Originally Posted by
grognard
Nothing in the NPRM states that one must join a CBO in order to use a FRIA. It is only necessary to "follow the safety programming" of a CBO."
You're right, it doesn't say anything about it in the rules. But the "programming" of the CBO in fact DOES say that you have to be a member, not just of the CBO but also the club.
Originally Posted by
grognard
The FAA might have reasonably assumed that members of a CBO applying to have an existing flying site recognized as a FRIA were already dues paying members of that CBO - so there is no additional cost.
I cannot understand why anyone who values this hobby would be against FRIAs.
Remember, this is a rule for ALL citizens, not just CBO members. And the FRIA is the only option available for the 800,000 citizens who may have non-compliant equipment. That means the rule all but compels membership in a PRIVATE dues collecting organization in order to enjoy a privilege in PUBLIC airspace. IMO, that will fail on equal protection grounds if challenged in the courts.
As for the cost, there is additional cost for these non-members, significant additional annual cost not considered as part of the rule. $75 a year tithe to AMA and additional amount that can be equal to or greater to the club. Again, as these costs were left out of the economic analysis, it appears AMA "forgot" to mention the requirement to pay dues to use these clubs.
There's additional problems with the rule and thus more reasons to oppose FRIAs. One such reason is no specifics on what the site can and cannot claim as its geographic limits. It's not stated, and thus ambiguous. A second reason is what about the property owner's role? Can a club, without explicit permission of the land owner, apply for FRIA status? I think not. So I'm going to recommend that unless the club owns the land, the land owner must endorse the application. The third reason to oppose them is the rule is unclear about what happens when a citizen applies to use an FRIA that is "closed to new members." And a fourth problem is what happens when a site discriminates against some types of recreational sUAS.
Fortunately the fixes are easy. Any FRIA, as a condition of designation as such, MUST be open to any citizen w/o regard to membership status in ANY private dues collecting organization. If there is an insurance requirement, then the organization submitting the FRIA must offer an insurance only option that does not exceed the amount paid by CBO members as a pro-rata share of membership dues. For example, of the $75 paid to AMA for dues, approx 17% is insurance. So the CBO would have to allow anyone to use the field for an annual payment of 17% of the $75 annual AMA dues.
However, I strongly suspect that FAA will be reluctant to allow fixed sites that require private club membership, as if challenged in court and it loses, the much of the rule is severed, and any integration of sUAS is significantly delayed.