"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."

Bureaucratically that's easy; just change a few words. In the practical world it's much more difficult. I'll use my club as an example - though I will not identify it since I'm not an officer or official spokesman.

Our club was founded in 1973, and is on its third or fourth flying field. Our current facility is accessed off a country road, and is at the edge of a crop field on private property. We rent (don't know if there's a formal lease agreement) and maintain a 900 foot grass runway. We have a shelter house and shed, built by our members. We own and maintain our own mowing equipment, and do our own field maintenance on a volunteer basis.

Our members fly everything from ultra-micros to jets. We have everything from beginners to an ex-IMAC competitor. Most of our members are older guys flying park flier sized foamies or old glow powered models. And yes, we have a couple of young guys who play around with drones and FPV stuff.

We are a laid-back group who just want to enjoy our hobby and have fun. We each take our turn on the flight line and do not favor one type of model or style of flying over another. We welcome new members; in fact, those joining in the middle of the season get a discount.

Our dues are $100/year (not including AMA membership), most of which goes for field rent and mower maintenance. We host an annual fly-in for neighboring clubs, a summer picnic, and a swap meet. The club officers receive no payment for the work they do to run these.

Did I mention this is our fourth field? That's the fourth one for which we broke the sod, planted the seed, and rolled out the ruts. A good quantity of our sweat, and some blood, is in that ground. Nevertheless we don't charge "initiation" fees, and new members get a discount.
We welcome guests as spectators. Guest flyers must be AMA members to guarantee insurance coverage, and sponsored by a club member. Our expectation is that anyone who wants to fly at our field more than three times a year should join the club.

Our membership is in the 30s, and many of us would be happy to see it double. However, we don't need 30 freeloaders descending on us who will take advantage of our services while contributing nothing. And we cannot throw the gate open to all comers and become a public park. We can be reasonably certain that even suggesting that idea to the landowner would be met with, "Well guys it's been fun -- guess I'll plant a few more acres this year".

So, if your suggestion is adopted, the likely practical impact is that our field goes away. If similar things happen to neighboring clubs, then all our equipment is useless. Talk about a "taking" -- now THAT's a taking! Why are we being punished? Is it the Puritan Principle -- a deep, abiding suspicion that someone, somewhere is having a good time?

"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."

This seems to conflict with the first point. How can there be an "insurance requirement" when any member of the public can use the site without belonging to the organization? The Obamacare experience shows that the Federal government can't mandate insurance coverage, so who's going to enforce this?

"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."

The AIRSPACE appropriate for a FRIA will be on a case-by-case basis; one size does not fit all. The whole idea of a FRIA is to separate unmanned traffic without Remote ID from the remaining unmanned traffic. So the boundaries need to be the maximum possible airspace of the largest, fastest UAS that will be using the site. This will of course be limited by visual line of sight and the legal altitude limit.
With some of our members flying jets, the simplest boundary to request is probably a 1 NM circle centered at the middle of the flight line. This will provide plenty of room for traffic avoidance and minimize collision risk.

No, we don't own or lease the land under this circle, and we don't need to. The FAA has long asserted the right to regulate airspace usage; this would simply be reallocating a piece of uncontrolled airspace for use as a FRIA. It was "taken" by the Federal Government almost a century ago.

"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. "

Since the landowner has no control over the airspace adjacent to his property, it really makes no difference to him whether the FAA calls it a FRIA or not. As long as "FRIA" isn't a synonym for public park, that is.

"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."

Well, the FAA allows private use airports for full scale aircraft, and if you land without the owner's permission, you can be arrested for trespassing. Private airport owners are only required to notify the FAA of any changes to pertinent information so it can be listed on charts and directories. Opening a private airport absolutely does NOT require the owner to invite the general public to use his facility, nor open it to all types of aircraft.

I fail to see why privately owned FRIAs should be any different.