Docket Management Facility 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

West Building Ground floor Room Wl2-140 

Washington, D.C. 20590 

8623 James 'Cree:k.iDrive . ; , . u 2 

Springfield, VA 22152 

January 23. 2016 

Re: Request for Exemption from FAA Prohibition under the Washington, D.C. 

Metropolitan Area SFRA of Control Line Model Aircraft Operations at the 

Meadowood Special Recreation Management Area, Fairfax County, Virginia 

To whom it may concern: 

As set forth in the attached Petition, Northern Virginia Control Line (NVCL), a 

model airplane club, is seeking an exemption from the prohibition of control line 

model aircraft operations imposed by the FAA within the Washington D.C. Area 

SFRA with respect to its flying site at Meadowood SRMA in Fairfax County, 

Virginia. We are also requesting expedited review of the petition to permit control 

line operations to begin at Meadowood by late March/early April, the normal start 

of our flying season. 

I, and the other members ofNVCL, share the concerns ofthe FAA and other 

organizations and responsible citizens regarding the absolute necessity of 

protecting the safety of the National Airspace System for all users and preventing 

the use of an aircraft as a weapon, or means of delivering weapons, to conduct an 

attack on persons, property, or buildings in the area, and recognize the need for 

appropriate regulation to achieve this goal. 

Without prejudice to our legal rights, the members ofNVCL believe that this goal 

can best be furthered through constructive dialogue with the FAA, explaining why 

control line operutions nt Mcudowood pose u minimal risk to public sufety and 

security and, accordingly, why such operations should be exempt from the flight 

prohibitions currently imposed under the D.C Areu SFRA. 
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In that regard, I and other members ofNVCL would welcome the opportunity to 

provide clarifications regarding the petition, or answer any questions the FAA 

might have concerning the nature of control-line model airplane flying in general, 

and the operations at Meadowood in particular. We would be happy to meet with 

FAA representatives to discuss these issues on a face-to-face basis. In particular, 

we invite FAA representatives to visit our flying site at Mcadowood to obtain a 

lirst-hand view of how the terrain teatures of the site and our operational 

procedures contribute to a safe and secure flying environment. Weather 

permitting, we would be delighted to demonstrate a control line model in tlight. 

We thank you for considering our views in this petition. Should you have any 

questions, I can be contacted at the above home address, at my home telephone 

number (703) 451-0143 H, (703) 304-3162 (C), or by e-mail at 

fidm jd({i<verizon.net. 

Sincerely, 

Frank Dobrydney, President 

Northern Virginia Control Line 

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UNITED STATES DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

PETITION FOR EXEMPTION 

Petitioner: 

This petition for exemption is submitted on behalf of Northern Virginia Control 

Line (NVCL ), a Virginia corporation, by Frank Dobrydney, President, 8623 James 

Creek Drive, Springfield, VA 22152; phone: (703) 451-0143 (H), (703) 304-3162 

(C); e-mail: fjdmjd@verizon.net. 

Specific Sections of Title 14 of the Code of Federal Regulations from which 

Petitioner Seeks an Exemption: 

The following subsections of Subpart V ofTitle 14 ofthe C.F. R.- Washington, 

D.C. Metropolitan Area Special Flight Rules Area (SFRA): §93.331(Purpose and 

applicability of this subpart); §93.333 (Failure to comply with this subpart); 

§93.335 (Definitions); §93.337 (Requirements for operating in the DC SFRA); 

§93.339 (Requirements for operating in the DC SFRA, including the DC FRZ);and 

§93.341 (Aircraft operations in the DC FRZ); together with Advisory Circular AC 

No. 91-57A, September 2, 2015, Model Aircraft Operating Standards, Notice 

N JO 7210.891, November 25, 2015, Unmanned Aircraft Operations in the 

National Airspace System (NAS), including any revisions to or replacements for the 

aforesaid rules and regulations, as well as any other relevant documents issued by 

the Federal Aviation Administration (collectively, the "Measures"). 

The Extent of Relief sought by Petitioner and the Reasons Petitioner Seeks the 

Relief 

Petitioner seeks relief from the Measures to the extent that the Measures prohibit 

the operation of control line model aircraft at the Meadowood Special Recreation 

Management Area (SRMA), Fairfax County, Virginia (Meadowood). Meadowood 

is within the 30-mile radius from Reagan National Airport, and is, therefore, within 

the Washington, D.C. Metropolitan Area SFRA. 

In addition, although the FAA Notice Petition for Exemption or Rulemaking states 

that petitions for exemption must be sent 120 days before the exemption takes 

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effect, NVCL respectfully requests the FAA to provide expedited review of the 

petition to permit control line operations to begin at Meadowood by late 

March/early April, 2016, the normal start of our flying season. 

NVCL is a model airplane club chartered by the Academy of Model Aeronautics 

(AMA) (AMA Charter No. 308). While membership numbers fluctuate from 

year-to-year, NVCL membership currently consists of 18 active members. As 

provided in its constitution, the purposes ofNVCL are: 

a. "To support and promote the hobby and sport of control line model 

aviation in Northern Virginia; 

b. "To secure and maintain a public control line flying site in Northern 

Virginia; 

c. "To serve the youth of Northern Virginia by providing training in control 

line model airplane building and flying; 

d. "To establish a better under understanding and appreciation, on the part 

of the public and the local, state, and Federal government of the 

importance and benefits of control line model aviation." 

In furtherance of these goals, NVCL, over the years, has engaged in various 

community outreach activities to promote control line model aviation by 

encouraging public participation in the hobby. Such activities have included 

demonstrations of control line precision aerobatics and conducting introductory 

control line flights in trainers for members of the public, under the direct control of 

experienced members ofNVCL, at such venues as the Udvar-Hazy Center of the 

National Air and Space Museum, "Dulles Days" at Dulles Airport, and at local 

schools and churches. All activities ofNVCL are conducted strictly on a hobby or 

recreational basis, without remuneration. 

Operations at Meadowood: Meadowood is owned and operated by the Bureau of 

Land Management of the U.S. Department of the Interior (BLM). There are two 

flying circles in the lower meadow of the west parcel of Meadowood (See the 

schematic map attached as Attachment A, a Google photograph of the site attached 

as Attachment B, and photographs of the two circles attached as Attachment C.) 

These circles are used solely for the recreational purpose of flying control line 

model airplanes. They were installed by members ofNVCL and maintained for use 

of club members and control line flyers of the general public while the property 

was under private ownership, with the permission of the landowner. 

Under the current direction of BLM, the circles at Meadowood are reserved for the 

flying of control line models only (no free flight or RIC models or other UAVs) by 

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the general public 7 days a week during daylight hours only. The use of alcohol at 

the site is prohibited. NVCL members maintain the circles, at their own expense, 

time, and labor and keep fire extinguishers and a first aid kit on site. Although the 

control line circles are open to the general public, the principal users of the circles 

are NVCL members and their guests. NVCL has a Special Recreation Permit from 

BLM to conduct an annual control line aerobatic contest at Meadowood. This 

event, which typically attracts approximately 25-30 contestants from Virginia and 

nearby States, is formally sanctioned by the AMA. This means that the contest is 

open only to AMA members, and is conducted according to strict AMA contest 

safety standards. 

The control line flying circles at Meadowood are located approximately 1,000 feet 

from the entrance and main visitor parking lot for the west parcel of Meadowood, 

and is accessible only by a dirt road. There is a small mowed grass parking lot at 

the site (maintained by NVCL) where users of the flying circles can park their cars 

while using the facility. Vehicular access to the west parcel, including the flying 

site is restricted by a metal gate that is secured by a combination lock provided and 

maintained by NVCL. NVCL provides BLM with the combination, which is 

changed periodically. When NVCL hosts its annual precision aerobatic contest, 

the gate is left open during the hours of the contest to permit public access to the 

site. In addition to these security measures, BLM secures the gate with a second 

combination lock during the hours when the west parcel is closed. BLM does not 

provide NVCL with the combination to this second lock. 

Control line models: Unlike other forms of model aviation, such as free flight or 

radio control, control line models are unique in that for the entire duration of the 

flight of the model, the aerodynamic control of the model's elevation is controlled 

solely by means of flexible lines firmly attached on one end to the model, and on 

the other end to a handle held by the pilot. 1 These control lines are attached to the 

model and the handle for the entire duration of the flight. Accordingly, for the 

entire duration of the flight, the flight path of the model is limited to the surface of 

a hemisphere, with the pilot in the center of a circle whose radius equals the length 

of the control lines between the model and the handle held by the pilot. The handle 

held by the pilot is connected, through wires, a bellcrank, and a pushrod, to the 

model's elevators, and in some cases, to other control surfaces. This enables the 

pilot to control "up" or "down" movements of the model at the end of the control 

1 Under AMA rules, radio control is permitted in control line models only to perform secondary functions, such as to 

retract or extend landing gear, and must be under the direct control of the pilot, and may be further restricted under 

the rules for particular events, as noted below with respect to Precision Aerobatics. Relatively few control line 

models make any use of radio control, and none have been observed at Meadowood. 

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lines. As the model conducts its flight, the pilot rotates with the model, so that the 

model is always directly in front of the pilot. 

Control line models flown at Meadowood are flown in accordance with AMA rules 

prescribing the minimum diameter of wire, or other material of equivalent strength, 

used for control lines, based upon the weight of the model. In all AMA-sanctioned 

contests, the entire control system is subject to a pull-test, based on the weight of 

the model, before the model can be flown. Control handles are secured to the 

pilot's wrist by a safety thong to prevent the accidental release of the model. 

Models are powered either by an internal combustion engine or by an electric 

motor. Internal combustion engines run on a methanol-based fuel, not gasoline. 

They generally fall under the categories of beginner (trainer), sport, o.r competition 

precision aerobatic (stunt) models. Wingspans on models flown at Meadowood 

range from about 18 inches to 60 inches, with the majority of models in the 40-55 

inch range and weighing less than 60 oz. 

Most models flown at Meadowood come within the precision aerobatic category. 

Such models are limited to engine displacements of .92 cubic inches or less, or 

electric motors having a maximum no-load voltage of 42 volts. As a practical 

matter, most models have a displacement of .65 cubic inches or less, or their 

electric equivalents, Control lines are limited in length to70 feet. In control line 

precision aerobatics contests, fights are limited to 8 minutes duration. Radio 

control is permitted only to control the retraction or extension of the landing gear 

and a one-time irreversible cut-off of the engine or motor. Very few control line 

stunt models use radio control for any purpose. Pilots of precision aerobatic 

models are judged by the precision with which they perform 15 prescribed 

maneuvers. Photographs of typical models flown at Meadowood are attached as 

Attachment D. 

How Petitioner's Request Would Benefit the Public as a Whole: 

The control line facility at Meadowood is the only dedicated control line flying site 

in the State of Virginia, and one of only a few on Federal property nationwide. It 

complements the other recreational activities offered to the public at Meadowood, 

such as horse-back riding, trail biking, hiking and bird-watching. It provides a site 

for local control line modelers to fly their models and serves as a site for an annual 

major Mid-Atlantic-area precision aerobatic contest. 

Control line flying and the associated building of model airplanes help support 

STEM education locally. Model airplane building is taught at a local school (Frost 

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Intermediate) by three NVCL members. Students in the program at Frost 

Intermediate have flown control line models in the control line circles at 

Meadowood. These activities provide an introduction to topics such as strength of 

materials and blue-print reading, both supportive of STEM-related careers. Model 

airplane building is also taught at West Potomac High School to support 

technology and preparatory engineering education. NVCL has also hosted other 

youth groups at Meadowood to introduce them to control line flying. 

Reasons why the exemption would not adversely affect safety, or how the 

exemption would provide a level of safety at least equal to the existing rule: 

Control line model airplane flying in general, and control line operations at 

Meadowood in particular, pose minimal, if any, risk to other users of the National 

Airspace System, people or property on the ground, or any other threat to national 

security. 

14 C.F .R. § 93.311, (Purpose and applicability of ... [Subpart V. - Washington 

D.C. Metropolitan Area Special Flight Rules]) states, in part, 

"The purpose of establishing this area is to facilitate the tracking of, and 

communication with, aircraft to deter persons who would use an aircraft as a 

weapon, or as a means of delivering weapons, to conduct an attack on 

persons, property, or buildings in the area." 

Control line models, by their very nature, are inherently unsuitable for this 

purpose. Even if a person were to deliberately release the handle while the model 

was in flight, the model would fly erratically and would very likely crash quickly 

in the immediate vicinity of the flying circle. In this connection, it is important to 

note that the control line circles at Meadowood are located in a depression, are 

surrounded by shrubs and tall trees and are located at a considerable distance from 

any roads, structures or other activities conducted at Meadowood. (See 

Attachments A-C.) 

These same considerations would also apply to mitigate any danger caused by the 

accidental release of the handle from the hand of a pilot. The requirement that the 

handle be attached to the wrist of the pilot by means of a safety thong while the 

model is airborne minimizes the risk of a release of the model in the unlikely event 

the pilot unintentionally releases the handle. 

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Likewise, the AMA requirement for conducting a pull test on the control system of 

a model at all contests prior to flight minimizes the risk of a control line wire break 

in flight. Even if one line were to break, it is unlikely that both lines would break 

(nearly all control line models are controlled by a two-line system) and the force of 

the line remaining attached to the model (either full "UP" or full "DOWN") would 

cause the model to crash within the flight circle. 

Because of the minimal damages posed by the operation of control line models in 

general and, specifically, the particular geographical features of the Meadowood 

site, the exemption of control line flying at Meadowood from the prohibition 

currently in etiect under the Washington, D.C. Metropolitan Area SFRA would 

result in a level of safety essentially equal to that under the existing prohibition. 

Summary for Publication in the Federal Register: 

Northern Virginia Control Line seeks an exemption from 14 C.F.R. §§ 93.331 

through 93.341 and other relevant law pertaining to the Washington D.C. 

Metropolitan Area Special Flight Rules Area to permit the operation of control line 

model aircraft at the Meadowood Special Recreation Management Area, Fairfax 

County, Virginia. 

Respectfully Submitted by: 

Frank 

-.:? 

Dobrydney, 

~ ~ President 

Northern Virginia Control Line 

Date: I , 

/t3/2ol~ II' 

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Attachment A 
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Harbor 

View 

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'" 

Roads 

2000 0 

Meadowood Farm 

Resource Protedion At:eas 

2000 

N 

4000 Feet 

7 

+ £·~ • , : Creeks Ill Resource Protection Areas (RPA) 

D Meadowood Farm 

No wananty Is made by the Bureau of land Manaoement a& to the accuracy. reliability, or 

com~leteness of this data for individual use or aggregate use with other data. -=-·'"" ··r.;-···- -·-- '·~·· -· .. -· --·-· 

U.S. Department of the fhtetior 

Bureau of Land Management 

E~tern States 

March 2002 

MapS 
Attachment B 
Meadowood Recreation Area 

Imagery ©2016 Google, M 
Attachment C 


Attachment D 



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