“I have been involved in model aviation for over 60 years. I am USAF retired with 21 years of service. I fly, build or maintain model aircraft every day. In addition, I am a Part 107 certified pilot. I have more than 2 dozen aircraft or all sizes to include electric, nitro & gas. They include fixed wing, helicopter & quad drones such as the Mavic 2 Pro. To add a remote ID device to all these aircraft would be quite costly & individual registration burdonsome & costly, as well. Some of my aircraft are more than 20 years old, so the FAA idea that existing model aircraft would reach end of service life within 2 or 3 years is faulse. Stating there would be no need for approved fixed flying sites after a phase in of the proposed rule is faulse, as well. The Section 336 rules of a few years ago has worked fine & I see no need to further restrict activity at approved fixed flying sites. As a Part 107 pilot, I agree that more safety rules maybe required if large delivery services are allowed use of the airspace. For survey, aerial photography, inspection & the like, the LAANC system appears to work well. A lot of Part 107 activity can occur over more populated areas so the current rules are justified with a method for obtaining waivers for other drone activities. As president of our local AMA Chartered Club 5339 we have had to find a new flying site due to residential development near our old field. Finding a new field for an RC Club is a difficult, expensive & long process. We need stream lined procedures for approved FAA flying sites not more difficult procedures or out right no approved sites at all. If the FAA will look at the safety record of the AMA which is an approved CBO, we have over 80 years of safe flying activities. Restricting model aircraft activity to the proposed 400ft line of site distance will ground all of my aircraft except one. Which weights only a few ounces & has a wing span of 12 inches. There is no way I can fly my planes with 10 foot spans & weights of over 20lb in side a 400 foot distance. The proposed rule is a 400 foot distance from point not just 400ft AGL. A typical approach for landing of a 10 foot span 20lb aircraft begins approximately 600 to 1000 feet out. A 400ft distance from the pilots point is not reasonable. As a retired indiviual, the proposed rules as stated will severely limit my daily activities.”