On the next page you can access the NPRM document and supporting documents. You may also click on Comment Now! to submit your own comments. You may also upload a Word document file, if you wish.<\/p>\n
Note that the NPRM is 319 pages long and there are hundreds, if not thousands, of pages of supporting documents. This is a very complex rulemaking and the FAA has made it difficult for the general public to understand the details – we do not have teams of lawyers, engineers and other staff to go through all this.<\/p>\n
How This Process Works<\/strong><\/p>\n The Administrative Procedures Act requires that new proposed rules be posted to the public and the public be given an opportunity to comment on those rules. Unfortunately, the law does not require the agencies to listen to that feedback; it only requires collection of the feedback. An agency could, if it wished, accept the public’s comments, ignore them and issue its final rule. In practice, that does not normally happen.<\/p>\n Instead, the agency will\u00a0 analyze and remove duplicate filings, form letters and so on. Possibly\u00a0 they will be “counted” but the specific points raised are\u00a0 only counted once.<\/p>\n Agency staff will then begin reading the comments and identifying each unique issue. If dozens of people identify the same issues, then this is coalesced into a single issue point.<\/p>\n Once they have collected all of the issues raised, the FAA will proceed to interpret the issues and determine how to modify the proposed rule.<\/p>\n Once this lengthy process is completed, the FAA will issue its final rulemaking. In that document, they will list each of the key issues raised and explain how the resolved or did not resolve the points raised.<\/p>\n Good Comments \/ Bad Comments<\/strong><\/p>\n The best comments are those that identify specific issues, explain the problems, provide facts and logic to back up your discussion, and suggest recommended alternatives.<\/em><\/span><\/p>\n The worst comments are those that rant and whine or which just copy form letters. These comments may be ignored by the FAA.<\/p>\n <\/p>\n Do NOT submit comments immediately<\/strong>. Every day, we learn more about the proposal and learn more about critical issues in the NPRM. Take your time to learn about these issues, to understand the ramifications and to formulate fact-based arguments as to why the proposed rule should be implemented differently. Anyone that urges you to file “urgent” comments is naive about how this works (and yes, I am pointing to the AMA which sent out an email blast on January 7th mentioning just 4 points and urging people to file urgently without learning more.)<\/p>\n Do NOT submit comments that are rants and whining<\/strong>. These accomplish little.<\/p>\n Do NOT submit comments that are copied from form letters and templates<\/strong>. All government agencies remove duplicate form letters; they have no interest in reading the same thing over and over again.\u00a0 In essence, form letters are largely ignored.\u00a0 Sadly this is the exact path the Academy of Model Aeronautics has taken – this is the path to failure.<\/p>\n Example – here is their template letter<\/a> \u00a0 and here is the first bit of text in their sample letter:<\/p>\n I am writing in response to the FAA\u2019s notice of proposed rulemaking on remote identification of unmanned aircraft systems (UAS). I am deeply concerned that some elements of the proposal ….<\/p><\/blockquote>\n Here is a snapshot of filed comments as of this afternoon – all copied verbatim from the AMA web page:<\/p>\n The AMA is damaging this proceeding by encouraging members to file form letters. This is idiocy on display. DO NOT DO THIS.<\/strong><\/em><\/p>\n Updated<\/strong>: A similar problem occurred in 2017 with an NPRM from the FCC (not FAA). Over 23 million comments were filed – most were form letters, barely rewritten templates, and millions appeared to have been submitted by computer “bots” that fabricated fake comments. According to Wired Magazine, the FCC ended up largely ignoring the public comments and instead relied on those filed by law firms, corporations and large organizations. Only 6% appeared to have been unique, individually written comments. Read the full story on that<\/a>, plus comments from a former FCC Commissioner on how to write effective comments (pretty much the same as what I wrote below) (This paragraph added on January 21, 2020)<\/em><\/p>\n Do NOT submit comments saying the FAA has no business requiring Remote ID.<\/strong> The FAA has no choice in this matter. Congress, in Public Law 114-190 required the FAA to implement Remote ID. That law is already passed. The FAA cannot do anything about that – their charter is to\u00a0 \u00a0develop a solution through a “consensus of stakeholders”. The FAA does have discretion in how it choose to implement Remote ID, however.\u00a0 If you file comments to the FAA saying\u00a0 they have no business implementing remote ID, you are wasting your time and your comments. A number of people on social media have been advocating the “FAA can’t do remote ID” argument, which is pointless.<\/p>\n Do NOT submit comments saying that it may be law, but that doesn’t mean the FAA can enforce it<\/strong>. Oh yes they can. Once it is law, there are only two options to challenge the law: in Court, or by electing a new Congress that\u00a0 establishes a new law. The hobby community lacks the resources to do either of those.<\/p>\n Do work to understand the proposals.<\/strong> Do follow discussion groups online and on social media. This includes model aviation clubs, groups, quadcopter\/FPV enthusiasts on Youtube, Facebook and Reddit. Many groups are analyzing and thinking through strategic responses. I have seen a number of very good points being identified and good arguments emerging.<\/p>\n DO SUBMIT COMMENTS<\/strong> that identify issues, analyze the problems, and propose solutions. Well thought out arguments, facts and logic to help the FAA understand problems – and suggestions to how to solve those problems will get more traction than the short comment that just complains.<\/p>\n EXAMPLE ISSUES<\/strong><\/p>\n In one part of the NPRM, the FAA says home built model aircraft will be permitted to be flown only at Federally certified airfield sites. At least we can still build model aircraft!<\/p>\n Or may be not! Elsewhere, the FAA lays out the requirements for Amateur built aircraft – which makes it look like they will allow\u00a0 people to build their own planes. But read the details: few individuals may qualify for their >50% build requirement (this is a concern of many). That’s because most home builders design and construct airframes – but under this rule, you might be expected to develop from scratch your own lithium polymer battery chemistry, your own semiconductors and microcontrollers, your own servers, your own motors, your own transmitters and receivers – because if you do not do this you may\u00a0 not achieve the >50% build requirement.<\/p>\n The FAA seems to be banning future home built model aircraft – and prefer instead to allow only the assembly of certified, pre-manufactured kits. They say on page 174 that they’d like to eventually end their FRIA “reservations” for existing model aircraft to be flown.<\/p>\n A better solution would be for the FAA to mandate a set of core components such as certified transmitter, receiver, controllers with remote ID and certified smart phone app. Then let us build any fuselage we want around those core components. This is the kind of idea you want to put in our comments as a Recommendation for the FAA to create a better solution.<\/p>\n The FAA also bans the future flight of existing quadcopters and model aircraft. Three years after the rule takes effect only certified model aircraft may be sold, each containing Remote ID technology. All existing aircraft must be trashed, or you have limited options to fly them at one of few Federally approved flying sites. Because the FAA will prohibit the certification of new flying sites 12 months after the rule takes effect, this guarantees that over time, there will gradually be fewer and fewer places to fly (they say this on page 174).<\/p>\n For most of us this means trashing\u00a0 all of our aircraft and accessories. Some number of aircraft might\u00a0 have software or other updates available from their manufacturer; however the FAA itself says in the NPRM that most recreational craft will not likely be capable of updates.<\/p>\n The FAA’s own Advisory Committee proposed the idea of an add-on Remote ID transponder to retrofit existing model aircraft. This makes more sense for the environment too – why throw away millions of perfect good small UAS?<\/p>\n![\"\"](\"https:\/\/coldstreams.com\/3d\/wp-content\/uploads\/2020\/01\/Capture.jpg\")
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