Will You Register?

[Stambo]

Here I was thinking our regulations in New Zealand were a bit restrictive.
I hope our regulators don't follow this example.
9oz or 255 grams, really?
And then there is the cost, if not immediately, it will eventually be passed on through a registration fee.
Who will police it?
Will there be swat teams at your door at 4am just in case you have a 9 gram quad.
They can't stop the idiots at present, how is this going to make it any easier, they will not register.

http://makezine.com/2015/11/06/report-f ... quirement/

http://www.nbcnews.com/tech/innovation/ ... er-n447156

[pvolcko]

I think there's a lot unknown yet. And there is still time for comments to be submitted and reviewed to perhaps change the direction on some of this.

I think that it is a moronic idea. What use is the database? It is only useful if:
1) The person registers.
2) There is an incident, accidental or otherwise, that allows police to recover the aircraft and retrieve the number.

Given that, there is no reason not to simply require people to put their name, phone number, or AMA number on the aircraft. It will likely have a higher compliant rate, requires no government database, the manufacturers can help by including sticker tags or other means for people to label their aircraft prior to flight, along with a prominent note reminding the buyer/owner of the rule/law. All at relatively minor cost (far less than any embedded based registration scheme as a requirement prior to first flight). No impact to retailers, sales chains, etc. And easier for the cops than having to access a database which may or may not have been filled in with valid information.

Problems with a centralized registration:

1) Unless it is done at point of sale or somehow embedded into the firmware of the device to enforce registration prior to flight, it is essentially honor system and thus compliance is heavily dependent on perceived lack of intrusion and low/no cost to everyone involved.

2) If it is point of sale based, then you have a problem with second hand sales/transfers, parts replacement and follow up compliance, possibility of impeding sales due to network access issues or server issues at any given time, etc. If it is linked to an embedded hook that prevents flight before registration, that only works for the original owner. Still have second hand transfers to deal with. Both options incur relatively high costs for retailers and/or manufacturers. Indeed, firmware registration enforcement may only be practical on certain relatively high level devices where plugging into a computer is part of the deal. Most aircraft that this is intended to target do not involve computer connectivity and thus would be mandating a high cost of implementation, maintenance, and customer service for manufacturers.

3) If there is seriously critical information associated with the records then there is a need to hold the data secure, which is added cost, maintenance, etc.

4) We're talking about millions upon millions of records that will be in this database. If any kind of critical identifying information is maintained in the records then without strong protections against illegal use, anonymized research use, etc. this is a nightmare of identity theft waiting to happen. Also, the database will be ever growing unless there is a sunset for each record or a way for owners to de-register when selling or junking a device.

5) What is a "UAS" for the purposes of this regulation? I don't see how airplanes, single rotor helis, and other more traditional aircraft aren't just as much a concern from a flight safety perspective, perhaps even more so in some respects.

6) Online retailing complicates matters further, in particular for any point-of-sale based registration system. Again, high implementation costs for retailers.

7) If manufacturers or retailers are on the hook legally for enforcing registration then they become liable too. They will have to get insurance riders to cover this. More expense. Assuming liability insurance is even made available for this kind of thing. There is every possibility it wouldn't be, for instance gun stores can't get insurance coverage that covers their potential negligence in enforcing laws requiring they conduct background checks and maintain proper records, etc. This added risk and/or cost could put a severe damper on the sale of all RC aircraft that meet the thresholds they establish, hurting the industry significantly.

I could go on and on...

Suffice it to say, I think it is an amazingly bad idea to do this via a centralized database or with anything involving point-of-sale or embedded solutions. They should start off with a simple "put your phone number" on the model rule. It could literally apply to all model aircraft/drones without much impact at all. See how compliance rates turn out after a year or two and reassess. Why start with an expensive, intrusive, can of worms centralized registration system? It makes no sense.

[Stambo]

I agree with everything you posted.
Anything coded in to the device would be hacked pretty quickly, also can you imagine the people in the Chinese factories laughing over their green tea saying "FAA you want us to do what".
I thought our regs in New Zealand made us a laughing stock but the FAA of America has to go and beat us.