Hey guys, I know this is a control line forum but many of us also fly RC including myself. So I wanted to share my letter I'm writing to the FAA about their proposed rules for "Drones and UAS" in case some of you have yet written your letter to them time is running out, the deadline is March 2nd I believe. Maybe my letter will give you some ideas or you have other things you'd like to add. So here it is.
I am writing today with regard to the FAA proposed rules to UAS and model aircraft. Let me start off with a little bit about myself and previous model airplane history. I am 36 years old and I'm a 3rd generation model aviation enthusiast. My grandfather got my dad interested in building and flying model aviation when he was 12 years old. Now, he is 66 and still flies regularly to this day. My grandfather built and flew models right up until about 2 weeks before his passing while being in his late 80's. As a kid during school, all I could think about during the day was how can I make this day go faster so I can get home and work on my airplane so that this weekend I can go fly it with my dad. Also, as a kid all I ever wanted to be when I grew up was a pilot. Unfortunately, I never had the funds required to put myself through aviation flight school. However, flying model aircrafts instead, has been a great compromise and has brought joy to my life since I cannot afford to fly full scale aircraft. My father and I travel all over the country together to fly our planes at events all year long. Our Father/Son relationship is one of a kind due to model aviation. In today's world where there is a disconnect between fathers and sons, I am so happy that I get to spend one of my favorite hobby's with my father and how close it has brought us together over our lifetime. Not to mention the amazing people we have met, again all over the country and have become friends with, that also partake in this fine hobby. Now that I am a middle aged man, not much has changed, I still have a passion for model aircraft and I can't wait to get home from my job to work on my airplanes so that this weekend I can go flying. I myself have over 60 different model aircraft from as small as something that can fit in your hand all the way up to a 9 foot wingspan gas powered scale model aerobatic plane. We enjoy flying many different forms and types of model aircraft as well. These would include Radio Control, Control Line, and FPV (First Person View)and this is where I run into some issues with your proposed rules. Because as they are currently written, you will destroy model aviation as a whole. In some ways I think you are in fact trying to do this anyway, to clear the airways for commercial drone use. I hope that's not the case and it's just a lack of understanding of model aviation and UAS or drones as a whole.
You are unfortunately lumping in all forms of model aviation and calling them a "UAS" or "Drones". This is highly inaccurate. For nearly a hundred years now, hobbyist such as myself, have been flying model aircraft with no real safety issues or problems. If anything the hobby has gotten safer with Radio Control models switching over from the old 72mhz system to the new 2.4ghz spread spectrum technology with channel hopping capabilities. The chances of radio interference is much a thing of the past and having a plane get away from you due to this has been drastically reduced to almost nill. Now one of the biggest things I don't think you are realizing is that us hobbyist that have been flying now for decades without issue is that we fly line of sight. Meaning, we DO NOT fly beyond visual range because we have to see our plane to be able to fly it. And most of the time we also fly with a spotter as a precaution to avoid other model aircraft that may be flying in the same airspace or for example if a clueless person wonders out on the area we intend on landing that we didn't see because our eyes are on our plane. None of our model aircraft are designed to fly beyond visual range. Also we generally fly in an oval racetrack layout mimicking a full scale airport traffic pattern, as we need ample space to take off and land. We do not fly Radio Control models in a cylinder shape tube/box that you have imagined in your proposed rules. The only aircraft we fly that actually do fly in this imaginary cylinder is in fact called Control Line. However, these models are tethered, and cannot fly any further away from us than the maximum line length (70 feet) will allow it, and in a circle pattern. That's less length than many kids are seen flying a kite on, in an empty soccer field, on a windy day. So with this in mind you need to, at a minimum, differentiate between model aircraft and "drones or UAS" as you call them. Drones and UAS are not model aircraft. They are a completely different machine, and the only thing they have in common with model aviation is that they are controlled remotely from the ground in most cases. Drones have only been around now for about 5 years and us model aviation enthusiasts have gotten a bad rap because of them. Drones and UAS have the capabilities of being flown autonomously and under GPS control, inherently meaning, they can easily be flown BEYOND line of sight with the only thing determining how far they can go is how long the battery or energy source can take them before being depleted.
Now you are wanting remote ID on every single "Drone or UAS" starting in approximately the next 3 years. Here again This is where you need to differentiate model aviation and Drones into at least two groups. For example, I propose these two groups. The first does NOT need FAA Oversight, "Group A" being us Hobbyist where we are already flying; line of sight meaning again within visual range, at a restricted altitude below 400 feet, in designated areas or areas where permission has been granted, and on private property. This "Group A" would include every type of model airplane, Control Line (tethered models) , helicopters, flying wings, and multi-rotors not capable of autonomous flight. Then the group where FAA Oversight, registration, remote ID tracking, and Insurance, IS needed. Let's call it "Group B", Group B would consist of actual drones and UAS that ARE capable of flying beyond visual range (BVR) or beyond line of sight, flying in controlled airspace, or flying over populated areas including cities and events, and commercial use. This group will consist of mainly; multi-rotors, flying wings, and First Person View (FPV) platforms that can and do carry autonomous flight control systems, GPS devices, and typically Camera's.
Most of us that will be impacted by your proposed rules (a couple million of us) will fall into "Group A" and these rules are just ridiculous and here's why. Now remember, I said I have over 60 model aircraft, varying in size from fit in your hand up to 9 foot wingspan. Weight is critical on model aircraft they need to be as light as possible, so any excess weight from un-needed equipment or details will drastically reduced flying time and quality of flight. But that's just from the flight performance point of view. Much more the factor here I have an issue with is, that I would have to register each plane individually for remote ID and tracking... over 60 aircraft remember. I am already a registered member with the AMA (Academy of Model Aeronautics) and registered recreational flyer with the FAA from a couple years ago when you mandated us to register with you then. Now a couple questions about this remote ID tracking device, I wonder how much is this going to cost to equip for each plane? Who is going to pay for the internet service for the planes to synch up to your supposed tracking app? If we are flying in an area where there is no internet service then what? How will this internet connection be paid for? Are you expecting us the modelers in "Group A" to pay for this un-needed internet connection that should only apply to "Group B"? If so am I going to get basically like a cell phone data bill each month for 60 individual model airplanes? Some of the planes I have, I might only fly once or twice a year or not at all. If you're expecting us (the hobbyist modelers in Group A) to pay for that. There is no way this hobby will be able to afford to continue. So it is imperative that you differentiate "Drones and UAS" from Model Airplanes. I also believe It's an invasion of privacy if you are uploading not only my models location with remote ID onto an app but my location as the pilot. Now anyone with malicious intent can discover with this alleged app, Hey this guy isn't home right now because he's out flying his model airplane so let's go break into his house and steal whatever we want.
The next thing to consider is if you group us all together under these proposed rules. You will again be fundamentally killing the hobbyist side off and by doing so, robbing today's and tomorrow's youth of a wonderful hobby where ones imagination is the sky's limit. Even the Wright brothers had to build and experiment with models to see if flight could even be achieved before they tried to fly their first full scale heavier than air man carrying airplane in 1903. We already have a commercial pilot shortage, and in my opinion the best full scale pilots are the ones that also fly model airplanes. They just have a better understanding of how an airplane achieves flight and what it takes to maintain flight in an emergency situation. There are already fewer and fewer kids showing interest in aviation but so much can be learned in the model aviation hobby that can be carried over and generate interest into the full scale aeronautical field. So please don't detriment this hobby with these proposed rules and essentially steal this hobby away from my future children and the next generation who I hope have the same admiration I had growing up (as I mentioned at the beginning of this letter) to being so eager to learn how to build and fly model airplanes. With the hopes of making it grow into a possible career out of it in their future. We all will be sorry one day, if you do this. I promise you, this hobby is 1000 times better (and worth protecting) than what I see most kids now a day's doing, which is having their faces buried in their parents iPhone or tablets playing video games. This hobby can keep kids/adults busy for hours and hours while learning and socializing, heck in my scenario it kept 3 generations busy enjoying flying and building model airplanes. As a kid and young adult, the model aviation hobby also kept me out of trouble when other kids my age were getting into drugs, alcohol, and other nefarious things.
The last issue I have is the provision of slowly restricting designated flying sites and not allowing new sites to form. This is completely and inherently backwards. Instead of trying to shut down flying sites, the FAA should be proactive in working with the AMA, city, and state municipalities trying to gain more places for us model aviation enthusiasts to fly. Not only would it help get youth interested and involved in this hobby which can lead to interest in the full scale aviation industry, but it would help alleviate the "Drone and UAS" and model aviators from flying in areas they might unknowingly find themselves unwanted at. So help us get more designated flying sites or facilities rather than take them away. By doing this, it would also help free up the airspace like I believe you are trying to do, to use for commercial drones and UAS. One example of a place that makes a great flying site is on top of an old waste management facility or landfill, where once filled and capped, nothing can be built on top of it anyway. These sites can become perfect for us, all we need as model aviation enthusiast is a flat grass strip for a runway and some open space.
In conclusion I hope you realize that model aviation as I described in "Group A" or at a hobbyist level, is absolutely no threat to National Security, Privacy, or the National Airspace System (NAS). We have already proven this with nearly a century worth of safe and fun flying. We do NOT need FAA oversight or remote ID in model aviation. Lets preserve this great hobby of model aviation for the future generations rather than regulate it into extinction. We the hobbyist can surely, and have already co-existed with what I described as "Group B" and commercial drone and UAS systems, we can easily share the airspace for e-commerce drone use, if that's what it comes to, down the road. Please don't punish us the hobbyist with these burdensome rules you are proposing that should only be relegated to autonomous, commercial, or beyond visual range type of flight systems. I hope my letter has helped you understand and see the difference between model aviation and "Drone or UAS" flight.
Jared Hays
AMA member # 541389
FAA recreational pilot registration # FA39FLTKEX
Topic: My FAA letter (Read 1597 times)