Comment from Redge Meierhenry

I am writing on behalf of the Tri City Modelers with field location in San Manuel, AZ; to comment on the FAA's notice of proposed rulemaking on remote identification of unmanned aircraft systems (UAS). Club members are alarmed at some some elements of the proposal could impose significant costs on the model aviation community and unnecessarily restrict existing, safe model aircraft operations. First, the rule must consider hobbyists who fly in rural areas with little or no internet connectivity. As we read the proposed rule, club members could be required to have an internet connection even if flying at an approved fixed flying site in a rural part of the country. Unfortunately, our club RC field does not have adequate cell service, which means club members would not be able to fly under the limited remote ID option. Rural locations such as ours are frequently the safest places to fly because they are away from people, other aircraft and structures. The FAA needs to provide a solution for these areas or exempt rural sites completely from the proposed rule. Finally, the FAA should reconsider the proposal to register each aircraft, which will impose a cost and compliance burden on the model aviation community. While individual registration may make sense for beyond line of sight operations, it is an unnecessary requirement for aircraft designed to be flown within line of sight typical of our club operations. We build and fly model airplanes because it is a passion; and many of us own dozens, of aircraft of different shapes and sizes, some of which we fly infrequently. The time and cost involved in registering each model individually would be substantial and runs counter to the current registration framework for recreational operators. Also, aircraft that are built by hand do not have serial numbers, which makes individual registration more difficult. AMA members fly aircraft that require continual input and are only flown within line of sight. Advanced drones, on the other hand, with advanced capabilities to have sustained and controlled navigation beyond visual line of sight may need additional remote identification requirements. This distinction was also provided to the FAA by the Remote Identification and Tracking Aviation Rulemaking Committee, specifically Work Group Two, tasked to set a threshold of compliance. Model aviation is the natural precursor to careers in aviation, including commercial pilots and engineers and more. Also, model aviation supports a $1 billion hobby industry responsible for thousands of existing U.S. jobs. We simply cannot afford to further harm the model aviation hobby with overly burdensome requirements.