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Jan 02, 2020, 12:00 AM
Registered User
Quote:
Originally Posted by jcmors
As long as the location of the FRIA stays static in perpetuity that is true, except that the FAA reserves the right to revoke FRIA status with no provisions to re apply should there be any violation of any of the rules that may occur at the site. If your club site that is approved as a FRIA needs to move to a new location for any reson, the FRIA application can't be re submitted as basically you would be requesting FRIA status for a new geographical location and new applications will no longer be accepted. New AMA clubs that come into being after the initial 12 month period also will not be allowed to apply as a recognized FRIA site.
Yep. I found what I was looking for:

Renewal:
A request for renewal would have to be submitted no later than 120
days prior to the expiration of the FAA-recognized identification area
in a form and manner acceptable to the Administrator. The
Administrator may deny requests submitted after that deadline or
requests submitted after the expiration of the FAA-recognized
identification area.
89.225

I did also find that they did structure an appeals process:

Petition to reconsider the FAA’s decision to terminate an FAA
recognized identification area:
A CBO whose FAA-recognized identification area has been
terminated by the FAA would be able to petition for reconsideration
by submitting a request for reconsideration and establishing the
26
grounds for such reconsideration within 30 calendar days of the date
of issuance of the termination.

Not that this would work; In fact it really does look like a way to verify failure on the respective CBO's part.

And another question: The FAA speaks of 'CBO's'. The only one currently in existence is the AMA. Do they really believe that other CBO's will spring up, become 'recognized' by the FAA, and be able to submit the required paperwork in time to have their flying sites certified as FRIA's?

RStrowe
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Jan 02, 2020, 12:06 AM
Registered User
Quote:
Originally Posted by RStrowe

And another question: The FAA speaks of 'CBO's'. The only one currently in existence is the AMA. Do they really believe that other CBO's will spring up, become 'recognized' by the FAA, and be able to submit the required paperwork in time to have their flying sites certified as FRIA's?

RStrowe
I would think that with these new regulatory frameworks and regulations being proposed it may actually discourage the formation of any new CBOs. Not to mention that as the AMA, a CBO that has been around over 80 years, with a stellar safety record, is having trouble working within the current and proposed regulatory climate in order to keep us all able to fly, what would a new CBO have to back them up and give them any leverage?
Jan 02, 2020, 12:22 AM
Registered User
Quote:
Originally Posted by jcmors
I would think that with these new regulatory frameworks and regulations being proposed it may actually discourage the formation of any new CBOs. Not to mention that as the AMA, a CBO that has been around over 80 years, with a stellar safety record, is having trouble working within the current and proposed regulatory climate in order to keep us all able to fly, what would a new CBO have to back them up and give them any leverage?
Yep. I'm thinking along the very same lines.

RStrowe
Jan 02, 2020, 08:51 AM
Registered User
Quote:
Originally Posted by RStrowe
And another question: The FAA speaks of 'CBO's'. The only one currently in existence is the AMA. Do they really believe that other CBO's will spring up, become 'recognized' by the FAA, and be able to submit the required paperwork in time to have their flying sites certified as FRIA's?
Technically speaking there's zero CBOs, since the AMA is not yet recognized. But no, the FAA does not believe that. Like all regulatory agencies, they are quite good at couching impossibilities and implausibilities in bland language. Like the process for building a UAS with RID. All you have to do, according to the NPRM, is follow the technical requirements, issue a serial number, and file and get accepted a Declaration of Compliance, then keep the paperwork for two years. Hidden in a document incorporated by reference is the fact that an amateur cannot obtain a serial number. And only elsewhere in the document does it become clear that an amateur is unlikely to be able to successfully file a declaration of compiance.
Jan 02, 2020, 09:03 AM
Registered User
Quote:
Originally Posted by RStrowe
And another question: The FAA speaks of 'CBO's'. The only one currently in existence is the AMA. Do they really believe that other CBO's will spring up, become 'recognized' by the FAA, and be able to submit the required paperwork in time to have their flying sites certified as FRIA's?
No, in the key assumptions they only mention AMA fields. Which they assume 90% of will be made into FRIAs
Jan 02, 2020, 11:00 AM
Live to fly... Fly to live
mudman1959's Avatar
My Comment submitted to the FAA...

To Whom it concerns...

The new imposed regulations for as you call "Drones" with registration of each unit and Remote Id for each is unattainable for the average Hobby Flyer like me and will eventually Kill the Hobby Flyer and the Hobby. I have been a AMA Member for 20+ years and adhere to the rules of our charter. I also fulfilled the previous requirements that the FAA imposed on our hobby by registering with the FAA and adding my registration number to all of the current flying Toy Airplanes that I fly. TOYS... Not a real aircraft is what I fly! How is it that Ultra Lite aircraft have less requirements to operate than you are trying to implement on RC Hobby aircraft? To have a active Transponder system implemented on each Toy with each Toy registered and only allowed to fly in limited areas designated by the FAA will inhibit most Law abiding RC Hobbyist from enjoying the Hobby. How does the FAA intend to implement this ordinance and police the operators of Toys. The FAA has enough issues Policing the operations of Real Aircraft. Just like the debates going on over Firearms and trying to limit who owns them and the type that you can own... Taking the Gun away from a Law abiding citizen allows the Criminal to do what he wants to with no consequences. The Criminal will always find away to commit the crime Gun or not... So in lies the problem with regulating RC Hobby Toys... Some will try to adhere to the regulations imposed even if they are ridiculous just because they Love flying their Toy Aircraft but others will not. There will always be some out there that just do not care and will fly their Toys where ever and when ever they please with no regards to the ones that try to comply. So the answer is to take the Rights of everyone away... Right? Sounds like Communism to me... Thank You for Regulating our Hobby that I Love out of existence. To make it unattainable to the Average Hobby Flyer. This comment I have submitted will go on deaf ears and the FAA will do what they want with no regard to the Thousands of AMA Member Hobby Flyers and to the fact that we have been flying together with Real Aircraft for over 80 years with no reported incidences between the two.

Mudman1959
Jan 02, 2020, 08:46 PM
Registered User
aeronaut999's Avatar
Quote:
Originally Posted by nybbler
[re:] the process for building a UAS with RID. All you have to do, according to the NPRM, is follow the technical requirements, issue a serial number, and file and get accepted a Declaration of Compliance, then keep the paperwork for two years. Hidden in a document incorporated by reference is the fact that an amateur cannot obtain a serial number. And only elsewhere in the document does it become clear that an amateur is unlikely to be able to successfully file a declaration of compliance.
Hopefully the wondrous AMA will work a miracle and successfully encourage the FAA to enforce something other than the actual letter of the (now proposed, soon to be actual) regulations, especially in the matter of amateur-built models, ARFs, BNFs, etc. Wouldn't be the first time the FAA enforced something other than the actual letter of the regulations. Seems to rarely work in our favor though.
Last edited by aeronaut999; Jan 03, 2020 at 08:35 AM.
Jan 02, 2020, 08:54 PM
Registered User
Quote:
The ARC also recommends the FAA apply the remote ID and tracking requirements to the remote pilot, not to the manufacturer of the UAS. The ARC further recommends the FAA require manufacturers to label their products to indicate whether they are capable of meeting applicable remote ID and tracking requirements. If a product is labeled as capable of meeting remote ID and tracking requirements, such capabilities must be enabled by default and the manufacturer must not present the user with an option to turn off the ID and tracking
FAA is the Boss
Quote:
51.  In addition to the ARC feedback, during the development of this NPRM, the FAA received two letters specific to remote identification of UAS, one from the Academy of Model Aeronautics and the other from the Small UAV Coalition. Both letters provided their respective organizations' views on the policies that the FAA should propose in this rule. Neither of these letters were considered in the development of this rule. Both letters have been placed in the docket for this rulemaking.
Jan 03, 2020, 02:30 AM
Internet Pilot
fATAL's Avatar
Feel free to copy paste

To the Administrator:

When in the Course of human events, it becomes necessary for one people to dissolve the political bands which have connected them with another, and to assume among the powers of the earth, the separate and equal station to which the Laws of Nature and of Nature's God entitle them, a decent respect to the opinions of mankind requires that they should declare the causes which impel them to the separation.

We hold these truths to be self-evident, that all men are created equal, that they are endowed by their Creator with certain unalienable Rights, that among these are Life, Liberty and the pursuit of Happiness.--That to secure these rights, Governments are instituted among Men, deriving their just powers from the consent of the governed, --That whenever any Form of Government becomes destructive of these ends, it is the Right of the People to alter or to abolish it, and to institute new Government, laying its foundation on such principles and organizing its powers in such form, as to them shall seem most likely to effect their Safety and Happiness. Prudence, indeed, will dictate that Governments long established should not be changed for light and transient causes; and accordingly all experience hath shewn, that mankind are more disposed to suffer, while evils are sufferable, than to right themselves by abolishing the forms to which they are accustomed. But when a long train of abuses and usurpations, pursuing invariably the same Object evinces a design to reduce them under absolute Despotism, it is their right, it is their duty, to throw off such Government, and to provide new Guards for their future security.

These words began a new country, a country that recognized the rights of the common man, to abolish the rights of hobbyists for the rights of ill regarded businesses that are held back by the progression of the battery, is a crime against our rights to pursue happiness. Please disregard all constraints for restricting drones, and amateur hobby aircraft controlled via remote until a proper power source allows feasible operation of commercial drones. The horizon of technology yields no future to commercial operations below 600 ft yet and making provisions to these lobbyists will simply provide empty skies without usage or filled with those who up hold the declaration of Independence and choose to abolish your tyranny. Allow amateur hobby aircraft to proceed to fly within the parameters of LOS, flown for recreation, less than 55 ibs, and add flight times less than 1 hour with the markings visible and the operator to self identify using an APP operated by the FAA. Restriction of these rights is a constitutional violation and insensible. If the future of recreational remote piloting is to be threatened further by lobbyist, we will simply mount open source routers to our aircraft and connect to wifi hotspots on our phones, WE WILL NOT GO QUIETLY UNTO THAT GOOD NIGHT, if that is your intention.
Last edited by fATAL; Jan 03, 2020 at 02:36 AM.
Jan 03, 2020, 09:38 AM
Sink stinks
Montag DP's Avatar
Quote:
Originally Posted by fATAL
Feel free to copy paste

To the Administrator:

When in the Course of human events, it becomes necessary for one people to dissolve the political bands which have connected them with another, and to assume among the powers of the earth, the separate and equal station to which the Laws of Nature and of Nature's God entitle them, a decent respect to the opinions of mankind requires that they should declare the causes which impel them to the separation.

We hold these truths to be self-evident, that all men are created equal, that they are endowed by their Creator with certain unalienable Rights, that among these are Life, Liberty and the pursuit of Happiness.--That to secure these rights, Governments are instituted among Men, deriving their just powers from the consent of the governed, --That whenever any Form of Government becomes destructive of these ends, it is the Right of the People to alter or to abolish it, and to institute new Government, laying its foundation on such principles and organizing its powers in such form, as to them shall seem most likely to effect their Safety and Happiness. Prudence, indeed, will dictate that Governments long established should not be changed for light and transient causes; and accordingly all experience hath shewn, that mankind are more disposed to suffer, while evils are sufferable, than to right themselves by abolishing the forms to which they are accustomed. But when a long train of abuses and usurpations, pursuing invariably the same Object evinces a design to reduce them under absolute Despotism, it is their right, it is their duty, to throw off such Government, and to provide new Guards for their future security.

These words began a new country, a country that recognized the rights of the common man, to abolish the rights of hobbyists for the rights of ill regarded businesses that are held back by the progression of the battery, is a crime against our rights to pursue happiness. Please disregard all constraints for restricting drones, and amateur hobby aircraft controlled via remote until a proper power source allows feasible operation of commercial drones. The horizon of technology yields no future to commercial operations below 600 ft yet and making provisions to these lobbyists will simply provide empty skies without usage or filled with those who up hold the declaration of Independence and choose to abolish your tyranny. Allow amateur hobby aircraft to proceed to fly within the parameters of LOS, flown for recreation, less than 55 ibs, and add flight times less than 1 hour with the markings visible and the operator to self identify using an APP operated by the FAA. Restriction of these rights is a constitutional violation and insensible. If the future of recreational remote piloting is to be threatened further by lobbyist, we will simply mount open source routers to our aircraft and connect to wifi hotspots on our phones, WE WILL NOT GO QUIETLY UNTO THAT GOOD NIGHT, if that is your intention.
This is a good example of a very poor response to the FAA.
  • Full of hyperbole
  • Tons of unnecessary text (copy-pasting the Declaration of Independence is not helpful)
  • No alternative solutions offered, other than threatening to violate the rule
If I were on the board reviewing these responses, this one would go in the trash bin (even being a fellow modeler myself). It's a rant, not a reasoned response.

How to write a good response
Jan 03, 2020, 10:31 AM
Team Futaba
Silent-AV8R's Avatar
I'll post this again.
Jan 03, 2020, 10:55 AM
Registered User
aeronaut999's Avatar
Quote:
Originally Posted by Silent-AV8R
I'll post this again.
Especially "10. Do not miss the March 2 deadline."

At this point I'm still learning more about the situation by re-reading the NPRM , as well as other folks' responses on RC groups, and giving my thoughts some time to congeal, but I will definitely be sending the FAA a comment in another month or so.
Jan 03, 2020, 01:02 PM
Registered User
Quote:
FAA is the Boss
they got the RID go ahead from Congress & no exception, so the NPRM [DJI references] thrusts a foreign UAS manufacturer better than the US citizens operating in the NAS
Jan 04, 2020, 10:46 AM
Registered User
Quote:
Originally Posted by boombang
they got the RID go ahead from Congress & no exception, so the NPRM [DJI references] thrusts a foreign UAS manufacturer better than the US citizens operating in the NAS
When I watched the DAC meeting in Washington last Oct, DJI certainly has the FAA's ears. DJI used there comments to promote DJI technology. Right now, the FAA is technology drunk. DJI has all the answers to protect the general population from the "careless and clueless" UAS operators.
Jan 04, 2020, 12:23 PM
Registered User
Quote:
Originally Posted by Ray93J
DJI has all the answers to protect the general population from the "careless and clueless" UAS operators.
Remind me again what brand drone got into it with an Army helicopter over Long Island Sound?


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