Proposed NYC Rule changes are horrid.

BetterBizWorks · Jun 20, 2023

Leave it to NYC to lead on the negatives.

jmaganaski · Jun 24, 2023

Dale D said:
Vic:

You need to write something that we can all paraphrase and send it in ASAP. Please also include the correct e-mail for us to send our letter to.

Dale G. Davis, M.D.
Miami

What about an open letter we can all sign?

Starz · Jun 24, 2023

jmaganaski said:
What about an open letter we can all sign?

The system in the link provided in post #1 is for individual use and is adequate for the purpose intended. Probably what is expected to be used in NYC‘s system and they may not utilize any other form of contact for this purpose and may disregard what you mention. You are certainly welcome to contact yourself someone in authority from NYC to verify this information.

flyeratdca · Jun 24, 2023

Vic Moss said:
Call again for comments on the proposed NYC drone rules change.

As of today, there are only 13 comments, including one who is for the changes (it sounds like she hates drones, so there's that...). Mine will be approved within a day or so.

We need to comment on this, even if you don't ever plan on flying in NYC. If this passes, other cities may look at this as a great example of what they should do. And that would cripple the drone industry, both commercially and recreationally, just as it will in NYC if passed as written.

A few points:

First, these rules would not interfere with the FAA's sole authority to control the NAS. These are ground use rules, and cities and states are allowed to impose those. So please don't use that as an example of why NYC shouldn't do this. That's is incorrect, and your comments will lose credibility.

Make sure you let them know the notification requirements are onerous and would basically create the same "drone ban" they have now, except put it in actual ordinance instead of relying on an interpretation of a law from the 1940s.

Strongly suggest that the committee shelve this attempt at rule change, and instead start the process again, but this time work with all stakeholders in order to come up with a workable solution.

If NYC would do that, we can have a much larger voice. Because it's obvious to anyone who reads this proposal that the committee never bothered talking to those this would affect.

Also, mention that RID will be required on 9.16.23, and it will have much of what they want to know anyway.
So put together a reasonable and professional response, then go to their comment page (https://rules.cityofnewyork.us/.../applications-to.../), and comment.

This is imperative. Whether you fly under 107, or 44809, you need to comment.

Be professional.

Hi Vic--

Thanks for the awareness of this really onerous proposal. I'm involved in a lot of rulemaking with the FAA and see things like this a lot. A few questions/thoughts for you on this proposal.

1. Did the NYPD coordinate this proposal with local stakeholders? I don't know if there's a local group, association, non-profit that could speak for the affected users but that might be an opportunity to include. These kinds of rules usually reflect one point of view, in this case, law enforcement. Without the balance of user input, these rules will regularly overstep in support of making government's workload easier while imposing significant limitations on users.

2. Looks like July 7 is the deadline for comment submission.

3. These appear to be very penalizing requirements specifically targeting the drone community. The privacy and cyber policies suggested in the rule appear to be unequally applied across a broad spectrum of photography and videography users. Does the city require similar applications and privacy protections for ground based photography? How about aerial based photography or videography? I suspect that non-commercial ground-and aerial-based photography and videography anywhere in the city is allowed without a permit as long as airspace rules are followed.

4. The RID mandate mentioned elsewhere in the post is a valuable consideration. States and Federal government rules creating duplicative requirements to collect the same information is a burden on citizens. State and Federal governments should be working more collaboratively to seek needed information.

5. This notionally would not prevent anyone on the rivers or adjoining shores from flying drones over areas NYPD reportedly wants to address.

6. If successful, other cities will look at this effort in NYC as a model to follow to impose significant restrictions on drones elsewhere. Stopping this now is important if we hope to retain the privilege of flying our amazing machines in other parts of the country.

6. This is a classic case of government over reach that all of us should resist. Creating a permitting process that ultimately is so difficult and burdensome to apply for would create a de facto ban under the guise of a public process.

Doug