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.”Source: https://techraptor.net/technology/news/985-of-non-form-letter-fcc-comments-support-net-neutrality
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.”Source: https://www.wired.com/story/bots-form-letters-humans-fcc-net-neutrality-comments/
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.”Source: https://www.wired.com/story/bots-form-letters-humans-fcc-net-neutrality-comments/
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.”Source: https://www.wired.com/story/bots-form-letters-humans-fcc-net-neutrality-comments/
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.”Source: https://arstechnica.com/tech-policy/2017/07/saving-net-neutrality-tips-for-writing-persuasive-comments-to-the-fcc/
Also see our previous information on how to file comments to the FAA regarding the NPRM on Remote ID.
- 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