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More: Why submitting a form letter comment to the #FAA #RemoteID #NPRM is a Waste of Time #UAS #UAV #Drones

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.

Subsequent analysis of those comments revealed that millions of comments were form letters or slightly re-written template letters or written by computer software “bots”.

“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.


“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?

A former FCC Commissioner published an online blog post about how to write effective comments to the FCC. Her comments are equally relevant to the comments you write to the FAA.

For that post (and the issue under proposal then), she urged commenters to (and this is paraphrased back to the FAA NPRM issues)

  • Write about how the rules would impact you
  • Write about your understanding of the rules
  • Write about how you think the FAA should solve the issues raised
  • You can file more than one official comment. That is, suppose you have already filed a comment but since learned more and have more ideas you would like to contribute – go ahead and file another comment. You can make as many submissions as you need.

There’s more information in this news story about the former FCC Commissioners recommendation.

The key ideas are: write about your understanding of the rules and the impact they will have in the real world, including your own operations. Identify problems and suggest alternatives to those presented by the FAA.

“The purpose of a rulemaking proceeding is to not to see who can dump the most form letters into a docket. Rather, it is to gather facts and legal arguments so that the Commission can reach a well-supported decision,” Brian Hart, the FCC’s head of media relations, tells WIRED.”


Your comments become part of the public record and can have other value, longer term:

“Even if the FCC repeals net neutrality rules, meaningful comments could help net neutrality advocates argue in a future court case that the rules should be reinstated, she wrote.”


Also see our previous information on how to file comments to the FAA regarding the NPRM on Remote ID.

Bottom Line

  • Don’t waste your time submitting form letters.
  • Don’t waste your time with barely edited template letters
  • Do voice your own opinion in your own words. Back it up with facts, and logical arguments. Do document how the rules will effect you and others.
  • Do document problems and errors you see in the proposal.
  • Do offer suggested alternatives as recommendations to the FAA

Samsung drops Gear VR support on new devices; Google drops Daydream VR support on Pixel 3A

But with Gear VR not being compatible with Samsung’s newest flagship phone, and with Google announcing in May that the Pixel 3A wouldn’t support Android’s built-in Daydream platform, it’s hard not to think that phone-based VR may be on the decline.

Source: Samsung confirms Galaxy Note 10 won’t work with its Gear VR headset – The Verge

VR was sort of dead at CES 2019, sort of buried at E3 2019, and then Samsung and Google dropped out of the Cardboard-like phone-based viewer market. Paid VR content is said to be dead. IMAX said it is shutting down its VR theater offering.

Over the past six years since the Oculus Rift was introduced, the total number of VR users is estimated at 10 million – most of whom are video gamers.

I have three friends that are professional VR film makers, and one that has built a VR product for the dental industry. I get the dental product business model but do not get 2 of the 3 filmmakers’ business models.

A very few places are projecting VR video on to theater domes – this makes sense versus having everyone wear a large headset. But this is a far smaller market than was 3D.

I shoot VR myself, mostly still photos, that can be easily panned on Flickr or Facebook for 360 viewing without VR headsets.

VR was fading at CES 2019 – and it sort of seems that this might presage a collapse in 2020, similar to the path that was followed by consumer 3D (I shoot both 3D stills and video). VR remains stuck in gaming and is not being adopted by a wider consumer community. Proponents think it just needs better, new tech headsets.

Australia proposes A$20 license fee per model aircraft

The proposal would assess a fee of about A$20 for each model aircraft owned, plus a fee of A$100 to A$160 for each commercially used model aircraft:

CASA is planning to introduce a drone registration and accreditation scheme later this year.

Source: Drone registration and accreditation scheme – update | Civil Aviation Safety Authority

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.

How review sites have become an extension of camera sales programs

While many reviews provide useful information about camera features and capabilities, behind the scenes, many, if not most, are now motivated by increasing sales revenue of everyone involved.

Youtube camera enthusiast review “channels” are frequently tied to affiliate marketing programs. Watch the review, click on the link to one of the online retailers helpfully included with the review, and the reviewer sees a sales commission if you make a purchase (of any product on the web site, not just the camera).

Further, everyone is caught up with the idea that the next camera model with 20% more pixels will somehow make one a better photographer. Granted, there are some photographers and especially professionals and the semi-professional (wants to be a pro) for whom new features can improve efficiency, effectiveness, productivity and quality. But for the rest of us, the latest and greatest is often for bragging rights and showing off. emailed a summary of new items on their web site with this interesting wording:

Translation: We only get excited about really expensive cameras!

Everything is oriented towards not only having you salivate over the latest and greatest but to shame you in spending more money. No one wants to be seen in public with a camera for which you have not spent enough money! And geesh, only spending $900 – what sort of photo wimp are you?

Cameras have become the 21st century sports car, generally impractical but certainly a tool to impress others! We need not go far to see people hiking on trails with $10,000 worth of camera gear – the same price as a decent used car.

In the past two weeks I’ve had 2 photos selected and highlighted in the Flickr “Explore” photo collection, receiving thousands of views.

What’s my secret? I used discontinued, cheap Nikon 1 cameras, one of which cost me about US $200 🙂 Because photography isn’t about how much money you’ve spent on your camera!

Britain to require licensing, registration, allow police to issue fines and seize drones

Exclusion zones around airports will be extended and drone users will have to be registered under the plans.

Source: Police to get new powers to tackle illegal drone use – BBC News


  • Airport exclusion zones will be enlarged to 5 km (3 miles) (in the U.S., its already 5 miles). Additional exclusion zones will be added.
  • All users must be licensed and their model aircraft registered. (Like Mexico, this may end up prohibiting non-UK permanent residents or citizens from flying drones in the U.K.)
  • Police can order any drone flyer at any time to land the drone. Failure to land a drone or show your license and registration will be a fine-able offense.
  • Police will be allowed to “search premises and seize drones – including the electronic data stored within the device”.

This is done in the aftermath of the invisible drones at Gatwick Airport. At this time, the only provable drones in the air over Gatwick Airport were those operated by the Sussex Police, which they admit, were unmarked and were likely many of the reported sightings. After they admitted this, there have been no further updates on the investigation.

Sussex Police admit drones over Gatwick Airport may have been the police department’s own drones

Some of the sightings of drones which kept Gatwick Airport on shutdown may have involved the police’s own craft, a senior officer has admitted.

Source: Some Gatwick drones ‘may have been police devices’

The police chief insists that in spite of this, he’s still certain that there was an illegal drone flight because … well, he has no reasons other than he believes. Ok, fair enough, many of us believe he is an idiot, therefore, this must be true.

The broken drone they found in a field (at unknown location and unknown distance from the airport) – and a second one too – are acknowledged as having no involvement with Gatwick Airport.

The story of the bicyclist seen packing up two drones several miles from the airport? That story has vanished.

The innocent couple they arrested because they lived less than 3 miles from the airport and once flew model aircraft? Oh sorry, they are totally innocent – our bad, oopsie.

140,000+ people at Gatwick on the first day, 21,000 staff, plus police, military and media stakeouts all looking for drones – and not one photo or video clip.

67 or 93 people reported seeing drones? Where are the interviews of these people by the media? Mysteriously, there are none.

During this mass hysteria, some in the media and politics demanded more regulations, and some demanded a ban on all model aircraft – based on hysteria induced paranoia. Will any of the media retract their previous speculation – de facto fake news – reports? Doubtful. And they are shocked when people call them fake news.

You knew this was coming: “Drone users should be regulated and registered in the same way as firearms certificates.”

This is in the U.K.:

“A drone in the wrong hands could be just as lethal as a gun.

“They are unregulated and can easily be bought by anyone online for under £30. Even the cheapest has a range of 150 metres and can fly for half an hour.

“Drone users should be regulated and registered in the same way as firearms certificates.”

Source: Motorist says he saw Gatwick drone pilot frantically packing up two craft before racing off on a bike amid airport shutdown

Note – there’s a lot of oddities in this story and some things – like 30 pound quadcopters flying for half an hour – that are not true.

The logic is kind of weird. In the U.S., firearms killed over 30,000 people in 2017 alone. Model aircraft? To the best of our knowledge, no one in the nearly century has been killed by model aircraft.