[AlaskaRC] Your comments on FAA Rules Needed Now!

drfranklin at gci.net drfranklin at gci.net
Sun Mar 1 20:46:21 AKST 2020


Folks,

 

Please take the time to visit https://www.regulations.gov/document?D=FAA-2019-1100-0001 and comment on the proposed FAA rules affecting unmanned aviation. If adopted, these rules will have a hugely negative impact on our hobby of model aviation. My take is that the rules are designed with commercial drone operations in mind, and show zero regard for our hobby, other than eliminating it as soon as possible. I understand these are harsh words, but it is my honest opinion having read the rules that that is the intent. 

 

I am including my comment below the fold, in the event you may find it useful in articulating your own response to this proposal. 


Best regards,

 

Doug Franklin

 

 

I have been flying model airplanes for more than half a century, starting with free flight as a kid, and ending up with conventional "line of sight" radio control for the last quarter century. In that span of time I have never contributed to, observed, or even had anecdotal knowledge of model aviation operations that adversely affected manned aviation. 

 

My sense of the proposed rules is that they conflate traditional model aviation with the new generation of drone flight, and treat them as the same thing. This is a grave disservice to model aviation. My thinking is that the public would be much better served if a distinction were made between traditional model aviation, whose hallmark is the lack of autonomous operation, and drone aviation, whose main hallmark is autonomous operation. This is a simple distinction that could be used to differentiate between a hobby that has existed with a superlative safety record for 84 years, and an emerging technology with commercial and military applications.

 

Therefore I am very much opposed to the proposed rules. They advance a false equality between very different activities, and then seek to drastically curb if not outright eliminate over time the hobby of model aviation, apparently in favor of commercial drone operations, which are likely the only instance that can afford the requisite technology, and the only instance for which it is reasonably required. 

 

Please reconsider this ill-advised and over-simplified approach to regulating unmanned aircraft. Traditional hobby model aviation has very little in common with commercial drone operations, and should be handled differently.

 

Respectfully,

 

Doug Franklin

 

 

 

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