, United Kingdom

Posted on
2020-02-25 9:25:59
“I fly very small micro class multi-rotors, almost exclusively in FPV. Here in the UK we have a registration system the requires an identifiable serial number be present on UAVs over 250g and I believe this is reasonable due to the potential for property damage that such craft can entail. Such a system is non-intrusive, but allows for the identification and recovery of larger craft, whilst keeping the much safer smaller classes of craft exempt due to the greatly reduced safety concerns and implications of such craft. It also incentivises pilots to build and fly these safer, smaller craft, by exempting them from registration, meaning that hobbyists like myself are, in my experience, moving away from larger, more noisy and more potentially obnoxious or dangerous craft, and towards smaller, safer, less intrusive craft that can be flown in public spaces like parks as a recreational activity without alarming or causing harm to the general public. The proposed FAA requirements would have far reaching consequences that would severely damage the hobby of FPV flight, and would disproportionately affect responsible pilots over those who disregard the public for the following reasons: Those who wish to carry out illicit or otherwise dangerous activities would not abide by any regulations put in place, regardless of their stringency. I do not believe that this point can be stressed enough. The equipment required to meet the proposed FAA requirements would add weight, increasing craft size and therefore reducing safety. The proposed equipment would almost certainly completely eliminate the smallest and therefore safest class of aircraft which simply would not be able to carry the additional weight, further pushing pilots towards larger, more dangerous craft With the above experience and facts in mind, I might propose some ideas for how to more fairly and safely regulate model aircraft: Move towards a more similar system to the UK, mandating serial numbers for crafts over 250g. This would be a much less intrusive and much less expensive method of registering model aircraft, both for the end user and for the US government! Smaller craft do not reasonably require registration (many cheap and safe toy products would become illegal under the proposed FAA regulations, hindering the freedom of the mass market) and those who have legitimate reasons to fly larger craft would find such a registration system more than reasonable. Require pilots to alert local ATC of their intended flying location. This is a no-brainer. Smartphone apps for exactly this purpose already exist, and hugely improve the safety of the airspace that a pilot intends to use in a manner that is largely non-intrusive to commercial aircraft at no additional cost to the US government, hooking into existing ATC systems for alerting authorities to the location of aircraft. For example, commercial delivery drones could be made aware of such reserved airspace and could therefor easily avoid collision. It would also provide a convenient method to inform pilots of restricted airspace in their area, as a graphical representation of this can easily be overlaid onto a map. It also means that those who disregard such requirements are easy to identify, much as their full-scale counterparts are. Additionally, this would make it easier for legitimate pilots to identify themselves to law enforcement and assure such authorities that they are taking the proper precautions should a member of the public become concerned. I would like to finish my submission with a simple statement: what the US does, the world follows. Please take the concerns of hobbyist pilots seriously. This is a growth industry creating jobs around the world, and introducing many to concepts of aviation, electronics, and engineering. It would be ill-advised to prevent such minds from pursuing their passions in a way that contributes to the economy and grows the skill base of your nation’s STEM fields.”
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