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Polonius had leapt into the sea to join the Viking ship he saw in the bay; he swam with vigour towards the countrymen he was sure would give him succour from the lugubrious prior more saturnine than death. He swam as he had never swum, despite his advancing years. But when he reached the longship after his fine, arduous effort, and climbed the robe a surly Norseman dropped down to him, and climbed over the curved gunwale, and stood between rowing benches on the deck. The styresmand-skipper, standing at the tiller, looked at Polonius, standing drenched and shivering in his tattered cassock, as sternly as had the prior he had so recently fled. The holumenn at their oars eyed him with indifference that he sensed might easily turn to hostility.
"Why have you come from the pier at Whitby, monk? I would have left you to drown, but your desperate strokes made my holumenn curious. Have you come to tell us of some precious booty in the cloister you have abandoned, in some expectation we will let you share in the spoils won by our bloody toil? Or do you hope to join my crew and earn your booty as one of my holumenn?" The suggestion struck the Norsemen at their oars as quite absurd; the filungar, who yet stood at his bench carving a new tree for a mast, smiled cruelly at the jest; the cook and steward, working at the cauldron in the bow, turned askance, to hear the silly answer from their unexpected visitor. The captain, tall and grim, spat, "Ha!" and all the rest joined in, as if in obedience to his signal. But their laughter was from their bellies, lusty, long and raucous. Polonius saw, despite his heroic dip in the icy sea, that he was risible. Despite his shivering, he blushed, and felt himself turn red; he felt sweat between his buttocks as he was wont to do when his old, dead mother had reproached him for some fault, voicing disapproval for all about to hear.
But Polonius strapped his mind, and stood as manfully as he could, to put his case to the waiting styresmand, once the merriment had ceased. "Good skipper, I am no monk, nor any British serf or villein; I am a Dane, like you, Polonius, of some good repute."
"Polonius? He who left his fellows in an aged pinnace, who sneaked away as if to find a quieter life, to spend his remaining years in prayer, shunning the chance to live among his fellow warriors and Valkyries in Valhalla? Are you that shaming, dripping Polonius who dares wet my deck, the deck of Alrik, son of Giermund, the scourge of Whitby and Jarrow?"
"O, that Alrik? Of all the Alriks I could have met, I could not have hoped to meet a finer Alrik," enthused Polonius, judging that this moment was one when he should marshal his residual diplomatic skills. He saw Alrik was half ready to be flattered, and waited as if to hear more words of adulation. So Polonius continued, "Rough, fearsome berserker, dauntless styresmand, I left my fellows in no quest of solace in some comfortable cloister; but as you so wisely, so cunningly implied: to find a sacred treasure trove where silly relics are hid amidst croziers, chalices, crucifixes and other ruby studded, sacramental crafted from precious metals."
"You have unearthed such a find?" asked Alrik, striving to conceal his interest.
"Disguised in my cassock, I was invited to participate in the exhumation of a great founder and a saint of Lindisfarne, the very one who invented custard."
"O, old Saint Cuthbert, a great mind if ever Odin blessed Christendom with one. Sure to have died in a stately coffin, or at least buried in one," reckoned Alrik. "I have heard the monks who lived by his rule had one precious book at least-contained in gem-encrusted gold covers of beaten, red gold crafted by the holy Bilfrith."
"Of that very book I bring you tidings," said Polonius, with a confidential tone. Alrik return his confidential manner eagerly. "It has already be looted; but I am glad you were the first of all the Viking skippers to whom I could give the news."
"What foolish intelligence is this!" bellowed Alrik. "Hurl the churl into the sea." Two burly holumenn seized Polonius, his cassock still dripping with cold brine, and threw him into the even colder wavelets on the land side of the longship. The Vikings shook their fists at the sinking sage before applying themselves to the sweeps in their oarlocks, leaving him to drown or swim in their white, swirling wake.
Polonius took the latter option, and struck inward toward the land. Much to his delight, he felt himself caught in a current that took him close to the shore. He wondered if the flow was heaven sent, for it was too warm and pleasantly ebullient to be from Aegir, whose bubbles smelt of the beer he brewed in the grottos beneath the waves with his daughters; but if it were a kindly, Christian current, Polonius wondered if he had been snared in some pious drain that would never release him, if he had lost the good opinion of the likes of Alrik and his solid holumenn forever.
Never more would he return again from a jolly jaunt, raiding with a doughty, rude crew. Soothed in the soft white bubbles, he remembered fondly how he had raided, pillaged. None could daunt him from the delights of wild havoc, of razing castles and many a monastery too. Drifting toward the shore, he recalled, wistfully, how, on occasion his ships sank, but how Aegir had so often preserved him; how the god had sent one of his nine billow maiden daughters to revive him. He remembered the embrace of Dúfa, who took him up on her, moving as a the pitching wave; another occasion, fair Hefring rescued him from a stormier sea, shifting him from beneath in the from a surging wave. Or when he was lost in darkness, how Himinglæva had nestled him in a wave that reflected the light of the sky, and guided a ship to take him from the sea. But those daughters all had the scent of mead or beer, thickly topped with foam. The scent of the current round him now did not intoxicate, and the bubbles did not foam. It was sure Aegir's daughters had abandoned him in his tattered cassock; there was some other saviour giving succour that brought him undrowned, to some new haunt. As before, he found himself among the monkish ruins where he found a brew, as if to console him for the loss of Aegir's.
Still, it tasted well enough when Polonius took a sample. No doubt it was a devil-inspired brew for he drank much, far more than he intended when he took a specimen. His appetite was not satisfied until he had imbibed a near fatal quantity. Or so it seemed to Polonius, as he noticed flitting phantoms in the botany, half visible among the withering, half-uprooted shrubbery. Tonsured phantoms spirited along the Wearmouth, a stream he recognised from recent marauding. The ghostly sprites, he saw, were dressed in cassocks, their gaunt, shadowy faces in cowls. Though timid, they were forbidding, rather like the prior he had left not long before at Whitby.
It was as if these seeming earthbound, disembodied clerics had made the surrounding foliage into a chancery. For Polonius made out through his tipsy haze a susurration of vespers that issued from the direction wraiths in cassocks; he wondered if this place was where they had been slain by his order and left unblessed and unburied; if such circumstances explained their lugubrious, chanting whine. A spectral abbot approached Polonius; he gestured with the sign of the Cross and straightaway the castaway found himself afflicted with unsteady bowels. As a queasiness gripped him, the prelate spoke: "Polonius, you come a wicked, corrupted Chancellor; once virtuous and sagacious, you have turned into a lout, most uncouth, a sea brigand; one who conspires even in a cassock to pillage the holy books crafted by blessed monks, laboured over for many a year by the revered Bilfrith."
Imagine how, though squirming with a queasy gut, and his brain addled by a demon ale, Polonius flinched at the abbot's effrontery, his accusations fuelled by some false intelligence, some misunderstanding of the confidences he had offered Alrik. Surely, whoever spied on him was some malicious, gossip-mongering fiend; a miscreant who did not inform the sombre, fuscous abbot how Polonius induced the pirate Alrik to turn away from where the blessed Cuthbert had been exhumed.
But before he had time to utter any specious protest, the shrewd abbot anticipated him. "Do not deceive yourself, wanton, mealy-mouthed vagabond. If you had the means to win the good opinion of the avaricious Alrik, you would readily have done so. For you are nothing but a vicious, opportunist turncoat." Polonius was taken aback to hear such abrasive condemnation from one he believed was bound to practise charity, to utter chastisement with restraint. Yet the beer that had addled him likewise enlightened him to an alcoholic remorse. The profundity of his baseness caused him to cringe; his baseness was just then emphasised as the looseness of his bowels burst with a flatulence, followed immediately by a long, loose flow. Polonius could barely look into the eyes of the disdainful cleric, though he muttered, "Forgive me father, for I have sinned." Being of a learned frame of mind, he could not but ask himself if a ghost could serve as an absolving confessor.
"The dead can have more reason to forgive than living, Polonius; hear the counsel of the abbot, Ceolfrith" admonished the shade before him, his perspicacious knack proving quite discomfiting. "Hear one who would be blessed, if only buried in consecrated ground. Absolution is for incontinence of the soul, not the bowel. For which are you contrite, Polonius?" He took a stance from which Polonius saw he was ready to begin some litany of accusations.
In his soiled, tattered, still damp cassock; his brain still benighted by the brew he had imbibed; and the triumphantly cranky abbot backed by deceased clerics howls, Polonius saw he was at a disadvantage. But Polonius saw it was politick to take umbrage, to ask disingenuously of the holy spectre, "Now steady on. What's my vile crime?"
"Your crime, fallen Lord, is worse than bad rhyme. Was it not you who penned that trite, offensive piece, Poem upon a pome, that, as I remember, goes thus:
"Indeed it's true, the delight in poems
Is greater than found in any round pome
No matter how ruby red its hollow crown
Nor how shapely stretch its carpals round.
"For in your verse is far finer richer fruit
Than any mere red pome can ever bruit.
Your poesy does a truth quest to recruit
While the pome drops like a dead brute.
"So yes the pome may brightly shine.
Its juicy fruit may sweat on its rind.
It may nourish in manner truly kind.
But 'twill never rhyme like verses thine."
Polonius could not deny he had composed the very stanzas the dead cleric recited. He felt flattered Ceolfrith had learned his rhyme, even if only for its infamy. He saw it might not be ranked amongst the highest works of poesy. Yet this accusation, that he had written bad rhyme, was one with which Polonius had never before been confronted, but he readily intuited it was a serious one. It was one he had sought strenuously to avoid. He was o0f the profound conviction few crimes could be worse than adverse verse, featuring rhymes of low, vulgar degree, or clumsy device. He was moved to protest; he could not be condemned for the averred crime. "Take a moment to consider, Prior. Think of my more powerful works, of About the Wheel or Ode to the Onion. I am surely innocent and must resist any impending curse."
"Then do not call me 'prior'; I am Benedict, who found this abbey, who died an abbot, widely revered," the spectre said, with a wry, heavy pause. "But indeed those other works you cite are evidence of virtuosity. Still, a poem on pomes is a fiendish subject. It was, after all, a pome that brought Adam into a state of sin and caused him, with that wanton Eve, to be expelled from Eden. " Polonius saw Benedict's point as he watched to follow Benedict's melancholy eyes as they roved round ruined masonry.
Polonius urged, "Bad rhyme is less wicked than this destruction."
"Dear, wayward Polonius, in my view, your flippant, whimsical construction desecrates a solemn subject sorely, so that I find I alliterate bitterly."
"You are laying it on a bit thick, Benedict, and compounding your chagrin with a giddy flow of internal rhymes," Polonius protested with curt, indignant dudgeon. "Surely your ire would be better aimed at the vile Vikings who lay low your cloister. These charred corbels and felled arches of your bishopric aren't my doing."
But he saw me hedging. For compunction for my verse pricked me to see it was, if not worse, as bad as the Norsemen's havoc here. A ghostly parade emerged from broken bricks, from within the crumbling walls, blacked stones, grown with over with russet lichen.
"Polonius, our persecutor," they groaned in unison, iterating on and on their dirge like orison. "You who deride us in your naughty verse, who jeer as the sea raiders burn and break our holy home." Now recalled that I had heard my compatriots singing a tune much like my silly Poem upon a Pome when pulling on their oars, or burning or plundering, or engaged in other industry where a quick rhyme spurred them to their task. Polonius began, against his better understanding, to empathise. He had promised himself that he would never empathise except where empathy yielded some profit. Yet here such responsiveness could not be lucrative. Except, perhaps, to diminish the monkish carping that was even more pronounced in this shady company than among the displaced, yet quick, monastics with whom he had carried Cuthbert's casket; at least of their number, it was only the surly prior who had voice.
"Vile Norseman, you who disturbs our graves, you have broken hallowed ground. Now repent." These dead monks had spirit to so address those they regarded as knaves, holumenn from whom they would cringe just months ago.
"Ceolfrith, admonish this churl he must lament," wheezed out a grey shade more forward than the rest. "Heaven we crave. Yet we need him in our yeasty, skyward ferment."
Ceolfrith replied, "Sigfrith, I am downcast to opine He hasn't fully imbibed absolution in our wine." Listening to these diaphanous fellows whining while rhyming, Polonius saw it was a little one-eyed for Ceolfrith to take him to task for his own more expert verse, as he saw his Poem upon a Pome. Yet he now gleaned some insight from the monks' chatter. He had some inkling of their monastic plot; Polonius saw that he had earned some merit when, alone among the members of his longship's crew, he survived, undrowned, and escaped to the Holy Isle in his aged pinnace, plagued by the thoughts of mortification and self-redemption, as a castaway. He wondered if he were all the better valued because of the Vikings from his crew he had slashed with his broadsword, forcing them from his decrepit pinnace. He reckoned if these dead monks loved him all the more for stopping the Danish pagans coming safe with him to Cuthbert's burial place; even though as he arrived the monks of Lindisfarne were exhuming him.
Ceolfrith saw into Polonius' thoughts with the perspicacity of an airy wraith. He pre-empted Polonius with a show of frankness, telling him, "When your fellows sank to the deep to rot, it seems Providence favoured you for your earlier years when you were governed by reason and self-discipline. I will not deny that decapitating or maiming fellow Vikings did not earn you more grace, even though you acted more from cowardice than as a champion of Christendom. But we3 of the cloister are always ready to recognise our debts, even those of a self-serving poltroon."
"You offer painful insights into my character," answered Polonius, manfully willing to acknowledge his faults if not particularly manful when at a disadvantage in battle, or choosing between his own safety and that of his shipmates.
"Grace comes to you as if by some mysterious accident," went on Ceolfrith, as if ignoring Polonius' candour as specious. "I intuit Heaven succoured when Alrik hurled you into the waves, preserving for your short pilgrimage in earlier days."
Polonius understood the phantom, and acknowledged his wisdom, saying "But for carrying Cuthbert's coffin over the causeway and onto Durham Road, I'd be in hell's fires. I was their saviour because I was a stray."
The one called Sigfrith wrung his crinkled hands in greedy glee. "Did he quaff mead enough on the strand ? is he now enlightened with the holy yeast; will he die now from the spirits and take us with him to Paradise."
The Abbot Ceolfrith clapped hard on his brow. He was perturbed. He mumbled, "If he did not die, having imbibed the holy mead, we have no holy corpse to redeem us to the afterlife. Eosterwine, is much mead in the hogshead ?" He called to a monk who wore a vintner's cassock.
But before Eosterwine could answer, the sprightly sprite creased a worried frown. He ran, his abbot's pallium bouncing, as if he were more living than dead. He checked Polonius' mead barrel; his face fell down. Half the mead remained; the ghoulish monks reached out for their anxious scapegoat, as if they might hold him and force the barrel's remaining contents down his gullet.
But much to Polonius' relief, he saw a coracle float upon the strand. His brain was fully alive, unaddled. He pushed the little boat into the sea, and furiously paddled. He fancied that Aegir's watery daughters pushed him fast away from the wraiths he left behind in fruitless pursuit.


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Reviewed By Matt G (San Diego, CA) Reviewed for a 1998 Mitsubishi Montero Sport —12/5/2006 8:12 PM
Holy S#@& These are Insanely bright! I kinda feel bad for anyone I come across when I'm off roading...
Reviewed By Stephanie G (MAKAWAO, HI) Reviewed for a 2015 Nissan Frontier —5/26/2016 9:52 PM
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Reviewed By Christopher M (BRISTOW, VA) Reviewed for a 2003 Ford F-250 —5/22/2016 6:55 AM
Well built lights that throw a nice white beam. I went with one spot and one spread to get the best of both worlds. Installation was easy and straight forward. They might want to universalize the wiring instructions though.


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The Centre for Creative Collaboration (C4CC) is an initiative of the University of London, working in collaboration with the Royal Central School of Speech and Drama, Goldsmiths, University of London, and Royal Holloway, University of London.
C4CC supports new types of collaboration using the principles of open innovation. This is a ground-breaking project for London, delivering collaborative projects and multi-disciplinary ways of working in an attractive and flexible space.
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Funded in part by the European Regional Development Fund, London Creative and Digital Fusion is focused on job creation and new revenue opportunities for SMEs. It is a collaboration involving C4CC, the Council for Industry and Higher Education, Lancaster University, the Royal College of Art, Queen Mary, University of London, and the Work Foundation.
C4CC is also supported by the Higher Education Funding Council for England and by the London Development Agency.


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I have close to 10 pounds of butternut squash in my cabinet. Why, you ask? Because it's tasty and when I bought it at the farmers market this fall I knew it would last for quite a long time! We've probably gone through close to 15 pounds of butternut squash since August. It's such a wonderful sweet flavor and so easy to make that we bought a bunch! One of the squash weighs in at SIX POUNDS! I have no idea when I'll be using it…. I might have to cube it up and freeze it! Oh, that's a good idea. I'll have to do that after I finish this entry.
Anyway, since I have sooooo much butternut squash, I figured I would look through my "favorites" list on Foodgawker to see if I could find a savory recipe to post on here. I found a delicious one! It comes from Kalyn's Kitchen and I am very excited to share it with you.
Roasted Rosemary and Balsamic Butternut Squash
Servings: 5
Points Per Serving: 5 (although I'm questioning the recipe builder on the WW site because when I entered in the butternut squash (with a zero point value) it gave it a points value of 11! I'll get back to you on this issue.)
- 2 lbs butternut squash cubes (about 6 cups)
- 2 tbsp extra virgin olive oil
- 5 tsp best quality balsamic vinegar
- 1 tsp very finely chopped fresh or frozen rosemary, or slightly less dried rosemary (be sure it's especially finely chopped if you use dried rosemary)
- sea salt to taste
- fresh ground black pepper to taste
1. Preheat oven to 400 F/200C. Mix together the olive oil, 4 tsp balsamic vinegar, and rosemary, then toss squash cubes with the mixture.
2. Arrange the squash on a cookie sheet or dish large enough to hold it in a single layer. Roast 20 minutes, then turn squash and roast about 20 minutes more, or until squash is very soft and starting to get slightly caramelized.
3. Remove from oven and toss squash with additional 1 tsp balsamic vinegar, sea salt, and pepper. You can mash slightly if you want. Serve hot.
See? Easy peasy! It can be made ahead of time and taken out the next day to be warmed up once more. It's a great side dish for all holiday meals, or just as a tasty pairing with chicken and lamb. It's also nice to post a savory butternut squash recipe rather than one that's chocked full of brown sugar and butter, which is pretty typical of butternut squash recipes. It's Weight Watchers friendly and South Beach Diet friendly too! Not only is it tasty, but it's beautiful! I hope you enjoy.
Oh, and until I get back to you all with the points dilemma, it's either 5 points per serving or 2 points per serving. Quite a difference, eh!?! I hope WW gets back to me soon! Or I'm gonna have to go all crazy woman on their patooties.


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Hello next month I have a 300 dollar budget that I am going to buy mountain bike accessories for my mountain bike since I do a lot of road cycling. Below is what I am going to buy. All suggestions greatly appreciated.
Bike Rack,water bottle or camelback,bicycle clothing,bicycle bag ,personal care products ,bike pump,26x 1.95 tire size buying 2,gps possible ,wirelesscyclo computer helmet ,mountain bike shoes.


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Town Square
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OTHER TOPICSWednesday in Menlo Park: Kelley brothers at Kepler's
The whirlwind that is Tom Kelley was heading to San Francisco International Airport for "the ninth city in 10 days" on Oct....Original post made on Nov. 6, 2013
Last comment by Charlie Quimby, on Nov 6, 2013 at 8:23 pm | 1 comment | 11214 Views
MENLO PARKSunset campus sold to real estate investment firm
A little more than a month after employees were first told that the landmark Sunset campus was up for sale, the property...Original post made on Dec. 11, 2014
Last comment by Peter Carpenter, on Dec 17, 2014 at 7:45 am | 58 comments | 11211 Views
OTHER TOPICSAtherton volunteers rebuild plane-crash victim's home
Four years after a Tesla employee's plane plummeted into an East Palo Alto neighborhood, destroying Lisa Jones' home and...Original post made on Aug. 17, 2014
Last comment by Mary S, on Sep 27, 2014 at 1:00 pm | 15 comments | 11210 Views
MENLO PARKFacebook packs up for Menlo Park
Facebook's plan to shift headquarters from Palo Alto to Menlo Park has possibly been the worst-kept secret of the past month....Original post made on Feb. 8, 2011
Last comment by NQ, on Feb 9, 2011 at 7:45 pm | 2 comments | 11198 Views
AROUND TOWNTop stories of 2013
This was not a year reporters spent idling at their desks, desperate for news to write. On the contrary, 2013 brought a deluge...Original post made on Dec. 30, 2013
Last comment by Feeling defensive?, on Dec 30, 2013 at 6:04 pm | 2 comments | 11190 Views
MENLO PARKMenlo Park: Monte Rosa stop sign approval temporarily stopped
At Vice Mayor Catherine Carlton's request, the Menlo Park council last night tabled the question of whether to install stop...Original post made on Aug. 20, 2014
Last comment by Mike Keenly, on Aug 26, 2014 at 12:34 pm | 27 comments | 11173 Views
SPORTSGirls softball: Patton pitches perfect game
Woodside High School's Christina Patton pitched a perfect game Tuesday to lead her team to a 11-0 victory over Menlo-Atherton...Original post made on Apr. 4, 2013
Last comment by WHS Parent, on Apr 4, 2013 at 6:43 pm | 1 comment | 11141 Views
MENLO PARKLetter: Is it art -- or a disgrace?
Please take a moment to look at this photo. The "sculpture" in the photo is located on Willow Road and Coleman Avenue in...Original post made on Jun. 18, 2013
Last comment by mary ellis, on Jul 9, 2013 at 3:26 pm | 49 comments | 11106 Views
SCHOOLS & KIDSTim Hanretty pleads not guilty of embezzling funds from Portola Valley School District
Tim Hanretty pleaded not guilty this morning (June 19) to six counts of embezzlement from the Portola Valley School District,...Original post made on Jun. 19, 2012
Last comment by Stephanie, on Jun 22, 2012 at 7:39 am | 8 comments | 11090 Views
SCHOOLS & KIDSMenlo school district board to appoint new trustee
The Menlo Park City School District board will appoint a replacement for member Mark Box, who announced his resignation from...Original post made on Jun. 3, 2011
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WOODSIDEWoodside Community Theatre stages 'The Producers'
New faces will be appearing in "The Producers" the last weekend in October and first weekend in November as Woodside Community...Original post made on Oct. 20, 2013
Last comment by Darrell, on Oct 20, 2013 at 4:15 pm | 1 comment | 11011 Views
AROUND TOWNCircling the Wagons and Giving Change a Chance Position Paper by Michael G. Stogner, Candidate for Supervisor
The SamTrans scandal is a perfect example to illustrate many of the issues that I have been campaigning about in San Mateo...Original post made by Michael G. Stogner on May. 11, 2014
Last comment by Michael G. Stogner, on May 14, 2014 at 7:31 am | 5 comments | 10999 Views
MENLO PARKDriver killed by train in Menlo Park is identifed
Caltrain has identified the victim of the fatal accident on Monday, Feb. 23, at the Ravenswood Avenue crossing in Menlo Park. Read...Original post made on Feb. 25, 2015
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AROUND TOWNGuest opinion: Concern over church use of council chambers
The following letter was addressed to the members of the Menlo Park City Council: Read the full story here http://www.almanacnews.com/story.php?story_id=5558...Original post made on Jan. 22, 2008
Last comment by Richard Hine, on Jan 29, 2008 at 3:25 pm | 74 comments | 10966 Views
AROUND TOWNPossible misappropriation of funds found in Portola Valley schools
Already struggling to address a projected deficit of $854,000 in the next school year, the Portola Valley School District...Original post made on Jun. 2, 2012
There are no comments yet. 10922 Views
MENLO PARKDid Menlo Park fire district chief put TV show ahead of accident response?
There is little or no disagreement from Menlo Park Fire Protection District Chief Harold Schapelhouman on the facts in an...Original post made on Jan. 19, 2011
Last comment by Peter Carpenter, on Feb 13, 2012 at 8:20 pm | 228 comments | 10910 Views
OTHER TOPICSRally opposing Prop 8
Several community leaders in San Mateo County, including Supervisor Rich Gordon, will speak at a rally to oppose Proposition...Original post made on Oct. 15, 2008
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SCHOOLS & KIDSEditorial: Gap year -- a Year of Living Adventurously
It's not always obvious when we as individuals arrive at a crossroad. Decisions that seem inconsequential at the time can...Original post made on Jun. 13, 2013
Last comment by Ethan Knight, on Jun 14, 2013 at 11:06 am | 3 comments | 10856 Views
AROUND TOWNDutch Goose racing to finish ADA improvements
Businesses up and down the Peninsula are getting to know one customer by name. A San Jose resident has filed lawsuits for...Original post made on Mar. 6, 2015
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OTHER TOPICSthe new Gov. Romney VP choice post
Months ago, Emerle created a post on suggested VP candidates for Mitt Romney. Quite a bit early as it turned out, the scrubs...Original post made by Chuck Roofe on May. 6, 2012
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Terún to open second Cal Ave restaurant
By Elena Kadvany | 10 comments | 5,645 views
"This is Never Gonna Go our Way . . .
By Chandrama Anderson | 0 comments | 963 views
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By Cheryl Bac | 0 comments | 570 views
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By Laura Stec | 0 comments | 120 views


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I will definitely be returning!
Highly recommend.


text:
By Peter Sachs, Esq.
[Originally Published: 12/14/2013; Revised: 12/25/2015]
For purposes of this website, the word "drone" means any flying craft of the "model aircraft" variety and nothing else. Model aircraft are commonly those under 55 pounds, and are typically very much under 55 pounds. Members of the media have unfortunately contributed to some confusion as to the difference between military and civilian drones. Until about September 2014, nearly every news piece displayed a photo or video of a military drone, for any story about civilian drones.
Although much of the media still report inaccurately, or simply parrot whatever the FAA says, some news sources are coming around. For the most part, they no longer show a military drone for a piece on civilian drones. Over the course of 2014, most people have realized that these flying craft will always be called drones. In any case, anyone can call them whatever they wish. The legal issues related to drones do not at all include what they should be called. It's just a word.
Federal drone law.
In November 2014, the NTSB held (in the Pirker case addressed below), that drones are "aircraft," as the word is defined under federal statutes and regulations, and therefore, FAR 91.13 (the regulatory prohibition of careless or reckless aircraft operations) applies to drones. Although the FAA asserts that all FARs apply to drones, in the NTSB's decision, the Board did not expressly hold that any other FAR applies to drones. The relevant portion of FAR 91.13 reads:
"No person may operate an aircraft in a careless or reckless manner so as to endanger the life or property of another."
At this writing, there exist no currently enforceable federal statutes or regulations that apply to the general public other than:
[1] FAR 91.13, (in accordance with the NTSB's November 2014 ruling);
[2] all FARs that prohibit or restrict all aircraft from flying within certain airspace; and
[3] effective December 21, 2015, the Interim Final Rule of 14 CFR PART 48, entitled "Registration and Marking Requirements for Small Unmanned Aircraft." (More on this below.)
Again, the three items listed above are the only currently enforceable federal regulations regarding drones, that apply to the general public.
The FAA Modernization and Reform Act of 2012.
The FAA Modernization and Reform Act of 2012 (the "FMRA"), is a collection of orders from Congress to the FAA. Sections 331 through 336 dictate what the FAA may and may not do, and shall or shall not do with respect to drone regulation. But the FMRA applies to the FAA only. The FMRA contains certain drone-specific language that will apply to the general public at some point in the future, but it does not currently apply to the general public.
That's very important to note. All of what the FAA, and a handful of former FAA attorneys who parrot what the FAA touts as "the law," is based upon the FMRA, which doesn't even apply to the general public at this writing.
Within the FMRA is Section 336. It reads:
(a) IN GENERAL.—Notwithstanding any other provision of law relating to the incorporation of unmanned aircraft systems into Federal Aviation Administration plans and policies, including this subtitle, the Administrator of the Federal Aviation Administration may not promulgate any rule or regulation regarding a model aircraft, or an aircraft being developed as a model aircraft, if—
(1) the aircraft is flown strictly for hobby or recreational use;
(2) the aircraft is operated in accordance with a community-based set of safety guidelines and within the programming of a nationwide community-based organization;
(3) the aircraft is limited to not more than 55 pounds unless otherwise certified through a design, construction, inspection, flight test, and operational safety program administered by a community-based organization;
(4) the aircraft is operated in a manner that does not interfere with and gives way to any manned aircraft; and
(5) when flown within 5 miles of an airport, the operator of the aircraft provides the airport operator and the airport air traffic control tower (when an air traffic facility is located at the airport) with prior notice of the operation (model aircraft operators flying from a permanent location within 5 miles of an airport should establish a mutually-agreed upon operating procedure with the airport operator and the airport air traffic control tower (when an air traffic facility is located at the airport)).
(b) STATUTORY CONSTRUCTION.—Nothing in this section shall be construed to limit the authority of the Administrator to pursue enforcement action against persons operating model aircraft who endanger the safety of the national airspace system.
(c) MODEL AIRCRAFT DEFINED.—In this section, the term ''model aircraft'' means an unmanned aircraft that is—
(1) capable of sustained flight in the atmosphere;
(2) flown within visual line of sight of the person operating the aircraft; and
(3) flown for hobby or recreational purposes. (Emphasis added.)
Section 336 would provide "safe harbor" to pilots while flying strictly for hobby or recreation as long as all of the conditions (the underlined portions) are met. This section would apply at some time in the future, however. It does not apply right now. Right now, the only document that addresses model aircraft is
Advisory Circular 91-57 ("AC 91-57"), published in 1981. Advisory Circular 91-57A, published September 2, 2015, which replaces Advisory Circular 91-57. Like its predecessor, AC 91-57A is merely a guidance document. It is not itself law. Note: Section 336 would be codified and therefore be law, under the proposed future FAR Part 107. More on that later.
The June 2014 FAA Interpretation of Section 336.
In June 2014, the FAA issued its Interpretation of the Special Rule for Model Aircraft (Section 336 above). With its Interpretation, the FAA declared, among other things:
- Compensation of any sort is banned. The FAA claims that flying a drone in a manner that is "in furtherance of a business" is illegal even though no currently enforceable statute or regulation exists that would forbid it. (Remember, the FMRA does not apply to the general public.) That includes everything from the obvious (aerial photography) to the less obvious (flight instruction or demonstrations that would further one's business). Showing drone-obtained video and a company logo simultaneously online or on-air is considered "commercial." Moreover, drone flights that are "incidental to a business" (which would not be considered "commercial" in a full-size manned aircraft) are considered commercial if done with a drone.
- Flights within 5 miles of any airport may be denied. Providing "notice" alone is no longer enough. You must provide prior notice to ATC or Airport Operations whenever you fly within 5 miles of any airport, heliport, etc. However, ATC may say you may not fly in that location. It is arguable that this amounts to obtaining permission as opposed to simply providing notice. Since the Interpretation doesn't specify the size of the drone to which it applies, you must call ATC even if it's a tiny, 1-ounce drone hovering 1-inch above the ground in your backyard.
- Operating a drones using "first person view" ("FPV") is prohibited. This means you cannot use goggles or any modern "watch it on a monitor" system to fly, or even the long-accepted "buddy box" method where a second person (with a separate controller) observes the drone at all time while the pilot flies. Instead, the pilot's own eyes must be able to see the drone at all times while flying.
- All existing Federal Aviation Regulations apply to drones. Since the FAA considers "model aircraft" to be "aircraft," it claims that all Federal Aviation Regulations apply to drones, even though the plain language of Section 336(c) makes it abundantly clear that the definition applies only to Section 336 itself. This arguably means that all Federal Aviation Regulations, even those that cannot logically apply to an unmanned aircraft, apply to drones and the FAA can use any of those regulations for enforcement purposes.
With the Interpretation's restrictions and requirements above, the FAA has created new regulations pertaining to drones flown for hobby or recreation, which Congress expressly prohibited in Section 336 of the FMRA (see Section 336 above). Nonetheless, as "interpretive rulemaking," the Interpretation is the only potential "rule" that exists right now other than FAR 91.13 and all FARs that prohibit or restrict all aircraft from flying within certain airspace.
In response to the Interpretation, the public submitted over 30,000 comments. And in August 2014, three separate legal challenges to the FAA's Interpretation ("Petitions for Review") were filed in the D.C. Circuit Court of Appeals by attorney Brendan Schulman, on behalf of several Petitioners, including this writer.
The Petitions argue that the Interpretation is "arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law, in excess of statutory jurisdiction, authority, or limitations, and without observance of procedure required by law." That matter is now pending because the Court granted a Motion for Abeyance on the basis of the FAA having not yet reviewed the 30,000+ public comments.
Under the terms of the Court's granting of the Motion for Abeyance, the FAA is required to provide 90-day updates on its comment review process. And if the FAA attempts to enforce anything it purports to require or restrict under the Interpretation, (such as its claimed ban on commercial operations), all bets are off and the case may proceed. As of February 12, 2015, the FAA has stated that it had not even begun to analyze the public comments.
Update (March 9, 2015): In Perez v. Mortgage Bankers Association (March 9 2015), the Supreme Court held that agency interpretations of statutes and regulations are not legislative rules, and accordingly do not require agencies to follow the APA's notice and comment procedures. The Court further held that as non-legislative rules, agency interpretations do not have the force and effect of law, and only indicate to the public what an agency perceives the law to be.
Courts must still give deference to agency interpretations, and those interpretations will stand unless a court finds them to be arbitrary and capricious. Exactly what effect, if any, the Perez decision has upon the June Interpretation is unknown. Since the FAA remains free to interpret aviation statutes and regulations as it sees fit, and since courts must defer to those interpretations unless they are determined to be arbitrary and capricious, the decision appears to have little practical effect on curbing the FAA's use of interpretations to modify existing law.
Close attention should be paid to Justices Scalia's and Thomas' concurrences. Both express strong concern for agencies being able to draft broad and ambiguous regulations intentionally, knowing they may "fill-in-the blanks" at a later date simply by interpretation, thereby changing the meaning of regulations with relative impunity due to the deference requirement.
For decades, the definitions of "aircraft" did not include "model aircraft," the majority of which are now of the "drone" type. The FAA neither considered nor treated them as "aircraft." However, that all changed when, for the first time in history, the FAA issued a Proposed Order of Assessment against a foreign national named Raphael Pirker. Pirker is a well-known, highly skilled and experienced drone pilot. In 2011, at the request of the University of Virginia, Pirker flew a drone over the campus to obtain video footage and was compensated for the flight. That flight resulted in the FAA issuing an Proposed Order of Assessment of a civil penalty of $10,000.00.
In its Order of Assessment, the FAA listed all of its alleged facts concerning the flight, including an allegation that Pirker was compensated for it. However, the FAA did not rely upon that compensation at all for its proposed civil penalty. It couldn't. There existed no FAR that prohibited commercial operation (and there still exists no such FAR). Instead it based its Proposed Order of Assessment solely upon an allegation that Pirker flew recklessly, in violation of FAR 91.13. The Proposed Order of Assessment, in relevant part reads:
By reason of the foregoing, you violated the following section(s) of the Federal Aviation Regulations:
a. Section 91.13(a) which states that no person may operate an aircraft in a careless or reckless manner so as to endanger the life or property of another."
Pirker's attorney, the nation's first and preeminent "drone attorney," Brendan Schulman, filed and won a Motion to Dismiss. In March 2014, Administrative Law Judge Patrick Geraghty, in a well-reasoned, logical and scathing decision, granted Schulman's Motion to Dismiss and the FAA lost. The Administrative Law Judge ("ALJ") held that drones (which he referred to as "model aircraft.") are not aircraft under the federal definitions, and therefore the FAA had no jurisdiction over Pirker's flight. Not surprisingly, the FAA appealed the decision immediately to the full NTSB Board.
In November 2014, the NTSB issued its appeal decision, reversing the ALJ's granting of Pirker's Motion to Dismiss. It held that drones are aircraft as the word is defined under federal law and therefore subject to the recklessness regulation. It remanded the matter to the ALJ to decide whether Pirker's flight was, in fact, conducted recklessly.
The NTSB's decision was very narrow in one respect: it held that because drones are aircraft, FAR 91.13, the only FAR at issue in the matter, applies to drones. It did not address "commercial use" since that was not addressed by the Judge, and it did not hold that any other FAR applies to drones.
The Board's decision was very broad in another respect: it did not qualify which size drones are aircraft. So both a 1-ounce child's "toy" drone and a 55-pound industrial-sized drone are aircraft, and both are equally subject to FAR 91.13. In fact, given the extremely broad federal definition of aircraft, even paper airplanes are now subject to FAR 91.13. Yes, there is a manufacturer of paper airplane drones. In fact, the FAA granted me a Section 333 Exemption to fly it commercially. 🙂
As for Raphael Pirker, there was no decision on remand to the ALJ. Judge Geraghty first demanded that the FAA explain its authority to bring the recklessness action against a foreign national in the first place, since according to the FAA itself, it's not supposed to. The FAA's Order 2150.3B (Chapter 6, paragraph 34(a)) makes that clear. It reads:
34. Violations of FAA Regulations by Foreign Persons.
a. General. Legal counsel for the region with geographic responsibility for the investigation processes a case against a foreign person who violates the Federal Aviation Regulations. Legal counsel takes legal enforcement action against an airman who [1] commits a violation while exercising the privileges of his or her FAA airman certificate, a foreign individual who [2] commits a passenger violation, or [3] a foreign air carrier operating under 14 C.F.R. part 129. All other violations committed by foreign persons, except Canadian persons, are referred to the appropriate foreign aviation authority through the Department of State. Violations committed by Canadian persons, for whom legal enforcement action is not taken, are referred directly to Transport Canada. (Emphasis added.)
Pirker's actions did not fall under any of the emphasized language above. He is not an FAA certified airman. He did not commit a passenger violation and he is not a foreign air carrier. This means that the entire Pirker matter, should have been handled by the "appropriate foreign aviation authority" through the Department of State, not by the FAA— a fact that had been argued by Schulman.
In the end, Pirker settled the case that never should have been brought against him by the FAA, for $1,100.00, with no admission of wrongdoing on his part. The FAA got an NTSB decision that drones are "aircraft" as that term is defined under the federal statutory and regulatory definitions, and subject to a single FAR— 91.13 (recklessness). Unless and until definitions of aircraft change, or a new definition for drones is created, drones will remain aircraft.
The FAA's enforcement of its claimed prohibitions.
The FAA has not attempted to enforce its claimed new rules in the Interpretation. Nor has it ever attempted to enforce its long-claimed commercial use ban. Not once. Unless someone operates recklessly, at most they will receive an "educational letter" sent by FAA non-attorneys, that are carefully worded to encourage, but never order the recipient to do or not to do anything. Only FAA legal may issue such orders to do or not to do something, despite non-attorney FAA employees having issued such orders wrongfully and repeatedly over the past few years.
If a drone pilot receives a letter from the FAA, the first thing to do is to see who it is from. If it's not from the FAA's legal department, you need only read it and glean from it whatever useful information it might contain. Even then, according to the FAA's Compliance & Enforcement Order 2150.3B Chg 6:
When sufficient evidence exists to support a violation that poses a medium or high actual or potential risk to safety, legal enforcement action is appropriate. For example, legal enforcement action is appropriate when a UAS operation has a medium or high risk of endangering the operation of another aircraft or endangering persons or property on the ground. In addition, repeated or intentional violations generally warrant legal enforcement action. (Emphasis added.)
So if a drone pilot doesn't (1) endanger the operation of another aircraft or (2) endanger persons or property on the ground, they should be fine. If one receives several educational letters, the FAA claims it will start a legal enforcement action, but thus far even those who have received repeated "educational letters" have not faced any legal action.
As an alternative to simply flying safely, responsibly and commercially, those who wish to fly a drone commercially, and with the FAA's blessing right now, may opt to petition for a Section 333 Exemption. If such a petition is granted, an operator may fly their drone commercially, albeit with restrictions.
It should be noted that Section 333 was never intended to be applied in this manner. The intent (as the section's language makes clear), was for the Administrator to determine which types of drones could be operated safely in the NAS before the Final Rule was adopted. The intent was never to have the Administrator determine on a case-by-case basis, which particular persons or entities were deemed worthy of using drones commercially.
FMRA Section 333 reads:
(a) IN GENERAL.—Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act.
(b) ASSESSMENT OF UNMANNED AIRCRAFT SYSTEMS.—In making the determination under subsection (a), the Secretary shall determine, at a minimum— (1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1).
(c) REQUIREMENTS FOR SAFE OPERATION.—If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system. (Emphasis added.)
According to the FAA's online Section 333 Exemption Portal, that section permits the Secretary of Transportation to exempt a petitioner from certain existing FARs before future drone regulations are finalized if:
- the petitioner can demonstrate that existing FARs burden them;
- the petitioner can provide a level of safety that is the same or greater than the regulation from which an exemption is sought; and
- the petitioner's request is in the public interest.
In making that determination, the Secretary considers:
- What type of drone is it?
- How big is the drone?
- How fast it can fly?
- What can it do and not do (flight capability-wise)?
- How close would it be flying to airports?
- How close would it be flying to populated areas?
- Will the drone operator be able to see it at all times?
- Will it create a hazard to NAS?
- Will it create a hazard to the public?
- Will it pose a threat to national security?
If the FAA grants an Exemption, the holder will be subject to certain restrictions, some of which it relaxed a bit on March 24, 2015. However, you will still need to hold a airman certificate. The new FAA policy states that that certificate may be a an airline transport, commercial, private, recreational, or sport pilot certificate, as opposed to the private pilot certificate it previously required. The drone operator must also hold either a current FAA airman medical certificate or a valid U.S. driver's license. Previously, an airman medical certificate was required.
The FAA also relaxed the areas in which operations may be conducted under an Exemption. Under the new policy statement, the FAA will grant a "blanket" Certificate of Waiver or Authorization ("COA") that may be exercised "anywhere in the country except restricted airspace and other areas, such as major cities, where the FAA prohibits UAS operations."
The blanket COA may be granted to any drone operator (1) who has been granted a Section 333 Exemption, as long as (2) the drone weighs less than 55 pounds, (3) it is flown at or below 200 feet, (4) it is operated during daytime Visual Flight Rules ("VFR") conditions, (5) it is operated within visual line of sight ("VLOS") of the drone operator, and (6) it is operated at certain distances away from airports or heliports:
- 5 nautical miles (NM) from an airport having an operational control tower; or
- 3 NM from an airport with a published instrument flight procedure, but not an operational tower; or
- 2 NM from an airport without a published instrument flight procedure or an operational tower; or
- 2 NM from a heliport with a published instrument flight procedure.
If a drone operator wishes to fly outside the blanket parameters, he or she must first obtain a separate COA that is specific to the airspace intended to be used for that operation.
For additional information on Exemptions, visit the FAA's Section 333 Exemption portal, and its Guidelines for Submitting a Petition for Exemption.
On February 15, 2015, the FAA issued its small drone Notice of Proposed Rulemaking ("NPRM"), entitled "Operation and Certification of Small Unmanned Aircraft Systems." The proposed rule would permit drone operation for non-hobby and non-recreational uses, thereby allowing, by regulation, commercial drone and non-hobbyist operations, under certain conditions.
There are some significant limitations in the NPRM. Drones may not be flown over "non-involved" people, and must not be flown to distances greater than those which would permit the drone operator to see the drone at all times. So beyond line-of-sight drone operations (such as long distance drone delivery services) would not be permitted under the proposed rule. Night operations would also not be permitted. This could hamper fire and other emergency services, among others. And ATC clearance would be required for flights conducted within Class B, C, D and E airspace, which might prove overly burdensome to both ATC personnel and drone operators.
Bear in mind, however, that the NPRM is a proposed rule and subject to change before it eventually becomes FAR Part 107 at some time in the future. The NPRM is not the law right now. The NPRM process is a long one, and public input might result in changes to the rule, favorable to some and unfavorable to others. That said, and much to everyone's surprise, the FAA has proposed the exact opposite of what the drone community had expected.
Although not perfect, the NPRM is, in this writer's opinion, quite a good start. Public comments to the proposed rule may be submitted for consideration for 60 days following its publication in the Federal Register. The FAA has provided a complete summary of the proposed rule here, which is included below.
Proposed drone requirements:
Under the proposed rule:
- an FAA airworthiness certification would not be required.
- the drone must be maintained in condition for safe operation and prior to each flight must be inspected to ensure it is in a condition for safe operation.
- aircraft registration is required in the same manner that applies to all other aircraft.
- aircraft markings are required in the same manner that applies to all other aircraft, but if aircraft is too small to display markings in standard size, then the aircraft simply needs to display markings in the largest practicable manner.
Proposed operator requirements:
Under the proposed rule, pilots of small drones would be called "operators," and they must:
- be at least 17 years old.
- pass an initial aeronautical knowledge test at an FAA-approved knowledge testing center.
- be vetted by the Transportation Security Administration.
- obtain an "unmanned aircraft operator certificate" with a "small drone rating," which never expires.
- pass a recurrent aeronautical knowledge test every 24 months.
- make available to the FAA, upon request, the drone for inspection or testing, and any associated documents/records required to be kept under the proposed rule.
- report an accident to the FAA within 10 days of any operation that results in injury or property damage.
Proposed operational requirements:
Under the proposed rule, drones:
- must weigh less than 55 lbs.
- must remain within visual line of sight of the operator or visual observer.
- must remain close enough to the operator for the operator to be able to see the aircraft with vision unaided by any device other than corrective lenses.
- may not operate over any persons not directly involved in the operation.
- may only be operated from official sunrise to official sunset, (local time).
- must yield the right-of-way to other aircraft, whether manned or unmanned.
- may, but are not required to use a visual observer.
- may be flown using "first-person view," but either the operator or the visual observer must maintain an unenhanced visual line of sight of the craft.
- may be flown at a maximum airspeed of 100 mph (87 knots).
- may be flown at a maximum altitude of 500 feet above ground level.
- may be flown in minimum weather visibility of 3 miles from the operator.
- may not be flown in Class A (18,000 feet & above) airspace.
- may be flown in Class B, C, D and E airspace with ATC permission.
- may be flown in Class G airspace are allowed without ATC permission.
- may not be flown carelessly or recklessly.
- require a preflight inspection before each flight, including specific aircraft and control station systems checks, to ensure the drone is safe for operation.
- may not be flown by a person if he or she knows or has reason to know of any physical or mental condition that would interfere with its safe operation.
- and no person may act as an operator or visual observer for more than one unmanned aircraft operation at one time.
Proposed "micro drone" option:
The NPRM also proposes a "micro drone" option, which appears to be based upon the Petition submitted by Brendan Schulman on behalf of my co-petitioner, UAS America Fund, in our action challenging the FAA's Interpretation. The FAA states in its NPRM that it is considering the following, with respect to the operation of micro drones:
- it would weigh no more than 4.4 pounds (2 kilograms).
- it would be made out of frangible materials that break, distort, or yield on impact so as to present a minimal hazard to any person or object that the unmanned aircraft collides with.
- it would not exceed an airspeed of 30 knots.
- it would not travel higher than 400 feet above ground level (AGL).
- it would be flown within visual line of sight; first-person view would not be used during the operation; and the aircraft would not travel farther than 1,500 feet away from the operator.
- the operator would maintain manual control of the flight path of the unmanned aircraft at all times, and the operator would not use automation to control the flight path of the unmanned aircraft.
- operation would be limited entirely to Class G airspace.
- it would maintain a distance of at least 5 nautical miles from any airport.
The NPRM does not change Section 336.
Finally, the proposed rule does not change Section 336. It merely codifies it. It makes it clear that Part 107 would not apply to model aircraft that meet the criteria set forth in Section 336, and that the FAA's enforcement authority extends only to prohibiting model aircraft operators from endangering the safety of the National Air Space.
State and local government drone law.
State and local governments have passed legislation that purports to regulate drone flight, but if challenged in court, any such laws would be considered preempted by the federal government's intent to "occupy the field," and therefore be invalid. By federal statute, "[t]he United States Government has exclusive sovereignty of airspace of the United States" (49 U.S. Code § 40103(a)(1)). The passage of the FMRA confirms the federal government's intent to continue to "occupy the field" of flight, thereby invalidating (through preemption) any state or local laws that purport to regulate it.
State and local governments may, however, regulate two things related to flight:
- They may regulate their own agencies' drone flight operations; and
- They may regulate the locations on the ground from which drones may be launched, landed or operated.
That's it. State and local governments cannot regulate drones in any other manner. They can of course use laws of general applicability (such as voyeurism, reckless endangerment, nuisance, etc.) to prohibit certain acts, which would apply to a drone pilot, if a drone happened to be the object used to perform the prohibited act. They could also pass unnecessary and duplicative criminal statutes specific to drones, but they'd be essentially meaningless since existing criminal statutes would already cover those crimes regardless of whether they were committed with a drone.
On December 17, 2015, the FAA released a fact sheet entitled, "State and Local Regulation of Unmanned Aircraft Systems." It is the first insight into the FAA's stance on federal preemption of state and local law with respect to the regulation of flight.
Effective December 21, 2015, all persons 13-years of age and older, who operate drones for hobby or recreation, must register themselves with the FAA, if any of the drones they operate outdoors weigh more than .55 pounds and less than 55 pounds. Drone owners who operated their drone(s) prior to December 21, 2015 were permitted additional time to register themselves — until February 19, 2016. Those who purchased their drones on or after December 21, 2015 have been required to register themselves before they conduct their first outdoor flight.
Drone Operator Registration requires the registrant to provide the FAA with their full name, home address and email address, and they must acknowledge their intent to follow certain well-known safety guidelines in order to complete their registration. Registrants must also provide a credit card number, which the FAA will charge $5.00. Drone Operator Registration must be renewed for an additional $5.00 every three years. Person who operated their drones prior to December 21, 2105 have until February 19, 2016 to register. Those who have purchased their drones from December 21, 2015 on, must register themselves prior to their first outdoor flight.
The Drone Operator Registry is the result of the FAA's Interim Final Rule of 14 CFR PART 48, and is an online web-based system. Those who operate their drones for any reason other than hobby or recreation may not register their drones using the online web-based system, but must instead register their drones using the existing paper-based system of Part 47.
The penalties for a person operating a drone if they themselves are not registered are significant, and include civil penalties up to $27,500, and, if warranted, criminal penalties of up to $250,000.00 and three years in prison. Exactly how the FAA plans to enforce the registration requirements is unknown. It has released a "UAS Enforcement Q&A" paper and a "guidance card" for local law enforcement, so presumably it is depending upon local police to pursue any enforcement.
Problems with Drone Operator Registration.
Drone Operator Registration is the registration of persons (which includes individuals, partnerships and corporations). Registering persons, as opposed to aircraft, has no basis whatsoever in law. 49 USC Section 44102 reads, "[a]n aircraft may be registered" and 49 USC Section 44103 reads, "the Federal Aviation Administration shall … register … aircraft." No statute permits the FAA to register persons. It should be noted that registrees need provide no information about the drone(s) they operate, since they are registering themselves and not their drones.
The Interim Final Rule of 14 CFR PART 48 has been widely criticized by many (including me), as being violative of FMRA Section 336, as it is a newly promulgated rule or regulation regarding a model aircraft, which is forbidden under that Section. The FAA has termed the new Part 48 as an "alternative" to the existing aircraft registration provisions of Part 47. Alternative or not, Part 48 is a regulation that did not previously exist, but exists now. Therefore, by definition, it is a new regulation.
The Interim Final Rule has also been equally criticized by several commentators (including me), as being violative of the Administrative Procedures Act ("APA"). The FAA also did not follow the normal and proper rulemaking process found in the Administrative Procedures Act, in creating the new FAR Part 48. Christmas gift-giving is not a proper "cause" for emergency rulemaking, and does not it "impracticable, unnecessary, or contrary to the public interest" to following the APA's normal rulemaking process.
Several commentators (myself included), have said that the Interim Final Rule does not accomplish what the FAA claims it does. The FAA claims that the registration of all drone operators will increase education and accountability. Exactly how assigning a number to a person creates education or increases accountability has been questioned.
During the registration process, drone operators are required to acknowledge their intent to abide by certain voluntary safety guidelines. There is no provision in the language of FAR Part 48 that requires or permits the FAA to request of registrees such an acknowledgement. There is also no legal basis for such an acknowledgement to be a condition precedent to registering an aircraft. People register manned aircraft under Part 47 all the time, and have never been required to agree to abide by anything, simply to register one. Nevertheless, if a registree does not place a checkmark in the box on acknowledge page, he or she is not able to register under Part 48. (They may instead register under Part 47 without having to make any similar acknowledgement.)
The safety guidelines suggested during the registration process is well known:
- Don't fly above 400 feet AGL.
- Don't fly beyond visual line of sight.
- Don't fly in areas that are under Temporary Flight Restrictions.
- Don't fly directly over people.
- Don't fly over stadiums or sporting events.
- Don't fly near emergency response efforts, such as fires.
- Don't fly near airports or manned aircraft.
- Don't fly while under the influence.
Although all of the above items might amount to sensible guidance, they do not alone amount to "education" by any means. Nor are any of them regulatory in nature. They are merely "suggestions" as to what the FAA believes drone operators should not do. Education goes far beyond telling pilots what they should not do.
As for accountability, a tiny number affixed to a drone does nothing to determine the operator, unless the drone is physically recovered. Thus, the registration does nothing at all to assist with enforcement against a "rogue" drone, when it is merely sighted. The existence (or not) of that registration number on a drone is, however, significant, since 49 U.S.C. 44103(d) requires all drone operators to show that number to any law enforcement officer upon request. Law enforcement officers need no reason to ask to see the registration number, as federal law imposes an affirmative duty upon the operator.
49 U.S.C. 44103(d) Certificates Available for Inspection.—
An operator of an aircraft shall make available for inspection a certificate of registration for the aircraft when requested by a United States Government, State, or local law enforcement officer.
Lastly, the information contained in the FAA's Aircraft Registry is a matter of public record, by law. It always has been. The FAA had claimed when it announced the registry that it, its contractor and law enforcement would have access to the information the registration database contains. Later, the FAA admitted that the names and home addresses of all registrees will be publicly searchable by registration number.


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Mario Kart 8 Playable at US GameStops this Weekend - NewsVGChartz Staff, posted on 13 May 2014 / 1,299 Views
Nintendo's kart racer has been gaining traction leading up to its release on May 30th. If you are curious how the game runs on the Wii U, 2,700 participating GameStop stores in the US are letting you take it for a test drive. To find a GameStop participating in the event, click here.
Earlier this month, Nintendo released some nuggets of information in a Direct video exclusively dedicated to Mario Kart 8. We now know that there will be an item which can be used to combat the infamous blue shell, a direct upload feed to YouTube for short highlights, and that during anti-gravity sections it is best practice to bump off your opponents for a boost.
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Louisiana-Monroe Warhawks at Georgia Southern Eagles Football
Sat, Nov 29, 2014 TBA
Allen E. Paulson Stadium, Statesboro, GA
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Dont like Peter King either, but this is the beginning of his MMQB column. I now wish the Giants would have won Sunday. Great read.
In my job, athletes are not very good interviews after 34-0 losses. They don't want to talk after 34-0 losses. They will find every excuse not to pick up the phone after 34-0 losses. But Sunday was different. Victor Cruz is different. This weekend was different, around the country and certainly within a short drive from Newtown, Conn., where 20 elementary school children and six women charged with teaching and protecting them were murdered.
"When I heard about the shootings,'' Cruz said from Atlanta, "I was just fighting back tears. I couldn't stop, all [Friday] night. I took my [11-month-old] daughter, grabbed her, and held her, and she slept with me Friday night. I didn't want to let her go. I don't know ... You drop your child off at school. A routine dropoff, parents do it every day. And this happens, and what can you do.''
The Giants and their ace wide receiver, Cruz, went to Atlanta to play a football game. In the hotel Saturday night, Cruz kept noticing messages on his Twitter feed. All were about someone named Jack Pinto. "Fifty, 100 tweets, right in a row, people wanting me to get in touch with the Pinto family,'' Cruz said. He found out young Jack Pinto, 6, was one of those murdered in Newtown, and Jack was a huge Victor Cruz fan, and so he asked his girlfriend and publicist, Elaina Watley, to try to find the Pintos' phone number in Newtown, and she did. At 10 p.m. Saturday, here he was, on the phone with the father, Dean Pinto, and then Jack's brother Benjamin, and then Dean again.
The conversations weren't long, because no one could talk very well.
"The father was taken aback that the message got to me,'' Cruz said. "I told him I was going to do whatever I could to honor Jack. And Jack's brother, he was very emotional, fighting back tears. He barely got any words out.''
On Sunday morning, Cruz wrote on Twitter: "Today's game is for you Jack.''
On one shoe, Cruz wrote in black Sharpie: "Jack Pinto My Hero." On the other, "RIP Jack Pinto."
Falcons 34, Giants 0. Cruz wishes he, and the team, could have played better. But when the family says a murdered boy may be buried in his jersey, and all Cruz wants to do is anything to make them feel better, the game is a game. Now Cruz will do something, privately, he hopes, this week for the family.
"I just want to go down there and help any way I can, if I can,'' Cruz said quietly. "It's hard to know what to do. You just have to put your faith in God and pray."
There is no way to segue to football without seeming totally crass, so forgive me. Before I do, praise to the Giants, in Atlanta, and the Jets tonight, in Nashville, for remembering Sandy Hook Elementary School on their helmets. And to the Patriots, New England's team, for the Newtown helmet decals (right), and for sending up 26 flares honoring the school victims during a prolonged moment of silence before their game with the 49ers.
It's hard to know what to do.
Read More: http://sportsillustrated.cnn.com/nfl/news/20121217/week-15/#ixzz2FOq77Ykx


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FDA Approves New Multiple Sclerosis Treatment: Tecfidera »
"The U.S. Food and Drug Administration today approved Tecfidera (dimethyl fumarate) capsules to treat adults with relapsing forms of multiple sclerosis (MS).
MS is a chronic, inflammatory, autoimmune disease of the central nervous system"...
Read the FDA Approves New Multiple Sclerosis Treatment: Tecfidera article »
Because of the possibility of sedation, patients should be cautioned regarding the operation of automobiles or other dangerous machinery, and activities made hazardous by decreased alertness. Patients should also be cautioned that the central nervous system depressant effects of baclofen may be additive to those of alcohol and other CNS depressants.
Phenylketonuric patients should be informed that KEMSTRO™ (baclofen) contains phenylalanine 3.9 mg per 10 mg orally disintegrating tablet and 7.9 mg per 20 mg orally disintegrating tablet.
Last reviewed on RxList: 11/20/2007
This monograph has been modified to include the generic and brand name in many instances.
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Our Injection and Laser Specialists
The Bengtson Center is extremely blessed to have, along with plastic surgeons Dr. Bengtson and Dr. Mitchell, an incredible staff of nurse and physician assistant injection specialists among the most talented in the United States. Each has a very busy practice in aesthetic medicine, specializing in BOTOX
Roxanne Cornelius, PA-C
Injection and Laser Specialist / Clinical Educator
Roxannes education and background, combined with her gentle touch, have made her ideally suited to be an Injection and Laser Specialist for the Bengtson Center. Recently she was honored when Allergan invited her to a Leadership Forum at their world headquarters in Irvine, California. At this select gathering of top injectors from around the United States, she had the privilege of helping to direct and form best-practice guidelines for this world-renowned company.
She is committed to teaching her patients about their aesthetic options, including associated risks and benefits, and allowing them to make informed choices to more fully participate in their own care. Roxanne has been a guest lecturer for resident doctors and
currently serves as an invited trainer and speaker for Allergan Medical Facial Aesthetics. In
this capacity, she has the privilege of instructing doctors, nurses and other medical
professionals in successfully providing BOTOX
- "I am always competing with myself to provide the best, safest, most current and comfortable injection and laser procedures for my patients in a relaxed and professional atmosphere. Each patient is unique and has specific concerns, which I strive to address with compassion, excellence, and artistry. I believe in a natural look: you, only better and beauty at every age. I am SO blessed to have a career that I absolutely LOVE and cant imagine anything more fun and rewarding than helping my patients look as good as they feel!"
Her professional affiliations include: American Academy of Physician Assistants, Michigan Academy of Physician Assistants, Society of Plastic Surgery Skin Care Specialists, American Academy of Aesthetic Medicine, and American Society of Lasers in Medicine and Surgery.
Kortne Custer, PA-C
Injection and Laser Specialist
Amanda Gorter, RN
Injection and Laser Specialist
In her free time, Amanda enjoys spending time with her husband, Derek, and their son, Christian, traveling, and spending time with friends.


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Nintendo has announced Pokťmon Rumble U, a downloadable game for the Wii U eShop.
It's the third in the Rumble series of spin-offs featuring animated Pokťmon toys.
The game's existence was revealed in Japanese magazine CoroCoro (thanks, Serebii), scans of which have found their way online.
Rumble U will feature all current Pokťmon species (649, until the launch of this autumn's Pokťmon X and Y), with up to 100 critters on screen at any time.
Nintendo of Europe has yet to announce the game. There's no release date for Japan yet, either.
In other Pokťmon news, Nintendo has begun to open up its huge archive of Pokťmon anime episodes via a new iOS and Android app.
Pokťmon TV, now available from iTunes and Google Play, currently features around 50 episodes from each generation of the show to watch. Episodes will presumably be rotated, and even movies will be shown.


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Lorraine Sanders
Get Ready: Discarded to Divine is Coming (Plus, a Sweet Contest)
Cast-offs become couture each spring in San Francisco, thanks to the arrival of Discarded to Divine, an annual fashion showcase of work by established and emerging designers who transform discarded clothing and textiles into one-of-a-kind apparel, accessories and items for the home in support of St. Vincent de Paul Society of San Francisco and its programs fighting poverty, homelessness and domestic violence.
While the big night isn't until April 28, Friday's de Young Museum Preview Night brings the first public viewing opp for this year's collection of garments. Even better, it's free.
What's the Deal: Serial Cultura, SanMan, Fashionistette + More
What's your deal? Here are ours...
Serial Cultura: A spring cleaning sale at the studio of Oakland-based designer Jennifer Jennings means a rare chance to snag her printed apparel at a discount. We hear tops from the Fall 2010 collection (reg. $200+) will be priced at $55, while dresses will be $75 and scarves will be $25.
SanMan Productions' Velvet Rope Experience: Have an out-of-towner you'd like to treat like a VIP? 7x7 readers can save 20 percent on this new service from Sanford Marshall's event services company. Starting at $500 per day (rates rise to $1,000 if you'd like Marshall to accompany as your guest's personal host), itineraries are customized, but frequently include such services as luxury vehicles, hard-to-score restaurant reservations, special entry to nightclubs and tours of wine country destinations not usually open to the public.
Fashionistette: The Bay Area-based online shop is having a warehouse sale this weekend at Fort Mason that promises discounts on designer labels such as Clu, Black Halo, Willian Rast and Twelfth Street by Cynthia Vincent. What's more, 30 percent of the proceeds will be donated to Half the Sky Organization and its programs benefitting orphaned children in China.
Double Dandy: Patrick McDonald & Jim Howard on Bill Cunningham, Hat Travel and Rocking the Boat
In a world where denim and sneakers rule the streets, Patrick McDonald stands out, and not simply because of his seemingly endless array of Rod Keenan hats.
2 Style Showdowns Have Local Bloggers, Stylists & Designers Vying for Fashion Dominance
The pursuit of style gets competitive in the coming days with the arrival of two spring style showdowns pitting local bloggers, stylists, designers and models against one another to vie for fashion dominance.
Playing Dress-Up: The Top Four Local Style Games
Despite a few notables from San Francisco's past (we salute you, Alexander Wang), the reality is that the hottest names in fashion hail from the other coast. But dispense with reality for the virtual, and the Bay Area is fast becoming a capital for the cutting edge, thanks to a number of local companies reaching millions worldwide through fashion games played primarily on Facebook.
What's the Deal: Set Boutique, Metalista, Bloomingdale's + More
Deals done daily...
SET: The spring sale at this locally-based online shop specializing in ethically-traded merch brings discounts of up to 40 percent off apparel, bags and jewelry produced in other countries using socially responsible methods.
Metalista: Geometric brass and vintage-inspired jewelry by this local designer is 15 percent off through Sunday when you use the discount code spring15.
Bloomingdale's: Through April 3, a friends and family sale offers shoppers 20 percent off sale and full-price items for men, women, children and the home when you use the discount code SITM20 during online checkout.
Fightin' Dirty…Gold, That Is
If you've never considered the curious life of jewelry before it arrives on your neck, lobes or fingers, then Shawn Higgins would be more than happy to tell you the dirty details. Luckily, you can also sip wine while you scope socially- and environmentally-friendly alternatives at D&H Sustainable Jewelers, the Castro jewelry shop Higgins opened earlier this year with Lindsay Daunell and Diaa Askandafi.
In fact, "dirty gold," or gold mined in a way that harms surrounding ecosystems and human populations, has become such an issue of late that numerous mainstream jewelry retailers ranging from QVC to Tiffany & Co. have signed on to support the No Dirty Gold campaign, which advocates safer, more socially-responsible mining and sourcing practices for the precious metal.
But Higgins is proud to say that his shop is ahead of the game.
Lighten Up: Fiat Lux Opens on Church
Despite its hardly-larger-than-a-postage-stamp size, Fiat Lux manages to pack much worth writing home about into its newly-opened Church Street space.
What's the Deal: A Miner Miracle, Black Peace Now + More
You're just going to have to find a way to deal with this...
A Miner Miracle: The nonprofit organization is holding an off-site sale this weekend at the Auditorium of St. Anne in the Sunset (850 Judah St.) on Saturday and Sunday. Check the Twitter feed for more info, but we hear that labels such as Ann Taylor and Michael Kors are among the merchandise.
New People: The goth-minded Black Peace Now collection at this Japantown multiplex for art, apparel and film is 20 to 50 percent off through April 3.
Beauty Benefit for Bay Area Girls Rock Camp
Tell us we can help the children by indulging in the self-serving wonders of a new body soufflé or heart-shaped bath bomb, and we're definitely listening. Add giving impressionable youths an ungeeky alternative to run-of-the-mill band camp, and we're in. A chance to do both takes place Friday during a Girls Rock Benefit at Laline on Chestnut Street.
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EraMED LLC and LifeFlight of Maine announced today the renewal of their contract naming EraMED as LifeFlight of Maine's provider of aviation management services. The two companies have worked together providing air emergency medical services since July 1998.
LifeFlight of Maine owns two Agusta 109E helicopters; one based at Central Maine Medical Center in Lewiston, Maine, and the other based at Eastern Maine Medical Center in Bangor, Maine, which cover all of Maine and its offshore islands. The aircraft transport patients primarily to the three trauma centers in Maine: Eastern Maine, Central Maine and Maine Medical Centers. Patients are also transported to hospitals in New Hampshire, Vermont and specialty centers located in Boston, Massachusetts.
In 2008, the National Association of Air Medical Services presented the Program of the Year award to LifeFlight of Maine at the Association's annual meeting. The award recognizes an emergency medical transport program that has demonstrated a superior level of patient care, management prowess, quality leadership through visionary and innovative approaches, customer service, safety consciousness, marketing ingenuity, community service and commitment to the medical transport community, as a whole.
LifeFlight Executive Director Tom Judge said, "We operate in a challenging environment and expect world class performance for the people of Maine. As one of the world's leading aviation companies, EraMED's operating philosophy and focus on safety, consistency, cost value, and quality performance fit well with our ethos of just culture. EraMED operates our Agusta aircraft at 98% availability, we continue to build an innovative low level IFR system, and we have been able to integrate our management systems and operations performance improvement. We expect world class performance and EraMED consistently delivers.â€
EraMED Vice President and General Manager, Terry Umfleet said, "EraMED is pleased to have the opportunity to continue our long standing relationship with LifeFlight of Maine. The proactive approach to sound operating practices and the positive safety culture within their program is a testament to their commitment to quality service. EraMED looks forward to continuing our long relationship.â€
About LifeFlight of Maine
LifeFlight of Maine is a nonprofit, statewide critical care helicopter service. Since 1998, Maine's only such service has safely transported more than 10,000 critically ill and injured patients from nearly all of the state's communities and offshore islands. LifeFlight is Maine's only licensed Scene Response Air Ambulance and is on call 24 hours a day, 365 days a year. It complements and supports the work of local physicians, mid-level providers, nurses, and EMS squads in caring for the critically ill and injured.
About EraMED LLC
EraMED is an innovative air medical service company, providing medical institutions with around-the-clock flight services that include pilots, maintenance, communications support and a diverse fleet of sophisticated twin-engine turbine helicopters. EraMED offers fleet management services to medical providers who own their own aircraft, as well as providing aircraft leasing arrangements for helicopter services.
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- 05-Jul-15 RP-C2726 AgustaWestland AW109E Mt. Maculot, Philippines (2F)


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Cfm coils
Just wondering what the advantage of your coils over stock are and if you guys have tested then on a car and got any results to post? Also more pics would be nice. Maybe installed. Thanks
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Narcís Calvet
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The full text of the Trans-Pacific Partnership (TPP) was released Thursday by pact member New Zealand. The trade agreement will set out trade rules for multiple industries — including automotive manufacturing and the import/export of those vehicles — for its member states.
TPP, an expansion of the Trans-Pacific Strategic Economic Partnership Agreement, includes members Australia, Brunei, Canada, Chile, Japan, Mexico, Malaysia, New Zealand, Peru, Singapore, United States of America and Vietnam.
New Zealand leaked the details on its Ministry of Foreign Affairs and Trade website.


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Currently working on the new album due out in late spring...stay tuned!
Hey ppl!! Check us out live at 2 kickass shows this weekend. 1st we will be rocking the house Friday night at Cafe 611 in Fredericksburg Md with Wild Eyes( Tool Tribute} The Averist, Queen Mother and Twin Radio , Then, Saturday night we will be tearing the stage up with Sick Puppies, Lacuna Coil, Eyes Set To Kill and Cilver. Sure to be an awesome time at either or both shows . Contact any band member for tickets....hope to see ya !!!
VOTE for us at: battle.rockstaruproar.com/u/SHADOWBURN Every listen, comment, and share boosts our buzz rating! Voting is UNLIMITED and each vote counts! Thanks for your support. We would not be anywhere without our friends, fans, and families!
GO TO: www.battleofthebands.com/u/shadowburn and VOTE, LISTEN, COMMENT, SHARE, & LIKE us to help get us noticed for the Vans Warped Tour Ernie Ball Battle of the Bands 2013! We would absolutely love the opportunity to play at such an exciting event. It would truly be amazing! Please vote for us and help us get there. THANK YOU ALL!
You can download the rest of the songs from our EP Release at www.shadowburn.bandcamp.com! Please check us out on facebook as well www.facebook.com/shadowburnband and like us! We hope you enjoy what we create, and thanks for listening!


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Once More Into The Breach
Every year, I fall prey to NaNo fever. This year was no different. And today is opening day, as it were. Everybody is off like a shot. And I'm waving them on with wishes of good luck. Sanity has prevailed.
Trying to participate is even more insane than usual this year because I have 2 out of town trips on TOP of Thanksgiving and end of semester stuff at the EDJ. I also changed my project 3 times–the first two novel ideas aren't being given up, but both require more time plotting and sorting, and I'm most definitely not willing to waste my time sprinting forward when I didn't put in the work on the front end yet. And the third–well the third is fully plotted and ready to go. BUT, I have significant revisions to make to Be Careful.
I knew when I sent it out to my first round of betas that there were issues with the second half. This was a gut knowing. And having heard back from my first one, my gut was confirmed. We had a long chat yesterday, winnowed down to what the problem was, and brainstormed some options for fixing it. I COULD go the route that means I don't have to change as much. But it wouldn't be as good a story because now I SEE THE PROBLEM and I spent my time last night sorting out a plan for how to fix it. It just happens that that plan means I'll be rewriting 12 of the original 14 scenes from that half.
And I'm okay with that. I had life stuff happen right after I wrote the midpoint that completely blew up my brain. Which meant I pushed through and wrote and finished anyway, which is its own valuable lesson. I tried something, it didn't work, and I kept up with the discipline and avoided page fright (always a big issue with me), where in the past I would've just frozen and been unable to work.
More life stuff is coming down the pike in December that I fully expect to wreak havoc on my writing life for that entire month, so the goal is to knock these changes out in a jiff and get it out to round 2 of betas, and get it cleaned up and out the door in early December. That's the last big goal for this year. It's not what I wanted to get done or what I had planned to get done, but the best laid plans and all that. We have to adjust.
Life stuff will always happen. The point is to keep producing something, keep honing the craft. And it is, after all, exactly why I started A Round of Words in 80 Days.
9 thoughts on "Once More Into The Breach"
Whew–sounds a whole lot like where I'm at. NaNo has been great for me to address page fright, but now I've got three drafts that I need to spend time with in the next phase. I really wanted to go to the drafting party, but this year, this is the place where I am.
I'm glad you started ROW80 so I wouldn't feel like I had to do NaNo. I didn't like myself during November those two years I did it, and hubby liked me even less. LOL
You are WAY too busy to tackle NaNo. And if I know you, it would freak you out if you started it and didn't WIN NaNo. I was like that when I did it, so I had to win both years, no matter what it took. I think you made a really wise decision.
Like you, I felt the NaNo temptation. All this morning and so on (it is early afternoon here), I've been fighting the desire to jump in, especially since all summer I had told myself I would do it this year. I even have one of those "ready to go" projects myself.
However, that's not what I should do now or focus on. I think making a choice based on my writing needs is a more responsible choice and the one someone with a writing career should make. Or, at least, that's the crap I'm telling myself.
l'm lovlng NaNo so far. l dldn't get too much wrltlng done yesterday because of some llfe stuff, but after l flnally get my halr cut and h;ghlghted later (lt's been a whlle), l plan to get to lt. Fkrst l have to do some stralgtenlng up around the house and see lf my frlend's hubby ls comlng over today, tomorrow or one evenlng thls week to get my new smart a** phone set up. tt's easler for me to do thls because l'm worklng on short storles lnstead of all one book.