Below is the full text of a comment I have submitted to the FAA regarding the proposed rule on Operation and Certification of Small Unmanned Aircraft Systems (Docket ID: FAA-2015-0150).  I encourage everyone who agrees with my comment to submit it again using copy / paste.  Or modify it as you consider appropriate to express your own take.  Regardless, the more they see specific feedback like this the more likely positive change will occur.

Age of Operator (Tracking ID: 1jz-8hrz-9006)

The proposed rule cites a minimum age for an operator of 17 years. However, most states allow a learner permit for driving a car prior to age 16.

I contend that driving a car involves: (a) higher probability of accident; (b) greater potential for significant injury or death; (c) the principal of "see and avoid"; (d) maintaining positive control (pending driver-less car technology); and (e) similar operational skills.

With regard to age qualifications the rule should, at the very least, be modeled after age qualifications for operating a car. The minimum age for independent operation of a small UAS should be 16. If the operator is under the age of 16 they should be required to be accompanied by a qualified operator who is over the age of 18. They should be required to maintain direct visual and audio contact with each other at all times while the younger operator is in control of the small UAS.

Frankly, I believe operators as young as 12 is reasonable. Most people have sufficient motor skills and visual acuity by age 12 to operate a small UAS better than many twice their age. The real question here is whether they are responsible and will make mature decisions during operation.

It's not about skill ... It's about understanding the risks involved ... And this is usually where a 12 yo or even a 16 yo person comes out short ...

The part of the human brain involved with this is actually not fully developed until the age of 25!

In Canada the age is 18 if you are flying commercially and under the  2kg exemption the following applies:
Any persons operating under this exemption shall be a minimum of 18 years of age, or be at least 16 years of age and conducting research under the supervision of an academic institution.
Not sure of the rationale because you only have to be 17 to get your private pilots license.  I think it is because they feel it is harder to fly a UAV from the ground rather than fly a manned aircraft....

I would ask that a younger age be allowed with Adult Supervision. Just like a Driving Learner's permit. I started driving cars in a parking lot (empty and large) with my Uncle when I was 8 years old. I went on to Racing Fuel Cars at 300 + MPH in my later years. Never had an incident that I couldn't control.

FictitiousPerso Posted at 2015-3-28 03:31
Quads/Hexi's, Octo's are very easy to fly so i don't see why there should be an age limit(supervis ...

Well ... if I was flying over an open field I would have no concernes about letting my 4yo daughter fly my I1 ... But there is a big difference flying in populated areas with "random people" and property close by

My son has been flying since he was 8. He flys safe, well and respectfully to his surroundings. Now 9 I let him fly my inspire and he treats it like he does guns when we go shooting together, Safe, controlled and responsibly. Honestly if a lot of the people out there fly as safe as he does we wouldn't see half of the news reports we see on the news. He has his check list, he checks to make sure the conditions are safe, he knows his surroundings and makes sure he is not near any airports or places where there might be other aircraft etc.

The general consensus of age vs responsibility is a stereotype and nothing more than profiling and in the case of kids under the age of  16 the problem isn't the kids, its their parents. Teach your kids right, hold them accountable for their actions, and be with them thru the learning process and whether its guns or multi rotors or cars, teach them to respect them, understand them and know the hazards and positives to them and you most likely wont have a problem.

Ill add this..... much like some other laws does anybody think this kind of age limitation will stop it from happening? Drugs, under age drinking, etc???  Laws dont stop people from making stupid decisions.....  they will happen regardless...

PureSQNut Posted at 2015-3-28 03:52
Ill add this..... much like some other laws does anybody think this kind of age limitation will stop ...

Well ...

A friend of mine says that 95% of all humans are idiots ... I'm afraid he is right!

FictitiousPerso Posted at 2015-3-28 03:54
Thats where the adult supervision comes into play. The difference is the risk! hence the adult sup ...

Yes, adult supervision is key.

I may let my nine year old fly my inspire but he sure as hell doesn't get to do it on his own.

Glad to see the discussion.

NOW

Did anyone translate this into action with a comment on  the rule?