franklin_m

A couple facts to string together as you please:

- FAA does not account for cost of CBO and private club membership in their cost figures. At least $75 a year to CBO to even get access to FAA Recognized Identification Areas ... and club membership is often the same or more.

- Current FAA registrations number around 1.0 million. CBO says it has 200,000 members. That means non-CBO members outnumber CBO members by FOUR TO ONE!

- If non-CBO members are required to join CBO in order to access FRIAs, that represents up to $60 MILLION annually to the CBO.

- An option that requires membership in a CBO in order to exercise privilege in PUBLIC airspace means the rule requires overwhleming majority of recreational sUAS flyers to join a PRIVATE DUES COLLECTING organization in order to enjoy the only option available short of expensive equipment upgrades.

- Government mandated membership in a CBO in order to enjoy privileges puts that CBO in control of whether or not a citizen can exercise privileges under the rule. Examples include, but not limited to:

RCUer75345

It's also a fact that neither the AMA, nor any other CBO, has been officially recognized by the FAA.

jcmors

Good point, and if the FAA never gets around to officially recognizing any CBO then there will be no FRIA sites ever!

RCUer75345

Yes, and no FRIAs means all of our existing equipment (ultra micros excepted) will be junk three years after the effective date of the final rule. Retrofit, if technically possible, will require individuals to get their home shops approved as "UAS producers".

With no FRIAs to fly them in, the option for "amateur built" unmanned aircraft also goes away. Our choices will be limited to "ready to fly" models which, because of the requirement to include 100% of SYSTEM components, will have to include useless toy quality transmitters. Oh, and "UAS kits" as well - which will be the identical models disassembled and shipped in smaller boxes. Gee, we get to bolt the wings on so the Chinese can fit more of them in the shipping container.

That's how important FRIAs are in the context of this NPRM. Without them, traditional model aviation is over.

If someone is concerned about the AMA, some more constructive uses of comments might be:
- Request the FAA to expand the application period, to give time for more CBOs to form.
- Request the FAA to extend eligibility to other organizations (such as STEM schools) and individuals with suitable properties.
- Request the FAA to remove the unnecessarily harsh and burdensome language that states that FRIAs terminated at the request of a CBO can never be reactivated. Sometimes clubs lose fields for no fault of their own. That doesn't preclude someone else from using the same site in future if circumstances change.
- Request the FAA to accept FRIAs as a permanent part of the airspace system. UAS being safely operated within the confines of a FRIA are not being operated elsewhere, where they might conflict with other unmanned traffic. Keeping FRIAs open for as long as possible benefits both recreational UAS users and the FAA.

speedracerntrixie

My Feedback: (29)

Your numbers are misleading, just because somone registered when they bought a MR up to 3 years ago does not mean that it is currently in use. Now if you had actual usage data that may be worth reading.

Tipover

My Feedback: (44)

I suspect most of those 800,000 currently non AMA members are not going to join a CBO simply so they can fly around in circles without remote ID. The statistics suggest the largest segment of the hobby are multi-rotor who primarily fly BVLOS, do they not?

speedracerntrixie

My Feedback: (29)

Tipover, unfortunately we don't have the numbers that I think would be the most useful. IMO the registration numbers simply don't give the whole story. I do agree with you that the BLOS segment may very well have the largest numbers but do they represent the hobby? I would say some do but not all. Drone racing is a segment that I consider within the hobby, using a drone for photography purposes I do not consider part of the hobby. The distinction in my mind is the difference between flying for the sake of flight or flying as a means to obtain pictures/video. The latter have no interest in an organized club or fixed site as they defeat their purpose.

The next point, are their 800,000 active traditional and MR/FPV non AMA pilots out there? I personally don't think so. As someone who has not only been around the hobby all my life but have almost 2 decades in the industry. A percentage of what gets sold never got used. Some flown a few months and interest lost, some crashed and never repaired. So out of that 800,000 people who registered how many have remained active? I nor anyone have the factual answer to that question, rest assured it is not 800,000 or as was mentioned 4:1 over AMA members.

astrohog

My Feedback: (1)

Then how can you possibly make your statement? Simply ludicrous!

Astro

mongo

My Feedback: (15)

well, it appears that the guy uses the:

do not do as i do, do as i say do

philosophy

and please remember, some of us have some folk on ignore, and you quoting those folks sorta defeats the purpose of the ignore button...

speedracerntrixie

My Feedback: (29)

It's called long term experience. Funny thing about experience, when you need a Plummer, mechanic, Doctor, roofer etc you look for someone whom has experience. When talking about model airplanes when someone with experience offers an opinion people start acting offended.....

speedracerntrixie

My Feedback: (29)

Ignore = head in sand

Tipover

My Feedback: (44)

I'm sure the AMA has some numbers, such as how many AMA members are park flyers vs full privilege membership. That percentage could give them a rough estimate of how many traditional flyers may come knocking on their doors once the RID goes into effect. I suspect(that experience thing again) that most non AMA giant scale flyers could also care less about being registered. That assumption is based on them being primarily rural and private property operations that have no intent on flying at AMA sanctioned events. Rural America is still a vast amount of space.

tedsander

The FAA claims:

• 1,509,617 Drones Registered
  • 420,340 Commercial Drones Registered
  • 1,085,392 Recreational Drones Registered
• 160,748 Remote Pilots Certified

Hmmm, that's a bit more than 9 "drones" per pilot. How do they know how many I have?
I wonder how many of the Certified Pilots are AMA members? All? Most? Some?

astrohog

My Feedback: (1)

Ummm......I only have a problem when you mince fact with fiction.

You stated that no one has the facts, but SURELY the facts are NOT what was presented. Then you bloviate about your experience (remember, you admitted that you did not have the facts, so your experience in this instance is moot) and accuse me of being offended by your opinions???? Are you insane? What, pray tell has experience to do with the facts that no one has?

You are so full of yourself that you cannot see the forest for the trees..........

Astro

franklin_m

The numbers to use are the AMA's numbers and the FAA's. If you have something better, I'm sure we're willing to use those. But unfortunately, if we justify our comments with "Speedracertrixie, who worked in a hobby shop once says .... " it's not going to carry much weight.

Read the footnotes in the NPRM. Numbers I quoted above are more than adequate to show FAA that the FRIA is nothing more than one more AMA attempt to get forced membership. I would be really curious if AMA was clear to FAA that for a citizen to use these fixed sites, they have to send $75 a year to AMA. Matter of fact, I'm fairly certain AMA was not open about this important detail. Why? Because it would have been included in the cost analysis if they had.

And FAA does not like it when groups are less than honest about important things like that. Not going to endear them to FAA when the FAA finds out AMA didn't tell them about the $75 annual fee AND equal or greater for local club on top of it!

franklin_m

That would surely help to know, but unfortunately FAA could care less about that. I think that if we're talking recreational, we have to stick with those numbers. So that means 1,085,392 remote pilots registered. AMA says they have 200,000 members (actually just 110,000 are paying). That means roughly 800,000 non-members, which is how I arrived at the 4:1 non-member/member ratio.

RCUer75345

"Read the footnotes in the NPRM. Numbers I quoted above are more than adequate to show FAA that the FRIA is nothing more than one more AMA attempt to get forced membership. I would be really curious if AMA was clear to FAA that for a citizen to use these fixed sites, they have to send $75 a year to AMA. Matter of fact, I'm fairly certain AMA was not open about this important detail. Why? Because it would have been included in the cost analysis if they had."

It is true that the NPRM projects that 90% of AMA chartered club fields will be approved as FRIAs, implying that the FAA intends to recognize AMA as a CBO. That does not change the fact that recognition has not yet occurred. Nor does it prevent additional CBOs from applying for recognition.

Nothing in the NPRM states that one must join a CBO in order to use a FRIA. It is only necessary to "follow the safety programming" of a CBO.

The FAA might have reasonably assumed that members of a CBO applying to have an existing flying site recognized as a FRIA were already dues paying members of that CBO - so there is no additional cost.

I cannot understand why anyone who values this hobby would be against FRIAs.

tedsander

The FAA numbers make a distinction between "drones" and "pilots". Are you noting that they are assuming each sUAS registrant only has one "drone"? What then is a "pilot" - part 107 registrants?
Seems to me that the number of actual pilots reported is actually less than the number of AMA members...which I would suspect is true.
(I'm just going by this page: https://www.faa.gov/uas/resources/by_the_numbers/ , which has no information as to where the numbers came from). Is there a better source on-line?

BTW - can anyone point me to language governing what a "CBO" is, and what qualifications it takes to be recognized as a "CBO"?

Just doing the homework, so I can craft my own comment to the NPRM.....

franklin_m

You're right, it doesn't say anything about it in the rules. But the "programming" of the CBO in fact DOES say that you have to be a member, not just of the CBO but also the club.

Remember, this is a rule for ALL citizens, not just CBO members. And the FRIA is the only option available for the 800,000 citizens who may have non-compliant equipment. That means the rule all but compels membership in a PRIVATE dues collecting organization in order to enjoy a privilege in PUBLIC airspace. IMO, that will fail on equal protection grounds if challenged in the courts.

As for the cost, there is additional cost for these non-members, significant additional annual cost not considered as part of the rule. $75 a year tithe to AMA and additional amount that can be equal to or greater to the club. Again, as these costs were left out of the economic analysis, it appears AMA "forgot" to mention the requirement to pay dues to use these clubs.

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. 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. 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.

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. 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. For example, of the $75 paid to AMA for dues, approx 17% is insurance. So the CBO would have to allow anyone to use the field for an annual payment of 17% of the $75 annual AMA dues.

However, I strongly suspect that FAA will be reluctant to allow fixed sites that require private club membership, as if challenged in court and it loses, the much of the rule is severed, and any integration of sUAS is significantly delayed.

franklin_m

I was looking at recreational registrations, which is a ONE OPERATOR to many drones. So that 800,000 number represents recreational registrations, which is representation of recreational operators that are NOT members of AMA. Download "Registrations-City-State-Country-Count-2019Q3Q4.xlsx" from the site appended below. Do a pivot table on 336 worksheet, and select only US for the country. You'll see there are 1,017,829 recreational registrations in the US. Each represents ONE operator.

Here's the link to recreational sUAS registrations:
https://www.faa.gov/foia/electronic_...room/#geo_list

Tipover

My Feedback: (44)

Given the complexity of the situation at hand, one has to assume the FAA dangled the carrot well knowing the AMA and it's associate clubs could never comply. Unfortunately a very sad situation for those that put so much faith into a dues collecting organization. All I can conclude is that there's going to be long term non compliance as a result of the fallout from this blunder.

RCUer75345

"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.

franklin_m

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.

RCUer75345

"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.

franklin_m

It's clear we will disagree. When there is one potential CBO that controls access to 3000 sites, and only the possibility of other CBOs, then that's all but a monopoly. And the fact remains that they do indeed charge membership fees. That means any of those 800,000 that want to enjoy the privilege of flying in the pubic airspace MUST be members of a CBO, which means they MUST pay money to a PRIVATE organization, and it's that near monopolistic control of that privilege that will be of interest to regulators.

As to your comment above, I too will make my points to the regulators. The difference being that my comments will be supporting where I'm confident they want to go.