What are you doing to fight the FAA's proposed Remote ID?

[Wayne]

I have been asked by a few folks to post up our email so they can link to it and discuss further. Here is the first email, there will be more:

LET ME BE CLEAR:
The FAA's proposed Remote ID will decimate the RC Model Hobby
If you are like me and love flying remotely controlled aircraft, or would like to see the hobby continue to be an affordable and enjoyable, or just want to see its educational value continue for future generations, then you need to take action right now.

The Notice of Proposed Rulemaking (NPRM) not only makes it nearly impossible for some to fly, it will also make it very expensive for those that try. The requirements for the manufacturer's to meet these requirements are so complex that they financially threaten the model aviation industry. The requirements in many ways are beyond what a licensed pilot is required to do to fly a full scale aircraft.

When it comes to flying at approved fields, you basically have one chance to get your field approved, after that no new fields can be approved, but existing fields can be removed. The FAA does not want to get into the workload of approving fields, so they simply will not. Ultimately this looks like a method to end the hobby in its tracks.

I would like to share an article by our good friend Scott Page that he wrote about this threat from the FAA:

The FAA published their plan requiring broadcast from all aircraft weighing over 250 grams (0.55 pounds) on Dec 31. Don't be misled by the term "drone" in the NPRM. The FAA uses the term "drone" to apply to all Unmanned Aircraft Systems(UAS), this includes everything we fly via remote control and may even include free flight and control line.​

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Once one dives into the 319 page NPRM in depth it details how the FAA is proposing to progressively annihilate the hobby. This NPRM proposes to make it illegal for a landowner to fly over their own land in the short term, and eventually eliminate model flying fields. There are many many levels of concern. Grouping Line of Sight (LOS) modeling in with the regulations of Beyond Visual Line Of Sight (BVLOS) operations is a one size fits all solution that is inappropriate. Making it impossible to establish new flying fields, or even move an existing club flying field to a new location is well beyond what Congress mandated in the FAA reauthorization act of 2018.​

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It's seriously imperative that all interested reach out to the FAA and to all elected representatives.​

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This NPRM is ONLY open for public comment until March 2. The AMA, AOPA (Aircraft Owners and Pilots Association), and EAA (Experimental Aircraft Association) as well as others petitioned in vain for an extension to the comment period. In response to the requests the FAA replied on January 28:​

"...the need for remote identification of UAS increasingly has become important as new public safety and national security concerns arise regarding the use of UAS. Accordingly, the FAA has determined that any extension of the comment period, and the subsequent delays in promulgation of a final rule implementing remote identification of UAS, would not be consistent with the safety and security objectives of the proposed rule.​

Therefore, your request to extend the comment period for the Remote Identification of Unmanned Aircraft Systems NPRM is denied. The comment period for the NPRM closes on Monday, March 2, 2020."​

Sorry, this just doesn't compute. When ALL of the MAJOR aviation associations are asking for an extension, why aren't they listening?

Hey, why are all of the major aviation associations siding with the RC Model Hobby?
Because they know the majority of their members started right here in the hobby, and many are still very active. Maybe the FAA just doesn't understand how much education comes from these models. Maybe they don't understand that the majority of pilots and aviation professionals started off flying RC planes? Maybe they don't care about STEM programs and the promise they have for the nation?

We need your help to fight this!
It isn't too late to fight this! We have some strong associations fighting for us but we need you more than anything! The FAA is very focused on National Security, it is not a Line Of Sight (LOS) vs First Person View (FPV) fight, or a hobbyist vs commercial fight like some initially thought. Congress wants the FAA to be able to identify our models to assess risk of an attack.

The EAA (Experimental Aircraft Association) has a great track record of working with the FAA and getting big changes for the betterment of aviation. They know what works and what doesn't work, and they are suggesting:

"When you do comment (on this NPRM), please be respectful and use rational, fact-driven arguments in your own words. Form letters and emotional comments have much less impact on the regulatory process."​

Spend a little time and write your own message it does not need to be a long and wordy novel, do what seems right from your point of view. That is the best thing we can do at this time. And please consider sharing information about this subject with your friends and get them to send in some comments. If the FAA does not hear from us, then they will move forward and bulldoze this wonderful hobby.

RC modelers have been happily sharing the airspace for 70 years now and we have an excellent track record. We should not be turned into outlaws.

Submit your Formal Comment with the FAA: (BEST IMPACT)

Remote Identification of Unmanned Aircraft Systems

This action would require the remote identification of unmanned aircraft systems. The remote identification of unmanned aircraft systems in the airspace of the United States would address safety, national security, and law enforcement concerns regarding the further integration of these aircraft...

www.federalregister.gov

or Visit AMA's Comment Templates page: (OK Option)

Submit a Formal Comment to the FAA's Proposed Remote ID Rule - AMA IN ACTION Advocating for Members

On December 26, the FAA released a proposed rule for remote identification of UAS. There are several areas of concern with the proposed rule that AMA will b ...

amablog.modelaircraft.org

 

[Wayne]

I would like to share what I will be doing in the coming days..

I have reached out to a number of larger businesses that I feel should be active on this front and asked them what they are planning to do after I explain why I think this is a threat to our community. I have been pleasantly surprised to hear back from them all thus far. I suggest you all do the same. If you have not heard from a company or an organization that is in the aviation field or in the hobby, don't be shy, reach out to them.

I will be speaking at our local pilots group. Not only that, but they will be posting up some information on their facebook page, web site and newsletter. This is at my local airport, will be speaking to general aviation pilots.

I have reached out to my EAA chapter and should be doing the same with them. This chapter is very active and they also fly RC from their airport.

We are in touch with as many AMA clubs as we can think of to make sure their membership is alert to this threat.

We are also adding some information to our home page with a link to this thread.

We will be doing some more emails to our customer list. When checking in with some of our walk ins I am finding that most all of them are aware of the NPRM and the need to comment, but they have not actually commented yet. So as much as I hate to bug my customers with the same stuff, I will be doing at least 2 more follow up emails as reminders. I am open to suggestions on how to persuade people to take a few minutes to comment to the FAA. Any ideas?

I have also received some comments that people think the FAA has already made up their mind and nothing we do will help. I do not believe this, and right now this is our only tool, we need as many comments as we can get, and if the FAA should decide to ignore them, then the comments can be used for fuel for the next steps.

We have over 8400 comments as of today, that is an OK start, I think we need to do a lot better! I would like that see that much closer to 100,000. Share your aviation story with the FAA. Do you think your story would exist future under these new rules?

I have been impressed by the number of people that have shared stories of themselves or their children or grandchildren that got their start in aviation careers via the RC model hobby.

Many thanks all!

 

[Wayne]

Got this from the AMA today:

As a united front and voice, the AMA Coalition visited several offices today to convey our concerns regarding the proposed rules on Remote ID.

Our government affairs team reported that our message has been well received. Please keep in mind, that the team has two additional days of meetings which include the House and Senate FAA Oversight Committees. When I receive an update I will certainly pass it along.

The following offices were visited today;

Angie Craig, Representative of Minnesota
Rodney Davis ,Representative of Illinois
Steve Cohen, Representative Tennessee
Kyrsten Sinema, Senator, Arizona
Eleanor Holmes Norton, Representative District of Columbia

 

[Wayne]

Was just having a conversation via email and I wanted to share my thoughts here. He got kind of a canned answer from one of his elected officials he emailed. Looked like it came from the FAA.

I think a decent conversation for the representatives is to share a comparison to something they can hopefully understand a little better.

Vehicles on roads
The roads are facing a new level of automation via driverless cars, yet cars with drivers do not have any new requirements to make room for this new driverless user. Instead driverless cars have to figure out how to work with the existing users.
New technologies and uses are fine in our airspace, but they need to adapt to the current users. Not the other way around. As far as tracking, cars are much more of a weapon than our RC planes, yet they can not be tracked. Why should we need to be tracked? It makes no sense to me.

You better believe that driverless vehicles will be doing a lot more work than drones in the future.

 

[sande005]

Wayne - still prepping my comments (there is SO much wrong with the NPRM!) I got some very old (2012) data from the Hobby Manufacturers Association that gave a rough scope for the economic size of the RC hobby in the US. (~$625,000,000 in retail sales back then). Anything better to use for pointing out the potential scope of damages this rule would have? Est. US sales per year, number of companies, number of employees that could be laid off, etc., etc.??

Excellent point about the driverless cars!

Ted Sander

 

[Wally]

I've made a couple of comments to the FAA, focusing on the loss to the country that will result from added hurdles for young modelers and STEM programs. I'm trying now to look at the issue from the point of view of law enforcement. I know there are legitimate concerns. I used to know a guy who had been approached by someone from a family-owned pipeline monitoring company to develop an autonomous fixed-wing vehicle to do aerial inspections. He was well into developing a large aircraft with a substantial payload bay when the FBI showed up. Turns out that the client, though a member of the family that owned the business, was no longer affiliated with the business, and was instead, looking for a vehicle to move drugs across the border from Canada!

 

[Scott Page]

There is so much in that NPRM I wanted to address -- but ultimately kept to what I believe was the most pressing issue -- specifically that traditional LOS operations are not an appropriate target of the NPRM. Attached is the .pdf that I sent. I'm horribly insecure about my response at this point - don't know if it will make a difference - suspect it won't. I feel like Don Quixote taking aim at the FAA windmill.

 

[Scott Page]

I got in touch with Jim T Gram and Jason Cole of RCG a couple days ago and sort of scolded them for having done nothing in this regard.
Interestingly -- Jim went with a picture of a Quad for the article he wrote - which will automatically filter out many readers. He did use Aloft as a reference and gave Aloft some credit.

FAA RID NPRM - Info, Videos, Discussion and How to Take Action - RC Groups

FAA RID NPRM - Info, Videos, Discussion and How to Take Action Model Aircraft & Drone Advocacy

www.rcgroups.com

 

[Wally]

...I feel like Don Quixote taking aim at the FAA windmill....

I feel the same, Scott, but I just read your PDF, and I think you nailed it. Thanks!

 

[jvaliensi]

Please post your comments that can copied & edited to make it easy to get more comments to the FAA

 

[Scott Page]

Please post your comments that can copied & edited to make it easy to get more comments to the FAA

LOL... my comments are 4 pages long --- and only half of the 5000 character limit. Posting that in the thread would cause Wayne to bonk me over the head. However I posted the word document here if that helps.

 

[Wayne]

Good to see Jim take action over at RCGroups. I really do hope they will do a mass emailing on the subject.

I'll be speaking to a pilots group tomorrow morning at the local airport, and another one on Tuesday. I am looking forward to it, and hope they don't ask anything I can't respond to. I guess I should print out some bullet points and the link to the FAA to comment.

There are a couple of really good postings on Rc Groups I'd like to link to:

RC Groups - View Single Post - FAA RID NPRM - Info, Videos, Discussion and How to Take Action

RC Groups - the most active Radio Control model community: electric and fuel rc airplanes,rc helis,rc boats and rc cars. Features discussion forums, blogs, videos and classifieds.

www.rcgroups.com

RC Groups - View Single Post - New Resource FAAs Proposed Rule Remote Identification of Unmanned Aircraft Systems

RC Groups - the most active Radio Control model community: electric and fuel rc airplanes,rc helis,rc boats and rc cars. Features discussion forums, blogs, videos and classifieds.

www.rcgroups.com

And here is a great warning:

When you comment to the FAA, DO NOT just cut and paste a pre-written comment. When the Part107 NPRM comments were tallied, all of the form letters that were simply cut-n-paste were counted as ONE comment. Write your own comment to the NPRM.​

 

[jvaliensi]

The AMA podcast said cut and paste is counted separately-
I'll cut and paste and edit. I'm an engineer, that's another way of saying I hate to write.

 

[Wayne]

Aloft Hobbies is part of the AMA Coalition and they just sent an email to share:

They got an article on Politico:

Model aircraft lobby launches new umbrella group amid regulatory challenges
By Brianna Gurciullo
02/06/2020 04:47 PM EST
In a bid to up its juice in Washington as lobbying over pending drone rules ramps up, the Academy of Model Aeronautics has formed an umbrella group filled mostlywith businesses that make or sell model aircraft.
The group, made up of more than two dozen organizations and businesses,argues that their industry has taken a hit from a growing number of rules that deter people from buying and flying model aircraft. Tyler Dobbs, the head of government affairs for AMA, said that forming a coalition is a way to boost their heft.
"The majority of model aircraft companies around the U.S. are extremely small businesses, mom-and-pop type companies," Dobbs said in an interview with POLITICO. "So those companies don't have the resources that the larger ones do and they struggle sometimes to even find the time to read the regulations, let alone try to interpret it and determine how they're going to be impacted and what kinds of things they're going to have to implement."
Dobbs argued that the FAA is focused on "newer" platforms and technologies like quadcopters, and needs to "remember that there's a traditional, legacy-style model aircraft community that doesn't necessarily fit in the same bucket as what the quadcopter or the drone community fits in."
The coalition sent a letter Thursday to the leaders of congressional committees with jurisdiction over the FAA, saying that hobby shops have seen their sales decline in recent years as "regulations have steadily increased on model aviation hobbyists."
"It began with the requirement to register all [drones] and it has now evolved into requirements to seek authorization to fly in almost every instance," the group wrote. "In addition, we can no longer fly at night and are restricted to altitudes that are unsafe in many cases."
Model aviation as a hobby has already gotten smaller and "may never return to the size of previous decades,"according to the coalition's letter, which seeks lawmakers' help in ensuring that "regulatory burdens" don't "squeeze the hobby out of existence."
The group is particularly concerned about a remote identification rule for drones that the FAA proposed in late December. Among its concerns: The agency is proposing to give AMA and similar organizations only a year to apply for sites to be designated as "FAA-recognized identification areas," where people could fly drones that lack remote ID equipment.
"The way it stands right now, after the 12-month period, we could never request a new site," Dobbs said. "Just through attrition, the FAA would be removing each one of these sites over time."
The coalition is also concerned about how the proposed rule deals with "amateur-built" unmanned aircraft. Such aircraft wouldn't need to have remote ID technology, but the FAA would only consider an unmanned aircraft to be amateur built if "the person building it fabricates and assembles more than 50 percent" of it. The group believes the threshold should be considerably lower, Dobbs said.
In addition, it is concerned about a proposed requirement that recreational drone owners register their aircraft separately.

 

[Scott Page]

Horizon Hobby posted a brilliant video on this RID NPRM on Friday on both Facebook and Youtube. The Facebook video had over 10,000 views in just a few hours - not sure how many the Youtube had. Then... dark unseen forces compelled Horizon to delete both versions. Fortunately I was able to pull a copy from my phone cache and share it here.

 

[jvaliensi]

My primary comment is:

Traditional RC aircraft should be exempt form these regulations because:

1. The require the pilot to maintain line-of-sight vision to fly the aircraft.

2. Traditional RC aircraft do not have GPS control for flight path.

3. Traditional RC aircraft do not use an on-board camera for flight control by the operator.

4. Traditional RC aircraft have safely been operated for 50+years, with billions of flights and nearly zero deaths or damage to property.



Traditional RC aircraft are truly not unmanned aircraft like quad drones or military drones because the pilot must be able to see them to fly them,



No studies have been conducted to assess the safety record of traditional RC aircraft and these regulations are not justified for RC airplanes. The rules are may be necessary for the drones which are operated by a computer and GPS and have a completely different mission.

The FAA needs to better study this and understand RC aircraft before creating unnecessary and burdensome regulations.

It may not be the most detailed response, but if I can get 999,999 more people to cut and paste to the FAA comments, they'll take notice.

 

[Wally]

I always try to include something about these regulations being a burden to the young model aviators who will someday become our next generation of pilots and engineers.

 

[jvaliensi]

I'm thinking one subject per comment, rather than one very long comment. That's how its done in my business.
my son, wife, father and mother and brother and sister will make the same comments as me.

 

[Wally]

Here's the draft of my most recent comment.

 

[Scott Page]

Here's the draft of my most recent comment.

"FRIAs should be able to be created by flying clubs, school and school districts, parks and recreation districts and even private individuals who are willing to be identified and to participate in the program."

This is a very important point and one not being brought up enough. Additionally - the establishment of FRIAS should be possible in perpetuity, not just in a 12 month window. Great comments.