Joe

Scully

, Melbourne

, Florida

, United States

Posted on
2020-02-20 16:02:09
“These additional measures are unwarranted and unnecessary, and extreme in terms of the technologically required to adhere. The UAS industry is comprised mostly of hobbyists, and these measures could impose significant costs on the model aviation community and unnecessarily restrict existing, safe model aircraft operations. To date, with the number of UAS in operation, and the minute number of confirmed incidents involving UAS, the proposed measures would have provided no alternative outcome of any confirmed incidents, had they already been enacted, from my understanding of following the industry in the media and trade publications. The current regulations provide a satisfactory methodology of ensuring safe operation and proper training of remote flight. The proposed rules arbitrarily limit the number of approved sites and prohibit the establishment of new sites. As the industry continues to evolve both through consumer and professional markets, there will be an ever-growing demand for areas for safe operation for testing, training and enjoyment; locations need to be nurtured as opposed to being holstered. Many flying fields may be established on a temporary basis, for events within the UAS Professional markets or with the hobbyists with the Academy of Model Aeronautics for events and competitions, and the proposed legislations restrict the possibility for these flying sites to be regulated for a short period of time. This is very detrimental again for the growth and development of the Industry. In all reality, rural areas are the ideal locations for development and training; true kryptonite to having a reliable internet connection in 2020. Many of these ideal and currently approved flying spaces don’t have adequate cellular service, which under the new proposed regulations would result in flights being grounded. Quite simply, rural locations are frequently the safest places to fly because they are away from people, other aircraft and structures. The FAA needs to provide a solution for these areas, while the easiest would be to not enact these new rule changes at all. As others have commented, the FAA should also reconsider the proposal to register each aircraft individually, which will impose a major cost burden on hobbyists and professionals. While individual registration may make sense for beyond line of sight operations, it is an unnecessary requirement for aircraft designed to be flown within line of sight. A vast majority of UAS are custom hand-built models, resulting in a lack of serial numbers, making individual registration more difficult. Please re-consider these additional measures. Some may feel that on paper, they may make sense, but in reality, they are almost impossible to adhere to technologically and financially, and these proposed regulations will do more harm than good to an industry that supports a billion-dollar industry, provides thousands of jobs, and is developing the future astronauts, pilots and engineers of the Aviation industry. We need to grow the Industry, not handcuff it before it even ‘takes off’.”
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