New proposed FAA rule requiring remote identification for SUAVs over .55 lbs

[MikeT]

Please comment to the FAA on this but use your own words not the form letter. One well written comment is better than 1000 form letters.

Mike

[mshagg]

Funny a New Zealander is commenting about the FAA - I seem to recall that at one time he was banned from flying in New Zealand?

I understand he needs a spotter when flying due to his medical condition?

Many people outside the US are watching with interest because, for better or for worse, those practices will disseminate throughout the world in one form or another.

Regardless, he has a large supporter base in the US and has experience interfacing with airspace administration agencies so it strikes me as pretty relevant content for him to be making. From what I've seen his input is a lot more construvtive than ranting about drones and telling people to join the AMA.

[fredmdbud]

https://www.youtube.com/watch?v=pfoHqqq14Kk&t=327s

Funny a New Zealander is commenting about the FAA - I seem to recall that at one time he was banned from flying in New Zealand?

[CVA59]

https://www.youtube.com/watch?v=pfoHqqq14Kk&t=327s

[CVA59]

I concur with our friend from down under regarding the cut-n-paste approach for comments to the FAA/law makers not being as effective as a more personalized approach that reflects salient points of personal interest as to why/how these rulings affect you in a detrimental way.
It still is simply stupefying to me as to how the FAA believes that fixed wing modeling needs to be lumped into the basket of "rogues".
Look at what is now on the news out in the mid-west for the past week with these rogue elements in the evening/night skies and neither local/federal law enforcement or the FAA has a clue (yet).
So...…… I will make a personal comment preface onto the AMA response template but I am also not going to get wanged out about complying with whatever these bureaucrats want to try and handcuff me with.
I am gonna still fly my "ID"less warbirds regardless of the BS and let whomever have a nice day chasing after it.

mshagg / OV10.........I agree with both of you and that is why I am bypassing the AMA and going straight to the FAA with my letter(s). The AMA had it's opportunity to get ahead of the "8-ball" and they didn't. Anyone with a half of brain could have seen a few years back where the laws/rules for "droners" were headed and that there was a very high potential of us being dragged into it as well without some serious intervention from the AMA. The AMA should have already had a plan / proposal for this several years ago so that this day would have never come or at-least not to this extent we are seeing today. Is that easier said than done? OF COURSE! However, because of what we are about to have to start dealing with now, I cannot find any evidence from where any effective charge was mounted by the AMA to head this off before it got started, at-least on behalf of us non-drone hobbyists. My observation of what i consider "the passive nature" of the AMA in this manner is unacceptable. They are the sanctioning body of our hobby, they are the ones expected to protect our hobby from being infringed upon with unrealistic and downright stupid laws. Yet, now that our input could be considered by some as being almost being "too late" to make a difference, The AMA suddenly has a "form" for us to fill out and send in??? Haha. Where was this form over the last few years? The AMA is not stupid, they could see where the "drone problem" was headed. The AMA should have pulled us all together and requested we speak out minds way back when the rumblings of all this FAA crap first got started. Being proactive will 99% of the time yield much better results than being reactive!

• I would like to review the risk assessment data analysis of our hobby, in comparison (accidents, near misses, violations, terror attacks, etc.)
• I would like for the NTSB to compile all the data for all the accidents we "fixed wing" R/C flyers have been involved in with manned aircraft over the last 10 years.
• Again, let us review the reports, show us the factual data for the number of incidents involving drones versus unmanned R/C fixed aircraft vs. manned aircraft.
• I would like to review the documentation that the FAA has used in their basis for coming to the determinations they have with these "proposed" rules.
• I would like to review all the documentation that the AMA has submitted to the FAA in support of our rights.

AMA / FAA........ show all of us all your data, post it on your websites so we can see what has and hasn't been done on our behalf. If there is nothing to hide then this request should not be an issue. You don't simply just make laws, rules, guidelines without sharing the facts with the people who are about to have it forcibly shoved down their throats!

• FAA............Show me your proof to backup such a ridiculous package of rules that is based solely on factual and even reasonable evidence and I will apologize for my comments, concede my position and comply with your rules.
• FAA............Prove to me with facts, that we; responsible fixed wing aircraft flyers should be lumped into the same bucket as the irresponsible flyers and again, I will apologize for my comments, concede my position and comply with your rules. Show me/us what we responsible & law abiding flyers have done that give you the so called "right" to force us into compliance with these new "proposed" or any modified variation of rules.
• FAA.........Show me/us the proof that by enacting these rules into law, where it will stop the violators from being reckless and stupid. Please share the data that you complied to determine that these new "proposed" rules will end or even significantly stop the "problem" that is your claim for why you have to create such a package of rules. If you can show me the hard evidence, again, I will apologize for my comments, concede my position and comply with your rules.

I feel those are more than fair and justified requests.

Just to be clear, I am not talking down towards anyone who fly "drones". I have no issues with people who fly drones responsibly. My comments are geared strictly towards drone flyers and any other R/C aircraft flyers who fly in an unsafe and reckless manner with no regard for their actions.

[OV10]

I concur with our friend from down under regarding the cut-n-paste approach for comments to the FAA/law makers not being as effective as a more personalized approach that reflects salient points of personal interest as to why/how these rulings affect you in a detrimental way.
It still is simply stupefying to me as to how the FAA believes that fixed wing modeling needs to be lumped into the basket of "rogues".
Look at what is now on the news out in the mid-west

for the past week

with these rogue elements in the evening/night skies and neither local/federal law enforcement or the FAA has a clue (yet).
So...…… I will make a personal comment preface onto the AMA response template but I am also not going to get wanged out about complying with whatever these bureaucrats want to try and handcuff me with.
I am gonna still fly my "ID"less warbirds regardless of the BS and let whomever have a nice day chasing after it.

[mshagg]

It's not a horse I have a race in being outside of the states, but the AMA's guidance seems very much vested in the interests of their own organisation rather than the hobby itself. Those two things aren't always aligned.

We have similar issues in Australia where the MAAA is more concerned with carving out exemptions for their facilities (with the hope it will drive hordes of new members into their arms) than they are about opposing regulations which are poorly thought out and difficult to implement.

And that's fine - the AMA should absolutely focus on its own needs. Just be aware that they don't have the broader hobbys interests at heart and reflect on that before copying and pasting their submission.

As a professional bureaucrat and regulator myself, I'd also encourage people to add their own preface to any template they work with. Add your own context and explain why you care as an introduction to specific comments on the proposed rules. A pile of template submissions don't carry the same weight as a pile of unique ones. Wishing you the best of luck from across the ditch!

[T-CAT]

An important note to add, when people submit a comment to the FAA, I hope they read and understand the document, and/or perform thorough enough research on the situation by other means to enable themselves to comment properly after knowing enough of the facts. That always helps from multiple perspectives. Some people will use the template and others will write their own.

[Marco Polo]

Here is the latest email from the AMA. I would recommend that everyone file a comment with the FAA per the instructions below. Please note: The AMA does provide a template (link below), but it will be more impactful if you write your own unique comments in your submission. It's also important to note that the AMA's response to the FAA proposed regulation in their template is designed to support the AMA's interest and not necessarily the interests of the average hobbyist. Ultimately, I think the most important point to get across with lawmakers is the true difference between RC model airplanes and drones (what we know as multi-rotor aircraft).

Dear Members,
On December 26, 2019, the FAA released a proposed rule for remote identification (Remote ID) of UAS. There are several areas of concern with the proposed rule that AMA will push back against, and we need your help advocating for change.
Although the proposal does include AMA's request to exempt fixed flying sites, the rule should also provide community-based organizations (CBOs), such as AMA, more flexibility to establish and maintain fixed flying sites that satisfy Remote ID compliance.

Second, the rule should create a pathway for Remote ID compliance at AMA events and competitions, which might not take place at fixed flying sites. Third, the rule should better accommodate operations not at flying sites to include situations where there is no internet connectivity, because many safe places to fly are in rural areas with little or no service. Finally, the rule should not require modelers to register every aircraft individually.

The FAA is accepting comments on the Remote ID proposal until March 2, 2020. We have requested an extension to the comment period to give everyone more time to weigh in. To help us achieve the best possible outcome on the final rule, it is critically important that all who support the hobby submit a comment.

Please submit a formal comment to the FAA as soon as possible.

To submit a comment, go to the Remote ID proposal page on the federal website here. Click on the "SUBMIT A FORMAL COMMENT" button at the top of the page. You can copy and paste the template into the comment box, edit it to include your personal experience, or create your own message entirely. Complete the form and click on the "SUBMIT COMMENT" button at the end. Please note that comments and information provided are public knowledge.

Thank you in advance for your advocacy. Please listen to The AMA Podcast featuring Director of Government Affairs Tyler Dobbs to learn more about the recent regulations. If you are interested in reading a more detailed summary of the FAA's Remote ID proposal, visit our blog here.
Sincerely,
AMA Government Affairs

[xviper]

CVA59:
Thanks for the encouragement. IMHO if I fly in an empty park or school playground that's away from houses and traffic and spend (hopefully) 30 minutes going in circles and daring myself to try an aileron roll or a loop, who am I hurting? I just want to have some harmless fun without needless oversight and red tape.

To a government flunky, there is no such thing as "harmless". You might just be practicing so you can fly a big plane loaded with C4. (Honestly, I'm with you. Go have fun. Let the flunkies scramble to catch you.)

[flyin'fish]

CVA59:
Thanks for the encouragement. IMHO if I fly in an empty park or school playground that's away from houses and traffic and spend (hopefully) 30 minutes going in circles and daring myself to try an aileron roll or a loop, who am I hurting? I just want to have some harmless fun without needless oversight and red tape.

[fredmdbud]

The public comment period has just started, and some people are acting like the sky is falling. But it will be if people just rant and don't do anything. If you're not part of the solution, you're part of the problem. Lead, follow, or get out of the way.

[CVA59]

So I'm in a quandary - do I register with the FAA and adorn my ID on my planes just to be considered "Field Legal" and gain access to a Club and it's facilities, do I go rogue and hunt for schoolyards and local parks and hope not to get caught, or do I throw all my stuff in a dumpster and call it quits?

My advice to you is, go ahead and get your planes, batteries and have fun. To h_ll with the AMA, FAA and anyone else who thinks that we should smile, take our medicine and bow down to this infringement on our rights. As long as you fly with safety as the #1 priority then you should have no issues. However, once these rules are passed or a variation thereof, it may be a bit more challenging for you to fly but you can still do it just as I am. Although my posts may not sound like it, I do honestly make every attempt possible to comply with all R/C related rules and laws but in this case, the FAA has crossed the line with me. I already have too much invested to simply walk away from this hobby, beside the fact that this is and has been my only hobby for a long time. I don't smoke, drink, fish, golf or chase women (although sometimes that would be fun to do again, LOL), this is all I do for fun. So, therefore, I refuse to allow a handful of bureaucratic idiots to dictate when, where, how and such that I can enjoy my harmless hobby! Some on here can label my type as a "fear monger-er" or whatever, don't care. Unlike most in society, I unfortunately have a very intimate, up close and personal relationship with situations like this and have seen the far reaching negative outcomes. Anytime a federal, state, county, city government or department thereof starts out like the FAA has with these "rules" as a trial run, from my experience, 90% of the time, it is the end user / receiver who takes the hit. In some cases the "hit" may not be as bad as initially perceived but I guarantee you 100% that there will be a significant "hit"! I have seen this EXACT thing happen too many times to even discuss on here. Sometimes, true enough, it was not quite as bad as originally thought but more times than not, it was an outright travesty. These rules may change slightly but the overall plan of the FAA will mostly remain the same. They have put too much effort into this preliminary packet of rules to simply start tossing out stuff and catering more to what we want at this point, I ASSURE YOU! If there were any questions as to what rules, content, enforcement, validity, and extent to the rules, the vast majority of that would have been addressed prior to this most recent release. If anyone thinks the FAA is stupid or doesn't have a motive other than the front of "public safety", then you are delusional. Again, this is one of the biggest reasons why I retired when I did from being a Texas (Municipal) City Police Officer, Deputy Sheriff and Deputy Constable. I got so sick of these types of the lies and the slow intrusive injustices to citizens and property by the governments I worked for that I wanted to puke!

flyin'fish...........Please do not let the "sheep" who are so quick and willing to lay down to the "all powerful and all mighty FAA & AMA" make you feel guilty that if you don't follow suite with them, you will be considered a "non-conformist" or "rogue flyer". Again, if these rules would stop the "stupid factor" in our hobby, I would be the first one aboard to support and back it all the way but, IT WON'T. It will only hurt the people like us who have spent years flying safe and who have built this hobby to what it is today. It's really comical to me, I have been called "rogue" and many other immature and childish names simply because I choose to fight back and not give in to the "big machine" and it does not phase me in the slightest. However, I will digress & agree with some on here by saying; give it time to see what the "final" draft will look like. Regardless, none of this makes me any difference to me personally, as I have said numerous times on here already, I will never comply with any of this newly released power grabbing rules from the FAA but we each have to make our own decisions about how we chose to handle this. When the FAA decides to release a packet of new rules than do not infringe nor inhibit us R/C aircraft flyers, again, I will be the first to support and promote them. Pending the outcome of this will determine if I renew my AMA membership again and whether or not I affix any FAA numbers to my planes again. So, for now, those are the only 2 reasons I am keeping up with this crap.

HAPPY FLYING!

[fredmdbud]

“Park flyer” means aircraft that flow low and slow enough to fly within the confines of a small park. These would also tend to be below the .55lb threshold, thus exempt in the US.

[xviper]

We don't have "Park Flyer" memberships in Canada (that I know of). I don't even know what that means. We pay full membership to belong to a "club" or we don't fly at all (legally). I belong to 2 fields at present but used to belong to a 3rd field till it was closed. The one that closed did not require MAAC (like your AMA) but we still had to pay annual fees. The other 2 required MAAC plus their individual fees. With MAAC, you can join as many clubs as you like for one annual fee. One of those fields, I may fly there once a week, if that. It was a matter of choice and variety to belong to so many. If you are getting back into the hobby and don't know you want to continue or if you equate things to price per flight, then dealing with all these fees and regulations may not be for you. To be active in this hobby isn't cheap and it doesn't always stay stay that way when you first start. But also remember that it's already been said that these new regs are in the planning stage and it may be some time before they become "written in stone" and when they are implemented, the regs may not look anything like what the fear mongers are saying they "will" be.
We had the same deal in Canada when the current rules were being "talked" about. Permits, licences, tests, registration, ID and much more. Then came "inauguration" day and the rules looked nothing like what they were planning or hoping for. There were exemptions if you belonged to MAAC and flew at a sanctioned field. The only thing that happened that was a noticeable changed from what we had to fly under when dealing with the "club rules" already, was that we had to have a little piece of paper (with our information) on or in each plane we flew. They didn't even have to be permanent, just as long as the flying plane had one. I printed up some laminated tags and just tape one to my battery when a plane goes up. All the fear mongers and rule pushers and worry warts settled down and said, "Oh, is that all there is!" Tests and permits only applied to those who were doing it for commercial reasons or those who did not fly at sanctioned fields. Those who flew outside of sanctioned fields were then subject to municipal, provincial and federal laws already in place. This meant you virtually could NOT fly ANYWHERE without being subject to fines and prosecution for breaking local ordinances or provincial/federal park regs - had little to do with (Transport Canada or FAA). Beyond those, you have to deal with private land owner rights and trespassing laws.
My suggestion to Mr. Fish ......................... "Fly at a sanctioned field for now and worry about it when you see what the new regs really will be and how it will affect you and your club".

[flyin'fish]

Hi all. I'm a guy who got back into RC planes 4-5 years ago, after a 20 year hiatus. Recently, due to "life and stuff" I haven't flown in the last 2 years. Part of the trouble was finding a field nearby. Almost all of the local fields were controlled by large clubs who required joining the club in order to fly there. In addition, AMA membership and insurance were needed. Not a big deal IF I wanted to fly 4-5 days a week, but I don't. I've gone to state parks and tried flying on empty grass meadows and soccer fields, only to be chased by park rangers and referred to the "organized" legal field within the park. I threw my hands up and decided to put flying on the back burner.

This past week, I joined AMA and got a "Park Flyer" membership for $38/year. I figured this would at least get me admittance as a guest to a "legal" field. I especially wanted to bring 2 of my planes (28"-36" hi-wing trainers) down to SC so I could show my 2 grandsons how grandpa flies and crashes :-)). As I scanned AMA's website and read about things like Remote ID and FAA registration requirements, I'm beginning to think that it's not worth it to jump through all these hoops just to fly through a couple of batteries and go home. To rub more salt in the wound, I discover that the field in SC does not accept Park Flyer AMA Memberships.

So I'm in a quandary - do I register with the FAA and adorn my ID on my planes just to be considered "Field Legal" and gain access to a Club and it's facilities, do I go rogue and hunt for schoolyards and local parks and hope not to get caught, or do I throw all my stuff in a dumpster and call it quits?

[fredmdbud]

Every person who fly's R/C should be writing letters to the FAA immediately! I will begin mine today.

Yes, you should - the proposed rule will inevitably be different in its final draft, especially if the AMA membership machine gets in gear ...

[CVA59]

HAHAHAHAHA, I love the wrapping they put in on this "proposal" as relayed to us "sheep" in the video. "Oh, it's all about safety, enhancing the products, and so on, blah blah, blah". This is so comical to me, I will continue to stand on the opinion that this is strictly about the FAA having total power & control over us and our harmless hobby. There have been terrorists forever, manned aircraft since 1903 and R/C aircraft since 1938, but now, this is all such a HUGE problem that they have to create laws to govern our hobby, LOL. Again, the FAA can script all the detailed rules, plans and guidelines they want. However, "Mr. FAA"..........I am very proud to keep stating that I WILL NOT comply today, tomorrow or 4 years from now with your lies, rules or guidelines pertaining to a hobby that I have been peacefully doing for 30 years without one single incident!

To all the IDIOTS at the FAA who think this new "law" will stop stupid people from flying drones in places they shouldn't, IT WON'T! There will ALWAYS be stupid people flying drones in airspace where they have no business flying them! If this would forever and 100% stop the idiots out there who have created this crap from doing stupid stuff with their drones, I would be in 100% and agree totally but, IT WON'T! Any moron with the mental function of say, a mosquito, knows that. Again, because of a few bad apples who don't care about the AMA or protecting our hobby are simply going to laugh at the FAA and keep right on flying their drones in any unsafe manner they choose. These people have no vested interest in our hobby, they have no clue what we are trying to preserve and protect, they could care less. However, now, it appears that we all are going to have to suffer because of that element as with so many other things in life.

For all of you who feel like to do, you might want to go consider buying all the receivers & transmitters you can afford. I figure when (if) this FAA insanity actually happens, they will require all the transmitter & receiver makers to install the required remote ID crap before they can sell their products. I'm quite sure they will cover all the areas they can.

Every person who fly's R/C should be writing letters to the FAA immediately! I will begin mine today.


This guy says IT ALL!

https://www.youtube.com/watch?v=HjpTLAn87pQ&t=29s

[fhhuber]

RC car racers already have very small transponders that they use to log their laps. they are around $20.00 but the range is very limited.

Those are just transmitting the car ID number and are so short range they have to drive directly over the receiver antenna, which is less than an inch under the dirt.
They are low power on purpose so they won't trigger a sensor that is further around the track. Usually there are 4 to 6 sensors spaced around the track and the car has to pass over them in the correct order, or go past the last one crossed in correct order and then continue in the correct order again for laps to count. (so the guys flipping cars back upright at the local track toss the cars back over the line if they are near a sensor line)

But, yes, the transponders can be cheap.
We have telemetry in some RXs that are under $50 and they transmit back at full range of the 2.4 ghz RC system. Add the appx $15 GPS module and you have almost as much data going back to the TX as is recorded in some commuter airline flight controls black boxes. (No cockpit voice recorder) It already has the TX ID and RX (which is transmitting back the telemetry) ID encoded in the 2.4ghz communication protocol...That is how it knows to reject data blocks from other transmitters.

If you have telemetry, you have easily more data going back to your TX than the FAA needs for their system. You just have to send it out on their desired frequency in their desired data format.
And this is where the FAA and FCC are going to cause you high cost.

[fredmdbud]