx6DT_

3KV4LtHa6LeZS0ww06UE7x5FvxM-5sTv9HzCrZKTu8uhasBuMbbFQoP4JvU8k1a7WZaerBaiWhnCAon6kq

Experimental Aircraft Assn response: https://4xe68.r.a.d.sendibm1.com/mk/cl/f/ng-GUTebA8Qq0AYDQmNh-5sR7_AOYhQQFqpXivJrTD-XOxu14YFP4mKTx0uJ15s-IPuZm5bJF4eqr9zp28DHVZ6vSlS54A43yx7hpxVglOftCDfb3GFZiSGLvvI3CpLZ3KqYQZgc9x1KZmPode9cOzlqHfWERb1uOLjy_

SvE80KRyP0GEna_r2D5_hkuFg3ys3JxaDwCTxx8CsrvBNBisInV94U2Uy3o0nyINqMJ-11i_jan

US Powered Paragliding Assn response: https://4xe68.r.a.d.sendibm1.com/mk/cl/f/fSjyNdubAFvLO8lD5XK0ouOyZRehjomOpRgPwgDdVC-Cmuddme_2RioWOMAd4urD-hWLGp2Ej4NE-i8fQjtxYoGGdXaVSiToEJlX2KshriKCzI14Lx7PkfpD9w99FyWKXaJHwb139o3dRHIn5KlU0KV0vEb_

knsa0UPZknhnERw1BH6md5Q5FaPr8i1VNBUbiDCuqMFRFqWMhzxZTNymqxHK_I3PGbRncYqxKH_gw0J_udvb

Balloon Federation of America response: https://4xe68.r.a.d.sendibm1.com/mk/cl/f/N-MRyFDZNQgcCf6inOrCjpePRbaL4lP4mjMq-8MTeSczJBgooiYwh4fZDeRQq8izVvtJYBUrE7RpCaBwqoO53FeP8pq4yIo5oVeUSVar9IOTVC1fQZsZQZ27WuDAyIGjaAA8-

3bZuygHR7RJLRbm7hRFhMcBQphMwzm4ohj9HXsnp0z1VsQ2WcmZvIQmkbNDZ-fQ9G36Tyor4LVBMfHB0pUGxJM3g43-Rwkj8nR1auzC9mG0
After reading 14 of the 381 pages of bureaucratic bloviating nonsense I am more confused than ever. The BVLOS that they want to endorse is questionable in many ways. Keep in mind that I have a serious fleet of drones, and this airspace plan makes no
sense. Maybe I can stumble through all 381 pages but I doubt it will be any more enlightening. Old Bob, The Purist

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That's ok, Bob, we're discussing things with motors here. We don't expect you to understand. :)

On Sunday, July 31, 2022 at 3:23:24 PM UTC-7, youngbl...@gmail.com wrote:

After reading 14 of the 381 pages of bureaucratic bloviating nonsense I am more confused than ever. The BVLOS that they want to endorse is questionable in many ways. Keep in mind that I have a serious fleet of drones, and this airspace plan makes no

sense. Maybe I can stumble through all 381 pages but I doubt it will be any more enlightening. Old Bob, The Purist

--- SoupGate-Win32 v1.05
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My email response:

I oppose any measure to give UAV's (drones) the right of way over all aircraft in the airspace below 500 feet AGL, except those equipped with ADS-B or TABS. While I recognize the potential that drones have in the future of air operations, the top
priority in any action to move towards integration must be the safety of crewed aircraft, including gliders, balloons, and ultralight aircraft that currently do not have to be equipped with ADS-B.

I oppose any measure to allow drones to be flown beyond line of sight of the operator, due to the risk of collision with a manned aircraft.

It is common for gliders to thermal below 500 feet agl. Glider pilots also practice approaches to land in fields in preparation for a forced landing in a field away from an airport. Gliders frequently make off-airport landings in fields. Airplane
pilots also regularly train by flying low altitude approaches to land in fields. The task saturation in performing these maneuvers is very high. Adding a scan for drones is beyond a pilot's capability in these situations. These pilots would be in grave
danger of a mid-air from a proliferation of low level drones.

Today a military helicopter flew over my house at 400 feet agl. I looked for it on ADSB Exchange on my cell phone and it did not show up. In my experience, military aircraft do not usually show up on ADSB receivers, and it is my understanding that the
military is not required to display ADSB. I cringe thinking about an Amazon package being flown by an autonomous drone hitting the rotor blades of a large military helicopter over a crowded subdivision.

I have had a bird strike with a vulture, and it tore a hole in the leading edge of the glider all the way to the spar. After landing, I was surprised that the wing did not break catastrophically, and was glad to be flying with a ballistic parachute
system. It is my understanding that a vulture has much less mass than most small drones being flown today, and in the future drones will be much heavier, especially while transporting cargo.

STOL aircraft regularly land in small fields, and this activity is greatly increasing due to the popularity of STOL aircraft and off-airport landings. Those pilots are at grave danger from low level drones.

It is legal for all aircraft, including STOL aircraft, ultralights, gliders, and balloons, to fly to ground level when more than 500 feet from any person or structure. The UAS-BVLOS Report (the Report) does not mention any of the above listed low
altitude airspace uses and instead concentrates on crop dusting and other commercial activities. It is my belief that the Report is not aware of the many low altitude flights being conducted all over the US on a daily basis. Mid-air collisions between
drones and manned aircraft will happen all too regularly if drones are allowed to proliferate, and especially if they are allowed to be flown beyond line of sight.

Sincerely,
James Lee
Commercial pilot, CFIA, CFIG

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On Sunday, July 31, 2022 at 7:54:09 PM UTC-4, Jim Lee wrote:

That's ok, Bob, we're discussing things with motors here. We don't expect you to understand. :)
On Sunday, July 31, 2022 at 3:23:24 PM UTC-7, youngbl...@gmail.com wrote:

After reading 14 of the 381 pages of bureaucratic bloviating nonsense I am more confused than ever. The BVLOS that they want to endorse is questionable in many ways. Keep in mind that I have a serious fleet of drones, and this airspace plan makes no

sense. Maybe I can stumble through all 381 pages but I doubt it will be any more enlightening. Old Bob, The Purist
Jim,
The first sentence "I oppose any measure to give UAV's (drones) the right of way over all aircraft in the airspace below 500 feet AGL, except those equipped with ADS-B or TABS."
seems to say that if a UAV is ADS-B or TABS equipped, having right of way over all other aircraft is ok.
Is this what you intend?

--- SoupGate-Win32 v1.05
* Origin: fsxNet Usenet Gateway (21:1/5)

On Sunday, July 31, 2022 at 5:08:34 PM UTC-7, quebec...@gmail.com wrote:

On Sunday, July 31, 2022 at 7:54:09 PM UTC-4, Jim Lee wrote:

That's ok, Bob, we're discussing things with motors here. We don't expect you to understand. :)
On Sunday, July 31, 2022 at 3:23:24 PM UTC-7, youngbl...@gmail.com wrote:

After reading 14 of the 381 pages of bureaucratic bloviating nonsense I am more confused than ever. The BVLOS that they want to endorse is questionable in many ways. Keep in mind that I have a serious fleet of drones, and this airspace plan makes

no sense. Maybe I can stumble through all 381 pages but I doubt it will be any more enlightening. Old Bob, The Purist

Jim,
The first sentence "I oppose any measure to give UAV's (drones) the right of way over all aircraft in the airspace below 500 feet AGL, except those equipped with ADS-B or TABS."
seems to say that if a UAV is ADS-B or TABS equipped, having right of way over all other aircraft is ok.
Is this what you intend?

No, Quebec, that is not what I intended. I copied the first paragraph from another responder and carried on from there.
I am opposed to any drone having any right of way over any manned aircraft. Thanks for spotting that.

--- SoupGate-Win32 v1.05
* Origin: fsxNet Usenet Gateway (21:1/5)

On 7/31/2022 5:08 PM, John Godfrey wrote:

On Sunday, July 31, 2022 at 7:54:09 PM UTC-4, Jim Lee wrote:

That's ok, Bob, we're discussing things with motors here. We don't expect you to understand. :)
On Sunday, July 31, 2022 at 3:23:24 PM UTC-7, youngbl...@gmail.com wrote: >>> After reading 14 of the 381 pages of bureaucratic bloviating nonsense I am more confused than ever. The BVLOS that they want to endorse is questionable in many ways. Keep in mind that I have a serious fleet of drones, and this airspace plan makes no

sense. Maybe I can stumble through all 381 pages but I doubt it will be any more enlightening. Old Bob, The Purist

Jim,
The first sentence "I oppose any measure to give UAV's (drones) the right of way over all aircraft in the airspace below 500 feet AGL, except those equipped with ADS-B or TABS."
seems to say that if a UAV is ADS-B or TABS equipped, having right of way over all other aircraft is ok.
Is this what you intend?

I thought it meant manned aircraft with ADS-D or TABS had the right of way over a drone.
This is possible because he drone can use the ADS-B/TABS transmissions to determine the
presence and path of the manned aircraft. Without the ADS-B/TABS transmissions, the drone
would have use cameras and visual recognition to give the manned aircraft the right of
way, which might not be reliable enough.

--
Eric Greenwell - USA
- "A Guide to Self-launching Sailplane Operation"
https://sites.google.com/site/motorgliders/publications

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On Sunday, July 31, 2022 at 8:47:18 PM UTC-7, Eric Greenwell wrote:

On 7/31/2022 5:08 PM, John Godfrey wrote:

On Sunday, July 31, 2022 at 7:54:09 PM UTC-4, Jim Lee wrote:

That's ok, Bob, we're discussing things with motors here. We don't expect you to understand. :)
On Sunday, July 31, 2022 at 3:23:24 PM UTC-7, youngbl...@gmail.com wrote: >>> After reading 14 of the 381 pages of bureaucratic bloviating nonsense I am more confused than ever. The BVLOS that they want to endorse is questionable in many ways. Keep in mind that I have a serious fleet of drones, and this airspace plan makes

no sense. Maybe I can stumble through all 381 pages but I doubt it will be any more enlightening. Old Bob, The Purist

Jim,
The first sentence "I oppose any measure to give UAV's (drones) the right of way over all aircraft in the airspace below 500 feet AGL, except those equipped with ADS-B or TABS."
seems to say that if a UAV is ADS-B or TABS equipped, having right of way over all other aircraft is ok.
Is this what you intend?

I thought it meant manned aircraft with ADS-D or TABS had the right of way over a drone.
This is possible because he drone can use the ADS-B/TABS transmissions to determine the
presence and path of the manned aircraft. Without the ADS-B/TABS transmissions, the drone
would have use cameras and visual recognition to give the manned aircraft the right of
way, which might not be reliable enough.

--
Eric Greenwell - USA
- "A Guide to Self-launching Sailplane Operation" https://sites.google.com/site/motorgliders/publications

The email link is obscured - spell out the @ symbol.

--- SoupGate-Win32 v1.05
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My response, submitted to the NPRM Docket this morning:

I am against giving any unmanned aircraft (drone) right-of-way over any manned aircraft. Even if equipped with ADS-B/TABS equipment, there is no guarantee that the drone will be able to avoid a collision with a manned aircraft without full operator
control and visual contact with it. And drones are so small that it is difficult, if not impossible for the pilot of a manned aircraft to "see and avoid" contact. Drones also are capable of hovering, rendering them virtually invisible, even with an
active visual scan by a pilot. Motion is what attracts the eye. This is the basic lesson stressed in every training lesson on visual acquisition of potential in-flight hazards. Drones' unpredictable flight paths, from a hover to a sudden dart up, down,
left, right, forward or backward make it impossible to make a decision on how to avoid them. The concept of giving an unmanned aircraft priority over a manned aircraft is ludicrous, especially in the Beyond Visual Line of Sight (BVLOS) realm, where the
drone operator's situational awareness is greatly reduced.

Much of commercial drone activity is autonomous, or nearly so, and the operator is spending more time controlling the onboard equipment (camera, infrared sensors, etc.) than actually flying the drone in a responsible manner. Algorithms are geared toward
achieving stable flight with little operator input in order to provide optimum parameters for the sensors. Little effort is required to actually FLY the drone, as many systems simply take the operator as much out of the loop as possible. Without full
operator control and active situational awareness, the drone is essentially a hazard to other aircraft, simply because it doesn't know (or care) that there may be something else out there. Remember that not ALL manned aircraft are required to have
Transponders or ADS-B/Tabs equipment. Gliders, hang gliders and balloons do not have engine-driven electrical systems, and are therefore exempt from the mandate that they shall be so equipped.

Can you imagine the outrage from the public if the National Highway Transportation Safety Administration proposed giving right-of-way priority to self-driving cars? Just because Domino's wants to cut costs does not mean that a pizza delivery service
should be absolved from running down a kid in the street. Why are pilots and their passengers going to be subjected to this idiocy?

Respectfully submitted,

Mark Mocho

--- SoupGate-Win32 v1.05
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On Sunday, July 31, 2022 at 7:54:09 PM UTC-4, Jim Lee wrote:

That's ok, Bob, we're discussing things with motors here. We don't expect you to understand. :)
On Sunday, July 31, 2022 at 3:23:24 PM UTC-7, youngbl...@gmail.com wrote:

After reading 14 of the 381 pages of bureaucratic bloviating nonsense I am more confused than ever. The BVLOS that they want to endorse is questionable in many ways. Keep in mind that I have a serious fleet of drones, and this airspace plan makes no

sense. Maybe I can stumble through all 381 pages but I doubt it will be any more enlightening. Old Bob, The Purist
Jim, I made it through page 182 last night, that is about as far as I can go with this convoluted crap. I certainly am not in favor of drone BVOLS operations, and I do have ADSB out in my newer drones. The FAA limits operation to 400 feet agl, this
drone stuff wants 500 feet yet aircraft are prohibited from operating below 500 feet except takeoff and landing. I did not get the part where they made reference to UAS facility maps, it would be interesting to see the approach to operation in BVOLS
situations within these areas.
FYI, I did tow a motorglider yesterday, only because the motor blew up on the motorglider, I told the guy not to buy the damn thing. Take care, come see us again. Old Bob, The Purist

--- SoupGate-Win32 v1.05
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On Monday, August 1, 2022 at 8:20:05 AM UTC-4, youngbl...@gmail.com wrote:

On Sunday, July 31, 2022 at 7:54:09 PM UTC-4, Jim Lee wrote:

That's ok, Bob, we're discussing things with motors here. We don't expect you to understand. :)
On Sunday, July 31, 2022 at 3:23:24 PM UTC-7, youngbl...@gmail.com wrote:

After reading 14 of the 381 pages of bureaucratic bloviating nonsense I am more confused than ever. The BVLOS that they want to endorse is questionable in many ways. Keep in mind that I have a serious fleet of drones, and this airspace plan makes

no sense. Maybe I can stumble through all 381 pages but I doubt it will be any more enlightening. Old Bob, The Purist

Jim, I made it through page 182 last night, that is about as far as I can go with this convoluted crap. I certainly am not in favor of drone BVOLS operations, and I do have ADSB out in my newer drones. The FAA limits operation to 400 feet agl, this

drone stuff wants 500 feet yet aircraft are prohibited from operating below 500 feet except takeoff and landing. I did not get the part where they made reference to UAS facility maps, it would be interesting to see the approach to operation in BVOLS
situations within these areas.

FYI, I did tow a motorglider yesterday, only because the motor blew up on the motorglider, I told the guy not to buy the damn thing. Take care, come see us again. Old Bob, The Purist

I can't find the NPRM, can anybody post a useable link or the full e-mail for comments?

--- SoupGate-Win32 v1.05
* Origin: fsxNet Usenet Gateway (21:1/5)

On 8/1/22 09:32, Tony wrote:

On Monday, August 1, 2022 at 8:20:05 AM UTC-4, youngbl...@gmail.com wrote:

On Sunday, July 31, 2022 at 7:54:09 PM UTC-4, Jim Lee wrote:

That's ok, Bob, we're discussing things with motors here. We don't expect you to understand. :)
On Sunday, July 31, 2022 at 3:23:24 PM UTC-7, youngbl...@gmail.com wrote: >>>> After reading 14 of the 381 pages of bureaucratic bloviating nonsense I am more confused than ever. The BVLOS that they want to endorse is questionable in many ways. Keep in mind that I have a serious fleet of drones, and this airspace plan makes no

sense. Maybe I can stumble through all 381 pages but I doubt it will be any more enlightening. Old Bob, The Purist

Jim, I made it through page 182 last night, that is about as far as I can go with this convoluted crap. I certainly am not in favor of drone BVOLS operations, and I do have ADSB out in my newer drones. The FAA limits operation to 400 feet agl, this

drone stuff wants 500 feet yet aircraft are prohibited from operating below 500 feet except takeoff and landing. I did not get the part where they made reference to UAS facility maps, it would be interesting to see the approach to operation in BVOLS
situations within these areas.

FYI, I did tow a motorglider yesterday, only because the motor blew up on the motorglider, I told the guy not to buy the damn thing. Take care, come see us again. Old Bob, The Purist

I can't find the NPRM, can anybody post a useable link or the full e-mail for comments?

The email for comments is 9-FAA-UAS-BVLOS >AT< ffa.gov

Not hard at all if you're using an actual USENET reader to read a USENET
group.

--- SoupGate-Win32 v1.05
* Origin: fsxNet Usenet Gateway (21:1/5)

On 8/1/22 11:08, 2G wrote:

On Monday, August 1, 2022 at 9:36:09 AM UTC-7, kinsell wrote:

On 8/1/22 09:32, Tony wrote:

On Monday, August 1, 2022 at 8:20:05 AM UTC-4, youngbl...@gmail.com wrote: >>>> On Sunday, July 31, 2022 at 7:54:09 PM UTC-4, Jim Lee wrote:

That's ok, Bob, we're discussing things with motors here. We don't expect you to understand. :)
On Sunday, July 31, 2022 at 3:23:24 PM UTC-7, youngbl...@gmail.com wrote: >>>>>> After reading 14 of the 381 pages of bureaucratic bloviating nonsense I am more confused than ever. The BVLOS that they want to endorse is questionable in many ways. Keep in mind that I have a serious fleet of drones, and this airspace plan makes

no sense. Maybe I can stumble through all 381 pages but I doubt it will be any more enlightening. Old Bob, The Purist

Jim, I made it through page 182 last night, that is about as far as I can go with this convoluted crap. I certainly am not in favor of drone BVOLS operations, and I do have ADSB out in my newer drones. The FAA limits operation to 400 feet agl, this

drone stuff wants 500 feet yet aircraft are prohibited from operating below 500 feet except takeoff and landing. I did not get the part where they made reference to UAS facility maps, it would be interesting to see the approach to operation in BVOLS
situations within these areas.

FYI, I did tow a motorglider yesterday, only because the motor blew up on the motorglider, I told the guy not to buy the damn thing. Take care, come see us again. Old Bob, The Purist

I can't find the NPRM, can anybody post a useable link or the full e-mail for comments?

The email for comments is 9-FAA-UAS-BVLOS >AT< ffa.gov

Not hard at all if you're using an actual USENET reader to read a USENET
group.

Also, what is a link to the FAA docket for this NPRM? I searched for it, but could not find it.

Tom

I don't think there is an NPRM yet. This is for comments on a report
from the Aviation Rulemaking Committee for Unmanned Aircraft Systems
operating Beyond Visual Line Of Sight that was sent to the FAA.

--- SoupGate-Win32 v1.05
* Origin: fsxNet Usenet Gateway (21:1/5)

On Monday, August 1, 2022 at 9:36:09 AM UTC-7, kinsell wrote:

On 8/1/22 09:32, Tony wrote:

On Monday, August 1, 2022 at 8:20:05 AM UTC-4, youngbl...@gmail.com wrote:

On Sunday, July 31, 2022 at 7:54:09 PM UTC-4, Jim Lee wrote:

That's ok, Bob, we're discussing things with motors here. We don't expect you to understand. :)
On Sunday, July 31, 2022 at 3:23:24 PM UTC-7, youngbl...@gmail.com wrote:

After reading 14 of the 381 pages of bureaucratic bloviating nonsense I am more confused than ever. The BVLOS that they want to endorse is questionable in many ways. Keep in mind that I have a serious fleet of drones, and this airspace plan makes

no sense. Maybe I can stumble through all 381 pages but I doubt it will be any more enlightening. Old Bob, The Purist

Jim, I made it through page 182 last night, that is about as far as I can go with this convoluted crap. I certainly am not in favor of drone BVOLS operations, and I do have ADSB out in my newer drones. The FAA limits operation to 400 feet agl, this

drone stuff wants 500 feet yet aircraft are prohibited from operating below 500 feet except takeoff and landing. I did not get the part where they made reference to UAS facility maps, it would be interesting to see the approach to operation in BVOLS
situations within these areas.

FYI, I did tow a motorglider yesterday, only because the motor blew up on the motorglider, I told the guy not to buy the damn thing. Take care, come see us again. Old Bob, The Purist

I can't find the NPRM, can anybody post a useable link or the full e-mail for comments?

The email for comments is 9-FAA-UAS-BVLOS >AT< ffa.gov

Not hard at all if you're using an actual USENET reader to read a USENET group.

Also, what is a link to the FAA docket for this NPRM? I searched for it, but could not find it.

Tom

--- SoupGate-Win32 v1.05
* Origin: fsxNet Usenet Gateway (21:1/5)

On 8/1/22 11:14, kinsell wrote:

On 8/1/22 11:08, 2G wrote:

On Monday, August 1, 2022 at 9:36:09 AM UTC-7, kinsell wrote:

On 8/1/22 09:32, Tony wrote:

On Monday, August 1, 2022 at 8:20:05 AM UTC-4, youngbl...@gmail.com
wrote:

On Sunday, July 31, 2022 at 7:54:09 PM UTC-4, Jim Lee wrote:

That's ok, Bob, we're discussing things with motors here. We don't >>>>>> expect you to understand. :)
On Sunday, July 31, 2022 at 3:23:24 PM UTC-7, youngbl...@gmail.com >>>>>> wrote:

After reading 14 of the 381 pages of bureaucratic bloviating
nonsense I am more confused than ever. The BVLOS that they want
to endorse is questionable in many ways. Keep in mind that I have >>>>>>> a serious fleet of drones, and this airspace plan makes no sense. >>>>>>> Maybe I can stumble through all 381 pages but I doubt it will be >>>>>>> any more enlightening. Old Bob, The Purist

Jim, I made it through page 182 last night, that is about as far as
I can go with this convoluted crap. I certainly am not in favor of
drone BVOLS operations, and I do have ADSB out in my newer drones.
The FAA limits operation to 400 feet agl, this drone stuff wants
500 feet yet aircraft are prohibited from operating below 500 feet
except takeoff and landing. I did not get the part where they made
reference to UAS facility maps, it would be interesting to see the
approach to operation in BVOLS situations within these areas.
FYI, I did tow a motorglider yesterday, only because the motor blew
up on the motorglider, I told the guy not to buy the damn thing.
Take care, come see us again. Old Bob, The Purist

I can't find the NPRM, can anybody post a useable link or the full
e-mail for comments?

The email for comments is 9-FAA-UAS-BVLOS >AT< ffa.gov

Not hard at all if you're using an actual USENET reader to read a USENET >>> group.

Also, what is a link to the FAA docket for this NPRM? I searched for
it, but could not find it.

Tom

I don't think there is an NPRM yet.  This is for comments on a report
from the Aviation Rulemaking Committee for Unmanned Aircraft Systems operating Beyond Visual Line Of Sight that was sent to the FAA.

Ooops, the email address has faa in it, not ffa. That's a different organization.

--- SoupGate-Win32 v1.05
* Origin: fsxNet Usenet Gateway (21:1/5)

On Monday, August 1, 2022 at 4:27:05 PM UTC-7, 2G wrote:

On Monday, August 1, 2022 at 10:23:12 AM UTC-7, kinsell wrote:

On 8/1/22 11:14, kinsell wrote:

On 8/1/22 11:08, 2G wrote:

On Monday, August 1, 2022 at 9:36:09 AM UTC-7, kinsell wrote:

On 8/1/22 09:32, Tony wrote:

On Monday, August 1, 2022 at 8:20:05 AM UTC-4, youngbl...@gmail.com >>>> wrote:

On Sunday, July 31, 2022 at 7:54:09 PM UTC-4, Jim Lee wrote:

That's ok, Bob, we're discussing things with motors here. We don't >>>>>> expect you to understand. :)
On Sunday, July 31, 2022 at 3:23:24 PM UTC-7, youngbl...@gmail.com >>>>>> wrote:

After reading 14 of the 381 pages of bureaucratic bloviating >>>>>>> nonsense I am more confused than ever. The BVLOS that they want >>>>>>> to endorse is questionable in many ways. Keep in mind that I have >>>>>>> a serious fleet of drones, and this airspace plan makes no sense. >>>>>>> Maybe I can stumble through all 381 pages but I doubt it will be >>>>>>> any more enlightening. Old Bob, The Purist

Jim, I made it through page 182 last night, that is about as far as >>>>> I can go with this convoluted crap. I certainly am not in favor of >>>>> drone BVOLS operations, and I do have ADSB out in my newer drones. >>>>> The FAA limits operation to 400 feet agl, this drone stuff wants >>>>> 500 feet yet aircraft are prohibited from operating below 500 feet >>>>> except takeoff and landing. I did not get the part where they made >>>>> reference to UAS facility maps, it would be interesting to see the >>>>> approach to operation in BVOLS situations within these areas.
FYI, I did tow a motorglider yesterday, only because the motor blew >>>>> up on the motorglider, I told the guy not to buy the damn thing. >>>>> Take care, come see us again. Old Bob, The Purist

I can't find the NPRM, can anybody post a useable link or the full >>>> e-mail for comments?

The email for comments is 9-FAA-UAS-BVLOS >AT< ffa.gov

Not hard at all if you're using an actual USENET reader to read a USENET
group.

Also, what is a link to the FAA docket for this NPRM? I searched for
it, but could not find it.

Tom

I don't think there is an NPRM yet. This is for comments on a report
from the Aviation Rulemaking Committee for Unmanned Aircraft Systems operating Beyond Visual Line Of Sight that was sent to the FAA.

Ooops, the email address has faa in it, not ffa. That's a different organization.

Okay, then what is a link to that report?

Never mind - I found it on my own: https://www.faa.gov/regulations_policies/rulemaking/committees/documents/media/UAS_BVLOS_ARC_FINAL_REPORT_03102022.pdf

--- SoupGate-Win32 v1.05
* Origin: fsxNet Usenet Gateway (21:1/5)

On Monday, August 1, 2022 at 10:23:12 AM UTC-7, kinsell wrote:

On 8/1/22 11:14, kinsell wrote:

On 8/1/22 11:08, 2G wrote:

On Monday, August 1, 2022 at 9:36:09 AM UTC-7, kinsell wrote:

On 8/1/22 09:32, Tony wrote:

On Monday, August 1, 2022 at 8:20:05 AM UTC-4, youngbl...@gmail.com
wrote:

On Sunday, July 31, 2022 at 7:54:09 PM UTC-4, Jim Lee wrote:

That's ok, Bob, we're discussing things with motors here. We don't >>>>>> expect you to understand. :)
On Sunday, July 31, 2022 at 3:23:24 PM UTC-7, youngbl...@gmail.com >>>>>> wrote:

After reading 14 of the 381 pages of bureaucratic bloviating
nonsense I am more confused than ever. The BVLOS that they want >>>>>>> to endorse is questionable in many ways. Keep in mind that I have >>>>>>> a serious fleet of drones, and this airspace plan makes no sense. >>>>>>> Maybe I can stumble through all 381 pages but I doubt it will be >>>>>>> any more enlightening. Old Bob, The Purist

Jim, I made it through page 182 last night, that is about as far as >>>>> I can go with this convoluted crap. I certainly am not in favor of >>>>> drone BVOLS operations, and I do have ADSB out in my newer drones. >>>>> The FAA limits operation to 400 feet agl, this drone stuff wants
500 feet yet aircraft are prohibited from operating below 500 feet >>>>> except takeoff and landing. I did not get the part where they made >>>>> reference to UAS facility maps, it would be interesting to see the >>>>> approach to operation in BVOLS situations within these areas.
FYI, I did tow a motorglider yesterday, only because the motor blew >>>>> up on the motorglider, I told the guy not to buy the damn thing.
Take care, come see us again. Old Bob, The Purist

I can't find the NPRM, can anybody post a useable link or the full
e-mail for comments?

The email for comments is 9-FAA-UAS-BVLOS >AT< ffa.gov

Not hard at all if you're using an actual USENET reader to read a USENET >>> group.

Also, what is a link to the FAA docket for this NPRM? I searched for
it, but could not find it.

Tom

I don't think there is an NPRM yet. This is for comments on a report
from the Aviation Rulemaking Committee for Unmanned Aircraft Systems operating Beyond Visual Line Of Sight that was sent to the FAA.

Ooops, the email address has faa in it, not ffa. That's a different organization.

Okay, then what is a link to that report?

--- SoupGate-Win32 v1.05
* Origin: fsxNet Usenet Gateway (21:1/5)

On Monday, August 1, 2022 at 4:29:38 PM UTC-7, 2G wrote:

On Monday, August 1, 2022 at 4:27:05 PM UTC-7, 2G wrote:

On Monday, August 1, 2022 at 10:23:12 AM UTC-7, kinsell wrote:

On 8/1/22 11:14, kinsell wrote:

On 8/1/22 11:08, 2G wrote:

On Monday, August 1, 2022 at 9:36:09 AM UTC-7, kinsell wrote:

On 8/1/22 09:32, Tony wrote:

On Monday, August 1, 2022 at 8:20:05 AM UTC-4, youngbl...@gmail.com >>>> wrote:

On Sunday, July 31, 2022 at 7:54:09 PM UTC-4, Jim Lee wrote: >>>>>> That's ok, Bob, we're discussing things with motors here. We don't

expect you to understand. :)
On Sunday, July 31, 2022 at 3:23:24 PM UTC-7, youngbl...@gmail.com
wrote:

After reading 14 of the 381 pages of bureaucratic bloviating >>>>>>> nonsense I am more confused than ever. The BVLOS that they want >>>>>>> to endorse is questionable in many ways. Keep in mind that I have
a serious fleet of drones, and this airspace plan makes no sense.
Maybe I can stumble through all 381 pages but I doubt it will be >>>>>>> any more enlightening. Old Bob, The Purist

Jim, I made it through page 182 last night, that is about as far as
I can go with this convoluted crap. I certainly am not in favor of >>>>> drone BVOLS operations, and I do have ADSB out in my newer drones. >>>>> The FAA limits operation to 400 feet agl, this drone stuff wants >>>>> 500 feet yet aircraft are prohibited from operating below 500 feet >>>>> except takeoff and landing. I did not get the part where they made >>>>> reference to UAS facility maps, it would be interesting to see the >>>>> approach to operation in BVOLS situations within these areas. >>>>> FYI, I did tow a motorglider yesterday, only because the motor blew
up on the motorglider, I told the guy not to buy the damn thing. >>>>> Take care, come see us again. Old Bob, The Purist

I can't find the NPRM, can anybody post a useable link or the full >>>> e-mail for comments?

The email for comments is 9-FAA-UAS-BVLOS >AT< ffa.gov

Not hard at all if you're using an actual USENET reader to read a USENET
group.

Also, what is a link to the FAA docket for this NPRM? I searched for >> it, but could not find it.

Tom

I don't think there is an NPRM yet. This is for comments on a report from the Aviation Rulemaking Committee for Unmanned Aircraft Systems operating Beyond Visual Line Of Sight that was sent to the FAA.

Ooops, the email address has faa in it, not ffa. That's a different organization.

Okay, then what is a link to that report?

Never mind - I found it on my own: https://www.faa.gov/regulations_policies/rulemaking/committees/documents/media/UAS_BVLOS_ARC_FINAL_REPORT_03102022.pdf

My response to this is more blunt and to the point from others. This comes from my experience in seeing how the FAA evaluates these responses. I emphasize why change a maneuvering priority that has worked successfully for decades, and violates those same
principles.

Sirs:

This report recommends a complete change in the rules of right away that have been a centerpiece of the FAA for many decades, namely that the less maneuverable aircraft have right away over the more maneuverable. And it does it without a rational for the
change, other than it would be convenient for UAV operators. Let's be very clear here: this policy has worked for DECADES - changing for the convenience of UAV operators is SHEAR FOLEY!

UAVs are inherently small and highly maneuverable in all three dimensions. They can do high-G maneuvers that conventional aircraft have absolutely no possibility of matching, assuming that they even see the UAV to begin with. To expect a low maneuverable
aircraft to avoid such a device is ABSURD. It would be like expecting people to literally dodge a speeding bullet.

I am aghast that the ARC committee has made such a radical, ill-thought proposal. It must be denied under the most strenuous of terms. I say this as a licensed pilot with over 40 years and 4,500 hours of flight experience.

Respectfully,

Tom Seim

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