Lee

Paddock

, Washington

, United States

Posted on
2020-02-15 16:41:59
“Here is my story & in work response to the FAA. I am a line of sight & first person view UAV recreational pilot/hobbyist & have been for the past four decades. I am a member of both the AMA & FPVFC. I am also a recreational UAV flight instructor pilot at my local AMA field. My passion for aviation turned into my profession as my career is in Aerospace & my hobby is as a recreational UAV pilot. I fly 2 to 3 times a week at AMA Sanctioned fields, Public Parks, Private Property & Indoors. I own both line of sight & first person view aircraft UAV’s, in total I own & operate 15 aircraft (Airplanes, Flying Wings & Quad-Copter) ranging from 250g to 5kg. With my biggest 3D Aerobatic model which I fly Line of sight up to 1000 meters horizontal distance weather permitting. aircraft UAV. I assembly my UAV aircraft from Almost Ready to Fly kits or from scratch purchasing MFG’d & fabricating individual components, programming, testing & tuning. I fly in harmony & always make way / right away for manned aircraft. I have done so for four decades without incident & a perfect safety record. I represent the majority of UAS pilots the recreational hobbyist whom have an impeccable safety record far better than all manned aircraft. Per the FAA there are 1.5 million UAS & 250k Manned Aircraft in the United States. No recreational UAS has ever contributed to the crash, personal harm or fatality regarding manned aircraft. However per the FAA & NTSB records there are approximate on average 200 manned aircraft fatalities per year due to manned aircraft incidents. Also according to the NTSB, there are approximate 10,000 bird strikes on manned aircraft yearly. There have only been 14 UAS / manned aircraft related incidents from 2013 to 2018 that is approx only 3 per year on avg. Anyway you look at it recreational UAVs have a better (fatality / property damage/ incident) safety record than manned aircraft. If this FAA remote ID regulation goes into effect recreational UAVs will be more heavily regulated than a manned Paraglider, Hang glider or Ultralight all of which have an even poorer statistical safety record. All this said it’s it appears the FAA is promoting a new regulation based on fear & not fact or perhaps it’s corporate greed lobbying over public rights & freedoms. Remote ID is needed & important regarding the future growth of commercial UAV/S & safe use of the public airspace by companies such as Amazon, Google, UPS, FedEx etc for autonomous deliveries. It is also important to increase recreational UAS new pilot knowledge & I agree with a knowledge test as well as further promotion of the B4UFly app. An app like B4Ufly helps hobbyist flying from any location to check the airspace, validate if any airports are nearby & any if no fly zones exists or FAA NOTAMS/TFR’s are in place. Appearing to be strongly influenced by commercial drone lobbyist, the FAA proposed rule seems written oblivious to recreational pilot’s the majority of UAV’s or it was deliberately written to obliterate the UAV recreational / hobby. The Commercial Drone Lobbyist appear to be attempting to unlawfully purchase the airspace from 0 to 500ft from the FAA without consulting the true owner of class G the airspace 0-400ft the general public. These proposed FAA rules are disproportionately aggressive /restrictive against recreational UAS pilots & recreational aircraft UAV manufactures. There should be more definition between recreation LOS (Line of Sight) piloted UAV’s & recreational FPV (First Person View) piloted UAV’s. All recreational LOS UAS’s should be exempt from remote ID & recreational FPV UAS’s should require broadcast remote ID transmitting the serial number only or usage of LANCE or B4YFlY app to check the airspace. As the FAA Remote ID NPRM is written it destroy, devastate or discourage the following: Destroy/Hurt Recreational Hobby UAV pilots / 1.5m UAV’s registered / 400K Commercial / Majority 1.1M Recreational discouraging participation & making the hobby to cost prohibitive. Devastate/Harm Hobby negatively impact devastating a $1 Billion hobby industry responsible for thousands of U.S. Jobs. Discourage/Hamper STEM education efforts, further technical advances & cultivation careers in aerospace including an essential conduit for future commercial airline pilots & engineers. The FAA NRPM as written will only create resentment & gross lack of hobbyist compliance, which can’t be enforced by the FAA. The FAA cannot regulate international UAS or component MFG’s. The NPRM will do absolutely nothing to stop individuals with bad/harmful intentions. It will certainly generate numerous public class action suits against the FAA regarding privacy concerns FISA(Foreign Intelligence Security Act & COPPA (Children’s Online Privacy Protection Act) as well as “the taking” of property owners rights to some portion of the airspace above their home to enjoy, to use & to protect, linking to Crosby vs U.S. Based on the Commercial Drone Lobbyist intent, the general public has little idea how the skies in the future will be littered with delivery drones buzzing just feet above their homes & it becomes a federal crime for a kid to even fly a toy foam r/c airplane line of sight in a park. FAA has diverged far from the advice it received from 74 stakeholders as part of ARC panel & DJI recommendations. Peer European Regulatory agency EASA’s 2019 enacted remote ID regulation is far more reasonable & realistic utilizing broadcast ID & exempting recreational UAV’s as long as they fly in un-congested / low population area’s within line of sight. Main Issues with the NPRM: Privacy Violations UASS collection provider Network / Internet ID Cost Connectivity FISA / COPPA Personally Identifiable Information Info should not be available to public only government / law enforcement Broadcast ID should be the standard transmittting serial only Retrofitting Broadcast ID on legacy non-remote ID compliant UAV’s Greater use of LANCE or B4UFLY App Solution -Crosby vs US Property owner doesn’t own airspace to space / Gov doesn’t own Airspace to ground -Armature build should be less than 25% MFG. -400Ft radius rule geo-fencing should not apply -FRIA should not exists / should be able to fly anywhere were it is safe not resricted. -FRIA applications limited to 12 months should be not be limited -MFG Certification is pointless & will grossly increase the cost for only US MFG’s, International MFG’s will not comply”
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