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 some elements of the proposal may fail to help law enforcement ensure the safety and security of our skies. Furthermore, the proposed rule could impose significant costs on recreational operators, discourage compliance and unnecessarily restrict existing, safe model aircraft operations.
I am part of the law enforcement community working in [INSERT INFO ON YOUR JOB/LOCATION]. My years of professional experience and passion for model aviation make me well-suited and qualified to weigh-in on remote ID. Unfortunately, I do not think the proposed rule will allow law enforcement to track UAS and hold reckless operators accountable as the FAA intends.
The primary issue is compliance. As written, the proposed remote ID rule is overly burdensome and will likely discourage compliance. If UAS operators do not comply with the rule, there is simply no pathway for law enforcement to use remote ID to track irresponsible drones. Furthermore, there needs to be a substantial investment in training law enforcement on UAS – especially how they should and should not be operating. The FAA must implement a remote ID rule that is easy to follow and comprehensive for it to be successful and useful for law enforcement.
Furthermore, as an AMA member, I am also concerned this proposed rule places undue burden on existing, safe model aircraft operations. AMA members are an important facet of the UAS community, and the model aviation industry supports thousands of jobs, businesses and STEM learning opportunities across the country. I hope the final rule will address the following concerns:
- First, the rule should provide community-based organizations (CBOs), like AMA, more flexibility to establish and maintain fixed flying sites that satisfy remote ID compliance.
- Second, the rule should create a pathway for remote ID compliance at AMA events and competitions, which do not take place at fixed flying sites and are conducted at a myriad of venues within our communities.
- Third, the rule should account for situations where there is no internet connectivity, as many safe places to fly are in rural areas with little or no service. A software or network-based App solution could allow users to declare his or her location and intent to fly. This simple solution would ensure compliance for those not flying from a fixed location.
- Fourth, the rule should revise the definition of amateur-built UAS to effectively delineate the categories of aircraft.
- Finally, the rule should not require modelers to register every aircraft individually.
As a law enforcement officer and AMA member, I understand the need for reasonable regulations like remote ID. However, it is critically important to the future of the model aircraft industry and the thousands of law enforcement agencies across the country that remote ID is done right. I hope you will carefully consider my recommendations as you craft the final remote ID rule. We simply cannot afford to make compliance difficult and punish those who already fly safely and responsibly.
Use this template to form your comment on the federal website here.