, Austin

, Texas

, United States

Posted on
2020-02-24 8:59:21
“I have been scratch building and flying RC planes since I was 10, 40 years ago. It has been one of my most persistent and pleasurable, persistent life activities and I’ve enjoyed adapting as technology and the industry has evolved. What’s possible today was not even imaginable when I was a kid, and it’s this innovation and creativity that’s kept me learning and interested. I credit this hobby with teaching me life skills such as patience and the importance of precision in everything you do, which have had a big impact on my success as an adult in professional life as a software product developer. One of the beautiful things about modern technology is it’s opened up millions of areas as flying sites that were not feasible previously. Modern electronics, battery technology, and the Internet have made it possible to safely design, build, and fly small aircraft around your house or in a small, local field without creating a lot of noise or disturbing anybody. This has made the hobby far more accessible to those with busy schedules, kids learning in STEM programs at schools, and anybody with a passing interest. I see whole segments of young people getting involved and learning great technology and life skills that would not have been interested 20 or 30 years ago when the barriers to entry were so much higher. It has promoted the kind of innovation this country needs to invest in to develop the next generation of technology innovators. I and all of my friends have never acted in a way that was irresponsible and dangerous. This is a hobby to enjoy, not to create problems. Most non-hobbyists I’ve interacted with over the years while flying simply want to satisfy their curiosity or want to find out how to participate. While it’s understandable that the FAA wants to ensure airspace is safe for a future with many, many autonomous drones flying at low altitude delivering packages or whatever, the Remote ID approach being proposed is overly heavy-handed and does not accommodate the interests of millions of amateur hobbyists. The goal should be to allow autonomous aircraft to operate safely in the airspace. There are many, many ways to implement such a system that do not negatively impact individual hobbyists or turn them into criminals for safely enjoying the hobby they love. The Remote ID approach looks like a safety system developed for full size aircraft that has been blindly applied to an entirely different class of aircraft that have a very different operating profile. What the FAA needs is to identify, in near real time, the small pockets of airspace in which individual or small groups of hobbyists are responsibly operating their aircraft. Per existing rules, these aircraft are limited to line-of-sight and 400′ altitude. Most operate far below that 95% of the time. As an alternative to Remote ID, drone operators could easily identify or “declare” their operating area ad-hoc based on a simple, Internet-based registration system. This could easily be done using an app on a phone that reports GPS location. The FAA can add this “bubble” to the airspace chart and long-range autonomous aircraft (such as delivery drones) can easily navigate around it. The reality is very few of these ad-hoc, amateur flying areas will exist in a given geographic area at any one time. As a hobbyist, it would be easy for me to download an app, declare when and where I plan to fly for how long, and alert the FAA. The specific position in airspace my drone is occupying at any one time +/- 400′ is immaterial to the safety of other autonomous aircraft operating in the airspace. It’s the “bubble” of airspace that’s important to maintain safety as the number of aircraft multiply. Just like drone hobbyists are innovative, I’d like to see the FAA innovate to creatively solve this problem in a way that works for all their constituents. The proposed rule, as written will have a severe, negative impact on the positive benefits of this hobby both for individuals as well as educators as STEM programs leveraging this great technology will largely have to eliminate this from their curriculum. It will stifle innovation and put a damper on designing and building self-designed aircraft in convenient, accessible locations. The reality for individual hobbyists like myself is that this rule would simply turn me into a criminal. Enforcing it will be almost impossible and you’d put law enforcement in a position to penalize ordinary people, operating their aircraft safely in ways they’ve done for decades. Instead of creating a whole set of new problems that detract from law enforcement’s ability to address real crime, I’d like to see a solution that asks hobbyists to participate collaboratively in a joint system that preserves the flexibility and value of their current behavior while also making the airspace safe for autonomous, commercial drone operations. This is absolutely possible and practically achievable. I believe there are millions of hobbyists like myself who are willing to work together on this with the FAA. Please engage in this dialog and make sure you understand and accommodate the needs of all your customers before making significant policy changes that have huge unintended consequences to industry and innovation.”