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<blockquote data-quote="I B Spectre" data-source="post: 108666" data-attributes="member: 18605"><p>Pg. 53 of the NPRM states: <em>"...36% of the North America fleet is manufactured by one producer (DJI) that provided information to the FAA suggesting they could retrofit. The FAA estimates that about 20% of the recreational fleet is comprised of aircraft manufactured by DJI that could be retrofit". </em>The word "fleet" is not clearly defined and may or may not refer to the total aggregate of UAS. The DJI estimated retrofit of 20% of recreational fleet is encouraging and would allow a number of DJI drones currently flying to continue under RID.</p><p></p><p>The NPRM, especially the Federal Register version, is difficult to read and discusses the same subjects in multiple places throughout the document albeit with minor, but sometimes significant, differences.</p><p></p><p>I have a hunch that, since the subject of remote identification, has been discussed since 2016, the FAA felt pressured to finally put forth some kind of a proposal to show the process was still moving forward. The fact that the NPRM includes ALL unmanned aircraft is too big a bite to chew. In my opinion, everyone would have been better served had it been broken down into separate proposals for autonomous drone delivery systems championed by big business, commercial drones as used today, recreational drones and RC modeling.</p><p></p><p>What has emerged is a proposal that pits one group against another. The companies behind drone delivery see it as an important, though unproven, advancement of business without regard for the impact on the other entities.</p><p></p><p>The RC modelers, many of which have been flying for decades, look to be the most adversely impacted. The FAA allows only 1 year to submit applications for adding recognized identification areas. Many RC modelers see drones as the catalyst driving this change and likely have no interest in having to share their flying areas. Since many RC modelers build their aircraft from scratch or kits, there is no avenue to upgrade them with the FAA certified required capabilities to allow them to fly anywhere else.</p><p></p><p>Those flying drones under part 107 have gone to the trouble to pass the certification allowing monetization. This is a smart use of the technology and serves an important function on many levels. Unfortunately, they suffer the same potential impact as the recreational fliers.</p><p></p><p>It's easy to look at the proposal as an impossible mountain to climb. The frustration of sifting through the document trying to find the most important issues on which to comment can be overwhelming. It's not hard to throw up ones hands and say, "They're gonna do what they're gonna do". When I read many of the comments submitted already and listen to YouTube vloggers putting in their two cents, my optimism sinks further because it's obvious they have not done their homework, but are treating it as if it were a poll. Still, this may be our one and only important shot at saving the hobby. It deserves serious study, dispassionate discussion and thoughtful responses.</p></blockquote><p></p>
[QUOTE="I B Spectre, post: 108666, member: 18605"] Pg. 53 of the NPRM states: [I]"...36% of the North America fleet is manufactured by one producer (DJI) that provided information to the FAA suggesting they could retrofit. The FAA estimates that about 20% of the recreational fleet is comprised of aircraft manufactured by DJI that could be retrofit". [/I]The word "fleet" is not clearly defined and may or may not refer to the total aggregate of UAS. The DJI estimated retrofit of 20% of recreational fleet is encouraging and would allow a number of DJI drones currently flying to continue under RID. The NPRM, especially the Federal Register version, is difficult to read and discusses the same subjects in multiple places throughout the document albeit with minor, but sometimes significant, differences. I have a hunch that, since the subject of remote identification, has been discussed since 2016, the FAA felt pressured to finally put forth some kind of a proposal to show the process was still moving forward. The fact that the NPRM includes ALL unmanned aircraft is too big a bite to chew. In my opinion, everyone would have been better served had it been broken down into separate proposals for autonomous drone delivery systems championed by big business, commercial drones as used today, recreational drones and RC modeling. What has emerged is a proposal that pits one group against another. The companies behind drone delivery see it as an important, though unproven, advancement of business without regard for the impact on the other entities. The RC modelers, many of which have been flying for decades, look to be the most adversely impacted. The FAA allows only 1 year to submit applications for adding recognized identification areas. Many RC modelers see drones as the catalyst driving this change and likely have no interest in having to share their flying areas. Since many RC modelers build their aircraft from scratch or kits, there is no avenue to upgrade them with the FAA certified required capabilities to allow them to fly anywhere else. Those flying drones under part 107 have gone to the trouble to pass the certification allowing monetization. This is a smart use of the technology and serves an important function on many levels. Unfortunately, they suffer the same potential impact as the recreational fliers. It's easy to look at the proposal as an impossible mountain to climb. The frustration of sifting through the document trying to find the most important issues on which to comment can be overwhelming. It's not hard to throw up ones hands and say, "They're gonna do what they're gonna do". When I read many of the comments submitted already and listen to YouTube vloggers putting in their two cents, my optimism sinks further because it's obvious they have not done their homework, but are treating it as if it were a poll. Still, this may be our one and only important shot at saving the hobby. It deserves serious study, dispassionate discussion and thoughtful responses. [/QUOTE]
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