The major difference between FRIAs and private airports is that the private airport is not the ONLY site where an entire category of aircraft can fly. And in terms of total numbers, they're the overwhelming minority of airports. In the NPRM, they are the ONLY way where those w/o compliant equipment can fly. To use your private analogy, it would be like saying that ultralights can only fly at private airports, and you must be a member of ___________ private organization to fly them. You see, the private airport analogy falls apart rather quickly.

Secondly, the government is under no obligation to ensure the financial well-being of private organizations. They are however required to ensure that all citizen are equally protected under the law, and the FRIA as written fails. It creates two classes of citizens with respect to privileges in the public airspace. One set of rules in PUBLIC airspace for members of PRIVATE dues collecting organizations, and another set for everyone else. Given that the latter is the overwhelming majority of those who will operate under this rule, IMO it will fail a court challenge on equal protection grounds. And if it does, most of FAA Remote ID plan falls apart - and I doubt FAA wants to take that risk.

Landowner role. If a third party can submit information w/o explicit permission of the land owner to which it applies, it undermines the rights of that land owner. Simply requiring signature of land-owner should not be a big deal. In the case of a site that is public owned (state, city, town, country properties for example), it's even more problematic for a third party to apply for a federal designation w/o the buy in of the government agency.

Cost of maintenance. FRIAs serve a role more like public airports rather than private ones, since they are are the ONLY option for those w/o compliant equipment. And the vast majority of public airports DO NOT charge landing fees. A few searches of AOPA airport data show that somewhere between 70-80% of public airports do not charge landing fees. I argue that's the problem of the group applying for the FRIA status. In short, not the FAA's problem. Perhaps the CBO should re-examine money allocated to Muncie and instead apply it to the FRIAs? It would appear that AMA did not think this aspect through before they floated the idea of FRIAs to FAA. All they saw was the $$$ signs. They never asked "What if we don't get exactly what we want?"

Airspace. I'll grant you that is an interesting question. The most one can hope to do is make sure the FAA is aware of groups like Fairview Flyers and such, CBO members that were unable or unwilling to refrain from overflights of people and property not their own. I will however point out that the CBO's beloved safety code requires operators to "avoid flying directly over unprotected people, moving vehicles, and occupied structures." So it seems to me that a group unable to keep their toys inside lateral limits would be handing neighbors reasons to go to FAA and have a FRIA shut down Since the rule would preclude that club from EVER reopening as a FRIA, that seems a monumental risk to take just because someone wants to fly large and fast toys.

So the points remain the one of three options for flying would require upwards of 800,000 non-CBO members to give a private organization money, In fact, in section F, "other", the section dealing with FRIAs, costs, and assumptions regarding them, the NPRM specifically says "The FAA requests comments, with supporting documentation, on these assumptions." It's almost as if they know that the idea is problematic, and are specifically seeking comments to justify what they believe -- that the CBO was not transparent about the forced membership aspect of this idea. By all but inviting comments to prove this, it will be handing FAA the very reason they want to require them to be open to any citizen. I intend to provide them this issue.

Insurance. Interesting. On one hand you want to ignore the land owner's rights by not requiring their signature on a FRIA application, and on the other hand you want to honor it by requiring insurance to fly there. Sorry, can't have it both ways, which is exactly the point I'll make to FAA. If the landowner imposes an insurance requirement, then it's imperative that the landowner sign off on the FRIA application.