, Hayesville

, North Carolina

, United States

Posted on
2020-02-22 17:12:16
“I started flying RC aircraft as a freshman in high school over 50 years ago. The technical and mathematic challenges of designing and building RC aircraft, and experimenting with them for performance improvements, directly impacted my thought process, determination, and imagination. Because of this hobby, I was drawn toward science and math, and I achieved multiple engineering degrees including a Masters degree. My best friend growing up was also on the same hobby track, and ended up at the Air Force Academy in the aeronautical engineering program. He eventually worked on an aerospace team that invented commercial and military aircraft flight stabilizers, based on sensing micro changes in air pressure and density. This is a great example of industry level impact. This hobby has also given me some emotional and behavioral life lessons about winning and loosing in competition, as well as teamwork in international competition. The experiences I have through the hobby, also guides me to helping others to be successful. The proposed rule’s impact to youth through programs such as STEM will be terrible and should not be dismissed. America has a strategic interest in producing more scientists and engineers, and the proposed rule making does not facilitate that strategy. How do you explain ceased or restricted aviation opportunity to a student in STEM? While I certainly understand the need for safe and secure air space, the proposed changes seriously impact hobbyists and the hobby industry, and will have the net effect of a death blow. The changes are overly restrictive, and do not appear justified or feasible for the level of concern and risk. Most hobbyists are AMA members, and they want to do the right thing. Unfortunately, the proposed rules would result in inconsistent compliance, and resentment for the FAA. The FAA needs that they are dealing with behavioral change of modelers, perceptions of loss of freedom, and the feeling that “Big Brother is Watching”. Getting local law enforcement involved will also not be consistent, and will not foster positive community relations. Please consider a less restrictive and softer initial implementation, to increase the probability of compliance and acceptance. This will allow time to assess impact, compliance, and acceptance, before making further rules. Please consider the following as a reasonable and prudent implementation start: 1) Change the .55 pound exception to 1 pound. This will allow for many more home build and ready to fly micro aircraft to fly in compliance. .55 pounds is excessively low, and any airframes just over that weight will not be able to accommodate self identification equipment. 2) Change the flying ceiling from 400 to 600 feet and the distance from 400 feet to 1/2 mile. Many aircraft and modelers cannot operate in a 400 ft. box due to flight characteristics or operator skill level. A 400 ft. box will be so tight that safety will be a problem. 3) Allow current AMA chartered clubs to become FRIA sites. 4) Allow the AMA to administer future site approval, as an agent of the FAA, subject to all FAA guidelines, administrative requirements, and audit provisions. The AMA and members have a history of safe operation, and they have a network of regional VP’s that can process applications for approval, and conduct site visits as needed. Please note that flying sites are lost all the time due to development, noise, or other reasons, and they are extremely difficult to find. Not allowing for continuous approval of FRIA sites will also kill the hobby and industry. 5) Consider limiting the self identification to certain classes of aircraft that have a higher probability of impacting safety and security. For example, long range FPV aircraft, aircraft over some weight limit – maybe 10 pounds, multi rotor aircraft performing photography or commercial work, and all aircraft capable of autonomous GPS associated flight. 6) Allow self identification equipment to be configured for a number of aircraft, so the operator can select the appropriate aircraft and attach it to the airframe. This is also a cost consideration. 7) Be specific in the definition of UAS airframes for which the rules apply, in order to help consistency and compliance. For example “radio control fixed wing aircraft”, “radio control parachute aircraft”, “free flight aircraft”, “model rockets”, “heli and multi rotor aircraft”, “blimps and ballons”. etc. 8) Clearly state consequences of non-compliance, whether fines, loss of FRIA sites, warnings, etc. Also, be clear about liability implications. For example, will operators choosing not to comply, loose their AMA insurance coverage, or private umbrella policy coverage?”