Officials with the Experimental Aircraft Association (EAA) say they are “very concerned” that the FAA’s proposed rule on remote identification of Unmanned Aircraft Systems (UAS) — commonly known as drones — could have a severe detrimental impact on traditional model aviation.
The rule would require most UAS, no matter whether they are drones or traditional model aircraft, to carry equipment that identifies the device and broadcasts its location. Additionally, many would be required to be equipped with geofencing systems that autonomously contain the craft within a defined altitude and lateral boundary.
“While EAA is primarily an organization that fosters and supports passion for manned flight, we recognize the modeling community as an important pathway into aviation,” officials said.
“In fact, last year we launched the Young Eagles Build and Fly Program, a chapter activity to guide youth in building their own electric RC model, which they can then fly with a local Academy of Model Aeronautics (AMA) club,” officials continues.
EAA officials note there are “many legitimate safety concerns” surrounding drones, primarily those that are airborne camera platforms capable of flying beyond visual line-of-sight with little or no training by the operator.
“But traditional modeling has been operating trouble-free for nearly the entire history of manned flight,” they continued.
And they warn that model aircraft aren’t the only ones that may be impacted by the proposed rule.
“Despite this NPRM not directly impacting the manned flying community, we are concerned that regulatory overreach in the modeling world could easily set a precedent for future action against general aviation, such as an equipment mandate for the benefit of commercial UAS integration into the airspace.”
EAA’s first action on this rule was to request a comment period extension from 60 to 120 days to allow time for the public to adequately evaluate this complex and sweeping proposal.
After carefully reading the NPRM and consulting with partners in the model aircraft community, EAA officials say these are their top concerns with the proposed rule:
- This rule is based on an imagined security and safety threat that simply is not proven in relation to traditional modeling. There is absolutely a risk posed by drones operated in proximity to aircraft by poorly informed, careless, and/or deliberately malicious operators, but the same cannot be said for models.
- The rule would require every modeler to uniquely register every aircraft they own. Models come and go from modelers’ collections on a regular basis, which would necessitate frequent changes to the registry. A prolific modeler could easily own more than 100 models — a truly unwieldy number to maintain valid registrations, especially if there is a per aircraft fee involved.
- The FAA has based some of this rule on an assumption that the average UAS has a lifespan of approximately three years. This is wholly inappropriate in relation to model aircraft, which may last for 20 or more years or may crash on the first flight.
- The NPRM has a narrow exemption to the remote identification requirement, but only for aircraft that are more than 50% amateur-built and flying at a recognized model field. The “51% rule” works well for full-size amateur-built aircraft, but cannot simply be adapted to modeling without a large amount of unnecessary bureaucracy. Adopting the rule as written could easily cause major consequences for builders of almost-ready-to-fly kits, which account for a majority of new model aircraft. These kits still involve extensive assembly and customization, but would likely fall short of the proposed 50 percent standard.
- Under the NPRM, model fields (termed “FAA recognized identification area” or “FRIA”) would be approved in a one-time, 12-month window. This is clearly meant to “grandfather” existing facilities, with no mechanism for approving new ones. From time to time, modeling clubs can and do relocate their operations for a variety of reasons, and new clubs are established. Additionally, EAA believes that anyone operating under the guidelines of a community-based organization should be able to establish a FRIA, such as individuals in rural areas who wish to fly from their own property.
- Under “limited remote ID,” in circumstances where a model is not flown at an approved FRIA or is not compliant with the amateur-built carve-out and lacks onboard reporting equipment, a geofencing system is required. These are difficult to engineer and would severely hamper operations away from FRIAs or the use of prebuilt commercial models.
- The rule mandates technology that is not available in large numbers and is not yet fully mature. In the case of the ADS-B mandate, for example, extensive testing took place prior to the 2008 NPRM that mandated its use (and the mandate was not in effect until a decade after the publication of the rule).
- There is ambiguity about whether this rule applies to control line and free-flight modeling, and it could even cause complications for indoor modeling.
There are many more elements of the rule that EAA is scrutinizing, officials said.
“Ideally, EAA is pushing for a solution that cleanly carves out traditional modeling as exempt from the RID requirement, which is only useful in identifying negligent drone users,” officials said.
Officials add they are preparing a “full package” of comments on the Notice of Proposed Rulemaking (NPRM).
EAA officials added they also will provide guidance to members who wish to comment.
“When you do comment, please be respectful and use rational, fact-driven arguments in your own words,” they suggest. “Form letters and emotional comments have much less impact on the regulatory process.”
Comments are due March 2, 2020.
Government Regulation is fraught with risk of unintended consequences. Simple rules usually work best, but ever since the FAA was taken over by Lawyers and bureaucrats, Simple rules have gone out the window (just look at the GPS system). It would be better if Drone Operators were self regulated, much like Amateur Rocketry is. Logical limits on what drones should be regulated, which should be limited to large heavy machines, or those used in commercial, government, or research work, are needed. I’m not especially worried about some kids plastic toy bouncing off my wing, but a 20lb commercial drone rivals a large bird strike in risk.
Wild Bill is absolutely correct. Over regulation is a serious problem universally, and model airplanes as well as drones is just another stumbling block in our lives. The next step is licensing and fees which is bureaucratic ice cream
I’ve been readily available to give the public a FREE RC flying experience for many years.
So if any club and/or Young Eagles Build and Fly Program needs flight instruction, I am available.
Keep in mind this is a FREE offer. This is not a business. I’m using Sig LT-40 trainers.
I also train people how to teach RC flying. It would only take a day or two if you’re a solo pilot
Who from the industry will be the first to step up to the plate and inquire on exactly what my mass and rapid growth program is all about. High officials in one modeling organization is fully aware because I trained him using my technique several decades ago.
All anyone has to do is to send a representative to my area so I can demonstrate and train her or him how to use this method. What does anyone have to lose by doing so?
Billions of dollars are on the line and what are people afraid of? Some in clubs are afraid that my promotion method is too legitimate. We just have to get through this covid-19 thing.
When push comes to shove, we can both be safe using mask. It would only take an hour or so to be convinced it works. No charge, whatsoever. Perhaps an EAA member would be a more open minded person. At least just email me for more information.
As a private pilot and commercial UAS operator, I agree with David Krakowsky that there should be a gps software limit on drones to limit flight altitude and even distance from the operator.
-Samuel
Taking the joy out of flying a toy
Says it all right there. The FAA and their unhelpful, unwanted, petty mindset.
Self guided drone technology ruined the Rc airplane hobby by creating the perfect storm. Commercial interests took over and the endgame is for the hobbyist to be corralled to a small number of flying areas or relegated to indoor flying. Model aviation has become the victim of it’s own success. They’ve stolen our hobby. The EAA has every reason to be concerned. General aviation should be concerned as well. The FAA plans are focused solely on the vast revenue of Commercial aviation. The rest of us are only in the way.
Continuous over regulation by over zealous bueacrats.
With all due respect for other’s opinion, I think that the comment from Mr. David Krakowsky represents the more logic, simple and affordable solution for the problem. And so, FAA should think seriously on that.
I Have been into Model Aviation since I was 14 years old (Now 60) – This Draconian measure to try to weed out the bad pilots. I have flown in Parks, At Registered Model Aircraft Fields, in the Desert, and not once have I have interfered with Full Size Aircraft. While my Aircraft (.15 to .40 Power Planes, Electrics, Sailplanes) have the capability of flying above 400 feet, it would not bring much joy if I did. I own several Drones, and fly them in the same manner. Sure, I could fly them beyond Line of Site, but I prefer not to.
If someone could make a small transmitter that could plug into my Batter Pack, and send out alerts, I would not object. But to do that for a Slope Soaring glider is ridiculous. I think it shows how technology is going beyond the public’s ability to understand it. The commercial interests here do not want to have to compete the legitimate “HOBBY” aircraft, so they can buy lucrative flight corridors in urban areas. I would never fly an model aircraft in those places, so therefore should not be swept up in this regulation..
Perfect rule. Goes even further than I have been warning about. Drones pose a direct and utter hazard to GA and commercial aviation as long as they can’t be seen/detected and are flown by non-pilot owners.
Perfect rule if you want to cripple general aviation! A lot of pilots, both G.A. and commercial got their start in model aviation. With the cost of the high end models exceeding many thousands of dollars, the last thing they want is to lose them by accident or otherwise. The F.A.A. is the problem, not model aviation. The F.A.A. let the drone genie out of the bottle and is now struggling trying to get it back in.
With this rule the only thing left flying will be drones.
As a licensed pilot and a former radio control enthusiast, I have been saying for years that the drone phenomena is a threat to full size aircraft.
It’s truly remarkable that an airliner has not yet been brought down by a drone.
At first the FAA had not done enough to regulate this threat, and now that they see what a serious issue this has become they now want to over regulate it.
A simple solution to the problem is to require all drones to be limited by gps hardware to 500 feet above ground level.
A simple task compared to what the FAA is attempting to do now.
David Krakowsky