David

Hill

, Worcester

, Massachusetts

, United States

Posted on
2020-02-13 23:59:21
“The RC flight hobby has been the second highest use of my time second only to work. I design, build and fly my own planes as well as build multirotors from parts. What concerns me most about the FAA rules is that it seems that the rules are geared towards commercial entities that may have a high impact on governed air space in the future. The future outlook for maintaining safety for autonomous flight seem reasonable, however, to qualify all UAS in the same category only reflects the lack of knowledge on the part of those writing the rules. While in graduate school my professor told me not to be intellectually lazy. The rules, as currently written, demonstrate the lack of energy, research and curiosity necessary to acquire a knowledge base and firm understanding of the impact the rules will have on the entire community who use the airspace. Safety to me is not a concern. The hobbyists have been safely negotiating the open airspace without incident for decades. The aspect of the hobby that has changed is that commercially built autonomous aircraft have become more available to the average person. For the most part, these aircraft are multirotors, so they take off and land just about anywhere and by design, are easy to acquire and operate without any real knowledge base. Other aspects of multirotor flight are should be considered are individuals who do not use autonomous flight as a main flight feature. It is unreasonable to require identification systems for those aircraft operating within line of site, whether FPV or otherwise. The FPV multirotor flying I perform is all performed near ground level and should not be regulated whatsoever. Another aspect of the proposed rule that severely impacts the hobby is 400 foot radius of flight in a recognized flight area. Most line of site fixed wing aircraft exceed the 400 foot radius. My flights can typically reach distances of 800 to 1000 feet while still maintaining safe operation. The consideration of proximity of the aircraft to the pilot needs to be reconsidered. When on vacation in Montana, I fly in places where there is no WiFi or cell signal. It seems unreasonable to assume that because cell phones are so prevalent that access is ubiquitous. Rural areas probably account for a large percentage of the average hobbyists flying fields. Regulating open country seems to be overreaching. I find it really interesting that the FAA is proposing to basically require transponders on model aircraft operating near the ground levels while still maintaining exemptions for manned gliders, ultralight, and manned aircraft operating in class G airspace. If these rules were aimed at safety, identification and collision avoidance initiative for autonomous delivery systems, then the real focus of the FAA should be towards commercial use of airspace rather than lumpting every UAS into the same category. I believe that it would be really easy to consider definitions of aircraft that should be regulated and apply exemptions for those who have already demonstrated an ability harmonious share airspace. One last point. I love flying my soaring glider. It is such a thrill to have a thermalling updraft carry the plane high into the sky. I enjoy flying the high flying aircraft with my buddies in friendly soaring competition to see who can stay up in the air the longest. Most of these flights take us above the 400 foot AGL. Our 7 and 8 foot wingspan gliders are easily seen from the ground and controlled. Further restrictions will simply kill this aspect of the hobby. My request for anyone reading this is to deeply consider how the rules will affect hundreds of thousands hobbyists and future hobbyist when no harm is intended. From my perspective the rules as written is pretty much a death blow to the hobby as we now know it. It would be really great if the average recreational hobbyist had a voice in the rule making. Sincerely, David Hill”
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