I am writing in response to the FAA’s notice of proposed rulemaking on remote identification of unmanned aircraft systems (UAS). I am deeply concerned that the current proposal would impose significant costs and place an undue burden on those who fly first-person view (FPV) flying, especially for freestyle and racing events.
The proposed remote ID rule is a problem for the FPV community for two primary reasons. First, it essentially limits FPV flying to operating at FAA-identification sites only. This is especially troublesome for the many established FPV competitions and events which are not at these identification sites and often raise money for local charities. These established safe events will likely be canceled if the remote ID rule goes into effect as is.
Furthermore, 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, further restricting FPV flying. I urge you to allow FPV flying at more locations than FAA-identification sites only.
Second, the limit on operating UAS “no more than 400 feet from the control station” is highly problematic for FPV flying, which is conducted at very low altitudes but farther horizontal distances from the operator. If implemented, this limit would drastically reduce the size and scope of FPV competitions and events which usually span a wider area. Again, these events are established and safe and I see no reason for them to be severely limited. I urge you to consider a pathway for FPV flying events to receive remote ID compliance at the location of the event, so the 400-foot limit would not apply and FPV flying could continue to occur.
Again, as currently written, the remote ID proposal is too rigid and overly burdensome for the FPV community. Please address these pressing issues so that our growing hobby can continue to flourish.
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