Larry

Delceg

, Phoenix

, Arizona

, United States

Posted on
2020-02-17 6:58:01
“When I was about 12 years old, my father taught me how to custom build model airplanes. He planted a seed that grew into a lifelong fascination with aviation. When my son was in his teens, I taught those skills to him as well. And today, he hopes to someday fly models with his young daughter. If the FAA’s proposed NPRM becomes law, the days of our family building small models together and flying, will be over. I have over $10,000.00 invested in home-built quad-copters and model airplanes, all weighing less than two pounds. Almost all of my flying is below treetop level. I have worked in professional videography, and have been preparing to take my FAA part 107 course, so that I can transition to specializing in aerial video work. When I fly, I use the LAANC system, and prioritize safety. Everyone in my community of model pilots flies responsibly. All of us avoid flying anywhere that people are around. This hobby is my passion. It means the world to me. If the NPRM is put into law, it will be devastating. I’ve invested so much money – and years of my time will be lost. And the NPRM does not permit retrofitting my equipment – my substantial investment will have to be thrown into the trash. If the NPRM is instituted, I will abandon my plans to transition to a career in aerial videography. Being limited to flying in a FRIA will prevent me from shooting on location. I will be unable to use my own custom built quad-copters. The burdens and obstacles to overcome in the complex details of the NPRM will be too great. And the types of ‘drones’ needed for my specific videography needs will not be available. I am also very concerned about the number of real people who will lose their jobs. I suspect that the FAA does not realize the number of people employed in the radio-controlled model industry. Every mid-sized town in America has at least one hobby store that specializes in radio-controlled models. Hundreds of these small businesses will go out of business. These are real people with families. Most of the American manufacturers who design parts for these models will go out of business, and their employees will also lose the jobs they love. In addition, thousands of real estate photographers, roof inspectors, videographers, etc. will also lose their livelihood. Small, recreational, remote control models have been flown for over 70 years, and there’s never been a serious injury or death. The news media (and perhaps the FAA) lacks a sense of proportion regarding “drones”. Many of the potentially dangerous incidents have involved large commercial drones, not our lightweight little models. Concerning my ‘under two-pound models’, it seems that the NPRM regulations are designed to solve a problem that doesn’t exist. And if implemented, will have a disastrous impact many people’s lives, including my own. The problems addressed in the NPRM could easily be resolved by instead implementing a retrofit radio beacon remote ID system on UAS weighing over 1000 grams (2.2 lbs). And then allowing custom built models under 1000 grams to be remote ID exempt if the LAANC system is used. This is an approach that will be simple, cost effective to implement, and will be embraced by the UAS community. I pray that the FAA has an open mind, and will be willing to change course and apply a common sense solution. Because family’s matter, their jobs matter, and people matter. Thank you for considering my thoughts, Larry Delceg”
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