“Dear FAA: I write to you to comment on the NPRM dealing with RID for UAS. To start let me say that I disagree with a large portion proposed in the RID. I have been a public-school teacher for over 25 years teaching with the Miami-Dade-County-Public-Schools District (4th largest school district in the nation) at the middle school level, teaching grades 6-8. In my beginning teaching years I taught wood shop, a great and enjoyable hands-on project-based course that so many of my students loved and experienced for the first time in their lives. After several years of teaching the course the school district started to implement STEM material/projects into my course. We started with small scale solid fueled rockets. These rockets were never kit versions, these rockets were scratch built from basic materials. Basa wood for the fins and nose cone (turned on the wood lathe) gummed tape for the body, plastic bags for the parachute and so on. The only parts not built by my students were the solid fuel motors, which we may have built if the school district had allowed. Newtons Laws, power to weight, drag, aerodynamics and numerous other areas of STEM were all put into practice, thus giving students a “real world” example of these principles. Needless to say, the students loved launch days, whether their rockets were a success or not. Single engine rockets led to multi-engine rockets, glider rockets and multi stage rockets. Other STEM projects were added: Dragsters, hot air balloons, gliders, all teaching STEM topics and all for the most part built from scratch. I believe it is import too understand there were several reasons for going the scratch-built approach: · Students had greater satisfaction · More tools and methods were learned · Students could repeat and expand what they learned at their homes · Greater cost savings (remember I teach at a public school where funding is never guaranteed and is always too little). As the years progressed our shop added CNC Milling and CAD design, which we of course used to great advantage in designing various components for our woodworking projects as well as our STEM projects. After nearly 20 years of teaching wood shop I was given the opportunity to transfer to the teaching of digital media and robotics, two subjects I might add that I have had no formal training in (but I love a challenge).It is in the robotics program where the use of quadcopters was put into use. The robotics course has many goals (all STEM based) and one of the critical ones is the introduction of computer programming(coding) to students. Coding can become a loathsome and boring task for the mind of a middle schooler. However, when students can immediately see the results of a few lines of code via their robot it tends to increase a student’s interest rate, resulting in an increased learning rate. Following the mantra of seeking the construction of scratch-built robot designs I scoured the internet and YouTube for knowledge and robot designs. After several years I began to have a streamlined course flow and it was wonderful to see the students coming up with design solutions and getting some insight into the basic frameworks of python programming. Soon the world was being introduced to the consumer quadcopter and I was introduced to the quadcopter first hand when my brother purchased a DJI drone. My first flights for my brother and I were simply euphoric because we had always shown an interest in RC aircraft since we were kids and now here was a relatively inexpensive and easy to fly aircraft(with control features which were unheard of when we were kids such as position-hold , way points, mounted cameras and on and on. I knew that I wanted my own drone but I wanted to build one from scratch. I wanted the personal satisfaction of building my own quadcopter so I could fully understand its component functions, customize it, repair it, upgrade it, program it……but more importantly I wanted to see if there was the possibility of my students being able to do the same! Well it turns out that many of my students can build, program and fly scratch-built drones. Hardware today allows for myself and my students to program their quadcopters using some simple python programming script. It’s exciting for my students to see their land-based robots controlled via their programming but it is exhilarating for them to see their craft take too the air and carry out their program. In addition, numerous scientific/aerodynamic facts/laws can come alive as they are being learned. I again make use of scratch-built craft for the very same reason that was stated in the making of scratch-built rockets back in my wood shop days. And just like in my wood shop days the robotics course incorporates CAD, CNC milling ….and now 3D printing, which are all put to use for the re-engineering of components for the quadcopters. The negative impact if not total elimination of the use of quadcopters in my (and many other of my fellow educators) STEM program that the NPRM and RID as it is currently proposed is as follows: · Cost of new hardware requirements. I must already use my personal funds to make up for shortfalls in funding available from my district. I can envision an increased cost that will make me have to close the program. · The requirement of communication via telecommunications (sim card). There is no way my students would be able to acquire or pay for an sim card account. And why would they register and pay for UAS that the school system owns, the same goes for me, why would I register a UAS(s) that belongs to the school system. Miami-Dade-Public-Schools would also not acquire an account due to various costly and legal reasons. · The option of flying at an approved FISA site is not an option because of the: a) Distance (the nearest AMA[and possible FISA] site is 20 miles from my school site) and b)The need to be testing and flying every day and week(Except weekends…the days when the local AMA sites are open.). · The barriers of a quadcopter with locked down hardware. My students would not be able to enter new code nor alter existing code. · Privacy: Parents, students, the school system, the state of Florida, the federal government and many others I am sure am sure would have a problem invading the privacy of under aged students some as young as 11 years old. · Allowing the public to be aware of where, when and who is flying a UAS in the area. For me as a teacher the safety of my students is always my number one priority. With the remote id program, I would have the possibility of having to deal with unwelcome strangers showing up at our flying location to see “what’s going on?” or to rant and rave(unnecessarily) about my students flying drones in their neighborhood…even though we are on school property. Then there is the possibility that my students (aged 11-13) could be flying their personal drone at their homes inviting the unwanted encounters with strangers. My feeling is that if the FAA wishes to implement a remote id program there is no need to implement such an imposing system as is described in the current RID proposal. I highly recommend that: · For all noncommercial UAS (and non-BVLS operations) the RID program scraps the network (internet) requirement portion of the proposal and simply stick with the broadcast system for all noncommercial UAS operations. · You should also delete the 12-month window period for the creation and approval of future FISA sites and instead allow the creation of new FISA sites for an unlimited time period. · For all noncommercial (and non-BVLS flight operation) UAS there should be no ANIS hardware requirements. This would allow for costs to remain reasonable for constructing scratch-built craft as well as allowing for “legacy” UAS and hardware. In this comment I have attempted to point out the negative impact the NPRM will have on my robotics course content and with my future students. However, as a private UAS operator I personally share all the RID concerns that were brought up when dealing with the STEM program at my school. I have read through the NPRM and I come away with the feeling that many of the arguments for the proposed RID are either unrealistic, have no data to back them up, or based on overhyped news reports. · The NPRM mentions safety concerns…Where is the safety study (Data) that shows a need for such a drastic RID program? · The NPRM mentions “nefarious” persons and criminal activity. The proposed RID program will not stop or even decrease criminal activity due to the fact that criminals do not follow the laws/rules. · The NPRM seems to point to the near future when the skies will be filled with delivery drones. While I agree drone delivery will be a real occurrence, however it will be on such a small and limited scale due to the flight limitations of the drones themselves. I want to thank you for your time. And wish to close in saying that I understand the need for a RID program…however this NPRM as it is written is not the RID that should be adopted. Thank you, Dean Coppolo Riviera Middle School 10301 SW 48th Street Miami, Florida 33165 email 174516@dadeschools.net I have attached a photo of myself and some members of Riviera Middle Schools Drone Team at a local 2019 Career Technical Education (CTE) drone competition.In the center of the photo is the superintendent of Miami-Dade-Public-Schools,Mr. Alberto Carvalho.The team also competed at a STEAM event that included a drone flying competition.This STEAM event hosted over 25,000 students,parents and spectators who enjoyed competitions ranging from Robotics to Performing Arts.”