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Amazon requesting insane exceptions for its drones

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12notes

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Aug 27, 2014
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Louisville, KY
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:
https://www.federalregister.gov/doc...summary-of-petition-received-amazon-prime-air

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.
 
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