How to insure no helicopter will every be forced to land because of a drone...

[AMGPilot]

I'm not sure where the disconnect is here. I feel like we keep talking past each other. I keep saying "the last 100' of operation" and you come back with "But all those references you give for seeing helicopters land are just that they are landing and not in their normal mode of flight."

For whatever reason, I can't seem to get the point across that you can fly at any speed you wish ABOVE 400' AGL (which should allow you to reach ANY emergency in ANY situation in a timely manner). It's only when you break the 400' floor that the "Class H" would govern your speed to < 50 knots. I honestly can't say it any clearer and I'm not sure why you don't directly address that exact assertion.

Are you asserting that the only way a helicopter can conduct operations or even be useful as a tool is that IT MUST fly OVER 50 knots BELOW 400'??? Is that your assertion? That forcing a helicopter to conduct high-speed operations ABOVE 400' would render the helicopter useless or less effective?

Are you asserting that emergency helicopters NEED to fly UNDER 400' AGL from point A to point B and back?

Call me nuts, but I always assume if a helicopter were going to haul someone back to the hospital from say 10 miles away, that ascending to 500'+ would not only be SOP, but would be a darn prudent! Do you mean to tell me you emergency helicopter guys fly the entire 10 miles UNDER 400' AGL? And that rising to ABOVE 400' AGL would impede emergency operations? Is THIS what you're asserting?

I'll address the rest of your comments later.

Still trying to get educated, but we seem to be talking past one another.

D

No the problem is you are uneducated and not listening
Autorotation speed in a helicopter is treated just like blue line in a multi. You don’t go below it until you absolutely have to

why? It’s part of risk mitigation

you are advocating that drones have a priority over manned aircraft below 400feet. They don’t and they don’t have a priority over manned aircraft ever.

 

[AMGPilot]

You are deflecting and being vague. I NEVER ONCE asserted that helicopters would have to "reduce operational speed." I suggested that UNDER 400' AGL that they simply slow down. ABOVE 400' AGL you can fly the speed of sound for all I care. So unless you're asserting that ALL OPERATIONS MUST BE conducted UNDER 400' AGL, your assertion doesn't hold water.

And your reference to "comfort" is once again deflecting. My Class H proposal is NOT there for "comfort of UAV pilots." It's there for SAFETY of full scale aviation pilots!






Your argument that a helicopter HAS to fly over 50 knots to "be safe" doesn't hold water. According to the Helicopter height–velocity diagram (published by the FAA), even an 8500 lb. behemoth can autorotate @ 50 knots @ 150' AGL.

View attachment 27514



Hmmmm....not according to the Helicopter height–velocity diagram published by the FAA (see above).






My Class H speed restriction allows for full auto-rotation for helicopters up to 8500 lbs. at altitudes as low as 150' (see above diagram).

The take-off profile recommends a speed of 65 knots for altitudes 50' and above. Even 65 knots is way safer in the "Class H UAV zone" than 125 knots.

In other words, according to all available data, my "Class H airspace" proposal allows helicopter pilots to remain at safe speeds for auto rotation uncontrolled descents.

That said, how many times a year do pilots have to auto rotate their craft? That would be an interesting statistic. Because if you are at a fast enough velocity for auto rotation, that sure as heck doesn't guarantee a place to land. And since we're talking about metropolitan areas (where emergency helicopters would operate), it almost seems moot your point regarding auto rotation speeds within city limits.

Any thoughts on that?

D

Well we know that you don’t have a helicopter license because you make some wild assertions

you don’t understand basic helicopter flight principals and you don’t understand that you can pinpoint your autorotation landing. Even in a city

 

[The Editor]

@AMGPilot - keep it civil please.

 

[Donnie Frank]

No the problem is you are uneducated and not listening
Autorotation speed in a helicopter is treated just like blue line in a multi. You don’t go below it until you absolutely have to

why? It’s part of risk mitigation

Yes, Class H takes auto rotation into GREAT consideration. For the love of all that is holy, even posted the Helicopter Height Velocity Diagram. Here is is AGAIN for your convenience.

you are advocating that drones have a priority over manned aircraft below 400feet.

With all due respect, are you insane? Nothing is further from the truth. For someone so willing to chastise ME for being "uneducated," you sure seem to lack either reading or comprehension skills.

Drones DO NOT GET THE RIGHT OF WAY EVER. Manned Aviation absolutely has the right of way in Class H airspace. The new airspace simply states that IF you're going to fly UNDER 400' AGL, then you must do it a < 65 Knots. This allows for full auto rotation at all altitudes below 400' AGL. I don't know how to say it any clearer, bud.

They don’t and they don’t have a priority over manned aircraft ever.

That's EXACTLY what Class H airspace says. You're literally agreeing with my Class H airspace suggestion in a combative manner.

D

 

[Donnie Frank]

Well we know that you don’t have a helicopter license because you make some wild assertions

While I concede that I don't have a helicopter license, I've made no "wild assertions." I've taken risk mitigation and auto rotation and landing and take off into full account. What am I missing? Be specific.

you don’t understand basic helicopter flight principals and you don’t understand that you can pinpoint your autorotation landing. Even in a city

Touché. My assertion - which has literally nothing to do with the helicopter itself - is that you may not find a safe space to land in a congested city. I most certainly concede that you MIGHT, but one would have to be obtuse to not concede that the very possibility exists of not finding a place to land in an uncontrolled descent situation. That said....

My Class H airspace rules take auto rotation into full account.



See??

D

 

[The Editor]

 

[AMGPilot]

Yes, Class H takes auto rotation into GREAT consideration. For the love of all that is holy, even posted the Helicopter Height Velocity Diagram. Here is is AGAIN for your convenience.

View attachment 27516



With all due respect, are you insane? Nothing is further from the truth. For someone so willing to chastise ME for being "uneducated," you sure seem to lack either reading or comprehension skills.

Drones DO NOT GET THE RIGHT OF WAY EVER. Manned Aviation absolutely has the right of way in Class H airspace. The new airspace simply states that IF you're going to fly UNDER 400' AGL, then you must do it a < 65 Knots. This allows for full auto rotation at all altitudes below 400' AGL. I don't know how to say it any clearer, bud.




That's EXACTLY what Class H airspace says. You're literally agreeing with my Class H airspace suggestion in a combative manner.

D

Ummm the H/V diagram you posted was for ONE aircraft, doesn’t take into account density altitude or winds. It doesn’t take into account if it’s a down slope take of an upslope take off

your proposal is myopic at best.

how would your proposal addressed the recent Air7 incident. Give you a hint. It wouldn’t

the best solution is see and avoid and ground your drone at the first indication of a manned aircraft

 

[Donnie Frank]

If you don’t understand what the FAR’s

I KNOW what "FARs" are. I'm just unfamiliar with Part 61 and I have neither the time nor the inclination to read all 60 subparts. If you can be specific to which subpart is germane to this conversation, I will read it.

are and how part 61 applies

Which part of part 61? There are 60 subparts. Which one are you referring to????

then you can be making proposals because you lack the base knowledge of how airspace works

I know perfectly well how airspace works. I believe you're being vague on purpose because you either lack understanding of what I am proposing, or you're just combative by nature.

putting a speed limit below 400 feet to accommodate drones is NOT the solution

You see...this last sentence tells me that you completely do NOT understand my Class H airspace proposal. Again, for like the 12th time...drones DO NOT have a "right of way" in Class H. Class H is there for manned aerial vehicle protection. It is NOT there for drone protection.

If you would take time and read my proposal more thoroughly, you would understand this.

D

 

[AMGPilot]

I KNOW what "FARs" are. I'm just unfamiliar with Part 61 and I have neither the time nor the inclination to read all 60 subparts. If you can be specific to which subpart is germane to this conversation, I will read it.






Which part of part 61? There are 60 subparts. Which one are you referring to????





I know perfectly well how airspace works. I believe you're being vague on purpose because you either lack understanding of what I am proposing, or you're just combative by nature.




You see...this last sentence tells me that you completely do NOT understand my Class H airspace proposal. Again, for like the 12th time...drones DO NOT have a "right of way" in Class H. Class H is there for manned aerial vehicle protection. It is NOT there for drone protection.

If you would take time and read my proposal more thoroughly, you would understand this.

D

As a commercially rated pilot operating in the system for 35+ years I suggest that you read ALL of part 61 as the answers are there.

61,91, 121,135 all parts I have to read and understand and in order to make a propostal that works you need to know and understand the FARs

 

[Donnie Frank]

Ummm the H/V diagram you posted was for ONE aircraft,

Yes...an 8500 lb. behemoth...published by the FAA. I assume that the FAA publishes "worst case scenario" risk mitigation data. Do you refute the FAA's diagram?

doesn’t take into account density altitude or winds. It doesn’t take into account if it’s a down slope take of an upslope take off

Then take it up with the FAA and get it changed.

your proposal is myopic at best.

Quite the contrary. I've considered all worst-case scenarios. Granted, I ASSUME that smaller, lighter helicopters (under 8500 lbs.) are able to auto rotate EASIER than the 8500 lb. counterpart. But if you have data to show otherwise, I'm all ears.

how would your proposal addressed the recent Air7 incident. Give you a hint. It wouldn’t

I'm unfamiliar with the Air 7 incident. Google search turns up a myriad of websites with the words "air" and "incident" in them, but nothing specific. Provide a link or more information:

1) Was this a drone strike?
2) At what altitude?
3) At what location?

the best solution is see and avoid and ground your drone at the first indication of a manned aircraft

Clearly, you have zero understanding of my Class H proposal. Class H does NOT give drones the "right of way." All Class H does it give drones a fighting chance to get OUT OF THE WAY of full scale aviation.

Read my proposal again.

D

 

[Donnie Frank]

As a commercially rated pilot operating in the system for 35+ years I suggest that you read ALL of part 61 as the answers are there.

61,91, 121,135 all parts I have to read and understand and in order to make a propostal that works you need to know and understand the FARs

OR...you can simply articulate which part of my Class H proposal is not feasible, and why. Let's give that a shot and discuss intelligently. If you need to bury your argument in hundreds of pages of FAA jargon, maybe your argument isn't a good one. Self reflect.

D

 

[AMGPilot]

OR...you can simply articulate which part of my Class H proposal is not feasible, and why. Let's give that a shot and discuss intelligently. If you need to bury your argument in hundreds of pages of FAA jargon, maybe your argument isn't a good one. Self reflect.

D

Here’s how it doesn’t work

you are trying to change and limit manned aircraft to accommodate drones.
As for not being familiar with. air7 well that’s been in the forefront of drone on helicopter violence the last week

the hit happened at 1200 ft agl....

 

[philztoy]

Your argument that a helicopter HAS to fly over 50 knots to "be safe" doesn't hold water. According to the Helicopter height–velocity diagram (published by the FAA), even an 8500 lb. behemoth can auto rotate @ 50 knots @ 150' AGL."


The chart says at 150 feet 50kts is on the edge of being safe and from 150 feet to about 40 feet AGL50 knots is an unsafe flight condition. The Proper approach or take off is along the dotted line so 65 knots until about 50 feet is recommended. So I would say 60 to 70 knots until close to the ground is the safe curve for this helicopter. That curve changes for each model helicopter and is also dependent on relative wind conditions.

In all cases aircraft whether it is drones, airplanes, jets, balloons or gliders, should be flown within their safe operating capabilities. The FAA won't legislate that away for a dron airspace

Looking at the emergency vehicle helicopter landings in the videos you were posting, those guys are flying in "the dead mans curve" because they had to retrieve injured people from a parking lot. They had well maintained turbine equipment unlikely to lose an engine. But if they did the helicopter or crew was at risk of sever bodily injury or dying. Things to be avoided unless there is an emergency. Those pilots took a risk and made it.

Drones share airspace with helicopters which share airspace with airplanes which share airspace with balloons gliders and jets.

Class H isn't a good idea and will just make your life as a drone operator more complex and expensive. I am sure the FAA can make drone operation much safer by regulation if that is what you are after. A transponder in every drone, drone towers drone operator radios for communication with planes and control towers. Much safer for manned air trafic But it will also be 10 times more expensive.

I am not voting for Class H airspace.

 

[Donnie Frank]

Here’s how it doesn’t work

you are trying to change and limit manned aircraft to accommodate drones.

Well...not exactly. There is no "accommodation." Class H's purpose if for full scale aviation safety. Here's the argument...

Undeniably, the skies are filling with drones. And it's only going to get worse. Eventually Amazon will be delivering packages via drone...as will eBay and Dominoes Pizza and lord knows what else. Nobody refutes this. As the designated drone areas become more and more congested with drone traffic, the FAA is going to have to respond. Gone will be the days of being able to fly your helicopter as fast and as low as you wish. New FAA regulation will ultimately be for YOUR safety, as it always is.

Enter Class H airspace. Manned aviation still has the right of way in this airspace. The only difference will be that they'll have to slow down. As I'm sure you're well aware, collision avoidance is easier at slower speeds. So to mitigate risk, Class H says, "IF you're going to fly under 400' AGL, THEN you have to fly < 65 knots." This seems very reasonable and prudent to me. Obvious exceptions are made for Class B, C, D air space, military training routes, waterway landing fields, agriculture, etc.

The "accommodation," if you will, is for the safety of pilots and passengers of manned aviation vehicles.

That's the whole thing in a nutshell.

As for not being familiar with. air7 well that’s been in the forefront of drone on helicopter violence the last week

the hit happened at 1200 ft agl....

Okay...so you are correct. "Class H" would've done nothing for that incident. CLEARLY, the drone was outside of its Class H airspace, and therefore in direct violation of existing regulations and future "Class H" laws. This doesn't make Class H any less effective.

D

 

[Donnie Frank]

A good argument...refreshing...

The chart says at 150 feet 50kts is on the edge of being safe and from 150 feet to about 40 feet AGL50 knots is an unsafe flight condition. The Proper approach or take off is along the dotted line so 65 knots until about 50 feet is recommended. So I would say 60 to 70 knots until close to the ground is the safe curve for this helicopter. That curve changes for each model helicopter and is also dependent on relative wind conditions.

Touché. I have since upped the minimum speed to 65 knots. And keep in mind the chart is for an 8500 lb. behemoth. I assume the chart would be derated for lighter aircraft. But that is just an assumption at this point.

In all cases aircraft whether it is drones, airplanes, jets, balloons or gliders, should be flown within their safe operating capabilities. The FAA won't legislate that away for a dron airspace

What is the maximum helicopter speed limit at 300' AGL? How about 200' AGL? 100' AGL? If your answer is, "There is none." Then something needs to be done.

Looking at the emergency vehicle helicopter landings in the videos you were posting, those guys are flying in "the dead mans curve" because they had to retrieve injured people from a parking lot.

I watched a news helicopter land the same way just days ago. It seems that ALL helicopters have to spend some amount of time in the "dead man's curve." They can't all keep up 65 knots until the very last second. The question here is, "At what point do ALL helicopter pilots eventually abandon the dead man's curve?" 30' AGL? 50' AGL? 100' AGL? At what point do you say, "Okay...I better slow down into the dead man's curve, or I won't be able to land???"

They had well maintained turbine equipment unlikely to lose an engine.

It's my understanding that ALL aviation vehicles undergo rigorous maintenance routines. But I defer to your expertise.

But if they did the helicopter or crew was at risk of sever bodily injury or dying. Things to be avoided unless there is an emergency. Those pilots took a risk and made it.

What about the news helicopter I witnessed a couple days ago? By estimate, at 50' AGL he slowed to < 5 mph.

Drones share airspace with helicopters which share airspace with airplanes which share airspace with balloons gliders and jets.

Class H isn't a good idea and will just make your life as a drone operator more complex and expensive.

Class H doesn't really change drone airspace, how we fly or how we behave. Class H only changes the maximum speed allowed under 400' AGL, which I have amended to 65 knots.

I am sure the FAA can make drone operation much safer by regulation if that is what you are after.

The goal of Class H is super simple; Avoid collision. Moving out of the way of a speeding helicopter (125 knots) is much tougher than moving out of the way of a helicopter flying @ 65 knots. The whole purpose of Class H is to give the drone pilot a reasonable, prudent, realistic time to react to a manned aviation intrusion. A lot of pilots are reading this as "manned aircraft giving way to drones." Nothing could be further from the truth. This about giving us UAS pilots a fighting chance to get out of YOUR way.

A transponder in every drone, drone towers drone operator radios for communication with planes and control towers. Much safer for manned air trafic But it will also be 10 times more expensive.

Plus that technology doesn't even really exist for drones yet. And what's the range? Obviously, this will help manned aircraft know where drones are. So does this put avoidance responsibility on the shoulders of the manned aircraft? The technology you speak of will certainly not be available in toy drones sold at Best Buy. So I see this idea as a failure.

Conversely, the Class H idea puts avoidance responsibility on the shoulders of the UAV pilot. No exceptions. We're just saying, "Slow down so we have a chance to get out of your way." No cost. No new technology. Lots of common sense.

I am not voting for Class H airspace.

Now that I've clarified some points and amended the speed parameters, do you still feel that way?

D

 

[AMGPilot]

You keep making arguments without understanding the basic's or the system

you ask what is the maximum speed of a helicopter at 300 agl. Well, guess what that’s in the part 61 regs.

You also don't understand that for a helicopter down low, speed is life

I have twice survived helicopter incidents down low because we traded our speed for energy in the rotor system

 

[philztoy]

It’s a bad idea in my opinion. It just leads to more regulations for a problem not there.

I disagree with the premise.

Manned aircraft aren’t typically (like hardly ever)flying lower than 500 feet AGL There are towers, power lines, hills buildings and the occasional drone I suppose. Pilots avoid that stuff as much as possible.

I’m not sure any helicopters are flying at 150 knots and not at your class H altitudes for sure. There’s a little problem of retreating blade stall with helicopters starting at about that speed. If you go too much over that in a helicopter the retreating side of the rotor system loses lift and the helicopter inverts violently (At least that is what the pilot I knew who had it happen to him told me). Top reasonable cruise speed in my helicopter is 80 Ltd Vne ( velocity not to exceed) is 93 knots, as I recall. It cruises most efficiently at about 65-70 knots. Usually helicopter operators try for peak efficiency for maximum air time and minimum flight hour cost. So maybe in a bell jet ranger That ups the cruise speed to 120 knots.

The “drone strike” that started this thing was up at 1000-1600 ft at night not 400 ft AGL So class H didn’t fix that problem.


Everyone on the commercially licensed side here is a pilot or has pretty much taken ground school, so we all know what to do to avoid interference with other aircraft. A little on line class and test for recreational droning is probably not a bad idea and not a slippery slope in my opinion. Its not uncommon in other hobbies like CB or ham radio.

A new drone class airspace is a slippery slope for drone operators. i agree that Transponders, communication radios, annual inspections and FAA parts and instrument certifications don’t exist for drones. But they will if the FAA requires them. I don’t want to pay 10 grand for an FAA approved DJI phantom 4H.

I say let’s be good neighbors and keep our autonomy as long as we can. I think yout proposition puts us on a slippery slope to more regulations.

I’m sure my $20,000 fully FAA equipped Inspire 1H will be a lot safer for helicopters not really flying in Class H airspace. I’m willing to take one for the team if necessary. At least it would make the FLIR XT look like a bargain!

 

[AMGPilot]

[QUOTE="Donnie Frank, post: 205704, member: 32305"[/QUOTE]

What is the maximum helicopter speed limit at 300' AGL? How about 200' AGL? 100' AGL? If your answer is, "There is none." Then something needs to be done.

only there is a speed limit, 2 in fact. You need to learn a lot more

I watched a news helicopter land the same way just days ago. It seems that ALL helicopters have to spend some amount of time in the "dead man's curve." They can't all keep up 65 knots until the very last second. The question here is, "At what point do ALL helicopter pilots eventually abandon the dead man's curve?" 30' AGL? 50' AGL? 100' AGL? At what point do you say, "Okay...I better slow down into the dead man's curve, or I won't be able to land???"

Apparently you are not familiar with the Quick Stop

It's my understanding that ALL aviation vehicles undergo rigorous maintenance routines. But I defer to your expertise.

Yes and that's part of the entire thing you are missing. Your drone is not on a Maintenance plan or schedule and there is no regulatory requirement. Want to get your own airspace? you are going to end up with MUCH more regulation and proof of compliance

What about the news helicopter I witnessed a couple days ago? By estimate, at 50' AGL he slowed to < 5 mph.

No two flights are alike

Class H doesn't really change drone airspace, how we fly or how we behave. Class H only changes the maximum speed allowed under 400' AGL, which I have amended to 65 knots.

Only there is no such thing as "Drone Airspace" and there won't be. You have a false expectation that under 400ft is "Drone space" but that is simply not the case. Your "Flawless" proposal is flawed from the start since you lack any Part 61 knowledge

The goal of Class H is super simple; Avoid collision. Moving out of the way of a speeding helicopter (125 knots) is much tougher than moving out of the way of a helicopter flying @ 65 knots. The whole purpose of Class H is to give the drone pilot a reasonable, prudent, realistic time to react to a manned aviation intrusion. A lot of pilots are reading this as "manned aircraft giving way to drones." Nothing could be further from the truth. This about giving us UAS pilots a fighting chance to get out of YOUR way.

LOL manned aircraft are not "Intruding" they have right of way and will always have right of way. Drone "pilots" are supposed to use good ADM and mitigate their risks, not the other way around

Plus that technology doesn't even really exist for drones yet. And what's the range? Obviously, this will help manned aircraft know where drones are. So does this put avoidance responsibility on the shoulders of the manned aircraft? The technology you speak of will certainly not be available in toy drones sold at Best Buy. So I see this idea as a failure.

Conversely, the Class H idea puts avoidance responsibility on the shoulders of the UAV pilot. No exceptions. We're just saying, "Slow down so we have a chance to get out of your way." No cost. No new technology. Lots of common sense.

Ahhhh how little you know, AirSense and pingRX are two available solutions right now to drones, and they will be mandated in the next 18 months. As for range.... well again you need to educate yourself a LOT more.

See and Avoid is on the shoulders of all pilots and the FAA is quite clear on the responsibility of the drone operator. You have cited Amazon, UPS and Dominos entry into drone space as proof of the need for class "H" airspace, you fail to understand that those aircraft will fall under part 91 and 135 and will have to carry appropriate avionics to operate in the NAS and have the ability to deconflict autonomously

as to your claim of "common sense" well you seem to not understand that a drone can and has taken down manned aircraft. A tail rotor strike WILL produce a catastrophic failure.

Now that I've clarified some points and amended the speed parameters, do you still feel that way?

only you haven't clarified anything, so yes I still think your idea lacks any merit

 

[The Editor]

 

[Donnie Frank]

only there is a speed limit, 2 in fact. You need to learn a lot more

That's why I'm asking. I guess you don't know, either.

Apparently you are not familiar with the Quick Stop

I'm not. Explain what that is. Wait! I know! I'll use my google machine!

Yes and that's part of the entire thing you are missing. Your drone is not on a Maintenance plan or schedule and there is no regulatory requirement. Want to get your own airspace?

No. I do not. That's not what Class H airspace is. Not even close. I've explained this over and over (ad nauseum). I don't know how else to say it.

you are going to end up with MUCH more regulation and proof of compliance

If "owning my own airspace" were the objective, I might agree.

No two flights are alike

I get that. But I'm not sure what this has to do with anything. The FAA has created rules, regulations and published the Helicopter Height Velocity Diagram to cover all or most flight situations. If you don't agree with the HHVD, you can take up with the FAA.

Only there is no such thing as "Drone Airspace" and there won't be.

Agreed. But that's not what Class H is.

You have a false expectation that under 400ft is "Drone space" but that is simply not the case.

That's not even remotely close to my expectation. I'm not sure why I can't get this point across.

Your "Flawless" proposal is flawed from the start since you lack any Part 61 knowledge

I disagree. You hide behind a 100 page document like you know something we don't. I've yet to hear you quote a single line from that document. Not one. I submit that you know it no better than I do. If this argument were turned around, I would direct you to the part, the subpart and even the line germane to this conversation. But you don't do that because you don't know it.

LOL manned aircraft are not "Intruding" they have right of way and will always have right of way.

I have specifically stated that many, many times. I don't know how to say it any clearer.

Drone "pilots" are supposed to use good ADM and mitigate their risks, not the other way around

The fact that you would even remotely suggest that manned aircraft do NOT have to "mitigate risk" because "that's the sole responsibility of a drone" tells me you know A LOT less about aviation than you claim to.

Ahhhh how little you know, AirSense and pingRX are two available solutions right now to drones, and they will be mandated in the next 18 months.

Perhaps. I guess we'll see.

As for range.... well again you need to educate yourself a LOT more.

In regards to what? Range of what? What are you talking about?

See and Avoid is on the shoulders of all pilots and the FAA is quite clear on the responsibility of the drone operator.

So your position is that manned aircraft don't have to change course to avoid drones??? Okay....I think I know a couple pilots who disagree with you. In fact, full scale aviation has been grounded during rescue operations due to drone activity. So it seems manned aviation DOES make an effort to avoid drones.

You have cited Amazon, UPS and Dominos entry into drone space as proof of the need for class "H" airspace, you fail to understand that those aircraft will fall under part 91 and 135 and will have to carry appropriate avionics to operate in the NAS and have the ability to deconflict autonomously

Agreed! I'm glad we agree on something. However, worth noting, you will no longer be able to fly your helicopter @ 125 knots below 400'. Regulating manned aircraft speed at low altitudes with be PART OF THE RISK MITIGATION. Like it or not, that is what's coming down the pike. I give it 10 years. The FAA will never sign off on putting 100% avoidance responsibility on an autonomous drone. Congress will push the FAA to make concessions for the new technology. And boo-hoo, you will have to fly your helicopter a little slower in SOME airspace. Cry me a river.

as to your claim of "common sense" well you seem to not understand that a drone can and has taken down manned aircraft.

Name one. Cite your source. Or is that also buried in Part 61...LOL....

A tail rotor strike WILL produce a catastrophic failure.

There's no evidence to support this. Don't make your supposition a matter of fact. Cite your source.

only you haven't clarified anything, so yes I still think your idea lacks any merit

That's the pot calling the kettle black, Mr. "Part 61." You're the king of vaguery.

All these words....not one single good argument against simply slowing down in lower air space. Not one.

I've beat this horse enough. I can't argue with someone who argues with their ego and not their intellect. In addition, I'm tired of repeating myself over and over. Respond to this if you want. I'm done. I've learned futility.

Good day.

D