, Oro Valley

, Arizona

, United States

Posted on
2020-02-14 19:13:33
“Hello, my name is Lee Souter. I am a RC model enthusiast and have been a member of the AMA for the last 10 years. I am also a member of Sonoran Desert Flyers which is an AMA club here in Oro Valley, AZ. I fly line of sight as well as FPV with airplanes as well as multirotors. I am also a professional pilot holding a CFII in airplanes and rotorcraft as well as a remote pilot certificate. Our club has been actively engaged in Aviation/STEM education through teaching local children how to build and fly RC aircraft. We have worked with local schools with their STEM programs as well as the local Boy Scout troops with build and fly programs. Through these programs we have assisted the schools and Scouts in propelling numerous students into STEM careers. The FAA NPRM on Remote Identification of UAS as written will substantially affect those programs as well as my continued ability to participate in the RC model hobby. I currently fly at the club airfield which is located within one of the town parks. We have been operating here without incident for the last 10+ years, but as houses move closer to our site and the park continues to build out, we could lose this location at any time. The NPRM as written would grandfather our flying as a FAA-Recognized Identification Area (FRIA) at this time however if we should lose this site it does not provide the ability to create a new FRIA for us. The models that we typically build and fly for most of our educational programs are built from inexpensive foam board and then fitted with an electric motor, electronic speed control, servos and an RC receiver. These usually consist of 1-3 sheets of Dollar Tree foam board ($1-3) and about $50 of electronics (which are usually harvested from the previous project). The models that I typically build and fly are also built of foam board or EPP foam and are either built from scratch or as an almost ready to fly kit. These range in cost from $50 to about $200. The NPRM as currently written would basically outlaw these aircraft altogether. The means of remote identification listed in the NPRM would undoubtedly cost several orders of magnitude more that the cost of the aircraft it’s going into. Not to mention that as written each aircraft would require its own remote ID unit adding to the cost. If the unit could be something similar to the size and cost ($20-40) of the FPV video transmitters that we currently use that could be moved from one aircraft to another that could be a viable solution. Or an inexpensive wifi module that would broadcast a pilot ID number that could also be moved from one aircraft to another. We are just one of several thousand clubs serving tens of thousands of model aircraft hobbyists across the country. Model aviation has a stellar safety record that you will find far exceeds the safety record of general aviation. The NPRM as written will severely damage or outright shut down many model aviation based STEM programs across the country. As an example please look at St. Vrain Valley Schools Inovation Centers Aeronautics Program http://innovation.svvsd.org/Aeronautics and https://www.youtube.com/channel/UCB7Shy34z9h-10OWxK9vh2w/about. The current NPRM would destroy this premier program. I have attached some photos of my current aircraft as well as some of our STEM outreach programs. And I hope that you will reconsider you current plans for this NPRM.”