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#!documentDetail;D=FAA-2015-4378-0022
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
Comments
Thanks for posting link for online-comment! I sent my comment. Used yours as a template.