I haven’t made it through all 319 pages, so I’ll add comments as I progress.
Problem #1:
“The FAA proposes to revise the registration requirements to require all owners of unmanned aircraft to register each unmanned aircraft individually when registering under part 48.”
Today, a certificate is issued to model aircraft owners and covers “all” models, not “each”, registered under 48.100(b).
Problem #2:
“For purposes of this proposed rule, a “limited remote identification UAS” is a UAS that: (1) is designed and produced to restrict operation to no more than 400 feet from its control station;”
Note the use of 400 feet from its CONTROL STATION. Implies horizontal and vertical distance, not altitude only.
Problem #3:
“From takeoff to landing, the limited remote identification UAS connects to the internet and transmits the required remote identification message elements through that internet connection to a Remote ID USS.”
Implies investment in additional equipment. Nothing I have connects to the internet today. Perhaps the new iX series of transmitters from Spektrum do, but I’m not aware of them doing this while actually flying.
Problem #4:
“An area would be eligible for establishment as an FAA-recognized identification area if it is a flying site that has been established within the programming of a community based organization recognized by the Administrator.”
Alternative to Problem #3 above - implies that an AMA site is the only option, and that the site actually applies to be FAA-recognized.
Problem #5:
“This proposed rule would result in additional costs for persons responsible for the production of UAS, owners and operators of registered unmanned aircraft, community based organizations, Remote ID USS, and the FAA. This proposal would provide cost savings for the FAA and law enforcement resulting from a reduction in hours and associated costs expended investigating UAS incidents.”
Implies the math actually works. Reading through the pages so far, the requirements placed on the manufacturers, owners and operators requires substantial investment. All of this will eventually fall on the operators, in terms of prices for equipment which is capable of meeting the newly mandated requirements. Even if I decide to fly my current equipment from a club field, which is FAA-recognized, at some point in time, I will buy new gear. That gear will definitely be impacted and costs increased when this new rule is implemented. At $50 per hour, a total of 20,000 hours must be saved for break even on each $1,000,000 invested. I’m not sure that’s realistic.