Joe

Naylor

, Gouldsboro

, Pennsylvania

, United States

Posted on
2020-02-14 20:45:25
“Here are my comments to the FAA: I am Joe Naylor, an attorney, licensed private pilot and long time recreational user of all types of model aircraft. While I understand that PL 114-190 charges the FAA with developing consensus standards for Remote ID of UAVs, there is something fundamentally wrong with the proposed regulations which would prohibit people from designing and building their own model UAVs and flying them in their own backyard. These same activities have been safely carried out, unregulated, for decades. It is fundamental to effective regulations that they be (1) as simple to implement and admiister as possible while accomplishing their goals, and (2) designed in such a way as to encourage compliance. With regard to recreational users the proposed Remote ID regulations accomplish neither of these objectives, and in fact would effectively end the recreational design, construction, testing and flying of UAVs, to the detriment of, and with no benefit to, society, by imposing a system of recreational UAV “Corner and Kill” (first restricting most recreational UAV activity to FRIA sites, and then by gradually eliminating these sites.) Recreational use of UAVs should be encouraged, not discouraged, since this hobby, while perhaps seeming frivolous, in fact has great value to society. Recreational use of UAVs educates people of all ages about technology, engenders a love of aviation and related STEM learning in people young and old, leads to aviation and other STEM related careers, and creates high tech jobs for UAV equipment designers, developers, and small businesses. The ever-evolving technology of UAVs has just recently progressed to the point where it now enables Americans to invent and start new and useful businesses, empowers people to create new forms of art, encourages people to engage in outdoor recreation, and enhances public safety operations such as search and rescue. The freedom to operate UAVs without regulation has encouraged and stimulated the development of a whole new cadre of technically savy individuals who have made these developments possible, to the benefit of society. As proposed, the unreasonably and unnecessarily complex proposed Remote ID Regulations are infeasible for most recreational users due to the expense and difficulty of compliance, as well as the inability, per the proposed regulations, to retrofit the necessary equipment to existing UAVs. The complexity of the proposed regulations also serves to encourage noncompliance by recreational users and many may choose to simply ignore the Remote ID regulations and operate as usual on the assumption that “the government cannot punish me if they cannot catch me”. In fact, given the limited enforcement resources availabe, it WILL be difficult to catch recreational users who often only fly for brief 5-10 minutes. Thus, without developing regulations which create a culture of compliance from the start it is likely that Remote ID will be ineffective and UAV jamming technology will ultimately be the solution to control of undesirable UAV activities. An illustration of the effect of well meaning but overly complex regulations on a harmless hobby can be seen by review of the history of the Federal Communications Commission and its regulation of Citizens Band radio. The original CB regulations were complex and costly, requiring individual purchase of a license, assignment and use of a federal callsign, restrictions on antenna height, limitations on distance communications, restricted transmitter power limits, and much more. Users widely considered these regulations unnecessarily complex and unreasonable, and in fact lax enforcement led to widespread disregard of the regulations. Soon after implementation the FCC was forced to effectively end CB individual licensing and there is currently little compliance with the remaining regulations. Fortunately, by enacting PL 114-190 Congress left the FAA considerable flexibility, since the law did not require more than that the FAA “convene industry stakeholders to facilitate the development of consensus standards for remotely identifying operators and owners of unmanned aircraft systems and associated unmanned aircraft”. By mandating nothing more than a consensus the FAA was given the freedom to do its business in such a way as to accomplish the limited goal of remote ID without creating an unnecessarily complex regulatory burdens. I urge the FAA to reconvene the stakeholders effected by the proposed Remote ID rule, and by consensus reach a regulation which is reasonable for recreational users, is simple to implement and administer and which encourages compliance. I would personally like to offer my assistance in this effort. Joe Naylor”
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