, Scranton

, Pennsylvania

, United States

Posted on
2020-02-18 23:32:37
“My name is Mark Spatz, P.E.. I’m a licensed Engineer in the great Commonwealth of Pennsylvania and I take issue to the NPRM as it stands. It will kill off the RC model enthusiast hobby through being too restrictive and costly to keep in compliance. Additionally, it restricts amateur-built models to FRIA sites ONLY and proposes to eliminate FRIA sites over time (no new after 12-months). America is the “land of the free” and regulating air space use from 0-ft to 400-ft over my property is NOT the face of freedom. I’m 40-yrs old, but started in model aviation when I was 15-yrs old with my first balsa plane. I also took flight lessons at that time and logged 9-hrs of solo time before realizing I could not afford to continue and go to college for engineering. I publish content on the great hobby of model aviation, specifically racing drone focused, on my YouTube channel: (UAV Tech). I took an absence from the hobby from 18 to 35-yrs old (college, career, marriage, kids). Then I rediscovered the hobby in 2015. Becoming aware of the technological advancements I was excited at the possibility to be able to reacquire the sensation of flight without the tremendous cost of trying to get my pilots license again and all the RISK associated with acquiring and keeping an active license. YES, RISK! There are hundreds of deaths annually attributed to General Aviation (GA). There are ZERO deaths – EVER – (worldwide) attributed to model aviation. I do not believe a risk assessment for model aviation or drone activity was ever completed and published? Therefore, it is apparent the NPRM is NOT drafted in the guise of providing safer airspace. Since GA (licensed pilots) and paraglider (non-licensed) accidents are well known with zero increase in regulation the safety concern is not a valid argument for justification on the overreach contained within the NPRM. I understand the desire to make off-the-shelf store-bought camera drones “safer” (more nuisance control) for general consumer use, BUT IT IS IMPORTANTto distinguishbetween requirements of a commercial consumers store bought (BestBuy) camera platform drone vs. a professional hobby enthusiast amateur-built craft. A hobby-grade amateur-built craft takes skills to build and fly (like GA). Again, I do think the NPRM has valid requirements for tracking of something like a consumer-grade DJI drone, or future possible (although highly implausible) Amazon delivery drone when it comes to BVLOS flying, but NOT for a model enthusiast’s amateur-built craft and the NPRM does NOT allow for acceptable provisions for model aviation amateur-built crafts that are typically flown below the tree line and have a 70+ year track record of safety. ### Model aviation has a ceiling of 400-ft and GA has a floor of 500-ft. So law-abiding citizens in model and GA shall have a 100-ft clearance. Of course, non-law abiding citizens (for GA and model aviation) don’t follow laws so making the NPRM irrelevant in that regard. Finally, if clearing the air space from 0 to 400-ft is for business (political) speculation to allow for a future use of delivery drone traffic, I HIGHLY advise the FAA to look into how high implausible that concept is (noise, public rejection, weather, flight times, natural and manmade obstructions, etc…) and also consider paragliders and kites. The experts in the hobby find the concept of delivery drones a speculative bubble that will burst (a laughable topic). So if lobbying pressures are at the table, please don’t kill the long-standing (70+ years), SAFE, model aviation enthusiast hobby over something that won’t happen.”