"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."
That might be true if there was only ONE CBO. There is nothing stopping a group wishing to establish a FRIA from joining a different CBO, or even starting one of their own. And there is no requirement that a CBO charge dues.
"...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. "
Actually it restricts those without certain equipment from flying in most airspace. Just like restrictions on ultralights and full-scale planes not equipped with ADS-B.
"IMO it will fail a court challenge on equal protection grounds. And if it does, most of FAA Remote ID plan falls apart ."
Hmmm, maybe I should encourage you. Nothing would please me more than waking up tomorrow to find an FAA announcement along the lines of, "Sorry - the whole thing was a mistake".
"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. "
Which specific rights are undermined? The information requested is the geographic boundaries of requested AIRSPACE, not the landowner's property lines. The landowner does not own or control the AIRSPACE, whether over his property or adjacent to it.
"...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. "
Evidently 20 - 30% DO, and therefore it is legal. You might have a point that it would be inappropriate for a FRIA on PUBLIC land to charge "landing fees". Private clubs, like private airports, can make any rules they like.
"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."
Thank you for the customary quarterly safety presentation. Will there be a beer call afterward? Just before we all drive home, that is?
In our case, the outskirts of the nearest village are half a mile away. That's behind the safety line, so we don't fly there. All around the runway are crop fields, and there is only one tree on our side of the nearest road. Bacteria excepted, the only living thing that's going to get hurt when one of our planes goes down is some corn plants - and the landowner builds that cost into the field rent.
"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...
That assumes a significant number of them are even interested in flying at FRIAs. Most are probably park fliers and/or FPV enthusiasts who have no interest in our fields. They should be lobbying for more reasonable weight limits before requiring registration -- say 2 kg instead of 250g. They should be lobbying for more reasonable retrofit provisions for Remote ID, instead of having to qualify their home workshops as "UAS Producers".
"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. "
I don't "want" anything except to continue to practice my hobby as I have always done. Like any good debater I will use any argument that advances my cause.