Template Comment on UAS Remote ID: Amateur-Built Aircraft
I am writing in response to the FAA’s notice of proposed rulemaking on remote identification of recreational unmanned aircraft systems (UAS). While I am pleased the proposed rule includes an exclusion for amateur-built aircraft, the definition of what constitutes an “amateur-built” is not adequate and the preamble does not effectively delineate the true categories of UASAB.. If the FAA is proposing to apply the same policy that is used for manned aircraft, there will be significant difficulty in applying the rule on the recreational UAS (model) industry due to the popularity of recreational UAS that are nearly ready to fly aircraft and the intent of separating hobbyists who build, assemble, and fly from the off the shelf ready to fly products. Even this “Almost Ready to Fly” category requires skill, knowledge, and technical ability that falls under the intent of Amateur-Built as a definition.
If this rule goes forward without edit, the effect will be difficulty and subjectiveness in the field with how the FAA exactly applies the policy. A better explanation and clear definitions should have been included in the main body of the NPRM as well as the preamble. A poorly worded, inaccurate definition moving forward will severely damage the entire hobby.
I am also concerned that the proposed rule requires amateur-built aircraft to display a serial number, an unnecessary requirement for an aircraft that will only fly at FAA-recognized identification areas and within visual line of sight. Furthermore, serial numbers would potentially destroy recreational UAS (model) which may be detailed scale replicas of manned aircraft. Hobbyists spend hours poring over each detail of replicas to ensure accuracy. Adding a serial number would ruin the model, and for no good reason.
AMA members fly aircraft that require continual input and are only flown within line of sight. Advanced drones, on the other hand, with advanced capabilities to have sustained and controlled navigation beyond visual line of sight may need additional remote identification requirements. This distinction was also provided to the FAA by the Remote Identification and Tracking Aviation Rulemaking Committee, specifically Work Group Two, tasked to set a threshold of compliance.
In conclusion, I strongly urge you to revise the definition of amateur-built model aircraft to clarify the intent of the NPRM. I also urge you to remove any requirement for an external serial number for recreational UAS or provide a waiver process to permit the operation of recreational UAS at FAA-recognized identification Area
By addressing these issues, the FAA will protect the many model aviation businesses that sell model aircraft parts. In addition, the FAA will protect opportunities to learn about STEM, as AMA regularly hosts competitions, events and programs for young people to build model airplanes.
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