Jack

Hamilton

, Hot Springs

, North Carolina

, United States

Posted on
2020-02-22 12:44:24
“Aeromodelling has been in existence longer than full scale aircraft construction itself, some 120 years. The Wright brothers and their contemporaries certainly built and flew models before they attempted manned flight. The quest for flight has been around much longer than that, as far back as man mystified over the flight of birds. It can be traced back in time through the Greek myths where Daedalus and his son Icarus tried to escape prison on wings held together with twine and wax only to have Icarus in his untamed zeal come tumbling to the ground by flying to close to the sun. Leonardo DaVinci had legitimate designs for aircraft as far back as 1485! Minot Airforce Base called on our special skills to protect the Aircraft (B52H as well KC135R) from potential bird strikes. This alone cause and effect saved millions of dollars in life and property damage. Where would we be if modelers of all ages couldn’t experiment? I started in the early 1950’s with my father, he being an Airmen in the US Airforce. As life went on I became the Project Officer of Aircrew training devices for Minot AFB, ND. Life comes around full circle, started with Aircraft at a very young age then progressed throughout life. Modern day modelers have for the most part been building and flying their creations without much worry until lately when the FAA imposed pilot registration. We were a bit taken aback but most complied. If I understand these new proposed rules correctly the hobby will be devastated. This really would be no different than telling a golfer they can no longer golf, or a model railroad hobbyist, doll house builder or for that matter some one who passes the time with knitting or needle work they are no longer allowed to do so. Aeromodelling has been a lifelong passion for most of us and the restrictions you are proposing are simply uncalled for. As you consider all the comments presented to you please keep in mind my particular point of view and the repercussions it will have on a community of folks who have been enjoying this hobby for generations and with your due diligence many generations to come. It is unfortunate but obvious that with the introduction of an increasing number of unmanned aircraft in the skies there is a need for some sensible regulation. That being said the oneness must not fall on the backs of the traditional hobbyists who have a proven track record of safely flying their craft for many decades. I have read your entire proposal and am convinced there will literally be nothing left for the traditional aeromodeller if it is implemented as is. I will not quote chapter and verse from your document as it’s intent is clear to all, so I will make some bullet point facts and follow up with common sense proposals that should be satisfactory to all. In the following statements “We” indicates the traditional aeromodeller. – We pose no threat to national security. – We have an impeccable safety record – We have been instrumental in all aspects of aviation. – Your (the FAA) rule as written will essentially kill a safe and important hobby that has been around for decades. The rule as written is overreaching and burdensome in many aspects and for no apparent reason. I can only assume it is this way because there is a misunderstanding of the differences in the UAS involved. There is little argument that it is necessary to be able to track and identify any UAV that operates BVLOS, this is a matter of safety and security. This type of UAV is or will be primarily used in commercial/ government enterprises such as drone package delivery, aerial photography/ videography, law enforcement, military operations, search and rescue and in rare cases I assume, a hobbyist. In these cases it is understandable that there be an easy way to identify the aircraft and operator. On the other hand and in deep contrast we have the traditional hobbyist. For my intent here that would be those of us who have and continue to safely design, build and operate our craft which includes fixed wing planes and jets, helicopters and multi rotor UAVs on AMA designated fields and rural private properties without major incident for many decades. We use common sense rules that keep us and others safe. All full scale and commercial aviation has always had and will continue to have the right of way. With the continuing evolution of the airspace these harmless activities must not be impeded by unnecessary and burdensome rules that will do little if anything to make the skies any safer. Other aspects of the proposed rule that are particularly troubling is that it makes it nearly impossible for us to keep, maintain and procure flying sites and severely limits the distance we can fly. The style of flying we do is limited to our line of site, so we pretty much fly in circles or fly set patterns over a given area. Some of the larger planes and jets need quite a bit of space to safely take off, maneuver and land. For folks that fly sailplanes the challenge is to float on thermals and fly quite high to stay aloft as long as possible under no power except the thermals. A 450 ft bubble is not sufficient, 1000 ft would be acceptable in my opinion. FPV is also a very safe part of the hobby as most of us practice it. A spotter is used and so is still essentially line of site flying and quite safe. I believe the biggest threat to the hobby is the commercial/ government operated UAVs and they must bare the brunt of the responsibility of what happens due to their crowding of the airspace, not the average modeler who just wants to enjoy the hobby at their clubs and in their own back yards. To summarize, I urge you to take a good honest look at what will be the real problems in the airspace and realize it has very little to do with us model aviators who have and always will enjoy their passion in the same way they always have with no interruption from this burdensome and unacceptable rule. Thank you.”
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