Amerykanie aktualnie piszą podobne listy do swojego FAA. Poniżej tekst z dość w sumie dobrą sugestią, żeby rozdzielić przepisy obowiązujące lataczy VLOS i tych którzy latają FPV.
MY MESSAGE TO THE FAA. FEEL FREE TO USE IN WHOLE OR PART FOR YOUR OWN MESSAGE(S).
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 some elements of the proposal could impose significant costs on the model aviation community and unnecessarily restrict existing, safe model aircraft operations.
I would like to recommend that any technological tools used to achieve the FAA’s security needs be tiered depending on the capabilities of the aircraft and pilot in command. The FAA has already proven itself well capable of regulating the full-scale aviation community using such an approach by applying varying levels of regulations & qualifications. Most noticeably, private pilots flying single-engine piston aircraft are held to a very different standard that multi-engine commercial pilots. Further, their cost of maintaining their good standing with the FAA is also highly variegated in terms of hours spent keeping compliant and financial costs.
Scale pilots flying line-of-sight should be given unique considerations from those flying by FPV equipment that can navigate beyond line-of-sight. May I recommend that rather than creating one technological solution as outlined in the current NPRM which applies equally to all model/scale aircraft; that you create different regulations dependent upon the type and capability of the aircraft in question. This would mean for example, that the equipment standards for line-of-sight and FPV equipment be different. The long safety record of line-of-sight aircraft has been proven over many decades. The standards for flying in this capacity should thus be less onerous and costly.
Having a mere altitude restriction for line-of-sight pilots in conjunction with an exemption system should certainly be enough to address the safety concerns of the FAA in separating remote controlled aircraft from people-carrying aircraft operations. To add other boundaries such as 400’ limits is beyond the reasonable ability of people to recognize. Consider for yourself the ability to judge a distance of 375 feet verses 425 feet when in the air for example. If a large-scale airplane or helicopter being flown line-of-sight exceeds the 400’ distance how would a system be able to bound it safely? Having a computer program take control away from the pilot present tremendous dangers and creates liability concerns for the manufacturer and software developer.
Further, on slide 5 of in the FAA PowerPoint document “UAS Remote Identification – Overview of the proposed rule” submitted by the FAA to the House of Representations on 1/16/2020 ([https://www.regulations.gov/document?D=FAA-2019-1100-5896&fbclid=IwAR3bWEYrrmkThxp0qRp4LwJeSFiYGpV-pjedaORAcCy_DKyujqu38UqOBoM](
https://www.regulations.gov/document?D= ... qu38UqOBoM)), a FRIA was shown with a 400’ dome around the pilot-in-command. This is by no means representative of how any Academy of Model Aeronautics (AMA) location operates. Pilots fly along the edge of a safe flying area with no aircraft flying over any people. This is a critical component of safe flying established long ago by the AMA, this suggests to me that the FAA’s understanding of FRIAs is significantly different from reality, as such I strongly recommend that the FAA fully understand how AMA sites operate before bringing new regulations into effect!
For long-range FPV and or GPS-enabled equipment which can be flow well beyond the location of the operator, a different more stringent set of regulations may be well reasoned. As stated in the current proposed rules, having the ability to track such equipment in real-time and the ability to geo-fence such aircraft is a reasonable need. As such, the current proposed rules and the high financial cost of monitoring them may be reasonable, especially if the aircraft is used in a commercial capacity. Again, commercial application and private use application should be regulated differently just as in the full-scale aviation community.
While I am glad the proposal includes an option to comply with remote ID by flying at an approved fixed site, 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, rather than treat them as a viable long-term option for complying with remote ID. I encourage the FAA to view fixed flying sites as part of a viable long-term solution to remote ID and to amend the rule to allow for the establishment of new sites in the future.
