, Indiana

, United States

Posted on
2020-02-26 1:39:16
“I mostly fly commercially under part 107 however do occasionally fly recreationally. My concerns are: 1) In terms of commercial operations, the least restricted category for operation would be difficult to comply with and most likely prohibitively expensive for smaller businesses. This would make most businesses operate under the 400ft dome using limited remote ID. The 400ft dome while it sounds like a good idea would be extremely restrictive and would not allow commercial companies to fly data collection missions in a practical manner. In agriculture for example, missions are usually a 1/ 4 of a mile by a 1/4 a mile and are flown at 400ft. I currently fly for ag and this is a fairly typical size of one flight. Often times we will have to fly, land, relocate, then fly several times with mission areas of this size to get an entire field while operating in accordance with part 107. Having a dome at 400ft would completely block this type of mission from occurring because one would have to fly lower (which doesn’t work for many of the sensors we use) and would make the operator have to relocate so many times that it would not be worth it commercially. My recommendation would be to change from a 400ft dome as proposed in limited remote ID operations to a 1/4 mile by 1/4 mile x 400ft ceiling. This would still allow operators to fly in visual line of sight and would allow them to cover the areas they need to cover in order to collect the data needed. If there are concerns about law enforcement being able to identify the operator of a UAS, they should be able to point their device at the UAS and the UAS should be able transmit the location of its controller to the law enforcement officer. 2) I believe the ability for the public to see more information than the UAS type, mission profile, and UAS location to be a safety issue. If one is operating a UAS and a member of the public points their phone at a UAS, get the location of the operator, and comes over to talk while ones is operating, the distraction poses a safety concern as the concentration of the operator would not fully on the operation. My recommendation would be to only release the location of the controller to law enforcement and not to the general public. 3) Although I believe that it is important to have approved equipment on UAS I have concerns about the added cost of making the equipment approved. I believe that the added cost of equipment to make it approved would make it more cost prohibitive for small commercial UAS businesses. In addition to the added cost to the consumer, the added cost and complexity to the manufacturer to get the parts approved may be beyond some manufacturers capability. This would cause a decrease in the verity of parts available and a decrease in innovative solutions due to the complexity of the approval process. As an example I use the Pixhawk 2.1 cube, an open source autopilot system for both multirotors and fixed wing platforms, on almost all of my UAS used in Part 107 operations. I build my own systems because the systems that I need for my line of work do not exist. Under the new proposed rules, if I wanted to build my own platform and operate it commercially, the pixhawk manufacture would have to go through the approval process which could cost them enough that they would most likely decide not to do it. This would severely limit my options as a lot of my requirements cannot be met with an off-the-shelf UAS. My recommendation would be to allow the limited remote ID compliant UAS to use autopilot and other equipment not approved to the same standards as the standard remote ID compliant UAS equipment to: 1) minimize the added cost to both manufacturers and consumers, 2) allow consumers more choice in what they purchase and, 3) allow innovation of new technologies within the UAS field to continue. 4) The age restrictions for allowing people to fly recreationally would make it difficult to get kids involved in flying RC and make it difficult to pass on the hobby to the next generation.”