As the NPRM is written, the FAA should just shoot this horse before the gate even opens. The race is over before the starter even fires his starting gun. No one can even get past the first page of the Executive Summary without realizing that a key component to the success of Remote ID will not happen. There are three parts outlined, first the rule, second the network, and third "“collection of technical requirements that standards-setting organizations will develop to meet the performance-based design and production requirements in this proposed rule". There is no mention of the fourth interdependent part, and one that is crucial to the success of the Remote Identification system: Compliance.
The rule must consider pilots who fly in rural areas with little or no internet connectivity. Unfortunately, some rural areas don’t have adequate cell service creating no fly zones and fail to acknowledge that rural locations are frequently the safest places to fly because they are away from people, other aircraft and structures.
I agree with the EAA's request of an extension of the comment period. The complex NPRM being more than 300 pages in length, 60 days is inadequate for providing a detailed response that addresses all concerns.
This rule is based on an imagined security and safety threat that simply is not proven in relation to traditional modeling. There is absolutely a risk posed by drones operated in proximity to aircraft by poorly informed, careless, and/or deliberately malicious operators, but the same cannot be said for models.
Adding onerous requirements for recreational users will be catastrophic for the hobby. Compliance with regulations will substantially decline, and many users will simply leave the hobby. This will diminish or eliminate the positive effect in education and innovation that recreational modeling has provided for decades.
All scratch built drones and aircraft will, by definition, become FRIA (FAA-Recognized Identification Area) only devices unless 100% of "FAA approved" hardware is used, an impossible task for the hobby and racing flight.
The fixed 12 month FRIA (FAA-Recognized Identification Area) application window will decay overtime and eventually the hobby, sport, and innovation will evaporate because no chance for new locations. Actions like this are an attempt to kill off all non-remote ID flight.
The FAA should refrain from biting off more than they can chew. It would be better to focus on locations that need protecting, instead of creating an unwieldy tracking system for the entire United States, would be more realistic
The proposed rule would make law enforcement and SAR flights non-complaint as the drones used will not be able to broadcast location. This rule would cripple the ability fly in rural or mountainous terrain and cost the lives of people in need.
The FAA has not thought this through. The justification for this rule is utter bullsh*t. Show us the bodies. Surely you have better things to be focused on, why is the FAA not focused on the things that kill people.
Drones are the safest technology in aviation history. Despite the safety record the remote ID proposal in the first 20 pages states that it will allow for advanced operations, flights over people, or BVLOS or drone delivery. I don't consider the NRPM to be legal because it breaks federal law as a mass surveillance on American citizens via 50 U.S. Code § 1801 "the intentional acquisition by an electronic, mechanical, or other surveillance device of the contents of any radio communication, under circumstances in which a person has a reasonable expectation of privacy and a warrant would be required for law enforcement purposes, and if both the sender and all intended recipients are located within the United States;" (https://www.law.cornell.edu/uscode/text/50/1801)
Drone flights have been exceptionally safe over the years. Criminal thefts made possible by having access to the public data and system outweigh any perceived safety benefit provided by the remote identification data.
As outlined Remote ID is unfair as general aviation pilots are only required to have ADS-B capability in controlled airspace (A, B, C-veil, etc), but UAS per the proposal are required to be tracked 100% of the time for each flight. This is unfair and unjust and considering there are at least 3x more drones than planes we demand fair and equitable treatment and be provided reasonable access to national airspace
We Strongly Support Drone Remote ID. But Not Like This.
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Other ways to comment on docket number FAA-2019-1100
Federal eRulemaking Portal: Go to http://www.regulations.gov and follow the online instructions for sending your comments electronically.
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