Jim

Stewart

, Everett

, Washington

, United States

Posted on
2020-02-19 14:02:08
“As written, the NPRM contains a number of misunderstandings about the model aircraft hobby and will cause serious harm to hundreds of thousands of modelers/pilots. Here is my information, which illustrates some of the issues I would face if the NPRM is implemented: The NPRM assumes that the typical recreational UAS pilot has 2 aircraft, that on average cost $117 and have a useful life of only 3 years,. I believe I am a typical modeler,I currently own 17 model planes aka “UAS” ranging in cost from $70 to $500, and I expect to build or acquire an additional 3 – 5 planes a year, … and hope they will last decades. I prefer to build what I fly – mostly complex balsa wood structures that are, electric powered flown with radio control having no autonomous flight capabilities. The cost of adding tracking telemetry and registering each model would make their operation infeasible, and provide no perceivable benefit to anyone. I enjoy high performance gliders that are always flown safely at sanctioned locations within line-of-sight, but they can easily climb to 1000 feet or more. the NPRM would potentially end all such glider activities. I fly at two AMA sanctioned rural sites, and in my own 4 acre rural backyard, that is 7 miles from the nearest small airport. The NPRM will place burdensome restrictions on current and new approved flying sites, and make it illegal to fly small unregistered planes in my back yard. The FAA assumes that pilots will pay monthly fees to USS organizations to track their UAS flights. I believe that the FAA has underestimated the cost of UAS telemetry equipment, and grossly underestimated the number of potential UAS’s it would have to track and the data volumes and cost to maintain the proposed “solution”. It is not clear that ANY USS companies could be created or operate effectively, much less having NINE in operation. Regarding the technology, it is not clear how all this tracking and reporting infrastructure would work. The FAA should first implement a pilot project to verify the airborne and ground based components would all work and to better evaluate the cost and impact of the proposed program before any legislative action is taken.”
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