kevin

turner

, maryville

, Tennessee

, United States

Posted on
2020-02-13 22:40:18
“To whom it may concern… these new proposed FAA “drone” regulations have just left me shocked and dismayed on so many levels. firstly i would like to simply state or define who i am. currently i own over 30 rc aircraft that are flown by myself and my children. I am a husband, a father, a son, a physician, an rc fixed wing pilot, an rc fixed wing giant scale pilot, an rc IMAC competition pilot and event organizer and contest director, an rc multirotor pilot, an rc fpv airplane pilot, and an rc fpv multirotor pilot. i enjoy so many aspects of rc from flying foam rc planes and racing quadcopters to flying giant scale rc LOS planes in IMAC competition. i am someone that has enjoyed rc model airplanes and rc multirotors for over 10 years. it is almost impossible to formulate a short concise comment to rebut such a massive document chocked full of overreaching regulations to be imposed on such a large group of people that have a safety record spanning decades . I think the one largest issue to mention is the definition of what a “drone” or “sUAS” actually is . apparently the FAA definition at the moment is any flying thing over 250 grams that can be remotely controlled starting at an altitude of 1 millimeter AGL to infinity. using this definition for the purposes of applying blanket regulations is convenient but unfortunately an error. as you can see, by the descriptors i used above to describe my rc activity, there are so many facets to the world of rc which is one of the reasons i have enjoyed this hobby/activity for so long with my friends and family. It almost feels like trying to comment on these proposed regulations can not even start until the population these regulations apply to is more correctly defined. now i do understand that defining what a “drone ” is , from a regulatory standpoint, can be daunting. i think most people will agree that a traditional line of site remote controlled aircraft is not a drone regardless of whether it is a fixed wing, helicopter or multirotor. in my opinion if the rc aircraft has no fpv capability it should NOT be considered a drone and therefore exempted from all of these burdensome regulations even including any registration requirements especially any remote i.d. requirements. line of site rc aircraft have a safety record spanning decades. excluding these aircraft from regulation , it would seem to me, is common sense. including these types of rc aircraft is completely unfounded and the FAA initially trying to lump these types of rc aircraft into these proposed regulations is ignorant at best and irresponsible blatant punitive regulatory overreach at worst. let these line of site aircraft continue to be flown with no altitude restrictions as they have done safely for decades. if that point can be agreed on then you can look at what types of rc aircraft should have more regulation. what if a modeler attaches a fixed non transmitting camera to his aircraft in order to record a birds eye view of the flight. no live fpv feed in this case and therefore still a non issue in my opinion. i do agree that some regulations are warranted once an aircraft has live fpv capability enabling it to be flown beyond line of site IF the aircraft is actually being flown beyond line of site in controlled airspace at an altitude that is higher than surrounding structures (above surrounding trees or building tops). a large part of the fpv hobby i enjoy involves fpv flying in small areas below the level of surrounding structures. currently, if in controlled airspace the LAANC system seems to work very well for this. i simply use my phone to apply for clearance for the altitude i want to fly and if in controlled airspace i can easily get realtime clearances for appropriate flying. i am unclear on why this current ,functional, easy to comply with, system should be replaced with burdensome remote id requirements that may make my self-built small fpv multirotors non compliant. also i would recommend you educate yourselves on the shielded operations rules used in new zealand for rc aircraft. shielded operations use common sense methods of enabling rc pilots to operate safely in areas without the need for cellular services or wifi capabilities or remote id gadgetry. it seems the more autonomous an rc aircraft becomes then naturally the more regulations that should apply. a small fpv quadcopter used for drone racing or freestyle flying with no gps, no return to home or waypoint mission capability, no sonar/obstacle avoidance system and no autolevel features enabled would seem to be completely different than fully autonomous aircraft that can take off , fly way points and return to home and autoland. regulations scaled based on autonomous capability of the aircraft seems much more appropriate . also i do think looking at exactly what airspace the FAA has jurisdiction over is warranted. Private land owners should not have to deal with FAA regulations if in uncontrolled airspace with no proximity to airports. as currently written in proposed rules a private land owner flying an rc aircraft weighing over 250 grams is subject to FAA rules and remote id requirements even if flying at 1 or 2 inches AGL on his own property! how is this not poorly defined and over regulatory ?! 80 percent of my and my children’s rc flying is in our own back yard below 50 feet AGL. we have done this for 10 years without incident. flying at AMA fields and private property in uncontrolled airspace areas should be of no concern to the FAA when following safety guidelines already in place as clearly defined by organizations such as the AMA. limiting future flying fields/FRIA areas and designing their eventual extinction by not allowing new sites to form over time is convenient from a regulation standpoint but simply the wrong approach. obviously this is a complex topic and yes some regulations need to be in place but , as with most things in life, poorly thought out knee jerk reactions are often damaging to all parties involved. I really think the FAA organization as a whole needs to look at it’s originally intended mission and try to come up with a new set of logical proposed rules and guidelines that apply to an appropriate well defined population that actually needs some risk mitigation and excludes the large groups of non commercial rc enthusiasts that continue to operate safely as they have done so for decades . I think it is definitely possible to keep our navigable airspace safe while also letting us continue to enjoy our hobbies safely and unhindered with our families as we have done for so long . i would be more than happy to provide more input or answer any questions regarding any facet of the rc hobby that the FAA organization does not understand or needs more information about . please feel free to contact me any time. Sincerely, Kevin Turner AMA #937387 #FA33KEF73Y
https://vimeo.com/346642359″
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