Attendance at the Jan. 2020 meeting was sparse with only myself and six other hardy members, so we really did not take minutes, but there were two notable discussions and distribution of a lot of hobby materials free for the taking, rather than our normal raffle.
The primary topic of discussion was the FAA notice of proposed rule making requiring remote ID of “UAS,” or unmanned air systems which by their definition includes all radio controlled aircraft. I will address this concern in more depth below.
The other topic was discussion of an opportunity to view a remarkable HO scale model railroad club lay out, the Carquinez Model Railroad Society (CMRS) which is located in Crockett. This is only about 25 minutes from the Church Gym where we have our meetings.
This is their website: http://cmrstrainclub.org/
2020 Open Houses (All Open Houses are from 10 AM to 4 PM. Requested Donation – Adults $5, kids are free)
Sunday January 26th
Saturday and Sunday March 14th & 15th
Saturday and Sunday May 16th & 17th
Saturday August 8th
Saturday and Sunday October 17th & 18th
Saturday and Sunday December 12th & 13th
Below is a video of their lay out. Toward the end it seemed to intermittently loose the sound, but if gives you a good view of the operation of the layout. Crockett is an interesting place to visit anyway.
Below is a copy of a statement and plea from the AMA website. https://www.modelaircraft.org/about-ama/advocacy
On December 26, the FAA release a proposed rule for remote identification of UAS. There are several areas of concern with the proposed rule that AMA will be pushing back on and we need your help advocating for change.
While the proposal does include AMA’s request to exempt flying sites, the rule should also provide community-based organizations (CBOs), like 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 may not take place at fixed flying sites. Third, the rule should account for situations where there is no internet connectivity, as 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 also requested an extension on 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 everyone submit a comment.
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 in the blog below 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.
When writing your comment, please identify your concerns with the proposed rule. It is very important to provide a summary of how your concern will impact your model aircraft operations and include data to back up those concerns. For example, use numbers and address the financial impact the proposal will have on you and suggest alternative solutions.
Thank you in advance for your advocacy. If you are interested in reading a more detailed summary of the FAA’s remote ID proposal, visit our blog here.
Personally I think we could make a good case for excluding aircraft that have no autonomous navigation capability for the requirements for remote Identification.
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Below is the template for response Dennis Romano referred to during the meeting. Feel free to copy and paste as much or as little as you feel inclined.
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This proposal is very disturbing. It is a violation of our right to privacy and personal freedoms by requiring 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 for recreation as a hobby.
First, 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 review fixed flying sites and to amend the rule to allow for the establishment of new sites in the future. These sites should not be tied to a CBO, if you own property you should be able to apply for a fixed site approval as a land owner.
Second, the FAA must create a pathway for remote ID compliance at model airplane special 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 simple process for event organizers to apply for, and receive, waivers from remote ID requirements for these special 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, there is a requirement for standard and limited classification 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 we 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, or the ability to operate a standard or limited classification aircraft within a FRIA without using RID broadcast. .
Fourth, the annual cost of adding RID equipment to a cell phone account that will require a Smartphone with annual subscription of a service provider are just additional financial burdens on the hobby. We have enjoyed this hobby safely since the 1940’s without the use of RID or the complexity of connecting to the internet while flying model aircraft. Our hobby is line of sight non autonomous flight.
One of the stated purposes of this rule is to improve safety by providing situational awareness to the manned and unmanned aircraft that are operating in the NAS. This rule does not provide any ADS-B type signal for manned aircraft or ATC. RID for commercial drone operations should be just like manned aircraft based on ADS-B, not the internet. Commercial UAS aircraft should be equipped with software like “Geo Fencing” to prevent flight near congested airspace.
Finally, the FAA should reconsider the proposal to register each aircraft, which will impose a cost and compliance burden on the recreational model aviation community. While individual aircraft registration may make sense for beyond line of sight commercial and autonomous operations, it is an unnecessary requirement for aircraft designed to be flown within line of sight for recreation. We build and fly model airplanes because it is a passion; and many of us own dozens 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 by stimulating young minds, 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.
First, 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 review fixed flying sites and to amend the rule to allow for the establishment of new sites in the future. These sites should not be tied to a CBO, if you own property you should be able to apply for a fixed site approval as a land owner.
Second, the FAA must create a pathway for remote ID compliance at model airplane special 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 simple process for event organizers to apply for, and receive, waivers from remote ID requirements for these special 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, there is a requirement for standard and limited classification 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 we 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, or the ability to operate a standard or limited classification aircraft within a FRIA without using RID broadcast. .
Fourth, the annual cost of adding RID equipment to a cell phone account that will require a Smartphone with annual subscription of a service provider are just additional financial burdens on the hobby. We have enjoyed this hobby safely since the 1940’s without the use of RID or the complexity of connecting to the internet while flying model aircraft. Our hobby is line of sight non autonomous flight.
One of the stated purposes of this rule is to improve safety by providing situational awareness to the manned and unmanned aircraft that are operating in the NAS. This rule does not provide any ADS-B type signal for manned aircraft or ATC. RID for commercial drone operations should be just like manned aircraft based on ADS-B, not the internet. Commercial UAS aircraft should be equipped with software like “Geo Fencing” to prevent flight near congested airspace.
Finally, the FAA should reconsider the proposal to register each aircraft, which will impose a cost and compliance burden on the recreational model aviation community. While individual aircraft registration may make sense for beyond line of sight commercial and autonomous operations, it is an unnecessary requirement for aircraft designed to be flown within line of sight for recreation. We build and fly model airplanes because it is a passion; and many of us own dozens 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 by stimulating young minds, 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.
concordmodelengineers.org 