FAA/DOT UAS Registration - A Very Short Window to Comment

Hi All,

We have a very short window of opportunity to comment on the FAA's proposed registration process.

I have sent in the following comment which you are welcome to copy, edit, do whatever you want with, but I think it realistically presents a decent case for moderation and common sense on the part of the FAA.

(Yeah I know good luck with that!)

In any case, here is my comment:

I understand the need for increased accountability when dealing with UAS of all types and some sort of registration process if appropriately limited can provide the access needed to better assure safety for everybody.
But there are some very important issues that should not be ignored.
There is a very large hobby market already in existence including RC Planes and toy quadcopters with many tens of thousands of people already owning and flying.
And so far these have been flying for decades with a very good safety record.
There are several classes of remotely controlled flying things that represent little or no real hazard to anyone, based on light weight, low mass and short range.
Individual UAS registration seems excessive, I personally have over 20 RC planes and quadcopters and registering each of them would be an unnecessary burden and serve no practical purpose.
So I propose that you consider the following.
1. Register "pilots" not UAS and make it free or very cheap in order to encourage compliance. Provide a pilot registration number that is required to be affixed to each of the "pilot's" qualifying UAS.
You could even provide some legal obligations information in the course of the pilots registration process.
This is much less ponderous than trying to deal with huge numbers of each individual UAS.
2. Set some reasonable limits on what is to be defined as a UAS.
At a minimum their should be a weight limit below which registration is not required.
For Multicopters I would suggest 1 Kilogram as this is a common cutoff in Europe and the UK but I realize that 1 kilo could still be dangerous and even 1 pound could be OK and would represent very little hazard.
You could also consider exempting specific examples of both quadcopters and fixed wing UAS based on specific construction benefits such as foam construction, short range and low mass.
It is my feeling that if you do not exempt toys and small UAS you will create an unenforceable and ponderous mess and damage the existing hobby and toy markets severely for no reason other than that you can.
I sincerely hope that you choose to take a conservative and reasonable approach to this that truly serves all of the American Public.

You can send your commentst in via the link here:

http://www.regulations.gov/?mc_cid=0b6392ab70&mc_eid=07facd12d4...

3DRs link on this weeks download doesn't work and is already closed for some reason, but this one is still open (as I write this anyway).

Only have a few days to comment (probably don't want a repeat of all those comments they got last time).

Best Regards,

Gary

Views: 853

Comment by EngineerX on October 29, 2015 at 2:12pm

Thanks for posting link for online-comment! I sent my comment. Used yours as a template.


Moderator
Comment by Gary Mortimer on October 29, 2015 at 2:18pm
Comment by EngineerX on October 29, 2015 at 2:48pm

Looks like a very well represented task force, hopefully they don't bury FPV enthusiasts, the moderate-responsible kind that are only interested in flying sub 1 kg copters or  fixed wings, close range, below 400ft at the local park or R/C airfield

They should have included Hamasaki San...AKA TimeCop. LoL 

Comment by Tony Kenward on October 29, 2015 at 4:25pm

You advised that the task force takes a "conservative" engineering approach?

Oyyyyyy vey.

Comment by Gary McCray on October 31, 2015 at 6:48pm

 am advising that the FAA takes a conservative approach and not implement excessive, oppressive and unenforceable rules and restrictions.

Comment by Gary McCray on October 31, 2015 at 6:52pm

Hi all,

When I put this Blog post in there were 61 comments, now there are 1481 and the vast majority in support of a  more reasonable and supportable approach.

It may not make much difference, but at least we will be heard.

Best,

Gary

Comment by Tony Kenward on November 1, 2015 at 4:06am

Hopefully those in the hobby RC community come across to the working group as reasonable and safety-minded individuals that want to contribute to the discussion.  There are a lot of big players at that table, with a lot at stake for everyone involved.

We won't get a seat at the adult's table if the comments just turn into another gov'mint / FAA hate-fest for anonymous posters.  IMHO

http://www.regulations.gov/?mc_cid=0b6392ab70&mc_eid=07facd12d4#!docketBrowser;rpp=25;po=0;dct=PS;D=FAA-2015-4378;refD=FAA-2015-4378-0022

Comment by Tony Kenward on November 1, 2015 at 4:21am

Out of 1,542 comments currently submitted, only 751 are visible.

Agencies review all submissions, however some agencies may choose to redact, or withhold, certain submissions (or portions thereof) such as those containing private or proprietary information, inappropriate language, or duplicate/near duplicate examples of a mass-mail campaign. This can result in discrepancies between this count and those displayed when conducting searches on the Public Submission document type.

Comment by Gary McCray on November 1, 2015 at 12:12pm

Hi Tony,

The last time we did this (before the current "rules") there was a considerable lag before comments submitted were "visible".

They review each comment before making it "visible".

Last time, they actually withheld or redacted very few of them.

I expect that will be the case this time as well.

Most of the comments I read were quite reasonable and expressed an understanding of the need for adequate but not excessive regulation.

And from our previous experience, it did appear that in the long run the FAA actually did pay attention to what we said.

Hope that works again this time :)

Best Regards,

Gary

Comment by Rob Campbell on November 2, 2015 at 8:19am

We're watching all of this with great interest up in here Canada.

I hope the FAA hears that the hobby community has been a huge contributor to the current state of the UAV market and onerous registration and restrictions will severely limit potential future innovation.

Hopefully some of the members on that working group (e.g., 3DR) will advocate on our behalf rather than wholly pursue a regulatory system that discourages small operators for the sake of large, corporate and government investment.

When registration is required, only criminals will fly unregistered drones.

Good luck!

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