Letter from AMA

[RC Storick]

Dear Members,
 
The official comment period for the FAA's proposed rule on remote ID has closed and we are writing to provide an update.
 
First – and most importantly – thank you for your unending support for model aviation and commitment to advocating on behalf of our beloved hobby.
 
Your comments make a difference. Throughout the past two months, the aeromodeling community has submitted over 50,000 comments to the FAA expressing concerns with the remote ID proposal. This is an enormous number of comments, and we are overwhelmed with gratitude for your work on this important issue. All of your voices are critically important, and they make a difference. Thank you again for taking the time to participate in the remote ID rulemaking process.
 
In addition to your many comments, AMA HQ submitted its own formal comment detailing how the proposed rule would impact our community and the changes we want to see in the final rule. If you are interested in reading AMA's full comment,https://amablog.modelaircraft.org/amagov/2020/02/28/ama-submits-official-comments-on-remote-id-proposal/ it is available here.
 
Second, please know there is still a long road ahead. In fact, there is a lengthy bureaucratic process that the FAA must complete before a final rule is announced, including a review of each of the tens of thousands of comments you submitted. And even after a final remote ID rule is announced, there will be a significant time period before that rule goes into effect and everyone must comply. The whole process will probably take several years. Rest assured, we will keep you updated along the way.
 
Third, and finally, the fight for a better remote ID rule is not over. During the next several months while the FAA is reviewing your comments, we will be coordinating closely with other groups who have a similar viewpoint on the rule as AMA. We will also continue to meet with our allies in Congress about the importance of model aviation and the need to protect our community. Soon, we may ask for your help contacting these members of Congress, so please continue to keep an eye on our advocacy website and social media.
 
For now, we are filled with gratitude for the AMA community and hope for the future. As always, if you have any questions or simply want to connect with us, please call (765) 287-1256 or email amagov@modelaircraft.org
 
Sincerely,
 
AMA Government Affairs

[Jim Mynes]

Over 50,000 comments? The FAA site says 45,468 comments were submitted.
Is the AMA trying to overstate their influence in this matter?

[Ed W. Prohaska]

"Over 50,000 comments? The FAA site says 45,468 comments were submitted."

The "over 50,000" is from the dronedj.com site:

https://dronedj.com/2020/03/03/over-50000-comments-on-faas-nprm-for-remote-id-for-drones-what-are-the-next-steps/

Even "over 45,000" is pretty good. Whether it will actually "do any good" is another story. I just read the entire AMA comment, but found nothing in it specific to control line. Correct me if I'm wrong.

In the beginning they lobby for leaving traditional model aviation alone which would be a win for everyone if it happens. Further along they argue for no regulation or minimal regulation of UAS flown within Visual Line of Site (VLOS) vs. the mega buck delivery and surveillance drowns that fly BVLOS Beyond Visual Line of Sight. Control line is obviously VLOS, so if the end result is minimal or no regulation for that category, we win.

I was looking for a sentence that said "The category of model aircraft traditionally described as control line shall be forever exempt from regulation." Unfortunately, I could not find it. I wonder why the AMA did not include such a sentence, or something similar, in their comment.

I became "comment happy" last week and posted several to the FAA site. Most contained one or two sentences plugging control line, one promoted all of model aviation and another was specific for control line.

I read a few comments posted by others. Some contain four letter expletives and are probably counter productive. While they may serve as a stress reliever for the author, the recipient might take umbrage. Here are my last two posts:

"I'm posting this last of many comments to voice my deep concerns regarding the proposed FAA rules, especially Remote ID and Registration of each aircraft. These draconian measures, if they become law, will irreparably cripple Model Aviation for its current participants and destroy it for future generations of enthusiasts.

I can understand the need to register and track sophisticated delivery and surveillance drones in commercial or institutional service. These are the types of UAS that, if left unregulated, may pose a collision risk to manned aircraft, tall structures and each other, if their numbers and use proliferate (as expected) and their positions and trajectories are not tracked. The owners and operators of these UAS have the resources and access to technology enabling compliance to rational regulations.

However, Model Aircraft, in all their many varieties (radio control, fixed wing, helicopters, gliders, free flight, control line, hobby and video drones) do not pose a risk to manned aircraft or commercial drones. Moreover, WE, THE PEOPLE, who enjoy the Model Aviation Hobby, should have equal rights to the volume of airspace the operators of sophisticated commercial and institutional drones will likely be using. As such, we deserve to be treated fairly, equally and rationally in any rule making process.

The best possible decision the FAA can make is to leave Model Aviation alone, in its entirety, and exempt it from all regulation. If that is not possible, please take the required time and make a truly sincere effort to draft the most reasonable and minimal regulations, with the interests of all stakeholders accounted for.

Model Aviation represents a rich and diverse collection of activities whose participants, for many generations, have been united by a passion for things that fly. Please engage yourselves in deep thought and reflection before imposing disastrous regulations that would unnecessarily destroy this wonderful hobby for current and future generations."

"To all concerned parties I extend the warmest greetings: Model Aviation has been my hobby and passion for over 62 years. I have submitted several comments regarding the proposed FAA rules for Unmanned Aerial Systems (UAS). This one is specific for the type of model aircraft that is my main interest and that I build and fly the most.

I fly Control Line Model Aircraft and I'm writing to urge the FAA to provide specific language in the rules exempting Control Line Model Aircraft from government regulation, especially the requirements for Remote Identification and Registration of individual aircraft. Such requirements would be highly impractical and prohibitively expensive to implement, especially Remote Identification. It would effectively destroy a truly unique hobby that has provided enjoyment, learning, skill development and personal sanctification to many thousands of hobbyists for over eight decades, as well as business opportunities for thousands of entrepreneurs whose products and services support the hobby.

The real tragedy is that such regulation is completely unnecessary. The flight envelope of Control Line Model Aircraft is limited to the length of the control lines attached to the model. The control lines are made of steel cable or advanced polymers. Their strength far exceeds the aerodynamic and inertial forces acting on the model. The Academy of Model Aeronautics limits this length to a maximum of 70 feet for competition events. The length is measured from the center line of the model to the center line of the control handle, so the lines themselves are a couple of feet shorter. While it is possible to fly on lines of slightly longer length, it is impractical and would not benefit practicing for competition events which restrict the length to 70 feet. Most Control Line Model Aircraft fly on line lengths of between 35 and 65 feet, depending on the size of the model and the nature and rules of the event it is designed for. Due to this line length restriction, Control Line Model Aircraft do not pose a risk to full scale aircraft (manned aircraft). The lines are attached to the model and to a control handle which is strapped to the pilot's wrist. Even if the pilot had a medical episode and fainted during a flight, the model would stay attached to the pilot and safely crash within the radius of the control line length.

The intent of the proposed rules may be to clear the airspace for commercial and institutional delivery and surveillance drones. Control Line Model Aircraft do not pose a risk to these UAS. Such drones will be highly sophisticated Unmanned Aerial Systems bristling with cameras and the latest navigation aids. In the extremely unlikely event that the flight path of such a drone is on course to intercept that of a control line model, the drone's technology will surely be able to detect and avoid the control line model's flight hemisphere well before any potential collision becomes imminent. Such drones will be flying at altitudes of several hundred feet to avoid buildings, power lines, water towers, cell towers and wind generators and thus are never likely to cross paths with a Control Line Model Aircraft.

As a lifelong builder and flier of Control Line Model Aircraft, I hope to enjoy the free and unencumbered pursuit of my hobby throughout my sunset years and I hope the activity will be available to succeeding generations of hobbyists into the distant future. In the past I have also built and flown traditional Free Flight and Radio Control Model Aircraft. While I do not yet own a drone, I may choose to do so in the future. I know that enthusiasts who specialize in these types of flying models have serious issues with many aspects of the proposed rules. I join with my fellow hobbyists in urging the FAA to carefully study the many thousands of comments that have been submitted. Please take a thoughtful and rational approach to the rule making process with an eye toward avoiding the unnecessary destruction of a collection of activities that has provided countless hours of enjoyment to thousands of people over many decades." That's all for now, EWP



 

[Fredvon4]

For some contrast Bret Buck and Fred von Gortler were only 2 of 4500+/- comments in 2012 NPRM....very very few hobbyists respond....most were corporate lawyers with a dog in the fight....needing good rules to set insurance standards for commercial clients

[Dave Hull]

I'm not a corporate lawyer, but may be, as Fred might put it-- "an old dog in this fight."

Here is what I think the FAA should do, in fairness to the public with regard to their safety, in fairness to the taxpayer in regard to only paying for regulations that improve safety, and in fairness to people who dream about flying in their guaranteed pursuit of happiness via a completely innocuous hobby.  [I apologize that I cannot reproduce the indenture and formatting of the original Word-based submission here.]


Response to NPRM 84 FR 72438; Unmanned Aircraft Systems Docket ID FAA-2019-1100


The most urgent issues with proposed rule:

1. The definition of UAS, sUAS, unmanned vehicle, drone and model aircraft is inadequate. Terms are used interchangeably and many times inappropriately.

     Remedy: More carefully define a sUAS, UAS or drone as a flight vehicle which contains electronics that allows remote or autonomous flight control via electromagnetic link (RF, microwave, infrared, etc.), or an electronic preprogrammed flight plan. Specific characteristics that identify a UAS: an autopilot system; a GPS navigation system or inertial guidance system; and the use of a camera broadcasting system for BVLOS waypoint recognition.

And further, it follows that aircraft without flight control electronics with the characteristics above are not a sUAS, UAS, drone or “R/C” airplane. In particular, a tethered control line (also known as U-control) model airplane has no electronics; no software to “upgrade” as the executive summary of your proposed rule specifies; and no ability to fly autonomously. It has no autopilot or coupled GPS. It cannot fly beyond visual line of sight. Poor pilot judgement of distance is never a factor in control line flight. The distance is dictated by the regulated length of the stranded steel control wires which by rule and practice is generally around 60 feet, but never exceeds 70 feet.

In the case of this proposed rule, you are applying a one-size-fits all approach to a poorly understood and defined flight category. It is unnecessary, punitive, and counterproductive.
 
2. The need case simply does not justify portions of this rule for certain types of aircraft. What Congress has mandated, and you have used as rationale for this rule have not been tailored sufficiently to make best use of the airspace and to allow existing users to continue historically safe operations.

Remedy: Clarify the definition of UAS to fit the actual characteristics, as recommend above, else, provide a written exemption that interprets the rule when it comes out to exclude tethered control line model airplanes which have no on-board flight control electronics.

These models do not meet any of the criteria of your mandate.
(a). Control line models do not interfere with the NAS.  They cannot fly higher than 80 feet AGL since they are tethered to the pilot who is standing on the ground. This is lower than many trees that usually exist in the fixed sites (often public parks) that we use. Unless these are flown in exhibition on airport property (this is commonly done with ATC review and approval) there is no conflict with manned flight, period. Any future conflict with commercial drones should be worked out via model airport mapping. (ie. your fixed site or FRIA approach.)
(b). Control line models cannot be used as a weapon. These models fly in a fixed hemisphere of a maximum 70 foot radius. They are not autonomous. There is no foreseeable situation where the use of the model would facilitate a terrorist act.
(c). Control line models do not pose a risk to privacy. Since the model must fly continuously in a circle to maintain line tension and therefore control of the surfaces, they are not a viable camera platform due to the constantly changing heading. Further, since this is true, no one uses them in this way. A very limited number of cases have used an on-board camera to identify engine or flight problems. Since this is invariably done at a fixed site, there has been no privacy issue, ever.
(d). Control line models do not pose a risk to the public. When flown in a responsible manner, and at suitable locations such as fixed bases (FRIAs), and in accordance with AMA safety regulations there is minimal risk to bystanders. Less than most other sporting activities. When a control line model goes out of control it crashes within 70 feet of the operator, and within the safety area. These aircraft cannot maintain flight free of the wires or pilot control due to asymmetric trim that is required to make them work. For most flight categories, the control handle is strapped to the pilot’s wrist.

Just as non-complex, single-engine, land category aircraft are regulated differently than Part 135 operations, which the FAA believes is justified, a tethered control line model airplane should not be included in the category of ground station controlled, RF-linked, autonomous vehicles. They fundamentally are not. The capabilities are totally different, and the threat in any category of Congressional concern is negligible, if not non-existent.

Unless this is changed in the final rule, it is clear that the FAA has taken a punitive approach to sanitize the airspace for commercial users only. This is a dangerous precedent, and one that the FAA has avoided to this point.

3. Universal registration is onerous and unnecessary for some types of aircraft.  The FAA has not made the least case—apparently having lumped all of model aviation into a single category—that control line tethered model aircraft represent any measurable risk in categories (a) thru (d) above. It is therefore irresponsible to impose an onerous regulatory burden on hobby modelers which will also incur unnecessary enforcement costs on the FAA and local officials.

Remedy: Exclude tethered control line aircraft from the sUAS, UAS, drone, and R/C model definition, as stated above. Failing that, provide a written exemption of all control line model aircraft from the registration requirement at the time the rule is released.

(a). No control line model airplane has been involved in an incident with full-scale aviation. None that anyone can recall in over 75 years of operations. None of this type of model has landed on the White House lawn, has interfered with airport operations, has been involved in terrorism, has been used to take video or photos of sensitive installations. Ever.
(b). Many of these models are handmade still, and creating some process to provide manufacturer’s serial numbers is hugely out of proportion to the non-existent threat. A typical modeler may have 5 models of this type or may have several dozen. The cost to the FAA—and the hobby modeler—to operate and participate in a serialized registration system will be stifling, and provide zero benefit when considered against the Congressional mandates. Zero.

4. The plan to phase out fixed flying sites will be catastrophic to the aviation personnel pipeline. A very large number of professionals currently in aviation participated in some way in model aviation at some time in their lives. It has been an incubator for career involvement and also ownership of private aircraft. Where will those most motivated and already knowledgeable people come from in the future if the rule, as contained in this NPRM is released?

Remedy: Allow all existing fixed flying sites (FRIAs) to continue indefinitely, where they comply with reasonable operating rules consistent with NAS concerns. Allow new sites to be added as needed by the users following a reasonable review by the FAA and addition to the database. Eliminate all wording of phase-outs, deadlines for conversions, and so forth from these provisions.
Where there is negligible risk, such as with tethered control line model airplanes, it is unacceptable to simply phase out “the pursuit of happiness” of many thousands of American citizens. It becomes especially egregious when simple revisions of the proposed rule (law) would easily take care of this.

[Keith Miller]

I'm not a corporate lawyer, but may be, as Fred might put it-- "an old dog in this fight."
.......
...........would easily take care of this.

Dave Hulk - nice post and thanks for submitting to the NPRM site!

[Fredvon4]

Dave I only wish my first and last "comments"

were as well presented as your post above....good job sir

not that they ever read my stuff, but I am plagiarizing your post to send to Cornyn and Cruz my senators