Comment from ClearView Environmental Engineering LLC

After reviewing the proposal and randomly reading submitted comments, I do not agree with this unmanned aircraft flight restriction UAFR. I own a small environmental engineering company that operates sUAS in Class -D airspace, around military installations with 0 AGL altitudes. Have part 107 and a real fixed-wing pilot certification, retired Air Force. All my mission sorties have Airspace Authorization from the FAA before missions and full contact with responsible ATCT during missions; I’m a “good actor”. My simple reason for no … FAA can have 100s of rules/fines on UAS operations, but none of them discourage “bad actors” or even ignorant UAV operators from following them. I encounter kids flying UASs at 0 altitude Class-D airspace. I have parents tell me they buy UASs for their kids so they can take pictures for their business, no clue what Part 107 is or FAST knowledge, or even know they are in Class-D airspace. Anyone (child, foreigner, felon, anyone with money) can buy a UAS and fly it. No FAA rule prevents the purchase of a UAS in the USA. FAA UAS rules are equivalent to Federal and state gun rules, “bad actors” don’t care about them, and it does not prevent misuse. The average person still thinks drones and RC planes are just toys because kids fly them. The FAA has a hard enough time enforcing GA/commercial aviation rules. NTSB has cited the FAA numerous times for lack of enforcement. UAS operations are another layer of rules added to FAA’s already stretched-thin manpower. My nearest Flight Standards District Office (FSDO) is 4.5 hrs away in a different state. The next closest, in my state but in a different time zone, is 6 hrs away. The manning that handles UAS as an additional duty is about 3, sometimes 4 people. Last thing I want is to increase any federal agency funding/manning. FAA needs to realize that current UASs usage, in the USA, is a consumer “good or bad actor” free-for-all. The availability of very tech-capable UASs for very few dollars is astonishing. If one wants protection from UASs flying over them, one will need to adapt to active denial of flight means. Ukraine’s usage of UASs, in the last few years, are real lessons learned for UAS applications in the USA. Finally, as noted by others. When the FAA starts listing hundreds of small, restricted airspaces around the USA, on FAA UAS Data on a Map (arcgis.com), that will let “bad actors” know that there is something critical in that area. This rule will make things worse.