FAA’s proposed remote ID rules
My submitted comments on the Federal Aviation Administrations (FAA) Notice of Proposed Rulemaking on Remote Identification (ID)
Docket No.: FAA-2019-1100
Notice No. 20-01
? Remote Identification of Unmanned Aircraft Systems
To Whom It May Concern At The FAA,
As a drone pilot and aviation hobbyist of over 20 years, I understand the need to put into effect guidance and regulations to enhance the safety and security of our national airspace. I also understand and respect the tremendous amount of work and complexities involved with such an endeavor.
In your review of the public’s comments and during your finalization of proposed laws to come, I ask that your discussions on how to implement regulations are not solely focused on the egregious acts of a minority group of operators and that you take into consideration the impact your decisions will have on the next generation of aspiring aviation and engineering enthusiasts. Many of the people that will be impacted by these rules are currently responsible and safe operators, of whom, will eventually comprise the future workforce for America in the Unmanned Aviation Industry.
[CBOs] have a history steeped in airspace safety that involves successfully sharing airspace with manned aircraft…
By deterring the younger generations of today with overly burdensome and complex regulation we risk jeopardizing their future curiosity and interests in a lucrative, expanding, and highly competitive global industry. Additionally, this decreased interest (due to restrictive regulations) may hamper the growth in the labor force needed to successfully compete within expanding global markets. Many of the proposed regulations for Remote ID set up a cumbersome process that will impose unnecessary cost and inconvenience on tens of thousands of hobbyists (i.e., future UAS engineers, pilots, and workers), and demand more time and money from volunteers in all state and local organizations. Most of these organizations have a history steeped in airspace safety that involves successfully sharing airspace with manned aircraft. Additionally, for decades, many of these organizations have demonstrated numerous times their ability to work closely, safely, and consistently with either local Air Traffic Control or their local Flight Standards District Office.
I ask that the FAA consider my recommendation below on behalf of the hobbyist and drone community. Thank you.
CFR Section 89.510
Design and production requirements
“The FAA requests comments about whether persons should be allowed to produce kits for sale that contain 100 percent of the parts and the instructions for assembly necessary to build a fully functioning UAS without remote identification capability.”
As a model hobbyist for over 20 years, I feel strongly that persons should indeed be allowed to produce kits that contain 100 percent of parts and the instructions for assembly necessary to build a fully functional UAS without remote Identification capability. It is through the innovation and experimentation of technologies and the ability to “do-it-yourself” that pumps the heart of the hobby industry.
It is incumbent upon the manufacturer or seller to clearly inform the consumer that any kit that does not meet the proposed regulations.
It is at these early stages and usually done under cost restrictions where innovation and interest in STEM and aviation careers begin. Most of these kits would only be flown line-of-sight and most at community flying fields that have operated safely in the national airspace for decades. This rule would essentially kill not just the hobby industry but significantly impact future growth in the UAS and aviation industry in America by placing high costs on the consumer to purchase any equipment that would spur their desire to develop a career in these industries.
It is incumbent upon the manufacturer or seller to clearly inform the consumer that any kit that does not meet the proposed regulations be labeled as such. Additionally, as technology advances we will eventually be able to produce the equipment necessary for consumers to affordably attain the physical hardware to install in any aircraft of their choice that would allow them to comply with Remote identification; in whatever manifestation it takes.
CFR Section 89.201 – 89.230
FAA-Recognized Identification Areas (FRIA)
I appreciate the approach to designating an area to enjoy non-remote ID model aviation while the rules go into effect; for a time. What I’m concerned with is the unknown processes by which the FAA will either approve or deny an existing flying location to be designated as a FAA-Recognized Identification Areas (FRIA). You admit you are going to release another proposed approach on how these location will be designated before the rules go into effect however, my concerns are the risks of several locations, where modeling has gone on for years if not decades, may not be approved. This unknown policy approach could be significantly damaging the hobby industry by shunning flying fields with a historical record of safe operations.
Model aviation, specifically drones, have spurred STEM interest tremendously over the past 10 years and supports hundreds of millions of dollars in business revenues.
For decades hobbyist flying locations have shown safe operations, community friendly outreach, and are a place where people gather to share in and explore aviation in a multitude of ways. Many aviation hobbyists are also full scale pilots. Governed under a set of standard safety codes and conduct community based flying fields can manage pilots, thrive in numbers, and steward multitudes of current hobbyist and future generations into a career in aviation. Model aviation, specifically drones, have spurred STEM interest tremendously over the past 10 years and supports hundreds of millions of dollars in business revenues. There needs to bee more relaxed rules for the approval of FRIAs designations so they become a location where pilots wish to fly.
The FAA should not require volunteer staff of established model airfields to spend many more hours managing a complex application or waiver process to gain permission from the FAA to continue doing what they’ve been doing safely for years.
Allow for accepting applications from community based locations to establish FAA-recognized identification areas (FRIAs) on an ongoing basis and eliminate the 12-month restriction on new applications. Additionally, allow for re-application, renewal, or relocation of FAA-recognized identification areas at any time, regardless of how much time has passed since expiration.
At no time when the UAS is powered on should there be a need to be connected to the internet. Rather it should only activate when the pilot takes flight.
Minimum performance requirements for standard remote identification UAS
- 2. Automatic Remote ID USS Connection;
- C. Data Privacy and Information Security
- XIV. Remote Identification UAS Service Supplier.
“The FAA welcomes comments on whether the connection should be required from takeoff to landing or whether it should be required from start up to shut down.”
At no time when the UAS is powered on should there be a need to be connected to the internet. Rather it should only activate when the pilot takes flight. Hobby pilots spend hundreds of hours preparing their equipment over, in some cases, years. During this time it is required that they power-up their aircraft for testing purposes. A majority of these power-up instances occur with no intention of flight and happen at the pilots personal residence.
The UAS should connect to a USS Connection only when the vehicle is in motion from takeoff to landing (i.e., in flight). Regarding privacy concerns and pilot safety the ground station GPS location should not be made available to the general public, instead only to authorized law enforcement agencies responsible for the public’s safety.