My comment to the FAA

The FAA has proposed Remote ID regulations that would severely hinder recreational drone racers such as myself. This is the comment I submitted to the FAA. The deadline to comment is on March 2, 2020, and I encourage everyone who has not already commented to submit a comment right away.

My name is Susan K. Smith, and I am one of the few female drone racers in the United States. My boyfriend and I are members of a Tier 1 chapter of MultiGP. We travel to drone races across the country. We have approximately 40-50 drones of various sizes. The drones that we fly have no automated capabilities, do not have GPS and are amateur-built. We always fly under 400 feet and in uncontrolled airspace with permission of the property owners.

I ask that the FAA to lift restrictions on drones when they are indoors; when they have no autonomous capability; and when they are flown at less than 400 feet in uncontrolled airspace.

Of grave concern to us are:

Amateur-built restrictions:

All of our drones are constructed by us to meet various race requirements – and need to be repaired by us quickly at races. We need to be able to swap out components that break during races.

Costs:

To race drones competitively, you need to maintain a working fleet of at least five to six drones. Because my partner and I have dozens of drones, the cost of registration for us will be significant – possibly several hundred dollars. We have concerns about the purchase price of Remote ID. We are additionally concerned about the cost to replace Remote ID components.

Privacy and Safety:

First-person view pilots wear goggles when flying. This leaves pilots with no visibility into their surrounding area other than through their spotter, who will be focusing his or her attention on the drone. If Remote ID allows the general public to identify the pilot’s location, criminals could use this information to steal the pilot’s personal property or attack the pilot and spotter.

Limitations on Flight Areas:

To be competitive requires a great deal of practice. Each year, a woman – along with several others – is selected to represent the United States team in an international drone race held by FAI. I have concerns that, if these restrictions are enacted, the United States will be at a severe disadvantage compared with other countries who compete at the international level. The drones flown at international races are above 250 grams in weight. If U.S. pilots can only fly these drones in designated areas, it limits those who can compete to those who live near a FRIA. Even worse, drone pilots must share a limited band of radio frequencies. This means that only eight drone pilots can fly at any given time. Quadcopter pilots would also need to share the FRIA fields with other recreational users such as wings, airplanes, and helicopters, who are equally as passionate about their hobbies and are also skilled pilots. Imagine being selected to the U.S. team and having to drive a great distance to a FRIA. Then once you get there, you only have a few hours to use the field because that is the designated drone flying time to be fair to all different types of RC hobbyists. Then within those few hours, you have to wait 30 minutes each time for a channel. Each flight is only two minutes long.

Indoor Racing Limits:

I also have concerns about limitations when drones cannot get an accurate GPS reading. Given that racers fly only in relatively small fields (typically the size of a football field or less), I see no reason to require GPS technology. Moreover, many racers fly drones that weigh more than 250 grams indoors. These drones would not arm without GPS.

Impact on STEAM Education:

Drone racing has many benefits to STEAM education and has taught me a wealth of new skills: Soldering, physics, electrical engineering, reading technical diagrams, programming, social media marketing, and video editing, to name just a few. More importantly, I have met an amazing community of caring individuals. The United States has an interest in promoting STEAM to girls to stay competitive. Drone racing teaches all of these skills. I have developed a website and now have a following of several thousand people on social media channels. I have spoken to a few women in the last few months who said they do not want to get into drone racing given the potential future of these regulations.

In conclusion, I urge the FAA to reconsider restrictions that will hinder responsible drone pilots through unfair costs, privacy and safety concerns, and unreasonable restrictions on flying areas. We stay close to the ground and fly as close to the racing gates as possible.

Although my comments are mostly around racing as that is my personal interest, I also want to advocate for those pilots who freestyle and who are interested in capturing high-definition video. These pilots are carrying a high-definition video camera on their drone, which adds to their weight. Freestylers capture nature’s beauty for us all to see. I highly value the educational content that we can show our children of America’s beautiful mountain ranges, snow banks, and more.