In response to the FAA’s Notice of Proposed Rulemaking (NPRM) regarding Remote ID of small UAS, at least one national organization urged members to urgently file comments and helpfully provided a form letter – which as I showed previously – were submitted by many people. Submitting form letters is a waste of your time, as I explained then.
Here is what happened when another agency with another NPRM was overwhelmed with form letter responses from the public – they ended up ignoring most public input!
In 2017, the Federal Communications Commission (FCC) solicited public comments on proposed rules regarding Internet “net neutrality”.
The FCC received about 23 million public comments.
“For example, Ars Technica reported in May 2017 that 128,000 identical comments were submitted through the portal for receiving public comments on this particular matter.”
In many cases, “bots” had harvested actual comments by actual people, and then generated dozens more comments using the same names and addresses of real people, creating false public comments.
Ultimately,
“According to Pew Research, only 6 percent of the roughly 23 million comments submitted to the FCC were actually unique. The rest were a combination of form letters and bots. The most popular form, submitted 2.8 million times, was a pro-net neutrality comment drafted by the advocacy group Battle for the Net.”
The FCC was so overwhelmed with these garbage comments that, according to Wired magazine,
“As a workaround, the FCC has decided to ignore the majority of comments submitted by the public in favor of lengthy legal arguments submitted by interest groups and corporations.”
The above is what happens when the public overwhelms the agency with form and template letters. It happened to the FCC. It could happen to the FAA as some groups have published form letters with instructions to “urgently” comment on the FAA NPRM.
How Should You Write a Comment to the FAA’s Remote ID NPRM?
The UK is proposing an annual fee of 16.5 pounds. The U.S. assesses a fee of US$5.00 per pilot, good for 3 years; the registration number is applied to all aircraft operated by the pilot.
Flights in and out of London’s second-busiest airport were halted after drones were spotted flying illegally nearby in what was described as an act meant to intentionally disrupt travel.
The British government described the overflights as deliberate and being conducted by “industrial” drones, not hobbyist quadcopters.
Update: latest development is that two unnamed people have been detained and the police have suggested “eco-warriors” were behind shutting down the airport, as part of opposition to airport expansion plans.
She said the amount of time the drone had been above the airport supported the idea that it was being flown there deliberately. “This very much points to this being planned and not just some rogue hobbyist,” she said.
The weather at the time was windy and rainy. Small consumer quadcopters are not usually water proof and can have difficulty in winds over 10 mph. (Similar to most consumer cameras, they will likely fail due to water ingress.) Further, consumer quadcopters generally have a useful battery life in the 10 to 20 minute range.
Yesterday a Guardian journalists said on Twitter. “Considering the public safety danger of drones, why should any be permitted to have one for any use other than business?”
(Change the word “drones” to “cars” or “trucks” or “knives” and see if you can see a problem with that line of thinking.)
Separately, much of the public is now saying things like this comment appearing in the NY Times:
The PR damage is immense and likely insurmountable. From social media comments, people are calling for the ban of all model aircraft. Yet this operation over Gatwick was already in violation of current law.
A ban will not happen but expect governments to enact a strict (and potentially expensive) regulatory environment that will create so many hurdles to flight as to be a de facto ban on many recreational operations. As I have written previously, expect the following:
Model aircraft will be permitted to fly at certified model airfields, possibly license free – and possibly restricted to age 16 or older.
Home built model aircraft will be required to be “certified” after an inspection similar to how home built aircraft are certified by a volunteer designee of an organization and will be required to meet specific design criteria.
Flight conducted outside of certified model airfields will require the operator to be licensed. Here in the U.S. this will require either the Part 107 Remote Pilot’s license or an as-yet-to-be developed Remote Recreational Pilot’s license, including passage of an exam and Department of Homeland Security background check.
A fee will be charged for the operator license and the background check.
Flights conducted outside model airfields will require each device to have an on board radio transponder or other mechanism for tracking and remote identification.
A fee will be charged for air traffic control services. This fee, combined with the background check cost, may be so high that it de facto bans most people from flying model aircraft at other than model airfields. It is possible that flights in Class G airspace will remain exempt from the air traffic service fee; however, transponders will likely still be required.
All commercially built model aircraft weighing more than 8 ounces (250 grams) will be required to have on board GPS and geofencing built in to prohibit flight within some number of miles of airports. But note there need to be ways to override this – for example, drones are used to conduct power line and roof inspections and these will, from time to time, need to be done, with permission, within the radius of airports. Of course, it may be that only “large” and expensive drones will allow override capability, thereby priced out of access by regular consumers. Additionally, there will be commercially operated package delivery drones within these areas.
Retailers of commercially-built drones will be required to log drone sales with the government, including the identification of the buyer.
All commercially built drones, and possibly certified home builts, may require control links that can be overridden by police or other government authorities to remotely take control of an errant flight. This would likely render existing control transmitters obsolete and require their replacement at great cost.
Police will routinely stop and ask drone pilots to see their license and aircraft certification paper work, and will log their contact with you in their criminal database.
None of this will stop a terrorist or anyone else inclined to cause mayhem. It will, however, dramatically reduce the number of recreational quadcopters in flight.
Separately, a week earlier a collapsed nose cone on an Aeromexico plane that landed at Tijuana Airport was blamed by the media as caused by a collision with a drone. The media made up that conclusion – no one involved in the investigation has made that claim. This web page has photos of about 30 collapsed nose cones, many of which look identical – but which did not involve a drone. From expert commentary on that page, there are numerous causes of collapsed nose cones including bird strikes (often leaving no blood or feathers behind), weather phenomena including hail, rain and wind, and structural failures of the non-metallic nose cone.
The public’s limited understanding of aviation causes them to jump to conclusions based on what they think they know – to them, everything looks like a quadcopter because they are unaware of other options. (In propaganda theory this is known as “What You See Is All There Is”.) As one airline pilot said in a newspaper comments section, it is amusing to see how many non-experts had become experts on social media. (For the record, while I am not an active pilot now, I do have a pilot’s license and have been around aviation since age 20. I have 5 quadcopters and 2 fixed wing model aircraft, belong to the EAA, AMA and my local flying club.)
Today’s 80+ year old model aircraft hobby, with a spectacular safety record is threatened to be regulated out of existence – depending on how nutty the politicians and regulators choose to act.
Anyone flying a drone over 25 kg mass must meet the requirements for a remote pilot’s license (see below) which birth certificate or document identifying you as a Mexican national, passage of necessary examinations, “proof of pscyhophysical aptitude”.
To operate a small drone (less than 25 kg) you do not need a license but you must register your drone and you must be a Mexican national.
This prohibits the operation of drones in Mexico by all foreign visitors.
Google Translation
The rules to operate drones will come into effect in December of this year, and if you do not comply with them, you can become a creditor, so we give you the steps to follow to fly it under the law.
According to the Ministry of Communications and Transportation (SCT) and the General Directorate of Civil Aviation, this is what you must do to fly an Aircraft Piloted at Distance (RPAS, for its acronym in English) or a drone in Mexico :
The drones are classified according to their size in RPAS micro (2.00 kg or less), small RPAS (from 2.001 kg to 25 kg) and large RPAS (25 kilograms or more).
To obtain the pilot license of the large RPAS:
1.- Written request.
2.-Be at least 18 years old.
3. Birth certificate or document that accredits you as a Mexican.
4.-Formats registration card that you of the Civil Aeronautics.
5.- Proof of payment of fees for training permit, exam application and issuance of license.
6.-Document proving having submitted and approved the practical and theoretical examinations established by the aeronautical authority.
7.- Certificate issued by an instruction center recognized by the aeronautical authority.
8.- Proof of psychophysical aptitude in force 90 days from the date of issue, issued by the General Directorate of Transport Protection and Preventive Medicine.
9.- The license has a validity of three years from its issuance and may be canceled by the aeronautical authority for irresponsible operation, use for criminal purposes and at the request of the interested party.
To operate a micro and small RAPS does not require a license but you must register it :
The registration is free and you can do it online, you will receive the document in 10 business days.
1.-First you have to register it before Civil Aeronautics before operating it.In order to register you must have Mexican nationality, be of legal age (otherwise the parent or guardian can do it) and fill out a form.
2.- Once the form is completed, you must send it clarifying one of these two options: for Registration of RPAS commercialized in Mexico or Regsitros of RPAS by owners as the case may be.
3.- If you are a natural person you have to prove your personality by attaching a digitized copy of your INE or any official identification.
4.- If you are a moral person you have to prove your personality by attaching a digitalized copy of the constitutive act (legal registration of the creation of the company) and the power of attorney of the legal representative.
5.- Take into account that you must have at hand: digitalized copy of the documentation that proves the ownership or possession of your RPAS (supported formats .pdf, .docx, .jpg or .png)
6.- Send an email to the address rpas@sct.gob.mxrequesting registration for a RPAS, attaching the completed form to Exel, along with a printed version signed by you, manually adding your RFC with homoclave;also the digitized copies of the documentation that proves the ownership or possession of your RPAS.
7.- Finally, wait for your record sheet or the considerations to cover to obtain the same in the electronic address that you gave.
The regulation regulating the operation of drones in Mexico, published in the Official Gazette of the Federation (DOF), will come into effect in December 2018 and the fine for flying drones without a license could cost up to 403 thousand pesos.It is still a project and is subject to 60 business days for consultation.
This regulation is addressed to any individual or entity that owns or owns a RPAS.
Only State RPAS that carry out military, police, border and maritime patrols are exempt .These conform to other regulations.
Elsewhere, I see people now posting videos on Youtube with modified control systems that use 4G LTE modems to extend the range of their model aircraft. And flying them up to 25 miles. All of which is clearly and obviously illegal.
Such actions, which are now occurring in the U.S. are literally begging the FAA to establish strict regulations over use of model aircraft and the eventual licensing of all model aircraft pilots. It will take just one incident – and instantly the FAA will ground all model aircraft nationwide until strict new regulations are developed and in force.
This is literally what these reckless model pilots are asking for.
(Note – I am an RC model aircraft enthusiast, belong to the AMA and my local model aircraft club. I am pointing out the obvious way that many new enthusiasts are wrecking the hobby in their disdain for common sense rules we have now.)
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