, Poulsbo

, Washington

, United States

Posted on
2020-02-22 14:19:40
“I am a retired USAF Lt Col, and a qualified flight test engineer, with 45 years of experience as an aeronautical engineer. I grew up riding in the back seat of my father’s Cessna 195. I have passed the written test for the Private Pilot’s License, so I am familiar with FAA regulations and safe operations in uncontrolled airspace. Now that I’m retired, I’ve once again taken up building and flying model aircraft. Remote ID of everything in the sky is not the way to avoid collisions and assure safety. The fundamental rule for low altitude operations under VFR conditions in uncontrolled airspace is, “see and avoid.” There is no technical reason why commercial drones cannot or should not also adopt see and avoid as their primary means of collision avoidance. Model aircraft, full-scale aircraft, and commercial drones are not the only things in the air. Commercial drones need to avoid birds and unmapped obstacles in order to operate safely, and this requires they be capable of seeing where they are flying so the can take the appropriate action. I believe that restricting model aviation to operating within line of sight is reasonable, and unmanned aircraft operating beyond line of sight should provide some form of remote identification. However 400 ft is not a reasonable restriction in either range or altitude for line of sight operations. The FAA already has regulations in place for flying when the pilot cannot see conflicting traffic. They are called instrument flight regulations. If a commercial drone does not have the ability to see and avoid conflicting traffic, they should file an IFR clearance, just like every other user of the airspace. LIne of sight operations are not the principal terrorist threat – that is associated with beyond line of sight operation that can turn a model airplane into a cruise missile. Restricting line of sight operation on the basis of avoiding terrorist attacks will be counter-productive with regard to public safety because it will only encourage people to operate their models illegally. A reasonable policy will encourage compliance and make it easier to spot an anomalous operation that may be a threat. The FAA’s draconian policy on not accepting any flying site applications after one year makes no sense. Our club lost its flying site two years ago, and is operating from a temporary site now. Under the FAA policy, if we were to lose this site in another two years, the club would have to shut down completely. There needs to be an ongoing process for registering flying sites on both a permanent and temporary basis. There are good reasons why the FAA appropriations act has traditionally excluded model aviation from FAA control. This policy has been successful for decades, and should be reinstated.”