The is a Comment on the Federal Aviation Administration (FAA) Proposed Rule: Remote Identification of Unmanned Aircraft Systems
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Comment
As a 10,000+ hour ATP, former flight instructor, and Part 107 certificate holder this proposed NPRM is poorly reasoned, based on fallacy, harmful towards an emerging industry, and a detriment to education and our future.
As a professional pilot, aircraft owner, and UAS operator - I fail to see the unsolvable safety risks posed by UAS operation. I've not been able to find the accidents, the fatalities, or the damages caused by UAS. This burdensome regulation punishes, and inhibits the growth of an emerging industry by onerous, overreaching regulation. Flying in my private aircraft, or in the jets at work - I wouldn't fear hitting a UAS any more than I'd fear a bird strike. See and avoid seems to be working. Altitude segmentation and separation works. I don't fly my UAS above our current limits, nor do I expect to see aircraft flying at or below treetop height. We already have exclusion around airports by regulation - and requiring transponders won't stop someone from operating nefariously by intent.
The technology that is UAS is rapidly developing. No doubt commercial interests will earn huge profits by capitalizing off this market - in delivery of goods and services, and the sales, operation and service of the UAS themselves. However the garage tinkerer, the students, and amature engineers that experiment and play with these technologies should not be inhibited in their pursuits. Mandating transponders (or other means of electronic ID) will be a burden of compliance that only raises the barrier to entry.
FPV, drones, Remote Controlled aircraft and the like are a tremendous draw for young people. They excite kids about science, math and engineering. They're open and accessible to kids, and something that really engages students well - capturing their minds and perhaps helping to shape their career choices. Locking these hobbies down to only certain areas closes the door to this opportunity. I can speak from experience - as my local AMA flying field is fenced in, closed off, and only open to those that have gate access, not the general public. Kids can't even come spectate. However when I fly my FPV and model aircraft at the local park, I get asked daily by children and adults about the hobby, and how they can become involved. Closing the door to this opportunity will do to UAS what product liability did to General Aviation in the mid 1980's. You'll kill it, and lock it out to the general public leaving it only for the corporations and the wealthy.
I think you're potentially closing off opportunity for the organic growth and development of a burgeoning technology. You're taking the hobby away from children and hobbyists, and citing threats that have never materialized and can be addressed by other technology.
Leave a door open to the tinkerers. Let the garage innovators build, test and fly things in their backyards, the local parks, and at schools. Put the burden on commercial operators to fly higher, above where the amature builders and student projects fly. Internet access isn't everywhere - and those places where networks haven't yet reached shouldn't be off limits to the general UAS flying public - they're our skies too.
I hope you take these thoughts into consideration, and don't simply bow to the commercial interests and lock out the general public citing risks and threats that are being used to close the door on an exciting field of innovation. |
