Super Simple FAA Comment Guide on June 25 Model Aircraft Notice

Submit comments by July 25 at: http://www.regulations.gov/#!submitComment;D=FAA-2014-0396-0001

[Add brief introduction to who you are and what you do.]

[Pick and choose from the below main points. This is a guide only. Delete anything that does not apply to you. Add other things that apply (for example, you teach robotics to middle-school students). Be creative and specific, and make your comment your own.]

1. The FAA's Interpretation restricts people who are flying model aircraft from receiving any payments. For decades, people have been paid for hobby company promotional or product development purposes, model aircraft magazine reviews, and have participated in contests and competitions that have cash prizes. These payments do not change the underlying recreational purpose of the overall activity or make the hobby any less safe. The FAA's very narrow interpretation of "hobby," dug out of dictionaries rather than an understanding of actual hobby in question, will disrupt model aviation for the worse with no public benefit. [This part of the FAA's interpretation will negatively impact me because I like to participate in and watch model airplane competitions, I work for a hobby company, I am sometimes paid for my time teaching people to fly model airplanes, or I have plans to do one or more of those things.]

2. The FAA's Interpretation concludes with the statement that an unknown number of aviation regulations "may apply to model aircraft operations, depending on the particular circumstances of the operation." I believe this sweeping statement is contrary to Congressional intent in the 2012 statute, in which Congress required the FAA to exempt recreational model aircraft from new aviation regulations and to continue to allow community based organizations to self-govern the hobby instead. This interpretation negatively affects me because the FAA has not provided guidance on what kinds of model aircraft use might now be subject to regulation and possible penalties. This seems unfair.

3. The FAA's Interpretation suggests that hobbyists who fly their models by "first person view" (FPV) might be doing something wrong if they are using video glasses or "goggles." For the past decade, FPV has been inspiring students, engineers, robotics enthusiasts, and many others to take up the hobby or to expand their hobby activities. FPV control adds no danger to the hobby, especially when a spotter is present to monitor the airspace. The language of the 2012 statute concerning "within visual line of sight" indicates how far away a person should fly the model aircraft, not what method of control may be used for the recreational experience. [This part of the FAA's interpretation impacts me because I enjoy flying FPV or plan to explore FPV in the near future.]

4. The FAA's Interpretation appears to require any person with any size model aircraft to ask authorization from air traffic control before flying it, if within five miles of an airport. This is a new requirement for model aircraft, contrary to Congressional intent. If this

includes rarely-used grass strips and part-time helipads, how do I reach the airport controller when no one is there? In another part of the Interpretation, the FAA suggests that certain “classes” of airspace may govern what permission a model aircraft operator needs. This is confusing and contradictory, and imposes many more obligations upon hobbyists than they ever had before, in contradiction to Congress's intent. This interpretation does not provide clear notice to me of what I am supposed to do. [My home, local park or model aircraft club is within five miles of an airport and I am concerned that I will need to ask permission of air traffic control just to use a toy in my backyard or local park.]

Overall, it appears to me that the FAA has imposed new regulations on the model aircraft hobby without examining what the hobby is actually all about, including sponsored pilots, prize contests, FPV, and small models flown in backyards that do not require air traffic control clearance. All of these activities have been established as safe by the hobbyist community, with a proven self-governance safety record for decades. The Interpretation is contrary to Congressional intent, and will damage an important science-based outdoor recreational pursuit that offers many benefits to the country.