Got comments to FAA notice of proposed rulemaking (NPRM)? Deadline March 2
02-27-2020, 11:40 AM
#1
Got comments to FAA notice of proposed rulemaking (NPRM)? Deadline March 2
If you have not read it, it is a doozy. 33 pages.....just for the Executive Summary
I was curious if anyone had a clever slant on their responses (perhaps unique to jets, as I don't want the thread moved!)
The comments are due on March 2.
I was curious if anyone had a clever slant on their responses (perhaps unique to jets, as I don't want the thread moved!)
The comments are due on March 2.
02-27-2020, 12:09 PM
#2
https://eaa.org/eaa/news-and-publica...Remote-ID-Rule
https://www.aopa.org/news-and-media/...drone-tracking
Bob Klenke
JPO President
02-27-2020, 12:29 PM
#3
There are 23 basic areas where we as Jet Guys have issues with this NPRM. That does not include the FAA's overly Risk Adverse Culture, which has been studied and documented and the FAA still has not yet solved! If you do not know these 23 issues, then it is time for you to review the currently made comments! Every one of them has a direct negative impact on recreational modeling! IMHO, the most important issue is to make a separate rule for "recreational modeling." That may just stop the FAA from trying to implement Remote ID by having "No remote ID" in the same rule, etc.. Once there is a separate rule, it will be a lot easier to identify and resolve the other 22 issues that would be a lot easy to pick out and address! Also, ...
There is a lot more to this than just commenting to the FAA's NPRM. The root cause of this issue is the Legislative folks were conned by the commercial committees and lobbyists to require "Remote ID" in the FAA Reauthorization Act of 2018. The law should have required something like "collision avoidance methods or technology" versus "Remote ID." They made the law too narrow. For example; What is going to happen when "Remote ID" is obsolete in a few years? So we really need to go after the legislators! The FAA is only trying to make rules to meet the current law's requirements! Write to your legislators! Here a link to quickly find all your legislators and the President and make a comment that will go to all of them:https://results.org/volunteers/actio...src=%2fAddress
Yes we need to make NPRM comments to reshape its overbearing regulations. But, we also need to be more proactive by better organizing into one loud voice and get that voice in a position where that voice proposes the draft laws instead of us just commenting on what others propose. To accomplish this would make us more proactive!
Also, modelers have to understand that the AMA is a non-profit organization. There are limits to what they can do when it comes to directly influencing legistators. That is why there is a Political Action Committee forming. They can use thier $s to directly impact legislators! For the PAC's web site modelaviationpac.com For email [email protected]
So, please do make NPRM comments, support the AMA as our "Voice," volunteer for AMA leadership if you can or make sure you get your ideas to AMA, and lastly support the new PAC. They need seed $S to start having an imediate and direct impact!
There is a lot more to this than just commenting to the FAA's NPRM. The root cause of this issue is the Legislative folks were conned by the commercial committees and lobbyists to require "Remote ID" in the FAA Reauthorization Act of 2018. The law should have required something like "collision avoidance methods or technology" versus "Remote ID." They made the law too narrow. For example; What is going to happen when "Remote ID" is obsolete in a few years? So we really need to go after the legislators! The FAA is only trying to make rules to meet the current law's requirements! Write to your legislators! Here a link to quickly find all your legislators and the President and make a comment that will go to all of them:https://results.org/volunteers/actio...src=%2fAddress
Yes we need to make NPRM comments to reshape its overbearing regulations. But, we also need to be more proactive by better organizing into one loud voice and get that voice in a position where that voice proposes the draft laws instead of us just commenting on what others propose. To accomplish this would make us more proactive!
Also, modelers have to understand that the AMA is a non-profit organization. There are limits to what they can do when it comes to directly influencing legistators. That is why there is a Political Action Committee forming. They can use thier $s to directly impact legislators! For the PAC's web site modelaviationpac.com For email [email protected]
So, please do make NPRM comments, support the AMA as our "Voice," volunteer for AMA leadership if you can or make sure you get your ideas to AMA, and lastly support the new PAC. They need seed $S to start having an imediate and direct impact!
02-27-2020, 01:35 PM
#4
Len,
I agree with most of your comments. However, I would add that the FAA Reauthorization bill *required* the FAA address much more than Remote ID, including Beyond Visual Line Of Sight, larger UAS in the NAS, use of UAS for compensation and hire, etc...
The FAA has been told by the other organizations in the federal government, i.e., Homeland Security and the TSA primarily, that they *will not* consider any other proposed rules from the FAA until RID gets done. That is why the FAA has pushed Remote ID to the front - even though it has some of the most unknowns - they have to get that done before any of the other things Congress mandated that they do, can move forward.
The bottom line is, there is *no way* that RID is not going to happen, and any energy expended in trying to get the whole idea scrapped is just whistling into the wind, so to speak. The only work around for us is to get the RID rule implemented such that we can live with it...
Bob
I agree with most of your comments. However, I would add that the FAA Reauthorization bill *required* the FAA address much more than Remote ID, including Beyond Visual Line Of Sight, larger UAS in the NAS, use of UAS for compensation and hire, etc...
The FAA has been told by the other organizations in the federal government, i.e., Homeland Security and the TSA primarily, that they *will not* consider any other proposed rules from the FAA until RID gets done. That is why the FAA has pushed Remote ID to the front - even though it has some of the most unknowns - they have to get that done before any of the other things Congress mandated that they do, can move forward.
The bottom line is, there is *no way* that RID is not going to happen, and any energy expended in trying to get the whole idea scrapped is just whistling into the wind, so to speak. The only work around for us is to get the RID rule implemented such that we can live with it...
Bob
02-27-2020, 03:31 PM
#5
Len,
I agree with most of your comments. However, I would add that the FAA Reauthorization bill *required* the FAA address much more than Remote ID, including Beyond Visual Line Of Sight, larger UAS in the NAS, use of UAS for compensation and hire, etc...
The FAA has been told by the other organizations in the federal government, i.e., Homeland Security and the TSA primarily, that they *will not* consider any other proposed rules from the FAA until RID gets done. That is why the FAA has pushed Remote ID to the front - even though it has some of the most unknowns - they have to get that done before any of the other things Congress mandated that they do, can move forward.
The bottom line is, there is *no way* that RID is not going to happen, and any energy expended in trying to get the whole idea scrapped is just whistling into the wind, so to speak. The only work around for us is to get the RID rule implemented such that we can live with it...
Bob
I agree with most of your comments. However, I would add that the FAA Reauthorization bill *required* the FAA address much more than Remote ID, including Beyond Visual Line Of Sight, larger UAS in the NAS, use of UAS for compensation and hire, etc...
The FAA has been told by the other organizations in the federal government, i.e., Homeland Security and the TSA primarily, that they *will not* consider any other proposed rules from the FAA until RID gets done. That is why the FAA has pushed Remote ID to the front - even though it has some of the most unknowns - they have to get that done before any of the other things Congress mandated that they do, can move forward.
The bottom line is, there is *no way* that RID is not going to happen, and any energy expended in trying to get the whole idea scrapped is just whistling into the wind, so to speak. The only work around for us is to get the RID rule implemented such that we can live with it...
Bob
As much as i hate to say this, Bob is spot on and this is exactly what i have been saying ever since this Nprm came out. Once the FAA denied the extension period for comments, it just cemented that why they are saying could become the rules, WILL become the rules. There’s something Bigger that they need done that they are getting stonewalled with because this remote Id topic is done.
Its not a matter of if we can get rid of it, its a matter of how we are going to get it changed after they implement it so it doesnt kill our hobby entirely.
02-27-2020, 04:55 PM
#6
Did not think I suggested getting rid of the NPRM or resulting rules. Remote ID should be O.K. for Commercial operations. The FAA essentially did get rid of Remote ID for us when they created the No Remote ID option. Problem is they are also suggesting to phase the exemption out over time. All I am saying is separate the No Remote ID option out of this NPRM and they should get an easy pass for Standard Remote ID. Then iron out the rules for recreational modeling, which may include some of the Limited Remote ID rules that may apply to recreational modeling. Separating the two types of end-users, makes things a whole lost easier for everyone to interpret and clearly define.
My other point was we also need to be focused on the legislators. They passed the law that mandates Remote ID. On-board collision avoidance technology will most-likely surpass Remote ID in the near future. Remote ID and the infrastructure necessary to make it all work will most-likely end up proving to be cost-ineffective as compared to other emerging technology. For recreational modeling, we have proven that all that is needed the see and avoid methodology and maintain visual sight of our models. Throw in some reasonable altitudes and we will continue to prove what we are doing is safe. We need to clearly get that message across to the legislators! The FAA current authorization is up for reauthorization in 2022. That gives us a couple years to get our act together. In the meantime, with our comments maybe we can put some dents in the current NPRM and current legislators foreheads.
If you don't complain, things will never change!
My other point was we also need to be focused on the legislators. They passed the law that mandates Remote ID. On-board collision avoidance technology will most-likely surpass Remote ID in the near future. Remote ID and the infrastructure necessary to make it all work will most-likely end up proving to be cost-ineffective as compared to other emerging technology. For recreational modeling, we have proven that all that is needed the see and avoid methodology and maintain visual sight of our models. Throw in some reasonable altitudes and we will continue to prove what we are doing is safe. We need to clearly get that message across to the legislators! The FAA current authorization is up for reauthorization in 2022. That gives us a couple years to get our act together. In the meantime, with our comments maybe we can put some dents in the current NPRM and current legislators foreheads.
If you don't complain, things will never change!
02-27-2020, 05:07 PM
#7
You can fly a 747 clear of clouds, 1 nm vis, nordo, no squawk at 500' in class g airspace and the faa doesnt care. Fly a foamy rc model that weights .56lbs line of sight on a sunny 70 degree day and you are a felon. Our government is full of F'n idiots.
Last edited by tp777fo; 02-27-2020 at 05:12 PM.
02-28-2020, 07:53 AM
#10
And all this starts because of drones, long time ago Bob Violett told ama to never got involved with the drones they should have their own organizations and they should be that one to deal with this problem, but ama wants all the money but maybe only 20% off drones owners actually a ama card holder the other 80% buying them and flying everywhere and cost all the problems. Please correct me if I’m wrong but I think that all is started because of the idiots who got the first uav drones and started flying by the airports and other sensitive areas.
Last edited by sysiek; 02-28-2020 at 08:03 AM.
02-28-2020, 07:14 PM
#12
Len,
I agree with most of your comments. However, I would add that the FAA Reauthorization bill *required* the FAA to address much more than Remote ID, including Beyond Visual Line Of Sight, larger UAS in the NAS, use of UAS for compensation and hire, etc...
The FAA has been told by the other organizations in the federal government, i.e., Homeland Security and the TSA primarily, that they *will not* consider any other proposed rules from the FAA until RID gets done. That is why the FAA has pushed Remote ID to the front - even though it has some of the most unknowns - they have to get that done before any of the other things Congress mandated that they do, can move forward.
The bottom line is, there is *no way* that RID is not going to happen, and any energy expended in trying to get the whole idea scrapped is just whistling into the wind, so to speak. The only work around for us is to get the RID rule implemented such that we can live with it...
Bob
I agree with most of your comments. However, I would add that the FAA Reauthorization bill *required* the FAA to address much more than Remote ID, including Beyond Visual Line Of Sight, larger UAS in the NAS, use of UAS for compensation and hire, etc...
The FAA has been told by the other organizations in the federal government, i.e., Homeland Security and the TSA primarily, that they *will not* consider any other proposed rules from the FAA until RID gets done. That is why the FAA has pushed Remote ID to the front - even though it has some of the most unknowns - they have to get that done before any of the other things Congress mandated that they do, can move forward.
The bottom line is, there is *no way* that RID is not going to happen, and any energy expended in trying to get the whole idea scrapped is just whistling into the wind, so to speak. The only work around for us is to get the RID rule implemented such that we can live with it...
Bob
I've haven't heard ANYTHING that DEA, TSA, HLS.....is pressuring the FAA, from ANY of the FAA people I've spoken to.
The rules comes from the reauthorization and all of the facilities around me are happy with 400'. When it comes to approving people flying above 400' there is not a consensus. There is an issue with class G airspace. It's "supposed" to be uncontrolled airspace, but they want to control it....
There currently is no (almost) method to get approval to fly above 400'.....the FAA is considering an SRM for every request(flying site). An SRM is a panel (Safety Risk Management) of all the stakeholders to review the request. To me and everyone I've spoken to this is absurd. Do know that this entire process is fractured and the FAA barely knows what is going on with the law. I've done a lot of digging and I generally get sent to someone else....
I'm still working on all of this for our club.....YMMV
It's also very clear most people (jet rallies) are just going to ignore the 400' limit and wait to be caught. That's no big deal right up until it is......
Last edited by sideshow; 02-28-2020 at 07:30 PM.
02-29-2020, 08:56 PM
#13
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https://www.regulations.gov/docketBr...=FAA-2019-1100 Here is all who have submitted comments. you can read a few if you are looking foe ideas to add to your own comments.
03-01-2020, 04:49 AM
#14
My Feedback: (26)
https://www.regulations.gov/docketBr...=FAA-2019-1100 Here is all who have submitted comments. you can read a few if you are looking foe ideas to add to your own comments.
03-01-2020, 08:44 AM
#15
03-01-2020, 11:07 AM
#16
My Feedback: (52)
A point that very few have talked about is the definition of an "amateur built" model. If the FAA proposal stands with over 50% of the content built by the modeler we will be in serious trouble. In fact, altitude limits and remote ID will be irrelevant as there will not be any R/C models to fly.
If you have not commented yet or want to submit another, I would suggest this be a focus of your comment. The proposal is buried in the rule and does not have much space in terms of words but it is very significant to the survival of our hobby.
Paul S
If you have not commented yet or want to submit another, I would suggest this be a focus of your comment. The proposal is buried in the rule and does not have much space in terms of words but it is very significant to the survival of our hobby.
Paul S
03-01-2020, 02:15 PM
#17
A point that very few have talked about is the definition of an "amateur built" model. If the FAA proposal stands with over 50% of the content built by the modeler we will be in serious trouble. In fact, altitude limits and remote ID will be irrelevant as there will not be any R/C models to fly.
If you have not commented yet or want to submit another, I would suggest this be a focus of your comment. The proposal is buried in the rule and does not have much space in terms of words but it is very significant to the survival of our hobby.
Paul S
If you have not commented yet or want to submit another, I would suggest this be a focus of your comment. The proposal is buried in the rule and does not have much space in terms of words but it is very significant to the survival of our hobby.
Paul S
IF your local field can be declared a FRIA you are ok temporarily (FRIA = existing fields that could be certified by the faa for ONLY one year. Loose that field or have the faa take it off the list and it is gone forever). The FAA wants everything to have remote ID, and they want everything to be built and sold by a company that has certified the WHOLE thing (including the transmitter) as one package.
Next to medical devices and nuclear, FAA certification is the worst. The very fact that the FAA are planning this means they really don't think anyone does what we do ( meaning owning a plane that you build/install an engine and radio into yourself). These type planes, by FAA design, are outlawed everywhere but the dwindling FRIA sites.
Imagine a business investing, or continuing to invest in this US hobby space (jet engine/radio/kit/ARF) under these conditions.
Last edited by mr_matt; 03-01-2020 at 02:17 PM.
03-01-2020, 02:39 PM
#18
Yep - one owner of a well known radio retailer has already speculated publicly about what he might have to do to keep his business open if this passes...and it all involves dumping all hobby related items (which is all his business currently sells) and moving into some other area.
03-01-2020, 02:47 PM
#19
- The F'n idiots will destroy model aviation and the industry that goes with it and will still have the morons flying drones at JFK EWR and all the other airports and never understand why they were unable to "fix" it. Typical gumment bureaucracy. Thats what happens when the office pilots dont see the difference between a foamy and a 747.
Last edited by tp777fo; 03-01-2020 at 02:51 PM.
03-01-2020, 05:07 PM
#20
Well said. Up till now, I presumed worst case that a small (not yet developed) transponder could be mounted in any model and it would be compliant. As best I can tell, this scenario is not acceptable in the rules as written.
IF your local field can be declared a FRIA you are ok temporarily (FRIA = existing fields that could be certified by the faa for ONLY one year. Loose that field or have the faa take it off the list and it is gone forever). The FAA wants everything to have remote ID, and they want everything to be built and sold by a company that has certified the WHOLE thing (including the transmitter) as one package.
Next to medical devices and nuclear, FAA certification is the worst. The very fact that the FAA are planning this means they really don't think anyone does what we do ( meaning owning a plane that you build/install an engine and radio into yourself). These type planes, by FAA design, are outlawed everywhere but the dwindling FRIA sites.
Imagine a business investing, or continuing to invest in this US hobby space (jet engine/radio/kit/ARF) under these conditions.
IF your local field can be declared a FRIA you are ok temporarily (FRIA = existing fields that could be certified by the faa for ONLY one year. Loose that field or have the faa take it off the list and it is gone forever). The FAA wants everything to have remote ID, and they want everything to be built and sold by a company that has certified the WHOLE thing (including the transmitter) as one package.
Next to medical devices and nuclear, FAA certification is the worst. The very fact that the FAA are planning this means they really don't think anyone does what we do ( meaning owning a plane that you build/install an engine and radio into yourself). These type planes, by FAA design, are outlawed everywhere but the dwindling FRIA sites.
Imagine a business investing, or continuing to invest in this US hobby space (jet engine/radio/kit/ARF) under these conditions.
to fly our models and as long as we keep our models within two miles of that we we should be ok.
03-02-2020, 12:13 AM
#21
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And all this starts because of drones, long time ago Bob Violett told ama to never got involved with the drones they should have their own organizations and they should be that one to deal with this problem, but ama wants all the money but maybe only 20% off drones owners actually a ama card holder the other 80% buying them and flying everywhere and cost all the problems. Please correct me if I’m wrong but I think that all is started because of the idiots who got the first uav drones and started flying by the airports and other sensitive areas.
