Key points and effects to address relative to the FAA Proposed Rule on Remote Identification of Unmanned Aircraft Systems

The newly proposed rule will have many effects that will ultimately limit, if not eliminate the model aviation hobby in the next few years should the FAA enact this rule as it presently stands. It is an infringement on our personal right and a major over-reach in what should be the FAA’s authority. They have chosen to bow to the concerns and interests of big business and the emerging commercial drone advocates and are basically kicking the model aviation hobbyists to the curb. As you will see in the points explained below the FAA plans to limit our activity initially and then to push us out of existence totally in the coming years. They are taking this action without cause and in spite of our hobby’s impeccable safety record. They are infringing on our personal rights by favoring big dollars and business with no sense of justice for all relative to this issue.

The following are the key points and issues to address when responding to the FAA and requesting assistance from our Congressmen and Senators.  Addresses for PA Senators Casey and Toomey and Congressmen Doyle and Reschenthaler have been added below.

Remote ID Categories:

There are three (3) methods by which the FAA plans to implement their Remote ID System called Standard, Limited Remote ID and a third category called an FAA Recognized Identification Area. The first two options will both require transmission of data in real time to the FAA whenever a model is operated. The Standard version requires direct transmission from the aircraft via the internet while it is flying. The Limited Version requires that the aircraft communicates with a ground station while in operation and the ground station is connected to the internet via a cell phone. Neither of these versions will be able to startup or fly without the internet connection. The third category FAA Recognized Identification Area (FRIA) is for our current aircraft with no remote ID capabilities. To address this the FAA will authorize field locations where non-remote ID model aircraft can function. The following are key points related to these FAA Recognized Identification Areas:

1. Within one year after the final rule becomes effective we will have to apply to the FAA for permission to fly at our field.
2. We will likely be required to fly at a limited altitude and limited distance from our transmitters at all times. Though not yet specifically stated at best it will likely be under 400 feet altitude and no further out from the transmitter than 400 feet. Although it could be less.
3. All organizations that apply to be approved as an FRIA will need to be part of a Community Based Organization approved by the FAA such as the AMA.
4. No new applications for FRIAs will be accepted in the future by the FAA after the first year. Any organization that loses its existing flying site in the future will be out of business if that happens. By doing this they plan to reduce the number of authorized sites by attrition in the coming years.
5. Permission for the FRIA will expire in four years after it is granted and must be reapplied for and renewed by the FAA at least 120 days before the four year expiration to continue to operate.
6. The FAA reserves the right to revoke our permission to operate at any time in the future with our without cause.
7. There will be no permitted flying of model aircraft nationwide anywhere but at an approved FRIA for any model aircraft weighing .55 pounds or more. This means Float-Flys will become a thing of the past and special events and contests can only be held at FRIA approved sites.

Registration of Model Aircraft with the FAA

Up to the present time the FAA has required all model aircraft hobbyists to register with the FAA and obtain a registration number that is required to be displayed on the outside of the aircraft in order to operate it. Under the new FAA rule we will be required to register every model individually with the FAA prior to flying it and pay a separate registration fee for every model. The registration for every aircraft will need to be in the owner’s possession when operated. The initial fee will be $5.00 per model. This will include scratch-built aircraft also.

Regulation of the Manufacture and Sale of Model Aircraft

Under the new FAA rule all manufacturers must include remote ID capabilities in their model aircraft. It must be approved by the FAA and all models will be labeled as to whether they meet the Standard or Limited Remote ID capabilities and they must contain serial numbers. New model aircraft constructed by individuals will be governed by the percentage of the model they bought versus constructed. If the model is sold with more than 50% of its composition provided by a manufacturer they will be required to meet the standards, have it approved and serialized. If the modeler constructs more than 50% of the model and purchases components for completion, he will be required to have it approved by the FAA and meet the standards as the manufacturer. This will devastate the existing model and kit manufacturers. The model aviation industry is currently a $1 billion dollar + per year industry.

In addition to the the above elements of the new rule, all model aviation hobbyist will require certification per 14 CFR 107 to fly model aircraft.

We must make ourselves heard in opposition of the proposed new ruling by doing the following:

1. Between now and March 2^nd 2020 send your comments on this proposed rule to the FAA and inform them that you oppose these unneeded regulation of the model aviation hobby which has had an impeccable safety record spanning 80 years.
2. Contact your local Congressman and US Senators and request their assistance in applying pressure to the FAA to safeguard our rights and modify this over reaching regulation of our hobby.

Senator Robert P Casey, 310 Grant St, Suite 2415, Pittsburgh PA 15219  412-803-7370

Senator Pat Toomey, 310 Grant St, Suite 1440, Pittsburgh PA 15219   412-803-3501

18th CONGRESSIONAL DISTRICT:  Congressman Mike Doyle, 2700 Monroeville Blvd, Monroeville PA 15146  412-856- 3375

14th CONGRESSIONAL DISTRICT:  Congressman Guy Reschenthaler, 700 Pellis Rd, Suite 1, Greensburg PA 15601  724-206-4800