“1) WHY must the hobby be protected? Cost-efficiency, Creativity and Community The hobby of (remote-controlled) RC flight is a grassroots treasure, especially in the USA, for young children who aspire to be the innovators and engineers of tomorrow. Home-made (DIY) aircraft construction has the ability to align children, who are in their most impressionable years, onto a path of responsibility, discipline and creativity. The importance of such a driving force cannot be explained; it must be felt. A few years back, when I was pursuing a bachelors in Aerospace Engineering, I saw that my strong practical background in DIY RC aircraft design contributed heavily to my understanding and visualization of theoretical formulations presented by the professor. It was unfortunate and also frightening to look around the classroom and see that the majority of students – who are on track to become the next generation of aeronautical designers and consultants – had no idea what was being discussed due to their lack of practical experience. When asked about why they refrain from engaging in some simple aircraft construction on their own, the students mostly point fingers at the inaccessibility, complexity and cost of the RC hobby. Requiring remote ID abilities for simple RC aircraft projects would impose impractical financial and logistical burdens on children and families who wish to engage in this mentally and physically healthy activity. Aircraft design is a delicate and multifaceted process. Stable and safe operation of a model depends on precise balancing of the airframe in relation to the centers of pressure of its dominant lifting surfaces. A typical builder may construct, crash and rebuild more than three models on a monthly basis from cheap materials to prototype a new concept or learn new aerobatic maneuvers. Individual registration of each model is a highly impractical matter since any given prototype may crash the day of its first flight and require iterative design. Installment of standardized transmission devices in each of these airframes (that come in various sizes and aerodynamic configurations) is an impractical measure both in terms of cost and design considerations like weight, internal space and airframe balance. Furthermore, learning how to fly is an immense challenge of its own with extreme pressures including safety of the surroundings and troubleshooting of flight characteristics. To add to these pressures by requiring internet communication at take off and forced landings in the event of connection loss would only add to the intimidation of entry to the hobby. While it is questionable whether these blackboxes will directly ensure public safety on the fly, it is certain that they will discourage continued involvement in the hobby and its outreach to younger generations who wish to minimize RC expenses and pressures. In my school years, social pressures mostly distracted me from studies and good citizenship, causing a grave misallocation of psychological priorities. It was the small projects I engaged in at home that kept me on my feet, both in terms of academics as well as life in general. I would spend hours of my free time building helicopter models out of old shoe boxes and trying to replicate the F-14s I saw taking off overhead using construction paper. These simple projects planted inside of me an affinity for learning, growing as person, and building relationships with others. With the alarming diffusion of technological access through younger generations, the gravity of both human contact and mental engagement have greatly increased. The forces that are capable of suppressing one’s creative impulses and engaging one in destructive social interactions have unmistakably magnified. It has been scientifically shown that repeated involvement in social media can restrain intellectual creativity by enforcing endless cyclical thought processes. Furthermore, high school teachers are now being trained to allocate time for students to ‘voice their feelings’ since engagement in mobile devices reduces their ability to do so (personal account from a fellow graduate student working as a student teacher). The RC hobby has an immense power to open up children’s minds and build their intellectual prowess by challenging them to attack new design problems. Anyone who has built and flown planes, is also aware of the magical ability of the hobby to build powerful human connections. Some of my best friends are those who I meet with only once in a few months to discuss building challenges and fly similar models in formation (as opposed to some associates at college whom I see on daily basis but will hardly remember in a few years). This may not be immediately apparent to those who haven’t come into contact with the hobby, but designing, building and flying are at the heart of what unites several communities around this country and the world. Limiting the freedom of young children and local communities to engage in these activities, by imposing impractical financial and logistical hurdles, will dissolve an important part of the beating heart of our society. 2) How we enforce public safety while cultivating the hobby? Involvement vs. Alienation One of the truths driven home by my college professors is that Aerospace is one of the few industries that pivots entirely about human safety. It would be foolish to marginalize public safety with reckless and unhinged flying at the commercial or RC level, but burdensome laws that would gradually end the hobby are certainly not the solution. They are in fact a symptom of a mischaracterization of the actual problem. The new “problem” isn’t the plentitude of RC models in the air, or the ability of these models to cause life threatening injuries. Model flight and its dangers have existed for several decades, and can be expected to proliferate due to the permeation of unmanned delivery drones into the residential sector. Personally speaking, I have had several passerby’s at the local field including young children with their fathers, former pilots and police offers strike conversation and express their awe at my home-made model airplanes. However, there is also the opposite archetype, of reckless race pilots who crash their models into neighboring houses. How does one reconcile these opposing narratives? Both situations involve the excitement of RC flight, public involvement and high energy models that can cause serious injury. The answer must involve both responsible piloting and public awareness. We must require and involve spotters who are expert pilots: able to educate the public, enforce safe practices and steer aircraft away from spectators. The public must be aware of the dangers of overhead aircraft, but also feel welcome to pass by and join the excitement. Protecting public safety and cultivating this community-based hobby are not conflicting considerations, they are tasks that go hand in hand and must be treated as such. Remote ID requirements do not guarantee public safety; they guard legal establishments and manufacturing companies from potential financial losses that would transpire as a result of injuries. They also guarantee a gradual decline of community awareness and involvement in the hobby. If we wish to truly ensure public safety, the answer is education and collaboration, not suppression and alienation. While laws may protect institutions, people must project people. I cannot claim to have the ability to develop a nationwide one-stop solution to the “drone problem”, but I know for sure that positive change must first occur at the local level – with spotters, pilots and spectators supporting each other rather than fearing, blaming and alienating each another (as will result from the remote ID initiative). This alone will inspire a spread of healthy practices to communities across the globe, that can actually make RC flight safe for all parties involved. 3) How do we satisfy all relevant parties involved? Children, Hobbyists, Spectators and the Public So what is the wholesome solution? How do we cultivate creativity and empower the next generation, while ensuring the highest standards of public safety? Is the proper response further laws that suppress creative outlets and impose higher financial burdens on pilots? Complex remote identification software that are bound to frighten the public away from flying sites instead of educating them and drawing them toward the hobby community? In no way am I an expert in design, piloting, or law and I do not claim to understand all the dimensions of the challenging situation at hand. But I have experienced the positive dimension of the hobby – its power to satisfy all the above considerations, which are in fact difference faces of the same Rubik’s cube (please endure the analogy). Exposure to the hobby can provide aspiring engineers a fruitful, healthy and educational youth, preparing them to become responsible communicators and innovators who will manage and expand our airspace in the coming decades. Protecting the freedom of creative expression through aircraft design will strengthen bonds inside families and local communities, while maintaining an affordable cost line for such activities. Spreading knowledge about these positive practices will inspire hobbyists and the public in several communities across the globe to interact in a healthy manner, uplifting one another. Attempting to solve the “problem” by rearranging only one face of the cube while neglecting all the others will result in failure. Trying to enforce public safety by requiring remote ID will affect all the other faces, suppressing creativity, increasing costs and causing social tensions. For example, in my city, most of us fly at a few designated sites making sure to enforce safe measures by spotting each other during flights and watching for passer-by’s. The park-goers are made aware of the flight patterns by verbal communication and we ensure that our paths don’t cross theirs. We always make sure to have skilled pilots support those who are learning, or experimenting with untested aircraft designs. Even if the limited number of UAS’s without remote ID equipment are allowed to operate under line of sight and this right is protected moving forward, requiring CBO establishment of FAA-recognized ID areas within 12 months of the effective date of the final rule is extremely burdensome on simple hobbyists. We never know which fields will shut down and when any new locations may open up. This hobby at the grassroots level is far too multifaceted and time-varying to be successfully regulated by a blanket national provision (even if the latter is supposedly open to later developments) without suppressing the freedoms of recreational hobbyists to pursue their passion in a safe and healthy manner. It is apparent from the NPRM that great benefits lie ahead for air traffic controllers, public security agencies, and future industrial UAS operators. In view of the expected introduction of delivery multi-rotors into urban airspace, I would definitely desire and expect the manufacturers and the FAA to work together to ensure my safety and awareness of flight paths. But we request your understanding in terms of the financial and logistical burdens that this proposal would impose on recreational flyers, who sometimes construct entire airframes for under two dollars to share a healthy memory with their friends and family (The figure is not fabricated, I have constructed several such airframes as a beginner and continue to do so to inspire others). Application of the proposed rules to all UAS’s across the board (even with the careful classifications and concessions in the current NPRM) is a heavily reductionist treatment of the situation, since the sphere of fast-paced industrial drone development and the world of community based affordable recreational flying are highly distinct. The proposed legislations may be very powerful in guiding and regulating the development of industry-level drones and futuristic UAS technologies, but are far too passive and restrictive at the recreational level. Curbing my analysis to the second, implementation of this law will only provide a de jure appearance of safety, where we need de facto involvement and communication between pilots, experts and passer-by’s. Instead of simply requiring nervous high schoolers to ‘broadcast’ their wobbly take-offs, we must involve expert pilots and spotters at the local level to enforce responsible practices and educate aspiring hobbyists. Instead of simply publishing numerical data about the erratic flight patterns produced by Johnny Goode’s out-of-trim P-51 Mustang on Sunday the fifth, we need to involve the hobby community in actively protecting spectators while welcoming the public to witness the magic of flight. The only sustainable solution for everyday flyers that will actually ensure public safety is careful rearrangement the Rubik’s cube, paying attention to all of the faces: healthy cultivation of the hobby rather than blanket restriction; education rather than mere information; inclusion rather than division. The power of active and empowering change at the local level cannot be underestimated. Drawing from the timeless words of one of the greatest aviators of yesteryear, (and my childhood hero), one small step taken by each local community will grow and grow to become a giant leap for all of humanity towards unity and progress. I am grateful for your time and patience and request your kind consideration of the aforementioned. ~ Thank you ~”