"If one simply cannot do that to a model, use a FRIA. But know that you likely will have to pay some kind of a "launch fee" to use it."
You've missed the point, If Franklin gets his way, there will be no FRIAs. In the name of "equal protection" he's proposing that since not everyone can use them, then NO ONE can have one.
Of course, we can ask the FAA for anything we want in our own comments. I'm planning to ask for the following:
- Expanded FRIA application period
- Opening FRIA eligibility to non-CBO entities and private individuals
- Allowing temporary FRIAs, for contests, airshows and other special events
- Eliminating the rule that once a FRIA is terminated, even by request of the CBO, that it can't be reestablished
- Consideration of additional FRIAs based on the distance between them (so no one has to drive too far)
- Making FRIAs a permanent part of the airspace system, not a temporary expedient
- A higher weight threshold for the UAS registration requirement, for fixed-wing aircraft flown within visual line of sight
- Provision for "modular means of compliance" -- drop-in RID compliant components that a builder can install himself. The burden of "proof of compliance" being on the MANUFACTURER, where it belongs.
I may not get everything I ask for. But anything I get is a "win" for model aviation.