[MT-ALES] FAA NPRM

[CURTIS SUTER]

Good morning.
If you haven't heard there is a 60 day Notice of Proposed Rule Making comment period from the FAA that if this is approved as written will seriously change model aviation.  Commenting is easy, either use what the AMA has provided as a template, what I wrote or write your own.  If you haven't commented please do so as soon as possible.  Any questions please don't hesitate to ask or call.
Curtis


Copy and paste this comment on the federal website here<https://www.federalregister.gov/documents/2019/12/31/2019-28100/remote-identification-of-unmanned-aircraft-systems#open-comment>.



Template Comment on UAS Remote ID

Template Comment on UAS Remote ID

I am writing in response to the FAA's notice of proposed rulemaking on remote identification of unmanned aircraft systems (UAS). I am deeply concerned that some elements of the proposal could impose significant costs on the model aviation community and unnecessarily restrict existing, safe model aircraft operations.

First, while I am glad the proposal includes an option to comply with remote ID by flying at an approved fixed site, I am concerned that the rule arbitrarily limits the number of approved sites and prohibits the establishment of new sites. As such, the rule appears designed to phase out these sites over time, rather than treat them as a viable long-term option for complying with remote ID. I encourage the FAA to view fixed flying sites as part of a viable long-term solution to remote ID, and to amend the rule to allow for the establishment of new sites in the future.

Second, the FAA must create a pathway for remote ID compliance at AMA events and competitions, which may not take place at fixed flying sites. These events take place in defined locations for a short period of time, like an air show. For remote ID compliance purposes, they should be treated like fixed flying sites. I encourage the FAA to create a light process for event organizers to apply for, and receive, waivers from remote ID requirements for these ad hoc events and competitions, many of which support local charities.

Third, the rule must consider hobbyists who fly in rural areas with little or no internet connectivity. As I read the proposed rule, I would be required to have an internet connection even if flying at an approved fixed flying site in a rural part of the country. Unfortunately, some rural areas don't have adequate cell service, which means I could not be able to fly. Rural locations are frequently the safest places to fly because they are away from people, other aircraft and structures. The FAA needs to provide a solution for these areas, such as the ability to comply from home or other WIFI-enabled locations.

Finally, the FAA should reconsider the proposal to register each aircraft, which will impose a cost and compliance burden on the model aviation community. While individual registration may make sense for beyond line of sight operations, it is an unnecessary requirement for aircraft designed to be flown within line of sight.  We build and fly model airplanes because it is a passion; and many of us own dozens, if not hundreds, of aircraft of different shapes and sizes, some of which we fly infrequently. The time and cost involved in registering each model individually would be substantial and runs counter to the current registration framework for recreational operators. Also, aircraft that are built by hand do not have serial numbers, which makes individual registration more difficult.

Again, I urge you to carefully consider and address my concerns about the remote ID proposal. Model aviation is the natural precursor to careers in aviation, including commercial pilots and engineers and more - jobs which the U.S. desperately needs to fill. Model aviation supports a $1 billion hobby industry responsible for thousands of existing U.S. jobs. We simply cannot afford to further harm the model aviation hobby with overly burdensome requirements.



What I sent:

I am deeply concerned that some elements of this proposal could impose significant costs on the model aviation community and unnecessarily restrict existing, safe model aircraft operations and I would be forced to close my small business.

I realize that the ability to fly a so called Drone/Quad Copter etc... requires very little to no training compared to the Legacy Radio Controlled planes and helicopters that require extensive training.  This training instills safety for themselves, their models and the person and property on the ground and in the air avoiding full scale operations.  The Remote ID appears to be a good solution for the Drone operators but not for the Legacy models as written in the NPRM.  Internet connectivity from a mountain site flying a Slope Soaring glider would not be possible under the proposal.  Nor would it in the large areas of many rural areas of our country.

I am concerned that the rule arbitrarily limits the number of approved fixed sites and prohibits the establishment of new sites.  In time this will end model flying as fields are lost due to landowner changes or urban sprawl thus obtaining new flying sites and the die. Model Aviation is a huge stepping stone to full scale aviators.

LAANC is a great system of obtaining/restricting flying near Towered airports.  However, outside of Towered airports flying of all sUAS should be allowed without Remote ID outside of Class B, C and D or E airspace to the surface. Thus operations of sUAS in Class E that is not to the surface and Class G airspace should be allowed to operate using CFR FAR 91.113 (b) Right-of-way rules: Using See and Avoid tactics. The use of this airspace for Legacy modelers have an 80+ years safety record that is unmatched by any moving vehicle in the air or on the surface.
Curtis Suter
ATP and 40+ years of Model Aviation




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