, United Kingdom

Posted on
2020-02-14 5:33:22
“I am a 60 year old hobbyist model aeroplane pilot and a BMFA member in the UK. My first concern is the requirement that amateur built UAVs could only be flown at FRIA sites…… As can be seen in the attached photos my dad also built and flew model aircraft. He passed on his passion to me as a young boy and, as a father, I too have passed it on to my sons. It is a passion that has bonded us for many years and, at that age when young adults tend to rebel, our shared passion ensured we still spent quality time together. Sadly my dad passed away five years ago. I do not visit his grave. I have no attachment to him there, however, my sons and I still fly in the same rural countryside location where we made memories together and that is where we feel closest to him. He loved the private seclusion and beauty of the location in which we shared our hobby. We always built our own aircraft. We never bought ready made, ready to fly commercially available aircraft. Under the NPRM aircraft such as ours can never be equipped with remote id and would therefore be limited to only being flown in FRIA sites. This is a tragedy!! I fully understand the requirement for commercially available drones to be capable of being tracked and geofenced as they are designed to be easily flown without any previous experience, knowledge or skill set, however we hobbyists have honed our building and flying skills over many years and have an excellent safety track record. It has to be accepted that drones have only become a concern since these easily flown commercially produced camera drones became available to the masses. Ironically, if these proposals are passed, manufacturers will have to comply and those same problematic drones will have greater access to the airspace than hobbyist homebuilt model aircraft. So long as they have internet access and are not in a NFZ then they are good to go. I would be more than happy to use an app, such as the B4UFLY or LANCS app, on my phone to register my Flyer Id and my intent to fly in a certain location at a certain time and thereby still be able to fly in my favourite places, well away from built up areas, people and airports where it is safe and privacy is not an issue. My second concern is the requirement to register each and every aircraft that I intend to fly at a charge for each one…. I currently own several model aircraft. Many hobbyists own dozens. Some have not been flown for years. Others are flown regularly. What I choose to fly on any given day can be dictated by the weather, wind strength, wind direction or just my mood. I would therefore have to incur high costs just to maintain that choice. Here in the UK we only need to register as an flyer/operator having passed a flyer competency test. We are then issued with a Flyer Id and a Operator Id. We are required to affix our Operator Id. to any aircraft which we intend to fly. As you can only fly one aircraft at a time anyway it is all that is required. My final concern is the lack of provision for Slope Soaring sailplanes…. Many hobbyists build and fly sailplanes. Scale, sport, aerobatic etc. They are flown off the side of hills/cliffs where they soar in the lift generated by the wind blowing unto face of the hill. They too could not be retrofitted with remote id and therefore would technically be restricted to FRIA sites. As the wind direction dictates which hill you can fly at on any given day I think it highly unlikely that multiple hill/cliff sites would ever be considered as potential FRIA sites. Sailplanes have therefore not been given any consideration in the NPRM. In an attempt to strike a chord I ask the following…. Would they…. Restrict capable skiers to the training slopes? Restrict surfers to a beach that rarely has waves? Restrict fishermen to their nearest river/ pond/pier? Restrict capable climbers to an artificial climbing wall? Restrict motorcyclists to their nearest track? Restrict golfers to their one local golf course? I sincerely hope the FAA reconsider their proposed stance on hobbyist model aeroplane enthusiasts. I have lodged my comment in the appropriate FAA facility. Thank You Davy Orr”