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Dec 27, 2019, 08:50 PM
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Discussion

Let's fight the FAA Model RID NPRM!


I am starting this thead as a place to gather real, positive ideas for responding to the FAA Remote ID NPRM and further actions. The time for action is NOW.

PLEASE; lets keep it productive, positive and on topic. If you want to rant, complain, etc go to the other threads on this topic.

Paul

Please note:
Posts that are negative with nothing constructive to add will be deleted for the sake of brevity. It's not that your opinion isn't valued; this isn't the place for it.

Posts that are only a response to deleted posts, while valued, will also be deleted because thay won't make sense by themselves.
Last edited by PaulMN; Dec 30, 2019 at 05:13 PM. Reason: Inappropriate post deletion notice
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Dec 27, 2019, 08:58 PM
Multirotors are models too!
Phone your representatives and senators......
Latest blog entry: Test entry
Dec 27, 2019, 09:35 PM
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As a start, I read the thread about an FAA NPRM requiring manned sailplanes (gliders) to have transponders. It was triggered by a non-fatal midair between a sailplane and a commercial transport aircraft. Ironically, the sailplane involved had a transponder, but it was turned off. The NPRM requirement was defeated by the sailplane community in the area taking action to address the problem and responding to the NPRM with a large number of letters with rational, provable arguments.

My apologies for not posting a link to the sailplane NPRM here, If someone can help with that I'd appreciate it. It's on this site, "FAA listens to aviation community, withdraws NPRM..." 12/28/16

It is possible to overcome an FAA NPRM.

It is my understanding that the AMA meetings with the FAA were not with the FAA staff that actually wrote the 400' rule. The FAA staff that wrote that rule did not attend AMA's demonstration event, and likely have not seen what and how we fly R/C aircraft. I'd also bet that your congressional representatives have had no exposure to our sport. It's hard to gather any understanding and cooperation from authorities who don't know anything about us.

IMHO we need a PR video about our sport. It should be a 10 minute pitch with a quick history, show the diversity of modern R/C aircraft and flying, the educational, scientific and social values, and the emphasis on safety and the successful record we have maintained. This video would serve to educate the politicians we are asking for help as to what we are talking about.

I'd be willing to contribute to a go fund me account to have this professionally produced.

I also think we need to respond to the FAA in their own language. If you read the FAA final letter re: the sailplane transponder NPRM, it's obvious that it is a technical, jargon loaded document.

The AMA has done a terrible job of utilizing the resource of its members in writing to Congress and the FAA. The AMA has been slow in asking for member response, and the single form letter provided is badly written and poorly thought out. Expecting original responses from the membership to an NPRM in excess of 300 pages is unrealistic. We need help from people who know how and what to write.

Paul
Dec 27, 2019, 10:29 PM
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Quote:
Originally Posted by PaulMN
It is my understanding that the AMA meetings with the FAA were not with the FAA staff that actually wrote the 400' rule.
No surprise there, the AMA sits at the kiddie table if they get a seat at all.

Quote:
The FAA staff that wrote that rule did not attend AMA's demonstration event, and likely have not seen what and how we fly R/C aircraft.
The FAA has been out to model aircraft fields, to observe, to ramp check, and to shut them down. They know exactly what we are. They go into detail in the NPRM how they received requests to exempt us and have decided to deny it. They know; they do not care. Comrade Stalin indeed knows of our suffering -- it's all part of the plan.

Quote:
I'd also bet that your congressional representatives have had no exposure to our sport.
In my case, they're New Jersey representatives. If it involves banning something they're for it. Mine (Mikie Sherrill) was once a full-sized Navy helicopter pilot, which means she's against us on general principles (remember the now-banned franklin?) and for horrific regulation like the military has.
Dec 27, 2019, 11:30 PM
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Thread OP
I did some searching about how to write a response to FAA NPRM.

I stumbled across the Advance NPRM for the Remote ID NPRM, and skim read some of the responses. Many of the ones about legacy R/C flying were copies of someone's letter. Another I read was a rant that could have been written by a grade schooler, except for claiming to have been flying longer than the FAA had their jobs, and being President of his club.

These type of responses are not impressive to the FAA; I think they undermine the credibility of R/C fliers.

I did find an organization that does advocacy with the FAA. They have a page about writing responses to the FAA.

Again, my apologies for no link, I'm pecking this out on a phone and am challenged without a computer. Help is appreciated.

The company is JDASolutions.aero and page is " Comments on FAA NPRM part 107 detailed responses ..." . Please look this up. They specifically say the FAA does not care about number of responses, so copied letters are of no value. They say responses should be detailed, address specific areas in the NPRM, be logical and rational, establish credability of the writer, use data to support the arguement, etc.

In short, we and the AMA have been doing it wrong. It's no surprise we are getting nowhere.

Anyone up for doing a proper campaign, either helping out the AMA or independently? Again, a crowd sourced fund to hire pros makes sense to me.

Where are the industry people on this? I'd think those people should be front and center in this fight!
.
Dec 27, 2019, 11:46 PM
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The only people who have any idea how to write a response to an FAA NPRM are members of the aerospace community. The problem is, they're all against us. They look down on us because we don't have all the flight training and certifications that they do. They think we're ignorant, foolhardy, and extremely under-regulated, and that a proposal like this one is a good start. They're sitting on the other side of the table; there's no help there.

The only exception is the EAA, and I imagine they have problems of their own (since the FAA banned ultralight trainers I imagine membership there has been dropping precipitously) and no resources to spare to save us.
Dec 28, 2019, 12:17 AM
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Thread OP
Quote:
Originally Posted by nybbler
The only people who have any idea how to write a response to an FAA NPRM are members of the aerospace community.
Exactly. We either have to recruit qualified help from within our community, or hire it. It looks like that's a service that JDASolutions for one does. Is it a matter of money then? How much is needed I don't know, I do know I'd support hiring a pro and be willing to contribute money.

I also think we need to get as much support and awareness in Congress as we can. A quick, easily understood and appealing message package going to all Representatives and Senators, and a coordinated site for them to refer to could be effective. IMHO less than this is NOT going to preserve our sport.

I intend to have a chat with JDASolutions and AMA HQ Monday.

Let's have some more do-able, worthwhile ideas! I know we've got talented people here, what can YOU do? Someone knows how to put together a video. Someone does graphic design.
If not now, maybe never?
Dec 28, 2019, 04:03 AM
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scott page's Avatar
Quote:
Originally Posted by PaulMN
I am starting this thead as a place to gather real, positive ideas for responding to the FAA Remote ID NPRM and further actions. The time for action is NOW.

Paul
The time for action was 5 years ago when the handwriting was going up on the wall.

Too many of us took the opinion that "it's not my problem" either because they would refuse to comply with any regulations or that the FAA could not possibly enforce regulations. There has been a drum beat in WaDC over the past few years that has "educated" the legislators of the terrible dangers of model aircraft by highlighting a few bad actors. It's my opinion that the time for advocacy is over. It's now time for legal action - class action or otherwise. Legal challenge is the only voice that will command attention at this point. I have no idea how where funding for this would come from -- perhaps ACLU ? Anything less than legal challenge will be run over like a bug on the rug.

I read the RID NPRM completely once and in snippets as well. It's clear from the proposed rules for establishing FRIA's that the FAA has set out to eliminate all traditional model airplane flying sites through attrition. I've only talked to one other modeler in person about this NPRM and his reaction was - I fear - not unique as he said, "I guess I'll just have to give up flying, I've gotten too old to deal with this garbage." This is a modeler that's been an active leader in the hobby for over 50 years.
Dec 28, 2019, 05:02 AM
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Are we going to just quit, because we shoulda woulda coulda? I agree, a class action should be explored.

Any lawyers out there who can advise? Who is the AMA legal counsel? Anyone want to approach the ACLU?
Dec 28, 2019, 05:23 AM
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Doesn't https://www.nrhsa.org/ and https://www.hmahobby.org/ have a dog in this fight?
Last edited by fliers1; Dec 28, 2019 at 06:51 AM.
Dec 28, 2019, 01:41 PM
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Ok then, some of you feel there's nothing that can be done. While I appreciate your position, it does nothing to help.

This thread is a call for ideas and action. If you won't help, please respect those of us who aren't going to give up. Lead, follow, or get out of the way!
Last edited by PaulMN; Dec 28, 2019 at 01:55 PM. Reason: Clarity
Dec 28, 2019, 08:49 PM
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Bhodi11's Avatar
Some other ideas if we can get an action plan banner plastered on the front of every page of RCG. We could organize a schedule where we flood the Face-book pages of a couple Senators or Congressmen every day. If we could get 50k + people to give a unique comment on how the FAA rules will effect the model aviation hobby in short bursts people would start to take notice. You can’t tell me that if any Senator’s staff saw the FB page explode in a single day about an issue they did not even know about that they would not take notice? We do the same thing with the major news outlets. We do it to Trumps FB and Twitter pages. It will start to get attention. We have enough numbers to mount a social media campaign. So let’s do it!
Dec 28, 2019, 09:40 PM
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Yeah, Bhodi11, that's the stuff! I like it!

Can you help make it happen? I don't have the skills.

I'm thinking we need to coordinate this with RCG, and I've begun talks with AMA officers. I'll email Jim @ rcg and ask for his help.

Thank you for your idea, Bhodi11 !
Dec 28, 2019, 11:19 PM
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Quote:
Originally Posted by PaulMN
Yeah, Bhodi11, that's the stuff! I like it!

Can you help make it happen? I don't have the skills.

I'm thinking we need to coordinate this with RCG, and I've begun talks with AMA officers. I'll email Jim @ rcg and ask for his help.

Thank you for your idea, Bhodi11 !
I already emailed Jim you should too. If enough of us speak out maybe we can motivate our community. However for it to work it needs to come out of this toxic part of the forum. A lot of people avoid this section including myself for that reason. It needs to be plastered all over the main pages as a call to action by RCG so as many people as possible see it and hopefully participate.

Additionally most clubs have a FB page. Everyone needs to reach out to their respective memberships which will include a lot of people not on RCG. We can call on the staffs of all the vendors as well. There are a lot of possibilities. I would think Jim has a lot of contacts in the industry and some influence owning the largest most active forum in the hobby.
Last edited by Bhodi11; Dec 28, 2019 at 11:26 PM.
Dec 28, 2019, 11:59 PM
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Hi Bhodi11, I've emailed Jim. I'm glad you've taken action too. I totally agree with you on all points. This topic needs to be consolidated in a specific place; right now it is spread thin in many, dividing our voices.

I have less than no social media skills, I'm not the guy for that. I hope that talented fliers will join us in this campaign.
Paul
Last edited by PaulMN; Dec 29, 2019 at 12:11 AM.


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