I hope everyone had a great Holiday and New Year! As you may be aware, the FAA has recently released a proposed regulation which significantly affects all facets of our hobby. In this message, I will go over the implications somewhat in detail as well as lay out what we can do to respond to the FAA by March 2nd and fight against these proposed rules. Special thanks to MAR/C member Lee Paddock for speaking at our last club meeting on this topic and helping me write this message. The way the proposed rule making is currently crafted makes it seem that the FAA was oblivious to our hobby - or worse - strongly influenced by commercial drone interests to potentially have a large negative impact on our hobby. In their eyes, we conflict with their future Class G airspace use from 0-400ft.
In about 5 years, any manufacturer (Horizon Hobby/Extreme Flight/Motion RC/Flex Innovations/etc) that wants to sell a recreational UAV (FPV or line of sight/airplane/ heli/quad) weighing above 250g will need to get their product FAA certified as a limited or standard remote ID.
Standard ID is intended to be used by UAV for profit commercial pilots that have a part 107 certificate.
Limited ID would be used by aircraft in our hobby. Aircraft under Limited ID will be electronically geofenced to 400ft from the controller in all directions. This will prove perhaps too costly, with too much manufacturing liability and too FAA bureaucratically regulated for a parent company such as Horizon to deem profitable to produce. (Each plane would have to be designed to be able to autonomously turn around once reaching a 400 foot invisible barrier in all directions without pilot input, for perspective).
All our existing line of sight or FPV R/C aircraft above 250 grams will need to be flown only at FAA Recognized Identification Areas (FRIA) which are applied for only by a community based organization (CBO) and only for a 12-month period. These are essentially FAA approved flying fields. AMA flying fields would be examples of sites that would fit this description. Once the 12-month application period for FRIAs expires, no more applications for FRIAs will be accepted, nor will special event permits be accepted. This is not a good thing and must be fixed. This would mean no new R/C flying fields, period, after the 12 months lapses.
If you choose to build your own R/C drone/aircraft over 250 grams it will also be quarantined to an FRIA and must not fly beyond line of sight. You also can’t legally put an ID transponder in your legacy non-remote ID aircraft (PNP/ARFs for example) or amateur built aircraft (kits/scratch builds).
As the proposed regulation is written, even flying a quad or airplane above 250g indoors, at a park, or on your own private property will also be illegal unless it’s an FAA approved FRIA site under a CBO or the aircraft is an FAA certified limited ID type.
The regulation is really crafted to pave way for drone deliveries from Amazon, UPS, etc. In the future, all the sky below 400ft will potentially be littered with commercial delivery drones. Under lobbyist pressure and public drone fear, the FAA is trying to regulate all airspace (perhaps illegally) from the ground to space. They are ultimately requiring all 1/2lb to 55lb UAVs to be certified similar to full scale aircraft, for example. This will grossly inflate the cost of the hobby (both line of sight and FPV) and more than likely put massive financial strains on R/C manufacturers.
It is believed that Amazon is worried that a model airplane sharing the same class G airspace under 400ft could bring down one of their delivery drones. One could argue that with the sheer number of commercial drones in the air in the future, this seems to be one of the main real root causes of the proposed regulation - and one of the main reasons for the standard ID category.
It’s hard to say how the FAA is going to enforce these regulations.
To put this into context: imagine a different government over-reach scenario like the US the department of transportation requiring all bicycles to be remote ID’d. The DOT would require the location, speed, and rider name transmitted, monitored and logged while in use. All Bicycle manufacturers would require DOT certification, and bike ranges to be limited to a few blocks riding distance or they would be quarantined to DOT approved bike parks if they existed.
According to the FAA there are around 1.5 million commercial/recreational UAVs & there are only 250,000 manned aircraft general/commercial/military combined in the US. There are approximately 10,000 general aviation bird strikes per year (some causing fatalities) and only a handful of “actually confirmed” recreational UAV collisions with general/commercial/military aircraft ever documented. According to the NTSB, there are on average 200 general aviation related fatalities per year while there are “on average” nearly zero fatalities related to recreational UAV’s crashing into someone. There are zero fatalities related to a recreational UAV crashing into manned aircraft.
No matter how you look at it - recreational UAVs have a better safety record (fatality/ property damage) than manned aircraft. If this FAA remote ID regulation goes into effect as written, UAVs will be more heavily regulated than a manned paraglider, hang glider, or ultralight - all of which have an even poorer statistical safety record. There also seems to be a missing required FAA risk analysis to prove recreational line of sight or FPV pilots pose a significant public safety or security threat. It’s safe to say that the FAA is promoting a new regulation based on fear rather than fact. We must fight for our freedoms.
One theory out there is based on federal law, the FAA or law enforcement legally can’t monitor or intercept your “transmitted” personally identifiable information without a warrant or probable cause (the foreign intelligence security act). This might be one of the avenues for a class action suit against the FAA. The other class action avenue perhaps leverages and ties into Crosby Vs US airspace prescient regarding just how much airspace you own as a private citizen (which seems to be up to perhaps 200-400ft above your property).
It is vital that we all get educated and respond with our personal perspectives to the FAA by March 2. FliteTest went ahead and made a very helpful video on their suggestions on responding to the FAA. Below is their “how to” on responding. Be sure to complete your personalized responses by March 2nd and to also consider writing the Senate and local media regarding the negative impact of these proposed regulations.
We are extremely lucky to partake in the hobby we have at a field as beautiful as Marymoor and only our combined voices can help preserve the future of our hobby.
Here is where you submit your comment to the FAA: http://bit.ly/2RnY8Ty
1. Do not copy and paste from somewhere else.
2. Make it personal but not emotional. Let them know how you enjoy recreational flying and how the proposed rules impact your life and the people around you. ATTACH IMAGES. Images speak volumes. Images of you with your aircraft and especially promoting youth in the hobby would carry a huge weight.
3. What type of pilot are you? What aircraft do you fly? be specific - describe it what you fly and how you fly it.
5. Where do you fly? Is it at a fixed flying site? How far are you from a model field? Either give the location or just give a general description of what it is like and why you fly there. This will help give the FAA context as to how and where recreational flying is taking place.
6. Propose that people should have alternatives to comply with remote ID.
1. Broadcast Solution - Basically equip aircraft with an inexpensive Bluetooth or wifi module that would broadcast out an identification number and your identity would remain private.
2. App-Based Solution - An app where Pilots could publicly identify where they are operating their recreational models.
3. Network ID Solution - This is where your aircraft will need to be equipped with a telecom chip that will broadcast all flight data globally for each flight.
Here are some useful web-links on the PRM: