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For my NPRM response - how "big" is this hobby?

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For my NPRM response - how "big" is this hobby?

Old 02-02-2020, 11:06 AM
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tedsander
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Default For my NPRM response - how "big" is this hobby?

Anyone have a number for the yearly economic activity of the hobby that the NPRM would effect?
Est. retail sales nationwide?
Ancillary purchases - tools, supplies, etc.?
Number of companies/employees that are at risk (direct and indirect - retail, distribution, manufacturing).

Not looking for granular detail, just a scope statement of the potential impact....

I could guess, but it would be nice to refer to something a bit more "official"....
Old 02-02-2020, 11:26 AM
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speedracerntrixie
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About the only option I can think of is to contact Horizon and see if they would be willing to divulge their annual sales and how many wholesale customers they have. Being that they are one of the stakeholders I would hope that they have already furnished those numbers to the FAA. Then again I feel that since Horizon and Tower both shot themselves in the foot by selling customer direct, I have a feeling that they won't be much help. I have a feeling they think they will rake in a ton of money by developing a line of remote ID compliant RTF junk.
Old 02-02-2020, 02:36 PM
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You will likely find that the hobby not affected by the NPRM, because they fly at clubs, is larger dollar wise that the hobby affected. Jets, IMAA, Pattern, other SIGs. All big money. Even a lot of money in quad racing at some clubs. Don't need remote ID on them.
Old 02-02-2020, 03:06 PM
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Originally Posted by rgburrill View Post
Don't need remote ID on them.
Not to start with, but if the NPRM passes as written the FRIAs will eventually be closed down, and Remote ID will be required on everything that flies over 0.55lb.

BNF and ARF models will also essentially be banned beginning two years after the effective date.

So it's appropriate to scope the whole hobby - not just those initially affected.

Old 02-02-2020, 03:42 PM
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tedsander
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Exactly - companies like Aloft or Flex Innovations closing down because they have to comply with the manufacturing rules, especially if a model essentially has to be ready-to-go in a box. Du-Bro struggling because they lost a major share of their market, since few will be buying "bits and pieces". Desert Aircraft not selling engines separately. Sig or Balsa USA closing down because no one can comply with the rules for certification when building your own at home. .20 - .40 sized planes costing over $1,000 because everything has to be in the box, including transmitters. GetFPV giving up because of the rapidly shrinking market. Even more LHS's closing.....
Especially if there is a mass exodus of people from the hobby because it has become too onerous to own and find a place to fly.
(NOT saying any of companies are in any way considering drastic moves....but without changes, it strongly becomes a likelihood...)

I found this site: https://www.hmahobby.org/?page_id=163 and posed the same question. They don't mention the NPRM, but do have rants about the tariffs posted. We'll see what they say.
Morningstar, the Wall Street financial reporting company, would gladly tell me in great detail...if I bought their industry report, for only $3,600 .....
Old 02-03-2020, 10:54 AM
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I have not posted here in a LOOOOOONG time, but came over to see what the squawk is about the latest FAA NPRM over here on this site.

I currently hold my 107 cert and do work for construction companies etc. On that side, other than more paperwork, testing and fees I can probably handle that for commercial purposes.

What I CANNOT handle is that in effect, every single one of my many aircraft, whether fixed wing or multi-rotor, will in effect be illegal to operate unless I am at an AMA field (nearest one is an hour away). I live on 3 acres in an urban area and fly in my "yard" all the time. This will become illegal as will every slope soaring area around me. My vintage Hobie Hawks and 3D electrics will be illegal to fly. IMO this new rule set will indeed KILL the R/C industry and hobby.

The culprits are NOT necessarily the FAA entirely (but they are definitely co-conspirators and the implementers), but AMAZON, FED-EX and other delivery companies. The whole aim is autonomous delivery and services. They want very badly for us "little guys" to go away, clearer skies to navigate. When I spoke to the FAA folks at the CES show this year specifically about the new NPRM and asked who actually wrote the proposal he would not really say anything when I asked about the "big commercial companies" the FAA rep just shrugged his shoulders.

IMO, unless the AMA and other large companies in the hobby industry step up we are doomed and have been completely sold out by the FAA.

As I said, I have not been on this site for a long time, is there an official statement from the AMA about this?






Old 02-03-2020, 02:20 PM
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Originally Posted by CactusJackSlade View Post
...is there an official statement from the AMA about this?
The AMA has suggested template comments here:

https://amablog.modelaircraft.org/am...ormal-comment/

A number of people have copied these so faithfully that their response begins with the words "Template Comment". That's a good way to get the FAA to not even read it IMO...
Old 02-03-2020, 03:18 PM
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tedsander
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The Hobby Manufacturers Association responded!
They are a trade group representing many hobby manufacturers, distributors, and local hobby shops.
No clear idea as to how actually representative the results are, as they did not get full participation with surveys sent to both their members and non-members. Can't say whether any of the "big boys" at the time responded.
Their most recent data is from 2012, which was right into the teeth of the recession - and just as "drones" were starting to show up- and internet sales weren't as big a force as they are now.
Estimated retail sales for the Radio Control segment of the hobby industry was then about $1.2 BILLION in the US.
70% of their 110 respondents were small businesses - less than 50 employees.

They will be reaching out to others, to see if they can provide more data about how "at risk" the industry is with this proposed rule.
Old 02-03-2020, 03:41 PM
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Originally Posted by grognard View Post
The AMA has suggested template comments here:

https://amablog.modelaircraft.org/am...ormal-comment/

A number of people have copied these so faithfully that their response begins with the words "Template Comment". That's a good way to get the FAA to not even read it IMO...

Perfect, thank you
Old 02-03-2020, 04:55 PM
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Originally Posted by tedsander View Post
The Hobby Manufacturers Association responded!
Is their response public?

Would be nice to have a link so we can (a) read it and (b) quote it in our own NPRM review comments.

Old 02-03-2020, 09:07 PM
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tedsander
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They sent a summary pdf, which is attached. There was a miscalculation. According to the summary, the entire hobby industry is $2-2.5 billion. RC accounts for about 25% of that, which would be $625,000,000 No idea in their respondent count how many of the businesses are RC related. Of course, 8 years later is a lot of change, so still unknown as to where we are now. But at least it is something to reference....which seems better grounded than some of the stuff the FAA used in its assumptions!

Attached Files
Old 02-13-2020, 08:47 PM
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aviatortroy
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Here’s a copy of my comment, for what it’s worth...

FAA-2019-1100

Hello, as a lifetime model aviation enthusiast as well as a commercial airline pilot I am very concerned with certain aspects of the new UAV regulations that are proposed. I certainly understand the need to reconfigure regulations and airspace to address the future of UAV flight, but I feel it is imperative that traditional model aviation activities are not impacted. The waiver to fly at approved clubs is a good start but with the vast geographical areas of this country that are rural or on private land it is absolutely not practical to expect RC modelers to be able to join a local club or alternatively buy expensive new equipment (that hasn’t been invented yet) only to be able to continue a hobby that has been enjoyed by generations. In fact generations of airline and commercial pilots have been inspired by the very model aviation activities that are being threatened. Therefore I implore that the FAA differentiate between commercial drone operations and traditional radio control models, as well as free flight and low power amateur rocket activities and waive the hobby aspect from the new proposal.

Respectfully,
Old 02-14-2020, 08:48 AM
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Model aviation, in particular RC Model Aviation, has been impacted by the acts of uneducated and irresponsible individuals with Quadro-copters. The true safety concerns are being over blown and our federal legislators should not over react to imagined risks.
Nullification, in United States constitutional history, is a legal theory that a state has the right to nullify, or invalidate, any federal law which that state has deemed unconstitutional with respect to the United States Constitution (as opposed to the state's own constitution).
Per James Madison –

“Thus the right of nullification meant by Mr. Jefferson is the natural right, which all admit to be a remedy against insupportable oppression.”

We may have to gain support and battle this through our state legislators.
Old 02-14-2020, 08:54 AM
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I replied the following talking points to my legislators and on the FAA site.:Regarding Proposed FAA Rules Requiring Remote ID and More
Dear Representatives,
I have been a responsible RC Modeler and RC hobbyist for over 50 years. My hobby is under assault from over reaching FAA rule makers. I cordially invite you to our club’s (Lake County Radio Control Club) flying field on Russell Rd in Lake County IL, to show you practically why some of the proposed rules are so egregious in nature that it threatens its very existence. The impact to our national economy is significant.
I know you may have more important issues, but why should our hobby, with over 195,000 members be held to higher standards than that of guns or gun owners, owners of EAA manned aircraft, or even off road car enthusiasts? We are not the NRA and cannot lobby so greatly. Representative Greg Pence and Senator Todd Young have gone on record to support model aviation. This is not a partisan issue.
The proposed FAA rules for remotely identifying Unmanned Aircraft Systems (UAS) were written with severely biased thoughts with imagined risks more stringent to UAS ownership than that of guns, cars and even amateur built manned aircraft. The proposed rules goal to control any and all UAS’s over 0.55 lbs. in the air over both public and private land everywhere in USA. The rules were written by people who were not aviation modelers and who were not familiar with the practical application the hobby. I can only deduce from reading them that they were not familiar with the built in limitations of our systems. They were obviously not informed or were biased by not accepting the point of views of model aviation enthusiasts. Their bias is clearly shown by making rules that show how much can be done to control UAS operation and not by proposing the minimum we need to do to create a safe airspace.
The proposed rules do not fully recognize the long 60-70 year history, safety record and experience of current educated operators of UAS’s. Each of us carries $2,500,000 of liability insurance. How many aircraft have been brought down by a UAS? Public education and awareness of the safe use of UAS’s has not been adequately explored. Compare the number of incidents of people shooting guns at and hitting manned aircraft to the number of UAS hitting aircraft throughout the history of model aviation. How many guns are there in the US? How many civilian aircraft have been brought down by a gun? The incidents of lasers pointed at aircraft have been minimized by public awareness. Make it a law for an UAS to hit an aircraft like it is a law to not shoot at an airplane or point a laser at it. Otherwise, control all guns and bullets, and control all lasers used in the national airspace the same way we will be controlled. Focus on laws and technology to catch the knuckleheads without penalizing law abiding UAS operators. Create a fund from pilot registration and spend the money wisely to educate the public.

Here are some rules that need to be challenged:
The inability to obtain new approved flying sites beyond 12 months goals to eliminate RC flying over time. This is too egregiously harmful to our hobby. Our club has had to change location 4 times in 30 years. We are currently at the mercy of a local forest preserve. If we are forced to move after one year, we couldn’t fly any more. The rules will eliminate our flying sites by attrition by not allowing the registration of new fields. The rules should permit local authorities, by permitting, the safe operation of UAS’s in areas that local authorities feel are appropriate based on their knowledge of local UAS Operators, conditions and the environments that are deemed appropriate and acceptable. They know the local areas better than someone in Washington DC. The control of all airspace everywhere is over reaching with respect to hobbyist UAS’s.
The Registration of EACH and EVERY modeler-owned UAS, is not practical for our modelers. It’s not unusual to own 10-20 flyable aircraft. I currently have 9 flyable aircraft. It will impose on UAS operators an additional undo cost burden. You only fly one aircraft at a time. Registration should be on the pilot not each UAS that could be crashed in one day after buying it. A better application AND more practical implementation of RC technology would be to use the transmitter to broadcast an identity ID that would locate the UAS operator by location. We own perhaps one or two transmitters. Most computer radios are firmware updatable. Register the transmitter (gun analogy) not the flying UAS (bullet analogy).
The need for the UAS to broadcast a Remote ID, both standard and limited, with an internet based LAANC flight plan approval in rural areas is over-reaching. These areas are normally void of manned aircraft. The chance of mixing airspace in rural areas is too remote and too low beyond estimation to force this rule.
The proposed rules would restrict open flying only to FAA approved flying sites, again which could be lost by attrition. They prevent ad hoc or specialized contest events in known yet safe flying areas. We had a charity fund raising at the local fairgrounds and once at a wide open shopping mall parking lot. We did it safely without incidence. We also had flying events on ponds and lakes where we were able to fly off water. These events would be completely eliminated. Ad hoc approval should be allowed locally by local authorities.
If approved, UAS’s that have built-in Remote ID capability while flying at an approved flying site must use the internet system. In contradiction flying all UAS’s with or without such systems at an approved site should be acceptable. Whether or not the UAS has this capability should not default to having to use it when others don’t. This rule is burdensome and over reaching. Why the need for two approvals which are redundant?
The proposed rules do not adequately distinguish the practical differences between Quadro copter and fixed wing flying aircraft with respect to proposed 400 ft limits which imply a sphere (bubble) with an integration of range and altitude limitations. The use of commercial Quadro copters is implied. Unfortunately, whoever wrote this didn’t understand how model planes are flown. More flying space is needed. We should be allowed to fly within line of sight, typically less than 1500 ft. and within the range of our transmitters. We want to do that anyway so we don’t lose our costly aircraft.
If implemented, the rules make no provision for reimbursement of non-compliant aircraft to the long time owners and operators of UAS’s getting rid of these systems because they are made obsolete by these rules. (i.e. gun ownership buy-back programs have been proposed.) UAS operators will be forced to abandon their UAS systems operations and should be compensated.
The rules discourage safe, beyond line of site FPV flying. ALL FLYING is within the range of the transmitter in obvious safe areas and should be permitted. Safe operation by knowledgeable and responsible adults or youngsters with adult supervision should be allowed. It is to our benefit that we stay within transmitter range and not lose costly UAS’s. The loss of these systems in itself discourages unsafe flying. Imagine hunting for a small UAS and finding it. Very tough indeed.
The rules have an unfair impact on gliders / soaring due to height limitations even in rural Class G uncontrolled airspace where there is little or no manned air traffic. Line of sight and transmitter range forces safe flying. Failsafe controls can be used to force aircraft to spiral down.
The rules increase the costs of UAS’s which will be realized due to both increased R/D and manufacturing costs. Manufacturers will have to conform to UAS design standards incorporating the FAA guidelines for remote ID, GPS reporting and geo-fencing. i.e. a 400 ft. bubble for copters and will likely prevent any aircraft over approximately 12” in wingspan from flying.
Indoor flying of UAS’s over .55 lbs. is not specifically exempted. Indoor flying should be exempted and not required to have remote ID.

We are safe, responsible hobbyists driven by a 60-70 history of self imposed safety guidelines that have a record only hurt by the uneducated knuckleheads who are not members of a club or organization, who fly irresponsibly and without the proper education. Wouldn’t you think gun owners, both legal and illegal, have a greater chance of downing a manned aircraft than a UAS? Why control UAS’s more than guns? The benefit of supporting aero modeling is well known by pilots, astronauts, the EAA and other aviation enthusiasts. Please help us get these proposed rules reconsidered and moderated before they go into effect. Work closely with the Academy of Aeronautics as we ask the FAA to work with them to alter the severe restrictions that they are planning to impose on us.
Old 02-23-2020, 03:49 AM
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AMA knew they had a serious problem 10 years ago, but they also knew they didn't have anything towards a solution. Can't blame AMA for that. They've been trying for decades.

https://www.modelaircraft.org/strategic-task-force
Old 02-23-2020, 07:41 AM
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tedsander
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Well, my probably too long response is done and filed.
After making the case why a billion dollar industry (to quote Horizon Hobby) should not be shut down, I pretty much fell on the side of two sets of criteria: Line-of-sight, and beyond-line-of-sight.
Establish on-going FRIA's, sponsored by a CBO. Allow for temporary FRIA's for events. While space to be defined individually for each FRIA, the size requested would be only reduced if it would interfere with local manned operations.
BLOS capable aircraft with non-tamper 400' geofencing would be defined the same as LOS aircraft. Anything can be flown inside a FRIA.
No restrictions for build of LOS aircraft. Covers both RC and Free Flight flown in a FRIA.
Between the rise of Park Fliers and multi-rotors, especially BLOS versions, the fly-anywhere-I-want-whenever-I-want ethos has gotten out of hand. Having 6 cars in a town is a completely different thing than having 10,000. Same sort of issues. Some kind of rules of the road need to be established.
LOS outside FRIA operations can be anywhere there is no established presence of people, structures, or non-land property. Where there is such within LOS, the limit is a horizontal 400 ft. radius. Sorry you guys with the monster 3D plane, or jet turbine and hundreds of your own acres just out your back door....
Non-geofenced BLOS capable aircraft would have to transmit an FAA pilot identifier. Can be via a module that can be transferred between aircraft (the RX, or other). Identifier is for the pilot, not the craft. Can be reset if ownership transferred.
Non-geofenced BLOS flights outside a FRIA need to file an intent to fly plan. Same or similar to LAANC. Define date of flight(s), and maximum area to be overflown.

Legal guys have an easier way to comply. Too bad many more have to pay something to play (CBO costs, or LAANC access). Of course doesn't lock it down as tight as the current NPRM, but that too is all too easy to circumvent, it one wants to.
That unidentified drone hovering over the airport? Or that plane being flown into a building? Possible under all sets of rules.
"Bad" guys - well, they'd still be bad guys...just not near as many would fall into that group just because of the overly restrictive rules.

Last edited by tedsander; 02-23-2020 at 07:44 AM.
Old 02-24-2020, 04:27 AM
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It seems that the only strategy everyone has is to complain on forums and write letters to the you-don't-have-enough-votes government officials.

Except for Youtube, our message is basically preaching to the choir. Why not work on getting on TV? What if the industry and members donated a tiny amount each, say $20 or more to getting on local cable stations, or PBS specials. I'm certain that most if not all who have skin in the game wouldn't have a problem donating $100 or more if it means saving what we have loved for several decades. There are enough professionals in and out of the hobby/sport available to put together a meaningful TV program.

I have no idea of the cost, but with the help of 200,000 AMA members, along with the assistance of industry members, and 1 million drone pilots...that's a lot of money. That and we won't have to depend the whim and will of clueless politicians to get the word out. Every club could possibly get their activities aired on TV in their area.
Old 02-24-2020, 05:46 AM
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Originally Posted by fliers1 View Post
AMA knew they had a serious problem 10 years ago, but they also knew they didn't have anything towards a solution. Can't blame AMA for that. They've been trying for decades.

https://www.modelaircraft.org/strategic-task-force
LOL. Yep, they were laying the groundwork to embrace the drones ten years ago. Sounds just like our Federal Government...more $$ was their solution! I bet if they had focused on their core membership at the time, this would have turned out different.

Astro
Old 02-24-2020, 07:53 AM
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Had the AMA been taking care of the aircraft they were already watching over rather than trying to grab the "droners" and force anyone flying anything to join, EVERYTHING would be different
Old 02-24-2020, 10:56 AM
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Originally Posted by Hydro Junkie View Post
Had the AMA been taking care of the aircraft they were already watching over rather than trying to grab the "droners" and force anyone flying anything to join, EVERYTHING would be different
I Agree
Old 02-24-2020, 04:51 PM
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Originally Posted by Hydro Junkie View Post
Had the AMA been taking care of the aircraft they were already watching over rather than trying to grab the "droners" and force anyone flying anything to join, EVERYTHING would be different
Just keep rearranging the deck chairs on the Titanic while arguing over who's fault it was that you hit the iceberg.

There are seven days left in the NPRM comment period. 24,000 comments is nowhere near enough. If you haven't submitted comments yet, you should.
Old 02-24-2020, 06:08 PM
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I finally got around to submitting mine but I doubt the amount of comments will double before the comment period ends so we will likely end up with maybe 35-40K comments IMO.
Old 02-24-2020, 07:51 PM
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Originally Posted by ira d View Post
I finally got around to submitting mine but I doubt the amount of comments will double before the comment period ends so we will likely end up with maybe 35-40K comments IMO.

Which is a very high response rate for any NPRM I have ever seen. The Part 107 NPRM only had 4,700 responses.
Old 02-25-2020, 06:08 AM
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Originally Posted by grognard View Post
Just keep rearranging the deck chairs on the Titanic while arguing over who's fault it was that you hit the iceberg.
Maybe AMA leadership was on to something when they almost spent $1M dollars to purchase an indoor flying facility in Muncie. At least 100 or so AMA members would then be able to fly restriction-free. As it stands now, there will be exactly zero!

Astro
Old 02-25-2020, 02:15 PM
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Six days left. There'll be plenty of time for weeping, wailing and gnashing of teeth later. Get 'em in while you can!

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