[AlaskaRC] Your comments on FAA Rules Needed Now!

mjhall at alaskarcs.com mjhall at alaskarcs.com
Sun Mar 1 21:48:15 AKST 2020

Here was my response… 



In response to the FAA’s Proposal for Remote Identification of UAS dated 12/31/2019 

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. 


On a personal basis, I am a long time RC flyer, having started in the 1950’s. I have flown all sorts of RC aircraft, and built many of them from raw material and plans. More than a few the plans were of my own design. And I have flown “manufactured” aircraft. While in the Navy I have flown RC aircraft in other countries. I am an Academy of Model Aviation Leader Member and Contest Director. I have done many things with RC aircraft, but I have never interfered with, nor endangered, man carrying full scale aircraft, and now I find that I will have to have a license to fly, and my hobby is facing a remote identification proposal that is unnecessarily restricting it to the point that could lead to its demise. 


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 could 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 under the limited remote ID option. 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. 


Martin Hall 

AMA 5766


From: AlaskaRC <alaskarc-bounces at lists.alaskarc.org> On Behalf Of Doug Franklin via AlaskaRC
Sent: Sunday, March 1, 2020 8:46 PM
To: 'ARCS mailing list' <alaskarc at lists.alaskarc.org>
Subject: [AlaskaRC] Your comments on FAA Rules Needed Now!




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.




Doug Franklin




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