Comments for FAA's ANPRM for safe and secure operations of UAS
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Cetacean
First Officer
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United States
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Aloha,
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RE:  Comments requested for FAA's ANPRM for safe and secure operations of UAS

Model aviation needs your help to ensure that future regulations do not place unnecessary burdens on our community. Last month, the FAA issued an advanced notice of proposed rulemaking (ANPRM) regarding the safe and secure operations of small Unmanned Aircraft Systems (sUAS). In this ANPRM, the FAA is currently seeking comments on potential new rulemaking for operational and performance restrictions on UAS, including model aircraft. Some of the parameters being considered include altitude, airspeed,  standoff distances, and unmanned aircraft traffic management.
  
It is critical that we voice our support for the hobby by submitting a comment to the Federal Register regarding this ANPRM. AMA has developed sample text that you can customize with your personal story and then copy and paste into the comment field on the Federal Register website. The deadline for submitting comments is 11:59 p.m. on April 15, 2019.
COMMENTS
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Aloha and Drone On!


2019-4-2
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DJI Stephen
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Hello and good day Cetacean. Thank you for posting this valued informative regarding the comments for FAA's ANPRM for safe and secure operations of UAS. I hope all our co pilots will be aware of this matter. Great find and thank you for your support.
2019-4-2
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Cetacean
First Officer
Flight distance : 2528264 ft
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DJI Stephen Posted at 4-2 15:16
Hello and good day Cetacean. Thank you for posting this valued informative regarding the comments for FAA's ANPRM for safe and secure operations of UAS. I hope all our co pilots will be aware of this matter. Great find and thank you for your support.

Aloha Stephen,

     We need a lot of comments.  Mahalo for your interest and help!  Apparently, the United Kingdom is going through a similar process right now to.

Aloha and Drone On!
2019-4-3
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embayweather
lvl.4
Flight distance : 556667 ft
United Kingdom
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Indeed we are, although as usual the consultation process is so weighed down with how you can and cannot present evidence it will miss much useful information. We have many to thank for this not just the folk who defy the current flight rules, and those who fly plastic bags , sorry drones, across Gatwick. But these consultations are important to our futures, and those of our model aircraft flying friends. There are many who want to see our skies cleared of such things, and yet with proper regulation we can all live happily together. My main concerns are twofold. Any new regulations that are introduced will only affect those of us who already obey the rules. Those who chose not to for whatever reason will carry on doing so. There appears to be no sensible way that is being looked at that can ensure control over them as well, although control can actually be brought into use technically. Secondly, any recommendations made on either side of the water may well be expensive to introduce and may thus drive a number of pilots either underground or out of the hobby altogether. For example the use of transponders on craft, or radios to keep in touch with ATC.
I remain concerned that we have no one speaking up for us as a group. As such it may be believed that we all cannot agree what must be done. Thus your timely reminder Cetacean, for comments here might bring about a consensus that can be presented. One thing for sure is that our government will only care about big business, not about the little people.
Comments from me for what its worth are:- Regulate who flies by having a sensible exam, not a few silly questions on line. Make insurance compulsory. Register each aircraft be it new or secondhand with the pilot who owns it and who has passed said exam. Fit cheap transponders to aircraft that will fly above a certain height, and for those that do not limit their altitude, like toy drones. Make testing of aircraft airworthiness a factor of licensing . Lots more too but then again I am from the UK, so probably not much help.
2019-4-3
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Cetacean
First Officer
Flight distance : 2528264 ft
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United States
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embayweather Posted at 4-3 04:42
Indeed we are, although as usual the consultation process is so weighed down with how you can and cannot present evidence it will miss much useful information. We have many to thank for this not just the folk who defy the current flight rules, and those who fly plastic bags , sorry drones, across Gatwick. But these consultations are important to our futures, and those of our model aircraft flying friends. There are many who want to see our skies cleared of such things, and yet with proper regulation we can all live happily together. My main concerns are twofold. Any new regulations that are introduced will only affect those of us who already obey the rules. Those who chose not to for whatever reason will carry on doing so. There appears to be no sensible way that is being looked at that can ensure control over them as well, although control can actually be brought into use technically. Secondly, any recommendations made on either side of the water may well be expensive to introduce and may thus drive a number of pilots either underground or out of the hobby altogether. For example the use of transponders on craft, or radios to keep in touch with ATC.
I remain concerned that we have no one speaking up for us as a group. As such it may be believed that we all cannot agree what must be done. Thus your timely reminder Cetacean, for comments here might bring about a consensus that can be presented. One thing for sure is that our government will only care about big business, not about the little people.
Comments from me for what its worth are:- Regulate who flies by having a sensible exam, not a few silly questions on line. Make insurance compulsory. Register each aircraft be it new or secondhand with the pilot who owns it and who has passed said exam. Fit cheap transponders to aircraft that will fly above a certain height, and for those that do not limit their altitude, like toy drones. Make testing of aircraft airworthiness a factor of licensing . Lots more too but then again I am from the UK, so probably not much help.

Aloha embay,

     Many good points, I like your commentary.  As much as this is for those on our side of the Pond (water as you say), you make so many good points, somebody from our side should rewrite your post from our point of view and submit it!  You definitely have a handle on the issues.  Mahalo!

     The big problem with these "Rules" is fairness.  If the rules are perceived as unfair, the FAA has stated in the past that they know that those flying sUAS in unfair conditions will only make the FAA's problems more difficult to deal with.  That is one reason why the FAA is working so hard to create fair rules.  (Notice I did not put fair in quotes.)

     We are fortunate to have the AMA representing us over here, as you seem to note.  I think the UK has an AMA equivalent that works for you over on that side.  Maybe you could look into it.  If not, let me know and I will check with our AMA to see if we can help your side get an AMA equivalent going over there.

     This is a global issue and we need to get it resolved.  Most of us are concerned with the abuse of airspace by drones of any sort for any number of reasons.  We like our freedom of the skies!  But we all have to get committed to finding a fair use of our airspace through our various governments.  I am.

Aloha and Drone On!
2019-4-3
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DJI Stephen
DJI team
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Cetacean Posted at 4-3 03:17
Aloha Stephen,

     We need a lot of comments.  Mahalo for your interest and help!  Apparently, the United Kingdom is going through a similar process right now to.

Thank you for the additional information Cetacean. I hope that many of our co pilots will participate with this drive and give out there comments and suggestions as well.
2019-4-4
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embayweather
lvl.4
Flight distance : 556667 ft
United Kingdom
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Cetacean Posted at 4-3 22:49
Aloha embay,

     Many good points, I like your commentary.  As much as this is for those on our side of the Pond (water as you say), you make so many good points, somebody from our side should rewrite your post from our point of view and submit it!  You definitely have a handle on the issues.  Mahalo!

Thank you sir for your kind words. But I do think, what you have said, suggests to me that what we are facing is an international problem. For example if the UK decided that elephants were banned from flying drones, at the moment they are not, in the UK or the US I think it would be highly likely that the other party would follow suit. Indeed one of the questions looking for a response in the UK ask whether we know of any successful regulatory schemes overseas.
Thank you for your kind thoughts about a representative body. There are a couple of model aeroplane groups here, but I get the impression from others that they are focussed literally on that, model aeroplanes, drones are , well, outsiders. The 'professional' body we have seems nowhere to be seen in these crises, and with membership fees heading towards $200 a year I would have expected more.
2019-4-6
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