Garrett

Luellen

, Brighton

, Colorado

, United States

Posted on
2020-02-22 16:29:49
“Background I am 26 years old and I have been flying home built First Person View (FPV) drones and RC aircraft for five years now. It has taught me an enormous deal about electronics, radio (I studied and received my HAM radio license because of it), and flight technology. It has also inspired my son (4 years old) to develop a love of learning and an incredible technical aptitude towards building, fixing, and working with hardware, something uncommon for today’s youth in a world of finished, packaged goods. My father and I have bonded over this hobby, as have my son and I; it is something that has crossed three generations in my family. FPV drones have greatly enabled a love for learning in the younger generation, myself included, and these regulations will add a barrier to entry too large to encourage hobbyist like myself from remaining or getting into the hobby. The only people left flying drones are those capable of dishing out $1,000s of dollars for equipment they have no part in building, with absolutely no technical knowledge required to operate. This is the United States of America, the land of the free and the home of the brave — we should be free to fly and innovate; the mothers, fathers, sons, and daughters building drones in their homes and with their children are developing the free innovators of tomorrow. Alternatives In addition to the current regulations (400 ft ceiling, not flying over people, etc) I would suggest a simple app-based solution for registering where we are flying, such as an app where pilots could publicly identify where they are operating their recreational models. This would allow no increased barrier to entry but also add the benefit of real-time monitoring of where pilots are operating. Where possible, such as manufactured autonomous drones, an updated firmware could be used to enable remote monitoring. But a huge portion of us do not use manufactured autonomous drones, and instead enjoy flying aircraft and FPV drones through video goggles at parks and on our property. Issues with Proposition as Written All of my aircraft and drones have been built to be as light as possible. Adding hardware like remote ID interface would affect the flight characteristics of these aircraft by adding weight and they would likely require even further modification (bigger batteries, heavier motors, more durability modifications) to fly the same, ultimately increasing the cost far beyond that of just a remote ID module, if such a thing were to be made available. I and many fellow pilots live in urban areas where flying fields are an hour or more away. I love to fly in unoccupied areas and when I do fly in parks I frequently entertain the questions of onlookers (mostly children) on what kinds of drones and aircraft I fly and how they work. It is truly a blessing, and would no longer be possible if we were confined to approve open spaces. Traditional RC Aircraft On the note of aircraft flown via line of sight, I think it is relatively simple and low-risk to exclude these from the remote ID proposal. These are not flown at significant altitude and do not have significant autonomous ability. FPV Drones Likewise, drones built for FPV purposes are usually limited to a return to home function, where they return to the original launch area, and have no other autonomous capabilities. If they lose radio signal, they will not continue to fly but instead either begin a landing descent or simply fall, neither of which cause any hazards to manned aircraft or nearby people when flown within the current regulations (400 ft limit of altitude, and not over people or other property, etc). Due to the majority of these drones being built from hobby hardware, users are also usually more competent that individuals who buy non-hobby finished equipment. Commercial Pre-Built Drones Unlike fixed wing aircraft and FPV drones, cinematic autonomous drones (manufactured namely by companies like DJI) can be flown by anyone and have an enormous range capability. The risk here is that people who do not understand the aircraft’s capabilities fully can get it airborne and potentially threaten the safety of manned aircraft. If remote ID must be applied anywhere, it would be to these aircraft, as it could be implemented using low cost solutions at no affect to the pilot. Summary I believe the Remote ID is an overstep of the FAA’s power, and if enacted will eliminate an enormous doorway into STEM, learning opportunities, and jobs for the not only younger generations but all generations. There are also less limiting ways to accomplish a similar reduction in risk at no cost or inconvenience to existing hobbyists while maintaining the beautiful freeing nature that is intrinsic to the hobby of flying model aircraft and drones. I believe a biased argument has been presented from cinematic drone manufacturers as well to help limit the availability of hobby grade drones, thus influencing their market share through the use of regulations. Thank you for considering my comments! -Garrett”
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