, Dallas

, Texas

, United States

Posted on
2020-02-24 12:35:46
“Hello. I’ve been involved in model aviation since I was around six years old, about 45 years. My father got me started with a small hand-launch glider design, which he learned from his father. Both of my parents, both grandfathers and several extended family members were pilots, in both military and civilian aviation. Aviation, aerospace and technology has been a consistent theme in my life. We moved into RC gliders when I was around ten. This lead to gas powered aircraft, electric aircraft and rotorcraft over the following years. Early on, I was interested in modification and design of the airframes and systems. Model aviation has been an excellent medium for learning design process and how to iterate through success and failure to get the desired end result. This was my introduction to basic engineering process and how to measure results to guide design changes and improvements. As I got older, the projects became more sophisticated in different ways. This instilled the discipline and patience needed to follow through on the execution of an idea. Building these aircraft was also a means of gaining familiarity with a range of materials and understanding material selection as part of the design process. These skills and experiences have had a significant impact on my adult life. Most of my career has been technical or engineering based positions across electronics, fabrication, computer hardware and software engineering. There was also a natural progression to general aviation. I have a private pilot’s license for gliders and SEL. I’ve owned two amateur built experimental aircraft, one of which I built myself. The other is used for recreational and competitive aerobatics. My interest in aviation may have been a pre-existing condition, but model aviation provided the opportunity to turn that interest into action. In all my time flying models, I have only been to sanctioned club flying fields twice. Both times, despite being a member, I was unable to fly and found the culture and structure to be a challenge. The safety procedures were good and appropriate, but many of the other hurdles seemed designed to filter out folks that didn’t fit the group’s agenda. Outside of safety concerns, there were additional limits on model types, acceptable modes of flying and a general resistance to innovation. Both fields were already accommodating the activities they liked and saw no reason to change. Granted, this is anecdotal and a small sample, but I’m concerned that existing club agendas will drive usage, if club fields are the basis for approval of flying areas. I have flown at open flying fields that were less restrictive, but still maintained an excellent culture of safety. By far, most of my flying has been from private property, public parks where allowed, and also public land while living out west. Reducing the available choices for flying locations, will reduce the time spent flying. It can be challenging now to find an appropriate place to operate some types of models. A system that allows those areas to be used on demand would be a welcome change from the proposed flying site approval system. I’m also concerned that the proposed field approval process will only be available for the first twelve months. This is a guarantee that flying sites will eventually disappear altogether. What is the long term expectation here? As a pilot, I’m accustomed to limitations on flight activities based on airspace designation and types of operations. Usage of the national airspace doesn’t change based on the whether the flight is personal recreation or commercial. While handling and ground operations may differ, a private flight may take advantage of all the services and privileges of the airspace system, allowed to commercial flight. Once the bar is met for equipment requirements and pilot certification, no distinction is made. I would encourage thought about parallels to that system for UAS operations. The bar would necessarily be higher for autonomous or out of line-of-sight operations, than line-of-sight. Operations outside of Class G would be a similar concern, even if still line-of-sight, for example. The privilege of charging for services is a separate concern than use of airspace, however it is structured. I’m concerned about different requirements for amateur built models, than manufacturer built models. Innovation happens at the individual level much faster than with manufacturers. This holds true beyond just airframe development. Electronics, radios, video, motors, and even battery development all benefit from individuals working on their own designs and modifications. The drive to improve the existing systems is a significant part of the hobby. For some, it evolves into business or employment opportunities that would not have existed otherwise. The improvements made for the sake of model aviation have a reach well beyond the hobby. Discouraging or limiting the usage of amateur built gear only diminishes the hobby, without, in my opinion, increasing safety. Manufacturers who achieve the required approvals can only add this overhead to overall costs, further moving the hobby into a niche, high cost activity. With the primary driver of innovation gone, manufacturers will be incentivized to stagnate on the equipment already approved for use. I would encourage focusing on the specific requirements for models to operate in different manners, without concern for the type of builder. If the requirements are clear for modes of operation, areas of operation and designated airspace, tools/processes can be developed validate and certify that those requirements are met. Like most people in this hobby, I’m comfortable with and like to think that the status quo is sufficient. I know this is not the case. The potential benefits from developing unmanned flight for commercial usage are significant. They fill a gap that is difficult to address with general aviation due to cost. There are opportunities to automate flying services such as pipeline or agricultural inspection, that are tedious for pilots, which impacts safety as exposure increases. I believe that the activities, education and innovation driven by our hobby contribute significantly to the viability of commercial UAS operations. It is a pipeline of talent and technical development that is needed by this fledgling industry. The challenge to build the regulatory system is significant. I’m hoping that it can be done in a manner that allows the hobby to continue to be expansive, rather than reductive. Thank you, Ian Henehan”