January 28th the AMA Government Blog noted that the FAA denied the AMA request to extend the comment period beyond March 1. The window for comments to the proposed rule for remote ID will close March 2, 2020.

Bottom Line – AMA is encouraging all members to submit comment(s) before the March 2 deadline. AMA has provided the following drafted templates to express your concerns. You may send more than one comment.
Here is the link to the FAA comment site.

Below are four templates AMA has provided for us to use when making comments.  You can copy/paste the text into the FAA site link above or change the text to suit.

General Comment
I am writing in response to the FAA’s notice of proposed rulemaking on remote identification of unmanned aircraft systems (UAS). I am deeply concerned that some elements of the proposal could impose significant costs on the model aviation community and unnecessarily restrict existing, safe model aircraft operations.

First, while I am glad the proposal includes an option to comply with remote ID by flying at an approved fixed site, I am concerned that the rule arbitrarily limits the number of approved sites and prohibits the establishment of new sites. As such, the rule appears designed to phase out these sites over time, rather than treat them as a viable long-term option for complying with remote ID. I encourage the FAA to view fixed flying sites as part of a viable long-term solution to remote ID and to amend the rule to allow for the establishment of new sites in the future.

Second, the FAA must create a pathway for remote ID compliance at AMA events and competitions, which may not take place at fixed flying sites. These events take place in defined locations for a short period of time, like an air show. For remote ID compliance purposes, they should be treated like fixed flying sites. I encourage the FAA to create a light process for event organizers to apply for and receive, waivers from remote ID requirements for these ad hoc events and competitions, many of which support local charities.

Third, the rule must consider hobbyists who fly in rural areas with little or no internet connectivity. As I read the proposed rule, I could be required to have an internet connection even if flying at an approved fixed flying site in a rural part of the country. Unfortunately, some rural areas don’t have adequate cell service, which means I could not be able to fly under the limited remote ID option. Rural locations are frequently the safest places to fly because they are away from people, other aircraft and structures. The FAA needs to provide a solution for these areas, such as the ability to comply from home or other WIFI-enabled locations.

Finally, the FAA should reconsider the proposal to register each aircraft, which will impose a cost and compliance burden on the model aviation community. While individual registration may make sense for beyond line of sight operations, it is an unnecessary requirement for aircraft designed to be flown within line of sight. We build and fly model airplanes because it is a passion; and many of us own dozens, if not hundreds, of aircraft of different shapes and sizes, some of which we fly infrequently. The time and cost involved in registering each model individually would be substantial and runs counter to the current registration framework for recreational operators. Also, aircraft that are built by hand do not have serial numbers, which makes individual registration more difficult.

Again, I urge you to carefully consider and address my concerns about the remote ID proposal. Model aviation is the natural precursor to careers in aviation, including commercial pilots and engineers and more – jobs which the U.S. desperately needs to fill. Model aviation supports a $1 billion hobby industry responsible for thousands of existing U.S. jobs. We simply cannot afford to further harm the model aviation hobby with overly burdensome requirements.

Registration Comment
I am writing in response to the FAA’s notice of proposed rule-making on remote identification of unmanned aircraft systems (UAS). I am deeply concerned the proposed requirement to register all Recreational UAS (model) individually would impose significant costs on the recreational UAS (model) aviation community and place an undue burden on safe and responsible model aircraft hobbyists. Furthermore, if implemented as is, the requirement could deter compliance and therefore reduce the effectiveness of remote ID.

Individual UAS registration is a major issue for me and the recreational UAS (model) aviation community because of how many aircraft we own. On average, members of the Academy of Model Aeronautics (AMA) own nine aircraft each and some members own hundreds. Since we have so many model aircraft, many of them are flown infrequently – perhaps only a few times in the lifetime of the aircraft. And when we do fly an aircraft, it is always within visual line of sight, making it easy to identify the pilot at all times. Individual registration of recreational UAS may not accomplish what the FAA is intending. Many operators of recreational UAS not only fly any one aircraft infrequently but also trade or sell aircraft often, so the requirement to register and deregister will become cumbersome. The current process would meet the FAA’s stated needs by simply adding a requirement to the registration process that the owner provides a number of aircraft to be operated. The simple addition of a second block to be filled in (the first on is being added since the FAA has proposed to require a telephone number) would provide the FAA with a much more accurate number of UAS being operated in the US.

If the proposal to register UAS individually goes into effect as is, AMA’s 180,000 members would be forced to register about 1.62 million aircraft at a cost of $8.1 million, assuming the $5 per aircraft registration fee does not increase over time. This is clearly a substantial investment of time and resources for our community, which has already faced challenges in recent years due to increasing regulations.

In conclusion, I urge you to remove the proposed requirement to register each UAS individually. At a minimum, the requirement should be removed for members of a community-based organization like AMA who have operated safely in the airspace for more than eight decades and already register with their organization.

Education Comment
I am writing to you today as an educator who is deeply concerned by many of the proposals contained within the Unmanned Air Systems (UAS) Remote ID proposed rulemaking document.

There are no educational accommodations.
The FAA’s proposal on Remote ID does not make any accommodations for education. In Section 350, Congress specifically calls for the FAA to create allowances for recreational UAS that are operated by an institution of higher education for educational purposes. In order to continue to instruct and train new generations, educational accommodations need to be made.

Model aviation holds a strong position in our nation’s classrooms.
Model aviation is an effective tool for inspiring young people to explore careers in STEM-related fields. Building and flying model airplanes have long been a gateway to aviation for legions of aviators and engineers. Building and flying model aircraft are “hands-on” experiences to motivate and inspire a future generation of problem solvers and inventors, opening doors to careers in aviation and engineering.

In a time when our nation is experiencing a shortage of aviation professionals, we need to find ways to make flying model aircraft easy, not hinder the experience.
In order to fulfill future aviation roles, it is imperative to introduce newcomers to the exciting and engaging hobby of model aviation. We can accomplish this by making aeromodelling easily accessible to everyone without unnecessary restrictions.

The FAA’s registration requirement and proposed Remote ID technology will hinder the ability of educators to share these experiences with their students.
The AMA currently has more than 50,000 members between the ages of 13 and 18 and more than 13,000 members under the age of 13. For these AMA Youth members and their families, the FAA’s registration requirement and Remote ID technology could be a deal-breaker for continued participation in the hobby. The high costs and time commitment associated with a registration effort on this scale is insurmountable for many. The price of aircraft is already a potential burden, and adding in costly Remote ID technology in the manufacturing process will only exacerbate this problem. Model aviation has been and should continue to be available to all children, regardless of their socioeconomic status.

Fixed flying sites are not the only viable solution.
Our students learn and fly not only at school facilities such as gyms and school grounds outdoors but also at community parks and at home. Many of our kids don’t have cell phones and want to fly at locations that don’t have Wi-Fi or mobile phone/data cellular service. Your proposal would severely limit those options and require expensive and burdensome restrictions that would disallow the model aviation activities while having no significant impact on the overall safety of the National Airspace System.

Although it is helpful that the proposal includes an option to comply with Remote ID by flying at an approved fixed site, it is concerning that the proposal limits the number of approved sites and prohibits the establishment of new sites. The rule appears designed to phase out these sites over time, rather than treat them as a viable long-term option for complying with Remote ID. Please consider viewing fixed flying sites as part of a viable long-term solution to Remote ID, and to amend the rule to allow for the establishment of new sites in the future.

Remote ID makes sense for autonomous flight operations.
In the case of fully autonomous UAS that are equipped to fly via GPS coordinates and waypoints with no continuous, positive input via a pilot, it makes sense to have Remote ID requirements. However, a UAS that requires continuous, positive input from a pilot to maintain its flight within line-of-sight should be exempted from requiring Remote ID.

The flight envelope needs to be expanded.
Unfortunately, a 400-foot altitude limit is too small a space to accommodate all of the model aviation activities our students require. We need an easy way to accommodate flights outside of the proposed 400-foot bubble or our educational opportunities will suffer.

Model aviation has been and continues to be a safe activity.
Since 1936, AMA members have been safely flying model aircraft. Our safety record is overwhelmingly positive. We have safety standards in place that allow us to operate safely and without incidents in the National Airspace System. By operating within the safety guidelines the AMA provides for its members, the skies have been and continue to be safe for all aviation activities.

Amateur Built Aircraft Comment
I am writing in response to the FAA’s notice of proposed rule-making on remote identification of recreational unmanned aircraft systems (UAS). While I am pleased the proposed rule includes an exclusion for amateur-built aircraft, the definition of what constitutes an “amateur-built” is not adequate and the preamble does not effectively delineate the true categories of UASAB.. If the FAA is proposing to apply the same policy that is used for manned aircraft, there will be significant difficulty in applying the rule on the recreational UAS (model) industry due to the popularity of recreational UAS that are nearly ready to fly aircraft and the intent of separating hobbyists who build, assemble, and fly from the off the shelf ready to fly products. Even this “Almost Ready to Fly” category requires skill, knowledge, and technical ability that falls under the intent of Amateur-Built as a definition.

If this rule goes forward without edit, the effect will be difficulty and subjectiveness in the field with how the FAA exactly applies the policy. A better explanation and clear definitions should have been included in the main body of the NPRM as well as the preamble. A poorly worded, inaccurate definition moving forward will severely damage the entire hobby.

I am also concerned that the proposed rule requires amateur-built aircraft to display a serial number, an unnecessary requirement for an aircraft that will only fly at FAA-recognized identification areas and within visual line of sight. Furthermore, serial numbers would potentially destroy recreational UAS (model) which may be detailed scale replicas of manned aircraft. Hobbyists spend hours poring over each detail of replicas to ensure accuracy. Adding a serial number would ruin the model, and for no good reason.

In conclusion, I strongly urge you to revise the definition of amateur-built model aircraft to clarify the intent of the NPRM. I also urge you to remove any requirement for an external serial number for recreational UAS or provide a waiver process to permit the operation of recreational UAS at FAA-recognized identification Area

By addressing these issues, the FAA will protect the many model aviation businesses that sell model aircraft parts. In addition, the FAA will protect opportunities to learn about STEM, as AMA regularly hosts competitions, events and programs for young people to build model airplanes.