Comments on Line of Sight UAV, FPV and UAS requirments.

The following are my thoughts written in a letter in response to the “Line of Sight” requirement being applied to FPV operations and regulation of commercial operations. While I recommend you follow all rules and regulations. These are what I feel are the rational arguments for Liberty and Safe operations of these vehicles.

Regarding Line of Sight and commercial regulations from the FAA.

Philosophically, it’s an objection to Liberty and also an objection to voluntary exchange.

I would argue against the use of UAS / FPV only on a safety basis, not on the basis of reserving a monopoly of operations for one user over another. For example. I don’t have a problem with a person flying out of visual contact, but I would have a problem with them flying beyond visual ability to recognize full scale aircraft in an operational area.

One regulation is an objection to Liberty and Voluntary Exchange. The other acknowledges no limit of operation up to the point you egress into others Liberty (safety) becomes non-determinable or non manageable. A similar example is that I cannot see a bullet, but I must be aware of what I am shooting at and what is behind the target in the flight path of the bullet. I have a responsibility to protect the safety of others unknown to me yet I have no duty to see the projectile. NASA cannot maintain visual contact with a rocket for the whole flight path but through other technology is able to determine the rocket is not going to enter an area of unsafe potential contact with other objects in orbit.

My thinking allows for example an operator to fly behind a tree line he cannot see through but is not probable operational space for a full scale aircraft. Allows him to photograph a mountain close up if he can recognize a full size aircraft entering the area and simply command an evasive altitude.

Other ramifications of the poorly thought out “Line of Sight” language is the mapping or exploration of caves, inspection or exploration of abandoned buildings, fissures in geological structures, forested area’s etc…

As to the status of operations being professional or recreational and inhibiting operations on this basis is an objection to voluntary exchange. These are not man carrying devices, only sensor carrying devices. There is no significant risk to life or property. Why should we allow the industry to be stifled by regulation who’s founding intent is to keep people from falling out of the sky and dying in poorly maintained or constructed aircraft? Clearly there is no reason or need of government regulation over air photography services. We should be able to hire anybody we want to take a picture. We do not need government officials deciding for a photographer how he gets his camera into position as long as he does not present a hazard to other aircraft in the operational area. You don’t need a pilot’s license to see an airplane any more than you need a drivers license to operate a cross walk and recognize an automobile. Ask any 5 year old child.

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