Hello my name is Christian Seemann:

 

I am the founder and CEO of Peregrinus Solutions LLC, a US based unmanned vehicle manufacturer and service provider for industrial and government customers. I built this company with the goal of using autonomous technology to help make the world a better place while providing a quality working environment where we treat our employees as the valuable resources they are and help elevate them. 

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Humanity is already in the midst of a new technological revolution that is going to transform our world like never before.

 In order to develop and build unmanned vehicles and their accessories in the United States we utilize a wide variety of high tech software and equipment such as computer aided design and object recognition software, 3D printers and various CNC machines. We teach our employees how to use these tools in addition to soldering, wiring and electronics, precision machining, various elements of multiple engineering disciplines, machine learning & vision algorithms for object detection and recognition, solar & wind power generation, LED technology, thermography and LIDAR.  Not to mention: web design, marketing, financial analysis and leadership skills that I and other members of the team have acquired over the course of our careers.

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The passion for acquiring this knowledge and these skills evolves  through participation in model aircraft and drone development. This summer we will host our first annual Young Falcons: Teaching Youth to Soar, drone and STEM camp. This event is open to all youth members of our community, but it is geared especially towards  exposing underprivileged youth to the wonders of science and technology education in a fun outdoor setting at our 136 acre test facility and headquarters located just outside Syracuse New York. There are many other drone based educational programs across the United States with similar goals.

Unfortunately, the new regulations which have been proposed by the FAA under the guise of improved public safety threaten to  eliminate these programs along with the drone and model aircraft hobby, put small businesses that have developed around the hobby community or provide UAVs and drone based services out of business, and shut down drone focused nonprofit and educational programs. These all serve as methods to attract youth to science and technology  oriented educational pursuits and careers which not only improve their quality if life, the lives of their families and local community members, but help advance the progress of the United States along with the entire world. 

I was inspired to make this video after reading and watching much of the phenomenal content that has been produced by the online educational communities for recreational  & commercial UAV and model aircraft flight as a result of the proposed legislation, and after submitting my own comments regarding this proposed legislation on the FAA's website. 

 

One video, created by a high school student, was extremely well done and struck me in particular. It reminded me of well, me, my brothers and our friends when we younger. We each developed our passion for flight, education and science through our childhood adventures with model aircraft and we all went on to pursue degrees and careers in STEM fields.

 

 These proposed regulations serve only to monopolize the skies for large corporations and eliminate fair business competition, along with individual rights to the airspace between 0 and 400 ft altitude. The FAA's proposed regulations go against decades of proven and demonstrated safe use of drones & RC model aircraft.
I suggest that the FAA base it's Remote ID laws after what the European Union recently put into effect.  The EU regulations make much more sense and help benefit everyone rather than strictly big business, mega-corporations.
It is true that the evolving nature of technology has made recreational model and drone flight much more easily accessible than it has been in the past. For increased safety the FAA could expand on its Part 107 certificate for commercial UAV operators to include a less advanced course and test for recreational use. The FAA could choose to host the basic course and test online for free to encourage maximum participation in the program. FAA.gov is a tremendous resource for the aviation community, it already provides incredible amounts of the latest training and regulatory information for free. Specifically, https://www.faa.gov/uas/ currently provides a great deal of information for safe UAS recreational and commercial operations. This existing resource should have the necessary training information and/or certification programs added to it rather than effectively and simply banning all recreational flight instead.

 

Drone users wishing to participate in FPV or First Person View flight must already earn a Ham Radio Technicians license to comply with FCC regulations for safe operation. Offering free training & testing will help provide some minimum level of competence for recreational drone operations and model aircraft flight. It may not completely eliminate the problem of scofflaws just as there are people drive without motor vehicle licenses and commit traffic violations, jaywalk, etc.  This type of common sense solution will allow everyone to participate in this new technological revolution without erecting unnecessary barriers to entry. If you effectively ban drones and model aircraft completely there will be a great deal of people who will likely choose to fly illegally rather than allowing thousands of dollars they have invested in equipment go to waste because the government arbitrarily decided to criminalize it and their passion overnight. Potentially resulting in increased danger rather than increased safety.

 

The common sense approach to Remote ID implementation will encourage all drone and model aircraft users to participate in safe standard operating procedures while minimizing costs incurred by the FAA and the general public.

 Remote ID can and should still be required for unique applications such as flying Beyond Visual Line of Sight (BVLOS) or autonomous safety backup systems for commercial drone collision avoidance while operating in high-traffic airspace. 

We have been experimenting with Remote ID/ADSB for our commercial UAV products, as we are very excited about Beyond visual line-of-sight applications that such technology opens up. However, we don't feel that it's fair to place this burden on all commercial flights and certainly not for research or recreational flyers.

 

The video created by the high school student mentions astronaut, engineer, naval aviator, test pilot and professor Neil Armstrong. He one of my personal idols and someone I strove to emulate while I was growing up. Neil Armstrong credits building and flying model aircraft with his passion for aviation, space and technology. 

As I mentioned before, this hobby instilled the same passion in many  youth during their formative years. Inspired them to go on to do great things benefiting society. 

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When Neil Armstrong stepped off of the lunar module and onto the surface of the Moon he commented  "one small step for a man, one giant leap for mankind," to symbolize the paradigm shift in knowledge and technology which had occurred in order for a safe journey to  the surface of the Moon and back. 

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The autonomous technology revolution will change our lives forever. The cat is already out of the bag and the genie is out of the bottle so to speak. There is no putting them back. It is imperative that the FAA consider all stakeholders affected by its legislation, including long term outcomes and potential unintended consequences, rather than what currently appears to simply be the short term interests of huge corporations and their wealthy shareholders.

 Drones, R/C aircraft and autonomous technology provide a creative and fun experience for kids of all ages.  They are the catalyst of inspiration and educational pathways for children to grow up to be the next Neil Armstrong, astronaut, pilot, scientist, engineer  or healthcare worker, etc. This is much to the benefit of the US population and global citizenry alike.

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The technology and knowledge developed by small businesses and educational institutions in America has a strong track record of being acquired and further developed by larger corporations and the US government for further commercialization and use on a wide scale. 

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These new regulations place such a high and unnecessary burden on recreational users, small businesses, and non-profit educational groups and institutions from a cost and privacy standpoint that they will effectively terminate the hobby, be the direct cause of multiple small businesses going out of business, employees being laid off, and these amazing educational programs shutting down. 

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The new regulations may result in an uptick in short term profits for the large corporations that are approved by the FAA because they will essentially have a monopoly over, and free reign of the skies. Giving them permission to legally buzz over public and private property  with impunity. 

The long-term consequences of shutting down this pipeline of talent and innovation will be devastating; beginning in the not-so-distant future!

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New York State has been making great strides in encouraging start up business development regarding autonomous technology solutions. There are multiple competitions throughout the state which provide mentor-ship and funding opportunities to businesses operating in these fields. Many other states within the US, and other countries around the globe hold similar competitions for innovation and technology development. The new regulations will make the competitions within the US irrelevant or ineffective if the individuals and companies that previously competed in them go out of business or are unable to fly and experiment. 

We are at a point in time where the US federal government and its agencies should be doing everything in their power to encourage the safe use of drones, RC aircraft and other forms of autonomous technology to maximize innovation, research and development. If they don't, we all lose.

 

The FAA has a choice to make. It has the power to help catapult the US to the forefront of the autonomous technology revolution as we take this next giant leap for mankind. They can facilitate this by enacting common sense regulations similar to the EU and only require Remote ID to help make advanced drone UAV operations such as beyond visual line-of-sight safely possible; while not requiring Remote ID for general drone operations. As mentioned previously, the FAA could also expand the existing Part 107 UAS Commercial Operations Certification to include a free, basic flight safety course and competency test for UAV pilots with drones between .55lbs to 55lbs, and only used for recreational purposes. Access to this would help encourage mass adoption of the educational and certification programs by all recreational users.

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It wouldn't eliminate all the potential problems, but outright banning legal drone and RC flight within the US won't either and policies of outright prohibition have a history of failure. 
On the other hand, the FAA can choose to write this proposed legislation into law as is, or with little effective changes. This would prove to be a much darker path as it will directly oppose and ignore the will of the majority of community members who are directly affected by the proposed regulations and that of the informed general public.

 

The first option will help the US make our next giant leap while the second of option will effectively cut the United States legs off as we attempt to win the race for autonomous technology and artificial intelligence.

Please do the right thing FAA so we can all be our best selves, so we can all be great!

As I'm sure many of you can agree it's been extremely exciting getting to this point despite the future being uncertain. I'm very optimistic that the FAA will choose do the right thing and amend their proposal to encourage safe drone and RC model use for everyone, rather than eliminating this the hobby and field completely with the exception of huge corporations hand picked by the government and corporate lobbyists. 

 

The future is already here, now! The potential for life-changing innovation through autonomous technology and artificial intelligence is amazing! I have included helpful information for submitting comments to the FAA, tips for attending a peaceful protest, knowing your rights, links to information about the protest outside the FAA headquarters in Washington DC outside on February 29th, 2020, and other helpful YouTube videos from community members  regarding this topic:  xJet, Joshua Bardwell, Rotor Riot, Le Drib, Mr Steele, FPV Quickies, Drone Camp's USA, the high school student I mentioned. I'm sure there are many more out there so please include them in the comments if you have any positive information to contribute or links to add.

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I salute you for standing up for your rights and the rights of other American's, it's one of the most courageous and patriotic things you can do. Please give this video a thumbs up and share it with your friends family and the media. Comment on the FAA's website form and attend the protest if possible. If you aren't sure what you write, or competent in your writing skills please adjust my comment or someone else's comment or just use the exact comment if you agree with it. By standing up together we can fight for our rights and win despite what may appear like overwhelming odds.

 

 

Sincerely,

 

Christian Seemann and the Peregrinus Solutions LLC Team

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Christian Seemann B.S., M.B.A.

Founder & CEO of Peregrinus Solutions LLC

Autonomous Robotic-Drone Development

Designed and Manufactured in the USA

"Sea, Land, Air our Drones will Safely take you there!"

315-925-7404

solutions@peregrinuss.com

www.peregrinuss.com