This is a long post--don't say I didn't warn you.

While lurking--er--researching online, I stunbled across the Notice of Proposed Rule Making document for the remote ID of Unmanned Aircraft Systems (NPRM of UAS). It 87 pages, 3-columns each. The following paragraph is on page 2, column 2, paragraph 1, to wit:

"All UAS operating in the airspace of the United States, with very few exceptions, would be subject to the requirements of this rule. All UAS operators would be required to comply regardless of whether they conduct recreational or commercial operations, except those flying UAS that are not otherwise required to be registered under the FAA's existing rules. All UAS produced for operation in the airspace of the United States would have to comply with the design and production requirements established in this proposal with exceptions for amateur-built UAS, UAS of the United States government, and unmanned aircraft that weigh less than 0.55 pounds."

And later, page 24, column 2, paragraph 3:

"Amateur-built unmanned aircraft system means an unmanned aircraft system the major portion of which has been fabricated and assembled by a person who undertook the construction project solely for their own education or recreation."  [This wording is almost identical to the wording that allows for amateur-built full scale aircraft.]

The bold emphasis is mine, but would the exception apply to our homebuilt foamies? Does that mean we have a loophole (but not RTFs)? Are we impaled by the phrase, "All UAS operators would be required to comply . . ." or are we exempt because our aircraft don't need to be registered? Or do they need to be registered?

I don't want this to devolve into an FAA bash session; just looking for some opinions. And as I have not read the entire document perhpaps I just missed the clarification. We build/fly foamies for my H.S. classes so I'm a little anxious.

Thanks, and fly safely,

Quote 0 0

The NPRM is pretty vague; it's not clear at all. By "fabricating and assembling," does that mean I need to be winding my own motors? Does my foam airframe count as 10 pieces, or one? It's really not clear. Either way, as the NPRM is written, the excepted amateur built UAS would be still be restricted to FAA recognized identification area (FRIA) which (as proposed) could only be formed under the wings of a community based organization (as of yet undefined, none exist atm) within the first 12 months after the law went into effect. FRIA's would then phase out so within 3 years ALL sUAS would need to be RID compliant. Obviously this is ridiculous as it would outlaw any sort of homebuilt aircraft or multirotor, because the RID must be built into the aircraft and not be bypassable by the operator.

So in short, as the NPRM was written you would need to register all your aircraft (for $5 apiece), they would be restricted to FRIA's (which would disappear over the next few years), and any more you build would either need to qualify as "amateur built" (we don't know what this means) or would need to be RID compliant (which is impossible due to the regulation placed on "manufacturers" which you would then need to comply with). It's a whole mess, though as of yet there isn't any actual rule in place. This was just a proposal which they'll work on before issuing a rule (probably in another several years). I would recommend you communicate with your senator/congressman regarding this issue, especially since you use foamies in education and the NPRM would completely hose that. 

More good resources here:

Quote 0 0

I guess the time for panic is later. The FAA does have 53,000 comment to review so it’s not likely to impact us for a while. (We sent in several comments to add our opinions to the mix.)

Maybe they’ll listen to the alphabet orgs (AMA, EAA, etc.) and enact something more reasonable.

Thanks for the input. Fly safely.

Quote 1 0
All this while the FAA has given Elon Musk the approval to launch 60 thousand low orbit satellites. In the interest of "communication" and world web access.
Quote 0 0