Be Wise In Your Protest

Talking Points From The Community


  • Everyone’s goal should be to allow all aircraft including RC models, drones(UAS), and full scale aircraft to share the skies safely
  • The proposed rules would criminalize long standing retail and manufacturing businesses and safe operations, while creating barriers to entry to prevent small businesses from creating new innovations and technologies, stifling competition.
    • It also overreaches by creating barriers for the majority of companies and individuals who have no desire to be competition for large companies. 
  • Drones (model aircraft) are a great way to get people, including the younger generation, interested in aviation as well as other skills involving STEM
    • Many high schools and colleges have created STEM programs based around model aircraft and drones
      • The majority of these programs use off the shelf model aircraft kits as starting points which they build their projects around
      • The rules regarding manufacturers of UAS and the certification requirements may make it nearly impossible for USA manufacturers to continue to produce and sell the model aircraft kits
  • Model aircraft operations within the current community based organization guidelines have resulted in safe operations for years. Although the spirit of remote identification can improve safety and security overall, the current proposal imposes unreasonable costs and burdens on the model aviation community and manufacturers
  • Many major advancements in recent and past aviation have stemmed from individuals who have flown model aircraft/drones
    • The vast majority of the technologies used in commercial endeavors being created by major aviation companies were initially created by hobbyists experimenting with their model aircraft/drones
  • A system that is too complicated or expensive has the negative consequences of:
    • Scaring people away from the hobby
      • Parents less willing to bring their children in to it as a hobby
      • Schools less likely to create educational/STEM programs around model aircraft/Drones
      • Lower income individuals may not be able to afford the increased price of the aircraft and the costs of compliance otherwise
      • People may not start the hobby because they have fears of not being able to fully comply with the regulations
      • Individuals would not want to buy or give a model plane or drone as a gift because they or the recipient will be saddled with endless monthly fees to be able to fly it.
      • People will leave the hobby behind
    • Domestic manufacturers may be unable to comply without increasing costs by 50% or more and making simple systems overly complicated for beginners
      • Overseas manufacturers and retailers, many already bypassing existing US regulations, would ship non compliant UAS to US residents directly
        • Because of the low value of these shipments (often undervalued by the shippers), these shipments already are typically not processed through customs and avoid inspection by border patrol agents
        • Avoiding the overhead of compliance, these vendors are able to ship to customers at a much lower price than US vendors, putting the US vendors at a competitive disadvantage and reducing US jobs and innovation.
      • The listed requirements for compliance are impossible or unreasonable for many existing models, effectively removing the ability for many US manufacturers and retailers to sell products.
        • There currently is information in the released documents that is conflicting. Although UAS is defined as the entire system including the control system, it is unclear what determines the percentages for defining scratch built. (need better wording here)
      • UAS are specifically defined in the rules as the entire system, including the aircraft and the control system.
        • Multiple models often are typically linked to single controller by the operator, meaning there is no way that a “full UAS” can be sold as a kit or PNP if the user is using their own radio, which is the safest method of operation
        • If the FAA is proposing to apply the same policy that is used for manned aircraft, there will be significant difficulty in applying the rule on the recreational UAS (model) industry due to the popularity of recreational UAS that are nearly ready to fly aircraft and the intent of separating hobbyists who build, assemble, and fly from the off the shelf ready to fly products.  
        • Even this “Almost Ready to Fly” category requires skill, knowledge, and technical ability that falls under the intent of Amateur-Built as a definition.
        • A better explanation and clear definitions should have been included in the main body of the NPRM as well as the preamble. A poorly worded, inaccurate definition moving forward will severely damage the entire hobby, and it should be clear that “almost ready to fly” kits are considered Amateur-Built.
    • Because of the high barrier to entry, many people who have a strong desire to enjoy aviation through drones and model aircraft will simply bypass the FAA’s rules completely
      • This risks criminalizing those who simply want to enjoy the hobby and learn more about aviation and the electronics
      • Many people have already stated their desire to ignore the proposed rules completely because of the complexity
      • Many of these individuals would be more than happy to follow the regulations if they were simpler and easier to comply with.
  • The system for flying locations can be achieved far more easily using a system similar to the current LAANC system where an individual and submit and receive approval quickly and easily.
    • Many group events occur at locations which are not permanent flying sites such as air shows
    • These events can be held safely and under the guidelines of a community based organization, but the system should allow the ability to quickly and easily create a temporary flying site
    • The proposed rule appears to strongly restrict the creation of fixed flying sites and appears it will cause some sites to be phased out over time as new sites will not be allowed after 12 months
      • The reasoning stated for this is that new UAS will all have remote ID, however this conflicts with the concept of amateur built UAS which have strict limitations on where they can be flown and, as written, will require these fixed sites.
  • The requirements for every single aircraft to be registered are unnecessary to fulfill the requirements for safety and monitoring by the FAA
    • Outside of certain airspace, full scale aircraft don’t require a traditional transponder, ADSB, or even a radio (NORDO) if it left the factory without one. Why should rc planes or “drones” operating at less than 400 AGL require more detailed location reporting than full sized aircraft?
      • Info about aviation transponders: https://www.cfinotebook.net/notebook/avionics-and-instruments/transponder
    • A large number of model aircraft and drone operators have significant numbers of aircraft they experiment with 
      • Many could have aircraft counting into the hundreds.
      • This differs from the majority of those purchasing off the shelf fully ready to fly drones from manufacturers such as DJI. These individuals may only have one drone. 
        • The serial number and individual registration requirements make more sense for fully ready to fly drones capable of autonomous flight, but not for the hobbyist model aircraft and drone operators.
    • Although there are many off the shelf full UAS systems available, we believe the FAA has underestimated the number of systems that are built from kits and mixed systems put together from separate components
      • Many of the systems being built and flown can not be considered a single “UAS”, as the users often swap out parts, move parts between various kits and airframes, and generally have ever-evolving systems as they learn and rebuild
    • All the requirements could be easily obtained by requiring reporting based on the operator’s FAA registration alone
      • Regardless of on-aircraft remote ID or zone reported remote ID through mobile device, the FAA would still be able to determine who is responsible without forcing a separate requirement for each airframe
      • A user-based reporting standard would make it easier for users to operate at various safe locations, as the user could have a certified remote ID solution that is not tied to the aircraft itself but can be moved between aircraft and/or reported from the ground station
        • This system would make the flying locations requirement less important and reduce the amount of overhead for the FAA and the users.
      • The individual UAS registration requirement makes more sense for commercial operations where larger scale UAS are purchased ready to fly and the aircraft are likely to be flying autonomously.
  • Model aviation supports a $1 billion hobby industry responsible for thousands of existing U.S. jobs. We simply cannot afford to further harm the model aviation hobby with overly burdensome requirements.
  • In the past, legislators have included language in FAA funding bills to protect model aviation. This was done because of the understanding of all the good that can come from people enjoying the hobby and having a strong interest in aviation. We hope that legislators can intervene if necessary and stop this unnecessary proposed rule from being made law.

Below is more for sending to media outlets and/or lawmakers, as the FAA probably won’t care about this argument

  • Automobiles need a license to drive on public roads, however off road vehicles do not require licensing unless they are going to operate on public roads. Model aircraft and drones can and should use the same concepts. Model aircraft flying under Class G airspace up to 400 ft altitude should not require any special licensing, however operation within controlled airspace would benefit from some level of remote ID, even if far less restrictive than the current proposed rules.
    • Just as offroad vehicles do not need to meet all road-worthiness requirements if they are not intended to ever drive on public roads, model aircraft should have a category that does not require remoteID technology unless it is specifically meant for operation in controlled airspace.
    • The requirements of remote ID should be less strict than current proposals and should be placed on the operator, who in many cases would be modifying the original aircraft design for their own use anyway.
    • The same safety and monitoring arguments could be used to justify monitoring the real time location of every car/truck/vehicle in the US to help with law enforcement
      • This would not be considered acceptable and would be considered a violation of personal rights, so why is this different with model aircraft?
      • Not only would this go too far as-is, but paralleling the proposed rule, everything with wheels would be have to include government approved tracking technology