, Taylor

, Arizona

, United States

Posted on
2020-02-19 9:08:15
“Dear Sir or Madam, Thank you for taking the time to listen to my concerns related to this NPRM. My name is Justin Kriter, I am a firefighter Paramedic for Taylor Snowflake Fire & Medical out of Taylor AZ. As a first responder and model aviation enthusiast I feel I have a unique but valid perspective on the Remote ID NPRM. In the 30+ years since I got into model aviation, I have built hundreds of fixed wing aircraft and about 10 multirotors. I have also purchased A DJI Phantom 3 and a DJI MAVIC Pro. Most of my fixed wing aircraft are scratch built and of my own design based loosely on full scale aircraft. I have planes built from balsa, EPO foam, Adams Ready board and even a few that were printed on my home built 3D printer. My current fleet has planes that are powered by Nitromethane, unleaded gas, 2stroke fuel mix and electric battery. Some are equipped with cameras and video transmitters some are not. Most are capable of flight times of 8-12 minutes but I also have a few battery operated planes that will fly for over 2 hours on a single charge. My oldest plane is 27 years old and has a 72 MHz FM radio, I just finished building a plane last week (and have a new one on the table as I write this) that will have a 2.4 G radio. All of my fixed wing aircraft are flown within line of sight. In 30 years I have never had a conflict with manned aviation, I have never damaged anyone’s property (other than my own) and I have never been accused of an invasion of privacy. I have registered with the FAA‘s remote pilot program and have included my registration number on all of my aircraft. This NPRM would eliminate the sale and use of UAS without Remote ID capability, within 3 years of its implementation. Then only UAS that could be sold and/ or flown would be from FAA-vetted manufacturers. Effectively, this NPRM prohibits me from flying aircraft of my own design and production. As for multirotors most of mine have been kits with electronics sourced from the internet and following build guides from people such as Bruce Simpson and Joshua Bardwell to name a few. All of my multirotors are capable of capturing and transmitting video, however I do not do much FPV (First Person View) as part of the hobby and when I do it is with a spotter and NOT beyond the visual range of said spotter. Where FPV has been of use for me relates to my job. As I mentioned I am a firefighter paramedic for a small rural community in northeast Arizona. My department has 10 full time employees and a very small budget. We cover over 400 square miles of the Arizona White Mountains 24 hours a day 7 days a week. We assist in search and rescue, rope rescue, confined space rescue and Wild Land fire suppression. Most of which happen in areas that do not have cellphone or internet coverage. Rendering a live internet connection impossible if we would like to use an UAS in the future. As an example. In December of last year (2019) there was a local tragedy in which a family vehicle was caught in flood waters that left 2 children dead and a 3rd (6 year old) missing. The lasted for 2 weeks in some of the roughest country Arizona has to offer. A large part of that search was done with drones that were provided by volunteers (Recreational pilots) who could not have flown if their flight controller had required an internet connection prior to and during operation. FRIA The FAA makes a small concession to self-built aircraft by allowing them to be flown in FRIA areas, But many individuals do not live within reasonable distance of a FRIA (my closest AMA field is 67 miles one way and there are no local CBOs) and many flight fields that would become FRIA do not allow all types of vehicles to be flown, require a fee and or membership dues. The FRIA provision is inadequate. But even if it were adequate, it would not be a permanent solution since it is designed to expire. FRIA may only be approved for 12 months, and then never again. No provision is given for an existing FRIA site to be relocated after the end of the initial 12 month qualifying period, if a FRIA site is shut down for any reason (development, sold, loss of access) it is lost forever with no allowance to replace or relocate it. Flying a model aircraft is only part of the model aviation hobby. Model aviation involves aeronautics, electronics, mechanics, computing, programming, and other disciplines. The value of model aviation is not just that it allows people to fly radio-controlled aircraft. Model aviation’s value is also that it teaches people to design and build aircraft, To meet new people, to build lasting memories with family and friends. This NPRM takes all of this away, designing, building, troubleshooting, improving, learning all gone just like that. The value that will be lost if the NPRM is implemented as currently written is immense. Many hobbyists will no longer be able to legally fly aircraft that they have invested time and money in. STEM programs that use the thrill of flight as an incentive to teach core technology skills to children will be stifled. Law enforcement and other government organizations that rely on highly-skilled hobbyists to stay on the cutting edge of drone development will lose that resource. American RC companies will be at a significant disadvantage to foreign companies that are able to ship parts to consumers in the U.S. without restriction. Personally, this NPRM threatens a hobby that has been enjoyed for well over 80 years with an impeccable safety record. I am lucky I have enjoyed this hobby for 33 years, I have made friends that I never would have met otherwise. Most important are the indelible memories of me and my dad (who has since passed away) as he passed the hobby on to me and then me and my sons as I passed it on to them. Even if the NPRM achieved its goals, the price it demands would be excessive. But the NPRM will not achieve its goal of a completely Remote ID compliant National Airspace. The hobbyist who has the skills, knowledge, and desire to build a remote aircraft now, has the skills, knowledge, and desire to build non-compliant aircraft when this passes and for the most part will not be stopped. The foreign companies who manufacture parts to build these aircraft will not be stopped. Hobbyists by and large want to fly safely and comply with the law. But given the choice between quitting the hobby entirely and breaking the law, many of them will choose to roll the dice and risk getting caught. Because the NPRM is so restrictive, I fear it will encourage a culture of non-compliance and resentment against the FAA. There are solutions that achieve the FAA’s goal of a safe and productive National Airspace, without alienating RC flight enthusiasts. For example, the FAA’s own Drone Advisory Committee proposed a LAANC-like system where permission to fly could be obtained via a smartphone app, for any location, without any particular equipment being installed on the aircraft. Other countries have introduced the concept of “shielded operations,” where no permission is needed to fly within certain distance of obstructions that would prevent Manned air traffic. I feel there is a place for R ID when you enter the realm of BVR beyond visual range flight. I think this would be a viable option for businesses who would like to operate a UAS over long distances. The single most important thing that I would ask the FAA to consider would be a method that allows amateur-built aircraft to fly legally in any area where it is safe to do so (not just at FRIA fields or other pre-approved locations). Last of all please consider the cost. Whatever you pass we need to have the ability to implement for each of our UASs. Currently I have 37 but that number grows and shrinks almost on a weekly basis. Again thank you for your time and consideration.”