FAA RID NPRM - Info, Videos, Discussion and How to Take Action

Here are ways we can work together as a hobby to modify this NPRM.

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The Notice of Proposed Rule Making and Remote ID - Info, Action and More

The whole NPRM about remote ID is more than a little confusing and something that all RC hobbyists should be aware of. There are extensive threads about this topic on all of our sites but I thought I would try to pull as much together as I could in this thread to increase awareness and link to informational pieces that might help us all better understand not only what is being proposed, but what our options are to take a stand against the ruling...or at least help shape it into something that is RC friendly.

While I understand the FAA feels the need to control the airspace, I can't understand why traditional RC aircraft would fall into the same category as drones that are flown miles away from the pilot. I love FPV (first-person-video) and would be understanding of some limitations on that but lumping the whole hobby into this has to come from a lack of understanding.

One question is - has the FAA set an “internal limit” for FRIA’s at 2000 clubs? The budget numbers shown reflect that. Is that negotiable? If all the current people who fly on personal property start an AMA club (and AMA is the CBO), the number of clubs could probably double, or greater. Is that an option for FAA? They have complete control to authorize locations. But if we think ahead, and start a campaign to create more flying fields and the FAA goes along it could alleviate a lot of pressure for the next couple of decades.

Dave Baron Thoughts

I want to thank you for the great work that you and your team at RC Groups is doing for our hobby!!!! Let’s get the word out to the masses, we need to seriously ramp up the letters to the FAA!

  • All AMA members and drone enthusiasts need to make their voice hear to the FAA prior to the March 2nd deadline. (Many of us are sending more than one comment to this portal, when we think of a new concern we want to voice!) The bottom line is- BE VOCAL!! http://amablog.modelaircraft.org/ama...formal-comment
  • The second most important thing to do is to contact your Congressional representatives- letters to the house and senate! Let them know your liberties are being trampled by a government agency. Be clear, accurate, and most of all refer to the FAA’s RID clearly and accurately, so that they don’t go looking in the wrong direction or reference the wrong problem! NPRM
  • Support, (GIVE $$$) to the Model Aviation PAC! This is going to fund elected officials now and upcoming who will champion our concerns. Congress holds the purse strings to the FAA, they can make a difference to the future of modeling! modelaviationpac.com
  • Call your fellow modelers, and make sure that they are sending out the emails and letter also! We may not have the money of Amazon and other corporations that want us out of the airspace, but we do have hundreds of thousands of voices that can be put to the task of fighting back!

Here are some thoughts from Aloft Hobbies recent newsletter:

Hey, why are all of the major aviation associations siding with the RC Model Hobby?

Because they know the majority of their members started right here in the hobby, and many are still very active. Maybe the FAA just doesn't understand how much education comes from these models. Maybe they don't understand that the majority of pilots and aviation professionals started off flying RC planes? Maybe they don't care about STEM programs and the promise they have for the nation?

It isn't too late to fight this! We have some strong associations fighting for us but we need you more than anything! The FAA is very focused on National Security, it is not a Line Of Sight (LOS) vs First Person View (FPV) fight, or a hobbyist vs commercial fight like some initially thought. Congress wants the FAA to be able to identify our models to assess risk of an attack.

The EAA (Experimental Aircraft Association) has a great track record of working with the FAA and getting big changes for the betterment of aviation. They know what works and what doesn't work, and they are suggesting:

"When you do comment (on this NPRM), please be respectful and use rational, fact-driven arguments in your own words. Form letters and emotional comments have much less impact on the regulatory process."

Spend a little time and write your own message it does not need to be a long and wordy novel, do what seems right from your point of view. That is the best thing we can do at this time. And please consider sharing information about this subject with your friends and get them to send in some comments. If the FAA does not hear from us, then they will move forward and bulldoze this wonderful hobby.

RC modelers have been happily sharing the airspace for 70 years now and we have an excellent track record. We should not be turned into outlaws.

Remote ID

Remote ID is a way for the FAA to keep track of unmanned aircraft. This info is transmitted from a UAS, the FAA, law enforcement and the public may find out information from a UAS flying near them. In the current iteration of the rule, model aircraft are considered UAV's by the FAA and treated the same as drones. The info broadcasted will include your name and phone number. In theory that info is only available to the FAA and law enforcement. Your longitude and latitude will be broadcasted to the public.

Any RC aircraft that weighs between .55lbs and 55lbs, flown recreationally full under this proposed rule. as well as all RC aircraft und 55lbs flown commercially under part 107.

What is a FRIA

If your craft does not support remote ID you are limited to flying within the boundaries of an FAA recognized area or FRIA. A FRIA is an "FAA-recognized identification area". I read this to mean community-based organizations like the AMA. So the best-case scenario for pilots like me that fly out of an AMA field is that nothing would change.

Thoughts on FRIA from RCG users Scott Page:

I applaud the FAA for proposing FRIAS. This is in effect a reservation specifically for VLOS operations. However, the FAA FRIA proposal falls short as this appears to be designed as a grandfather provision with a sunset by attrition goal. FRIAS should become a permanent method of allowing CBO’s, municipalities, or landowners of over 2 acres to define a reservation for LOS aircraft which don’t conform to the RID proposal. The RID requirement is certainly appropriate for BVLOS aircraft but is a burdensome overreach for LOS model aircraft. Aircraft flying LOS at a FRIA reserved for this activity pose no threat to the public or other air traffic. This has been demonstrated with a fabulous safety record over about 80 years. I submit that model aviation is safer than golf. According to a study by Golf Digest, each year an estimated 40,000 golfers seek emergency treatment due to injuries caused by errant golf balls and flying club heads. Not to throw golf under the bus – but golf serves the same demographic as model aviation. Injuries and especially death from model aviation is very rare indeed. Interference with full-scale aircraft operations from LOS model aviation is very rare indeed.

Send Your Thoughts and Concern to Congress and The FAA

The best thing you can do for your hobby is to make your feelings known on this proposed rule and how it should be changed. The comment period is still open.

A big way for us as RC hobbyists to make a difference is to reach out to your representatives and senators. If you contact them they will notice an increase in concern over the new proposed ruling. The AMA says that contact is not going unnoticed and it leads to more discussion on the rule.

March 2nd is the deadline for submitting your concerns.

Here is a great link with more information about this topic.

How to Leave a Comment

The FAA has confirmed that every comment is counted, even if it's the same as the last 1,000 submitted. Your comment will be separated into a spreadsheet based on the concerns in the comment. Your comment isn't a vote. It is a way to let the FAA know you have an issue with the new proposed rule. Good data that is focused and unique is better but not required. I took the FAA's suggested comment and altered it to reflect my feelings and you can too.

Here is a link with comment templates that you can submit.

Video to Watch and Learn More

I am model aviation (3 min 6 sec)

Episode 16 - FAA Remote ID with Tyler Dobbs (24 min 27 sec)

Bonus Episode 3 - Government Advocacy Coalition and Writing Comments (14 min 14 sec)

How to make a comment to the FAA | Remote ID (19 min 56 sec)

FAA Remote ID NPRM Response Guide (47 min 38 sec)

Episode 16 - FAA Remote ID with Tyler Dobbs (24 min 27 sec)

🤠 Garmin Glass + Carbon Fiber (SCRAPPY 10) (23 min 26 sec)

Discuss and Learn

We have a good amount of threads that have been going for a while on RCGroups. Please take a look for more info for our users:

Links

Last edited by Jason Cole; Feb 22, 2020 at 01:53 PM..
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Feb 04, 2020, 11:51 AM
Jim T. Graham's Avatar
Thread OP
Feel free to use this thread to voice opinions, ideas, links and more.
Feb 04, 2020, 12:31 PM
A man with too many toys
Is their an FAQ about this?
I hear the same questions over and over but get a wide variety of answers.

I am especially interested about existing aircraft and those that are built from plans in the future. I have been getting into building some of the old classic airplanes and restoring some of my 30 year old airplanes. Might even fly some with my old radios. How will the FAA deal with those?

.
Feb 04, 2020, 02:26 PM
Registered User
A decent article but it understates the problem by not mentioning:

-Amateur-built craft can only be flown on a FRIA site
-FRIA sites can only be created within a certain 12-month period, after that no more can be created. If a club's lease on land expires, thats it.
-Remote-id cannot be retrofitted to an old craft or a scratch-build. It has to be from an "approved" design.

Suppose you build your own planes and you live way out on a farm, the closest club is 4hours away. Now you are not allowed to just fly the plane over your own land.
Suppose you are a kid, you build flite-test planes. Your town does not have a club, in any case you cannot drive. Now you are not allowed to fly in ball diamond at school.


I've started my letter. I am using a document format so I can include pictures of where I fly and some my harmless looking, but over 250g planes.
Feb 04, 2020, 02:51 PM
A man with too many toys
Quote:
Originally Posted by RetepTrun
Suppose you build your own planes and you live way out on a farm. Now you are not allowed to just fly the plane over your own land.
That's exactly my situation, 90% of my flying is from a small grass strip on my farm and I fly over my farm land. Sometimes I never see an airplane fly over for weeks or months. I have been flying for over 50 years and have dozens of airplanes - many that I have designed and built over the years. FAA needs to have provisions for that.

I think that the bottom line is that the same remote ID rules for commercial and recreational is just not a workable solution. I really don't see how that will ever actually happen. Making up unjust rules is not doing to have the effect that the FAA thinks it will have.


You also have the problem if very spotty cell service in rural areas. You could be doing everything you are suppose to but the info would never get to the FAA. A cellular solution is just not a workable solution - Look at how well it worked for the Democrats in Iowa - LOL


.
Feb 04, 2020, 03:33 PM
A man with too many toys
Quote:
Originally Posted by RetepTrun
-Remote-id cannot be retrofitted to an old craft or a scratch-build. It has to be from an "approved" design.
That's another indications that the FAA only thinks about drones and not RC airplanes. If that's what they want then they should have totally different rules for Drones and RC airplanes. Most all of my airplane fleet were designed many years before RC multirotor drones came into existence.

I wonder if the RC aircraft manufacturers and dealers are aware of that. Will they have to trash all their current inventory and wait years for FAA to certify each and every design. That's much more strict than home built full size airplanes. It would be crazy for RC modelers to have more strict rules that home-built manned aircraft and hang-gliders.


.
Last edited by RC Man; Feb 04, 2020 at 03:38 PM.
Feb 04, 2020, 05:03 PM
Registered User
rpstar's Avatar
Quote:
Originally Posted by RetepTrun
A decent article but it understates the problem by not mentioning:

-Amateur-built craft can only be flown on a FRIA site
-FRIA sites can only be created within a certain 12-month period, after that no more can be created. If a club's lease on land expires, thats it.
-Remote-id cannot be retrofitted to an old craft or a scratch-build. It has to be from an "approved" design.

Suppose you build your own planes and you live way out on a farm, the closest club is 4hours away. Now you are not allowed to just fly the plane over your own land.
Suppose you are a kid, you build flite-test planes. Your town does not have a club, in any case you cannot drive. Now you are not allowed to fly in ball diamond at school.


I've started my letter. I am using a document format so I can include pictures of where I fly and some my harmless looking, but over 250g planes.


Where are you getting this info? I don't see anything when I looked that prevents using older aircraft. They talk a lot about stupid manufactured drones but nothing about rc planes being restricted from "retrofitting" that I could find searching the proposal. Same with the site creation. Can you post the section and quote of where you saw this?

I hate the proposal and don't see it as very enforceable to be honest. If I had my own property I'd just keep flying my planes and not worry about it. Possible some police would bother you (doubt it) but if they did I'd eventually sue for harassment.
Feb 04, 2020, 05:14 PM
A man with too many toys
The FAA rules are so messy I don't see any way that local law enforcement would know if you were legal or not. Just tell them that rule is only for Class Z airspace and they will go away with a blank look on their face - LOL.

.
Feb 04, 2020, 05:20 PM
ƃuıʇɐǝʞ ʇʇoɔs
vulturetec's Avatar
Quote:
So the best-case scenario for pilots like me that fly out of an AMA field is that nothing would change.
Quote:
Originally Posted by RetepTrun
A decent article but it understates the problem by not mentioning...

-FRIA sites can only be created within a certain 12-month period, after that no more can be created. If a club's lease on land expires, thats it.

That point needs to be made loud and clear. I've seen far too many emails, discussions, and web sites with similar statements to the one posted by RCG above.

It would be a little less painful if our club fields were to be safe-havens from this monstrosity of rule making, but everyone needs to know club fields are not automatically going to be FRIAs. I would guess many will not. Twelve months after the rules kick in those sites that are selected to become FRIAs can never move. If a club needs to move due to a lost lease, encroachment of development - or even just an opportunity for a better site - can never apply for a new location.

Edit: Under 89.220(b) it may be possible to move an established FRIA. The rule says:
(b) If the community based organization wishes to change the geographic boundaries of the FAA-recognized identification area, the organization must submit the request to the FAA for review. The geographic boundaries of the FAA-recognized identification area will not change until they have been approved or denied in accordance with § 89.215.


It's unknown if they will accept changes to the "geographic boundaries" of an existing FRIA might include moving the boundaries to a new location as opposed to simply expanding the size of the existing FRIA. Time will tell.


Many club fields will probably remain intact for years, even decades (unless they change the rules again) - but once a field is lost so is that area where traditional modeling can exist.

It's also worth mentioning that the term "Amateur-built craft" may need clarification too. The FAA is proposing rules similar to those used for building amateur-built full scale aircraft (ie: experimental or a home-built, take your pick). The idea that the government employees are pushing rules to regulate not only flying toy airplanes, but also terminology that defines if one is actually qualified to be called "amateur built" is appalling. Keep in mind this isn't just aimed at 15lb or even 50lb airplanes, it's aimed at any radio controlled aircraft larger than about 9oz.
Last edited by vulturetec; Feb 05, 2020 at 08:54 AM.
Feb 04, 2020, 06:01 PM
A man with too many toys
Someone in another pointed out that the proposed FRIA site rule in definitely not constitutional. That will definitely have to changed in the final version.
Feb 05, 2020, 02:10 AM
Registered User
scott page's Avatar

FRIAS are temporary....


Quote:
Originally Posted by RC Man
Someone in another pointed out that the proposed FRIA site rule in definitely not constitutional. That will definitely have to changed in the final version.
How so? I'd like more info on that.

My issue with FRIAS is by design they are a method of phasing out recreational traditional model aircraft through attrition. As proposed: FRIAS can only be established in a 12 month period - from that time forward NO NEW FRIAS will be allowed. FRIAS can only be established in conjunction with a CBO. This means a private land owner could not legally fly on their own property. In addition to CBO's, land owners, municipalities, airports, and military facilities should also be allowed to create FRIAS in perpetuity.
Despite what the FAA thinks, intends, or mandates, home-built models will continue to be built and flown. FAA can know where these flights are occurring by allowing continuing establishment of FRIAS, or have models flying goodness knows where.
Feb 05, 2020, 06:07 AM
A man with too many toys
Quote:
Originally Posted by scott page
This means a private land owner could not legally fly on their own property.
That sounds unconstitutional to me. I'm sure that the FAA lawyers are aware of constitutional problems ans will make changes. I would not worry about that aspect as it will never stand up in court.

.
Last edited by RC Man; Feb 05, 2020 at 09:07 AM.
Feb 05, 2020, 09:16 AM
A man with too many toys
What are other countries doing or is the US the only country considering remote ID for recreational RC airplanes?
Feb 05, 2020, 11:57 AM
Registered User
earlwb's Avatar
I doubt whether it is unconstitutional or not will stop them from implementing it. The left has been trying to tear down the Bill of Rights for years. Lawsuits and courts will take years to meander through for a determination. If injunctions against it fail during that time it could pretty bad for the hobby.

The main problem is if they decidde to go ahead with the ID system, it could take them years to implement. They have to have someone design, engineer and test the things. Then go into manufacturing and get enough made to force people to have to buy the things. They have to have special servers and equipment all over the US to read the IDs, etc. too.

An app would be problematical at first too. It would be buggy and have problems working on all of the different phones out there. Plus they need many servers setup to take the data sent to them.
Last edited by earlwb; Feb 05, 2020 at 12:00 PM. Reason: add more info
Feb 05, 2020, 12:27 PM
AndyKunz's Avatar
Quote:
Originally Posted by RC Man
What are other countries doing or is the US the only country considering remote ID for recreational RC airplanes?
Read the document. The FAA calls out what is going on in Europe, and notes how many ways it is more restrictive than over there.

Everywhere else already has the 250g limit. That's the least likely thing to change.

Andy


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