AMA Government Affairs sent us an email relating to FAA's recent Notice of Proposed Rule Making (NOPR) for "Remote ID" of UAS. As written, this NOPR could have significant, negative impact to the modeling community and how we may conduct our hobby. However, as usual, AMA Government Affairs does have a plan and a strategy to work with the FAA to achieve the best possible outcome (on the final rule) for its membership. But, they need our help!
The comment period for the NOPR on Remote ID is open now. AMA is requesting, and the Board of AAM strongly agrees, that all AMA members (and other interested parties) provide comment to FAA. As usual, AMA has automated this process. The instructions and link, for providing comment may be found below (in the email from AMA Government Affairs). To begin, simply click on the "COMMENT NOW" button below. However, you will also need to "cut and paste" the text from AMA's Template Comment into the comment box. The Template Comment appears below.
Please note that comments are more effective if they are customized and personalize. AMA is encouraging everyone to edit the template to include your personal experience, or create your own message entirely. I have included a copy of my Comment on AAM's website as an example.
The comment period ends 3/2/2020, but please don't delay, DO IT TODAY!!!
Thanks in advance for your cooperation,
Joe Pirozzoli, President
Arvada Associated Modelers
AMA’s Template Comment on UAS Remote ID
I am writing in response to the FAA’s notice of proposed rulemaking on remote identification of unmanned aircraft systems (UAS). I am deeply concerned that some elements of the proposal could impose significant costs on the model aviation community and unnecessarily restrict existing, safe model aircraft operations.
First, while I am glad the proposal includes an option to comply with remote ID by flying at an approved fixed site, I am concerned that the rule arbitrarily limits the number of approved sites and prohibits the establishment of new sites. As such, the rule appears designed to phase out these sites over time, rather than treat them as a viable long-term option for complying with remote ID. I encourage the FAA to view fixed flying sites as part of a viable long-term solution to remote ID, and to amend the rule to allow for the establishment of new sites in the future.
Second, the FAA must create a pathway for remote ID compliance at AMA events and competitions, which may not take place at fixed flying sites. These events take place in defined locations for a short period of time, like an air show. For remote ID compliance purposes, they should be treated like fixed flying sites. I encourage the FAA to create a light process for event organizers to apply for, and receive, waivers from remote ID requirements for these ad hoc events and competitions, many of which support local charities.
Third, the rule must consider hobbyists who fly in rural areas with little or no internet connectivity. As I read the proposed rule, I would be required to have an internet connection even if flying at an approved fixed flying site in a rural part of the country. Unfortunately, some rural areas don’t have adequate cell service, which means I could not be able to fly. Rural locations are frequently the safest places to fly because they are away from people, other aircraft and structures. The FAA needs to provide a solution for these areas, such as the ability to comply from home or other WIFI-enabled locations.
Finally, the FAA should reconsider the proposal to register each aircraft, which will impose a cost and compliance burden on the model aviation community. While individual registration may make sense for beyond line of sight operations, it is an unnecessary requirement for aircraft designed to be flown within line of sight. We build and fly model airplanes because it is a passion; and many of us own dozens, if not hundreds, of aircraft of different shapes and sizes, some of which we fly infrequently. The time and cost involved in registering each model individually would be substantial and runs counter to the current registration framework for recreational operators. Also, aircraft that are built by hand do not have serial numbers, which makes individual registration more difficult.
Again, I urge you to carefully consider and address my concerns about the remote ID proposal. Model aviation is the natural precursor to careers in aviation, including commercial pilots and engineers and more – jobs which the U.S. desperately needs to fill. 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.
You can also view some detailed comments made by Gordon Collyer below.