Yes, and no FRIAs means all of our existing equipment (ultra micros excepted) will be junk three years after the effective date of the final rule. Retrofit, if technically possible, will require individuals to get their home shops approved as "UAS producers".

With no FRIAs to fly them in, the option for "amateur built" unmanned aircraft also goes away. Our choices will be limited to "ready to fly" models which, because of the requirement to include 100% of SYSTEM components, will have to include useless toy quality transmitters. Oh, and "UAS kits" as well - which will be the identical models disassembled and shipped in smaller boxes. Gee, we get to bolt the wings on so the Chinese can fit more of them in the shipping container.

That's how important FRIAs are in the context of this NPRM. Without them, traditional model aviation is over.

If someone is concerned about the AMA, some more constructive uses of comments might be:
- Request the FAA to expand the application period, to give time for more CBOs to form.
- Request the FAA to extend eligibility to other organizations (such as STEM schools) and individuals with suitable properties.
- Request the FAA to remove the unnecessarily harsh and burdensome language that states that FRIAs terminated at the request of a CBO can never be reactivated. Sometimes clubs lose fields for no fault of their own. That doesn't preclude someone else from using the same site in future if circumstances change.
- Request the FAA to accept FRIAs as a permanent part of the airspace system. UAS being safely operated within the confines of a FRIA are not being operated elsewhere, where they might conflict with other unmanned traffic. Keeping FRIAs open for as long as possible benefits both recreational UAS users and the FAA.