, Michigan

, United States

Posted on
2020-02-15 16:41:48
“I have been flying an ultra-micro park RC model airplane (Taylorcraft 130) for the past several years, mostly in my back yard. I recently discovered aircraft plans available from Flitetest and built a foamboard RC airplane. What a great learning experience! This is the first RC model that I built from scratch (FT Simple Cub) and it weighs a little more than 250 grams. Following the FAA rules, I obtained the Small UAS Certificate of Registration required to fly the model. I then built one additional plane (FT Simple Storch). I was planning to build more planes, but heard of the NPRM for Remote Identification of Unmanned Aircraft Systems and wanted to see what might be in store for the hobby. What I found was disturbing for so many reasons which I will list in no particular order: 1. The proposed rule calls for a change to registration, requiring each model to be uniquely registered, instead of one registration for the owner/operator. While I only have one model that would currently require registration, the hobby is filled with modelers that have dozens or more models. The life of a model can be either 1 flight or 30 years’ worth of flights. Trying to keep individual models registered would be unnecessarily complicated and cost prohibitive. 2. The operating rules for UAS without Remote Identification are too restrictive and would create excessive financial burden for many folks to continue the RC model aircraft hobby. In my situation, we own enough property to operate models over 250g. I can currently do so as we live in a rural area, outside of airport airspace. Under the new proposal, I would not be able to operate the model off my own property, but would only be able to operate the model from an FAA recognized identification area (FRIA). For me the closest flying field is almost 10 miles away. In order to use that field, I would have to be an AMA member ($75 annual fee) and join a local flying club ($100 fee + unknown annual cost). This is cost prohibitive and eliminates the ability to take in a quick flight in the morning or evening. I believe the AMA is a good organization, but I do not believe one should have to join clubs to safely fly RC aircraft as long as the Community Based Organization rules are followed. 3. FRIA sites are planned to go away due to attrition! It is clear that the FAA does not want UAS without remote ID to be allowed long term. There is only a 12 month period after the rule is enacted to apply for a FRIA site. Once that period is over, the FRIA sites can only be eliminated. This rule alone means that the FAA is seeking to eventually eliminate Amateur-built UAS (RC aircraft hobby!) 4. Only Community Based Safety Organizations can apply to establish a FRIA, so there is no way a land owner can make their own property a place to legally fly their UAS without remote ID (amateur-built UAS). 5. Limited Remote ID UAS will always be limited to a 400’ radius from the ground station next to the operator. The 400’ horizontal restriction is WAY TOO SHORT! Line of sight is more appropriate for this type of ID. This type of ID should also be allowed for folks with amateur-built UAS! 6. If this rule is proposed in the name of safety, where is the risk analysis? Model aircraft have a proven safety record and have been flying safely along with manned aviation for nearly as long as man has flown. There does not appear to be any Data to substantiate the proposed restrictions. In summary, I believe that the proposed rule as written will sufficiently restrict the Amateur-built UAS category to its demise, without ANY safety gains to the airspace system. Land owners with sufficient space should be able to operate or allow the operation of UAS without Remote Identification over their property as long as that operation does not interfere with airport airspace. LAANC system could be modified to work and ensure these areas are safe. Vast areas without cell coverage should not be restricted from flight with UAS exclusively, since these areas are often less densely populated and cause less of a safety risk to persons or property. Please do not allow this rule to go into effect as written! Many of tomorrow’s aviators are counting on building and flying model RC aircraft (amateur-built UAS) as a way of entering the field of aviation as has been the case for the last 80+ years”