, Fairfax

, Virginia

, United States

Posted on
2020-02-22 13:48:54
“My name is William M. (Bill) Cronin, I am 52 years old, and I am a model aviation enthusiast. I live in Fairfax, Virginia. I hold a B.S. in Aerospace Engineering and I have worked my ENTIRE career as a UAV Systems Integration Engineer designing, developing and testing Unmanned Aerial Vehicles/Systems (UAVs/UAS) for military use. I am a dues-paying member of the Academy of Model Aeronautics (AMA 157287), and have been continuously since I was about 16 years old (1983). I am a dues-paying member of the Northern Virginia Radio Control Club (NVRC, AMA Charter 636). I would not be a club member if it were legal for me to fly in school yards, etc. inside the DC SFRA. I hold an FAA SUAS Certificate of Registration (FA39CWAEAF). I am also an avid follower of the Flite Test Community Association, and contributed financially to the purchase of Edgewater Airpark in Ohio. I am currently beginning training for my Part 141 Private Pilot’s License. I would NEVER have been able to pursue my career without access to radio-controlled (R/C) aircraft building & flying. I got my first job in 1989 as a civil servant working on UAVs for the Navy, first and foremost, because I was an R/C pilot; my engineering degree was a bonus. Professionally I have flown drones weighing 100 pounds, flying at roughly 100 mph, and travelling out to 60+ miles at several thousand feet above ground level. I have built and helped operate fully-autonomous 1600 pound drones. I understand the need for airspace control and deconfliction to ensure the safety of all involved. The military has and still does accomplish this UAS deconfliction primarily through the exclusive use of restricted airpsace for given time periods (range times). Personally, I have flown many different types of R/C airplanes. I have flown exclusively R/C aircraft with little or no automation — they require constant direct visual observation, and direct “stick to surface” control inputs to control and direct them safely through all modes of flight. At most, my aircraft have included stabilization gyros to mitigate wind buffeting and make controlled flight easier, but not automatic. In my early years, I flew R/C gliders with 2-meter wingspans, and glow-powered (alcohol fueled) r/c sport aerobatic planes weighing roughly 5-6 pounds and capable of speeds of 60-80 mph. Most of these were made of balsa wood or light plywood and covered with heatshrink plastic. I’ve built them from scratch and from kits, and bought semi-finished and ready-to-fly airframes. Most required that I specify & purchase the necessary electronics and powerplants myself. Finished costs were typically $200 – $300 dollars. Currently, I exclusive fly electric R/C airplanes due to the clean, quiet, and convenient properties of modern rechargeable Lithium Polymer (LiPo) batteries and brushless electric powerplants. All cost $200-$400 each, not including rechargeable batteries, controllers, battery chargers, and other support equipment. Most are in the 1.1 meter class or smaller, weigh less than 3 pounds, and can travel at speeds up to 80 mph. Most are pre-built models made from Expanded Polypropelene (EPP) foam. I have a larger foam biplane that probably weighs 5 pounds, and a 4 pound Electric Ducted Fan (EDF) model jet capable of 100 mph speeds. I have foam scale models of a B-26 bomber, and a C-130, both roughly 1.6 meter wingspans and flying weights around 4 pound. I have a Flite Test VersaWing that I built & modified myself. Lastly, I have under construction a “Giant Scale” 50cc gas-engine powered aerobatic model with a wingspan of about 7 feet, flying weight around 15 pounds, and capable of speeds up to about 80 mph. I perform my own maintenance and modifications on my aircraft as I see fit. All that are flyable have my name, my AMA number, my cell phone number, and my UAS certificate number on them. Due to my aviation background, and awareness of the DC SFRA, I fly exclusively at NVRC’s Poplar Ford Flying Field in Chantilly, VA. This is about 30 minutes from my house and requires a major time commitment to pack up all the airplanes I wish to fly on a given day along with all their support equipment, and get it all to and from the club field (i.e., bring your own infrastructure; there is no FBO). When I lived in other locales, I’ve also flown in public parks, on soccer fields, or in school yards where the performance of the aircraft I chose to fly was compatible with the space available. I am frankly disappointed that “backyard flying” is essentially illegal even though by any practical measure that if I were to keep my aircraft’s altitude roughly at maximum tree height the majority of the time I am flying, I pose very little risk to manned or “commercial UAS” aviation. I have thousands of dollars already invested in this hobby for equipment I believe this proposed regulation will deem illegal within 3 years of it becoming law. I spend $65/year to be an AMA member, and another $100/year to be a member of NVRC so that I can have access to a “legal” flying site. I design and scratch-build my own aircraft and I modify existing designs as I see fit to achieve new & different performance. I don’t believe the FAA can practically regulate the design of so many homebuilt model aircraft, and I believe to do so would cause a detrimental stifling of the hobby and discourage existing and new inventors & experimenters from enjoying it. I understand the intent of Remote ID, but I believe this method of achieving safe airspace by denying access to it without mandatory equipment upgrades is a flawed approach. The real goal is first to educate all UAS operators to operate their aircraft in the safest manner possible to avoid conflict with manned or “commercial UAS” operations. Hand in hand with this should be standards of training, and airspace deconfliction techniques that do not encumber the hobbyist community with additional financial and regulatory burdens to equip and register every aircraft they ever purchase or produce themselves. Educational outreach, funded by the FAA, is key. The commercial drone industry is the reason new regulations are required; commercial entities that stand to benefit from this new industry should be bearing the cost of any regulatory burden or infrastructure changes THEY require, not the hobbyists. This need for airspace deconfliction has been coming for a long time — AUVSI discussed this at length as early as the 1980’s. Forcing an infrastructure solution financially onto the hobbyist is unfair and counterproductive. I recommend that, if truly needed, the FAA establish methods for coordinating airspace deconfliction that the R/C hobbyist can enact by different methods based on the existing air traffic and communications infrastructure domains in which they are located. Major population centers with significant air traffic and a robust cellular network could require a hobbyist to report/register a location and hours of operation for hobby flying using a free downloadable mobile phone application. Lower density areas should allow for hobbyist airspace coordination through as little as a telephone call to a regional coordinator (nearest Airport manager, or other official), or to merely attest that they understand air traffic regulations and will maintain constant vigil for nearby manned or unmanned aircraft (or employ a spotter/partner to do so – “buddy flying”). Remote locations should be permitted to fly simply by agreeing to see & avoid. All of these suggestions pertain to radio-controlled aircraft with little or no augmentation such that continuous visual contact must be maintained with the aircraft in order to operate it safely and successfully. I will say that I think the 400 foot altitude limit is unenforceable and should be struck because neither the R/C pilot (nor most law officials) has any practical means to accurately determine altitude. Different regulations should be enacted for hobby aircraft with sufficient automation that they allow the operator to conduct flight operations well beyond meaningful visual range — meaning that the aircraft can be so far away that attitude and course is indiscernible, and controlled flight is not possible, without onboard automation. These hobby aircraft can be differentiated from traditional R/C models in that they REQUIRE a bi-directional datalink and an operator display to provide the situational awareness (“state vector”) of the aircraft that can no longer be ascertained by direct visual observation. This class of aircraft includes multi-copter drones (e.g, DJI Phantom drone), and First Person View (FPV) aircraft. I would also suggest that regulations for automated aircraft (as described above) further be differentiated into at least two types based on INTENDED USE. Specifically, FPV race wings and multi-copters and sport FPV aircraft have automation, bi-directional links, and operator displays to allow hobbyist to experience flight from an “in the cockpit” perspective. But the INTENT for these hobbyists is to fly locally within the confines of a (sanctioned) flying site. This type of use should be regulated differently from long-range systems designed and operated well-beyond VLOS for either recreational cross-country flights or commercial operations. I would be remiss not to say that any savvy scratch-building hobbyist has the knowledge and the component equipment available to him or her via onliine resources to scratch-build an advanced long-range hobby drone. And with this in mind, I reiterate that I believe the correct approach to ensuring airspace safety for the hobbyists is federally sponsored outreach and training along with procedurally-based deconfliction methods, not through the banning of existing equipment, nor mandatory purchase and fitment of new tracking systems.”