[AlaskaRC] Your comments on FAA Rules Needed Now!

mjhall at alaskarcs.com mjhall at alaskarcs.com
Mon Mar 2 12:37:56 AKST 2020

I know a number of Federallies (FAA Safety Inspectors) and I can just
imagine some of the conversations going on in the Fed Shed.. I'll bet they
are SO just looking forward to all this...


From: Patrick Martin <n411x at hotmail.com> 
Sent: Monday, March 2, 2020 7:36 AM
To: mjhall at alaskarcs.com; ARCS mailing list <alaskarc at lists.alaskarc.org>
Subject: Re: [AlaskaRC] Your comments on FAA Rules Needed Now!


Very good letters thank for the heads up, I am not a very good at this but I
did send this.


I am a Commercial Pilot Certified Flight Instructor Instrument Airplane and
have been flying since 1970. I started as a young boy with Radio Control
airplanes. I have been flying Radio Control model airplanes with air space
safety in mind line of sight operation. Traditional Model aircraft operation
should not be a part of this rule, I am opposed to the proposed rules. We as
Model airplane pilots spend many hours building our aircraft adding some
Electronic device to our Aircraft my make them unsafe with added radio

50 years of flying in Alaska 

Patrick Martin  



From: AlaskaRC <alaskarc-bounces at lists.alaskarc.org
<mailto:alaskarc-bounces at lists.alaskarc.org> > on behalf of mjhall--- via
AlaskaRC <alaskarc at lists.alaskarc.org <mailto:alaskarc at lists.alaskarc.org> >
Sent: Sunday, March 1, 2020 9:48 PM
To: drfranklin at gci.net <mailto:drfranklin at gci.net>  <drfranklin at gci.net
<mailto:drfranklin at gci.net> >; 'ARCS mailing list'
<alaskarc at lists.alaskarc.org <mailto:alaskarc at lists.alaskarc.org> >
Subject: Re: [AlaskaRC] Your comments on FAA Rules Needed Now! 


Here was my response. 



In response to the FAA's Proposal for Remote Identification of UAS dated

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
<mailto: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
<mailto: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




Doug Franklin




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