The FAA rejected separate requests from the AMA and the EAA to lengthen the comment period by a bit. The EAA was surprised at the stern language used by the FAA in their rejection:
“We are taken aback by the strident tone of the FAA’s letter,” said Sean Elliott, EAA vice-president of advocacy and safety. “If the agency does not act carefully and deliberately on this NPRM, it could forever jeopardize the freedoms enjoyed by countless modelers, who represent a significant pathway into manned aviation.”
My interpretation of the FAA wording, unfortunately, is that the FAA may be intending to ignore the public’s input and intends to ram this NPRM through regardless of legal (like violating Federal law) and technical issues, let alone practical and very costly impacts on the recreational community.
I found the wording very disturbing, particularly after my courteous exchange with the Office of Rulemaking two weeks ago. I now fear that if the FAA considers any public comments, they will, like the FCC did with net neutrality, only review comments from corporations, law firms and large, well known organizations – and ignore comments from individuals. If that. The FAA may, indeed, close the comments on March 2nd and issue the final rule on March 3rd after ignoring everyone.
I have 58 pages of written comments and notes (all single spaced). I have about 27 pages of that in near final form and was working to edit and reduce the remainder. However, after seeing this letter, I am now working to wrap up my comments and just summarize the remaining items as bullet points – because I fear all my hard work is for naught as the FAA appears to be signaling it will ignore public input.
This is disturbing as I am well qualified to make substantive and useful comments on this NPRM. In my comments, I have a brief biography statement:
I am a model aviation hobbyist, an FAA Private Pilot Certificate holder (currently inactive), member of the Experimental Aircraft Association, member of the Academy of Model Aeronautics and the Field of Dreams RC Club.
I have a B.S. in computer science (senior thesis on the FAA and automation in air traffic control), a Masters in Software Engineering (thesis on Android smart phone power management) an M.B.A. degree and an Amateur Radio license. I hold two U.S. patents (one in wireless communications and one in aviation technology), have written about a dozen books on tech subjects, and have had a career in the computer and tech industry working in both software and wireless technology areas.
Separately, an FAA insider who is an R/C modeler told an acquaintance that unfortunately, this rule making is likely to shut down traditional R/C model aviation in the United States.
UPDATED: Yesterday I wrote this hypothesis:
The FAA is not being straight with the public and appears to be acting on secret information. We do not know if this is being driven by secret requests from Homeland Security, or if this is driven by the not so secret lobbying of AmazonGoogleUPS who have expressed a desire to privatize the low altitude air over our heads for their business uses. What ever it is, the FAA is not being transparent with the public and I have lost all confidence and trust in the FAA. The FAA is acting as a renegade agency at this point – and looks to be working under contract to industry, to largely eliminate recreational use of the airspace for model aircraft.
UPDATE: Today, I think I figured this out. The goal is to establish a national, aerial surveillance system, collecting detailed marketing data for businesses and detailed data for law enforcement.
The FAA and the operators of Remote ID USS databases envision using your drone to collect aerial images and possibly much additional data – such as WiFi networks, Bluetooth devices sensed, and so on, and selling this data for marketing purposes, for city government code enforcement, and for low enforcement.
This is a very big deal. This is one of the two main drivers behind the push to enact this rule as fast as possible. The other, of course, is automated drone fleets – which will themselves be collecting aerial surveillance data, spying on our homes and backyards.