"FRIAs are one of just three options for ALL recreational flyers, and the ONLY one that does not involve equipment upgrades or reprogramming. "

On paper, yes. In the real world, FRIAs are the only practical option for operators of existing UAS:
- The NPRM requires anyone installing Standard Remote ID in a new or existing UAS to qualify as a "UAS Producer". This doesn't just mean filing paperwork; it means performing system-level integration testing proving the Remote ID equipment functions as designed and retaining the results for two years. It means performing periodic "audits" on all RID equipped UAS and reporting any functional issues to the FAA. The NPRM specifically states this is intended for commercial entities; the FAA does not want hobbyists retrofitting RID into existing platforms.

-Limited Remote ID has the same drawbacks. More seriously, Limited RID is a joke for fixed-wing aircraft. A kinematic analysis of a simple traffic pattern shows that it can't be executed within the 400 foot "bubble" at a speed greater than about 27 MPH. Looking at typical park flyer wing loadings, only sailplanes and ultra-micro planes (which are under the 0.55 lb limit anyway) will meet the speed criterion. And that's without considering the effect of flying "three mistakes high" -- which quickly shrinks the "bubble" even more once the model is over 100 foot altitude.

Therefore FRIAs are the only PRACTICAL option for ALL "legacy UAS". And as we've previously discussed, trying to force private clubs to become public parks will only REDUCE the number of available FRIAs.

It is far more reasonable -- and constructive -- to lobby the FAA to extend FRIA eligibility to non-CBO entities and individuals with suitable properties. Maybe even REAL "public" FRIAs in PUBLIC places like parks.