# Amazon requesting insane exceptions for its drones

Discussion in 'Rules and Regulations / Flight Safety / Better Pil' started by 12notes, Aug 10, 2019.

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1. Aug 10, 2019

### 12notes

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Amazon has requested a bunch of exceptions from the FARs for it's drone delivery service. The first exception they want is ridiculous, in that they want to start flying before the aircraft has an airworthiness certificate. Umm, no, first you make it pass the inspection, then you can use it.

The second exception requested, is outright INSANE. They want an exception to the right of way rules. The rules that state that you are responsible for seeing and avoiding other aircraft. The rules that specify an aircraft in distress has right of way over every other aircraft. The rules that state that a balloon has right of way over every aircraft that can be directionally controlled, that a glider has right of way over a powered plane, etc. The rules that state which way two aircraft approaching head on should turn, and how to safely overtake.

In short, they are asking to not be responsible for noticing other aircraft, and also to make every other aircraft required to get out of their drone's way. This would mean that they could operate in the flight path of anything else in the air, and it would be the other aircraft's pilot's fault. I can't think of a single pilot out there that would agree this is a good idea, or even a slightly sane proposition.

The main argument Amazon makes for the airworthiness exception is that their business will be ready before the certificate is issued. The main argument they make for the right of way exception is that it's unlikely that they'll hit anything.

Amazon's petition is published and in the comment stage, you can make formal comments on their petition here:

Also, the petition can be downloaded there as well. There are several other rules they are asking for exceptions to, but pale in comparison to these two.

Please submit formal comments and help stop this insanity. No idea if it'll do any good, but it definitely won't if nothing is said.

My submitted comment is at https://www.regulations.gov/document?D=FAA-2019-0573-0009

14 CFR 91.113(b) through (f), is specifically what they requested an exemption for.:

91.113 Right-of-way rules: Except water operations.

(b) General. When weather conditions permit, regardless of whether an operation is conducted under instrument flight rules or visual flight rules, vigilance shall be maintained by each person operating an aircraft so as to see and avoid other aircraft. When a rule of this section gives another aircraft the right-of-way, the pilot shall give way to that aircraft and may not pass over, under, or ahead of it unless well clear.

(c) In distress. An aircraft in distress has the right-of-way over all other air traffic.

(d) Converging. When aircraft of the same category are converging at approximately the same altitude (except head-on, or nearly so), the aircraft to the other's right has the right-of-way. If the aircraft are of different categories—

(1) A balloon has the right-of-way over any other category of aircraft;

(2) A glider has the right-of-way over an airship, powered parachute, weight-shift-control aircraft, airplane, or rotorcraft.

(3) An airship has the right-of-way over a powered parachute, weight-shift-control aircraft, airplane, or rotorcraft.

However, an aircraft towing or refueling other aircraft has the right-of-way over all other engine-driven aircraft.

(e) Approaching head-on. When aircraft are approaching each other head-on, or nearly so, each pilot of each aircraft shall alter course to the right.

(f) Overtaking. Each aircraft that is being overtaken has the right-of-way and each pilot of an overtaking aircraft shall alter course to the right to pass well clear.

2. Aug 10, 2019

### pictsidhe

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Well no. They won't hit anything as they will have right of way. Stuff will hit them...

I seriously doubt that the FAA will need a single comment to throw this one out.

3. Aug 10, 2019

### choppergirl

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Too many rules: I say throw them all out. Because, well, freedom.
And they are often ludicrous. I guess that makes me the single pilot #1!

~
We'll start off with point 1...

(1) A balloon has the right-of-way over any other category of aircraft;

I'm totally going to Atlanta International Airport and releasing 99 red balloons.

Because, well, absolute Rule #1. Its an invariable, unyielding, absolute. Get the F out of my balloon's way, Delta! Ditto for you, jet fighters and stealth aircraft. My balloons rule your airspace...

Think I'm making a funny? Read the rule again.

A balloon has the right-of-way over any other category of aircraft.

No quibbling. No qualifications. No exceptions.

~

Do you want rules, or do you want freedom?
Because they are mutually exclusive.
The more rules you make, the less freedom you have.

When you make rules, and further say I must follow them, and you will compel me to with the threat of violence, and I have no say so in the matter, never mind I disagree with them... then we have a problem.

The answer is not to make a bunch of inviolate rules. Rules are for kindergarteners. The answer is for people to enjoy freedom in its entirety, but to also take into consideration common sense and their own knowledge and experience at that moment, and judge for themselves, the best course of action. That is empowerment, and that is freedom. And that is the planet I want to live on. So I live it like it already was real, and it becomes real not far in some utopian future, but right here, right now.

On a lighter note, enjoy Balloonfest!

Did Balloonfest break the law? No, no law was broken.
Did it agree with common sense? No, absolutely not, and someone should of argued strongly against it.
Helium, though the 2nd most common element in the universe, is a very rare resource on Earth in it's unbonded form, and what they did was incredibly irresponsible from a non-renewable resource perspective.
Did balloonfest kill two people? No, rain or fog or night would of reduced visibility just the same. The men falling overboard not wearing life vests killed them, not that they were unable to be found mixed in with thousands of floating balloons. Common sense should tell you, if you go boating, you wear or carry a flotation device.

Last edited: Aug 10, 2019
4. Aug 10, 2019

### BBerson

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They would need an exemption from FAR 107 also (commercial drone rules).
What altitude do they want?

5. Aug 10, 2019

### Rockiedog2

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Money talks

6. Aug 10, 2019

### pwood66889

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Roger the $... :-( Wonder if Air Force 1 has to get out of their way. Percy 7. Aug 10, 2019 ### Rockiedog2 ### Rockiedog2 #### Well-Known Member Joined: Dec 12, 2012 Messages: 2,313 Likes Received: 1,630 dunno prob depends on the campaign contribution oh yeh we not sposed to talk politics. thankfully. pictsidhe likes this. 8. Aug 10, 2019 ### Pops ### Pops #### Well-Known Member Joined: Jan 1, 2013 Messages: 7,405 Likes Received: 6,368 Location: USA. When I was doing contracts for the Feds, all aircraft had to be diverted around me. One time in 7 years I had to give way to an airliner. Never knew why, and I have been in the same sector with Air Force 1, Prior notice to ATC of the requirements and they were great. 9. Aug 10, 2019 ### Rockiedog2 ### Rockiedog2 #### Well-Known Member Joined: Dec 12, 2012 Messages: 2,313 Likes Received: 1,630 Pops, you were a spook and didn't know it! Typical country boy. Don't ask me how I know. LOL 10. Aug 10, 2019 ### Hot Wings ### Hot Wings #### Well-Known MemberHBA Supporter Joined: Nov 14, 2009 Messages: 6,565 Likes Received: 2,478 Location: Rocky Mountains How long have you been in the US!? Icon was just a warmup for the exemption process. See post #5. I wonder how all of this will work out with regard to ICAO membership? ICAO and Drones 11. Aug 10, 2019 ### Pops ### Pops #### Well-Known Member Joined: Jan 1, 2013 Messages: 7,405 Likes Received: 6,368 Location: USA. I knew what I was doing. Wanted me to relocate to TX for a LOT more money but didn't want to and sold the company. Contract was open to be used by almost all agencies. Could be most anything. Enjoyed the flying but a very hard stressful job. Hardest job I ever had. Last edited: Aug 10, 2019 Rockiedog2 likes this. 12. Aug 10, 2019 ### Rockiedog2 ### Rockiedog2 #### Well-Known Member Joined: Dec 12, 2012 Messages: 2,313 Likes Received: 1,630 Sorry, didn't mean to insult you Pops. It was kinda a joke. 13. Aug 10, 2019 ### Pops ### Pops #### Well-Known Member Joined: Jan 1, 2013 Messages: 7,405 Likes Received: 6,368 Location: USA. If it was an insult, it was over my head Last edited: Aug 10, 2019 14. Aug 10, 2019 ### Vigilant1 ### Vigilant1 #### Well-Known MemberLifetime Supporter Joined: Jan 24, 2011 Messages: 4,265 Likes Received: 1,990 Location: US Coming from a guy who did high-iron antenna installs/maintenance, that's saying something. 15. Aug 10, 2019 ### proppastie ### proppastie #### Well-Known Member Joined: Feb 19, 2012 Messages: 3,975 Likes Received: 1,167 Location: NJ BACK ON TOPIC Very impressive presentation...... #### Attached Files: • ###### Amazon_-_Exemption_Rulemaking.pdf File size: 1.4 MB Views: 8 16. Aug 10, 2019 ### BBerson ### BBerson #### Well-Known MemberHBA Supporter Joined: Dec 16, 2007 Messages: 12,513 Likes Received: 2,535 Location: Port Townsend WA I read that 29 page Amazon document (post 15). My concern is Amazon is neglecting the fact that aircraft often do indeed fly enroute below 400 feet. Specifically, 1)airplanes may fly below 500 over open water or sparsely populated areas if no closer than 500 feet to person, vessel, vehicle, or structure. 2) helicopters can operate below 400 feet without any distance restrictions if no hazard. 3) Ultralight vehicles can operate below 400 feet. FAR 91.119 doesn't apply to Ultralights. So it isn't clear how these autonomous Amazon UAS will sense and avoid these aircraft operating below 400 feet that are not required to be equipped with ADS-B out or other devices. 17. Aug 10, 2019 ### Hot Wings ### Hot Wings #### Well-Known MemberHBA Supporter Joined: Nov 14, 2009 Messages: 6,565 Likes Received: 2,478 Location: Rocky Mountains And what about other company drones that may get the same exemption? A couple of 2 meter diameter 88 pound drones flying at 60 knots running into each other is not a trivial event especially if it's less than 400 feet above your head. (83 pounds of structure to deliver 5 pounds of product doesn't seem like a very efficient vehicle?) If Amazon really wants to make drone delivery practical and safe maybe they can use their financial resources to develop an anonymous*$49.95 ADS-B module with builtin avoidance software that we can all use?

Partner with Uber and Google to make it cross compatible with autonomous cars/trucks. The guberment will then mandate it's use in all ground bound vehicles, including bicycles. Lots of market potential there for them to exploit.

I may sound like one of those old "get off my lawn" types, but I'm actually looking forward to a more modern airspace management system. I think it will free up more airspace for those of us that like to fly for recreation.

*no individual identifying data, just 'this is unit XXYYDD. I'm here and going this direction at this speed'.

18. Aug 10, 2019

### TFF

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In 2007 the AMA was slammed by the likes Boeing and Lockheed Martin wanting all airspace’s below 400 for drones cart blanch. Luckily someone in the back of the room raised their hand and said what about model airplanes? No one but the big companies and the FAA was in that meeting. It would have allowed them to bypass ADSB type regulation. It would have been all theirs. The right to fly model airplanes almost ended that day. The mini Walmart and more expensive small drones are working to nail the last nail in the coffin. Barrage balloons anyone?

19. Aug 10, 2019

### BBerson

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The "\$50 ADS-B" for ultralights would be great if it can run anonymously. I don't see why the gubment needs to get involved at all in class G.

20. Aug 10, 2019

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