My comments to the FAA are:
I find the new regulations very disappointing. I believe they violate both the letter and intent of the special rule for model aircraft in the modernization act, placing a burden on model aviators and ignoring the value of the existing model aviation communities, making the national airspace less safe. Further, I believe this creates an unnecessary government database that will be a target for cybercriminals.
Congress clearly recognized the value of model aviation in promoting STEM skills, and wrote the special rule for model aircraft to insure that the FAA did not interfere with this. The new registration process will discourage children from participating in these programs. The age limit just makes this worse, as there are children younger than the limit designing and flying model aircraft. These skills should be encouraged, not criminalized!
Congress also recognized the value of community organizations, citing flying according to those guidelines in the definition of model aircraft. These guidelines clearly work, since the members of these organizations have nearly a century of exemplary safety! Those guidelines require that all aircraft flown outdoors - not just those over an arbitrary weight limit - have contact information on them, so mine do. The weight limit shows that the registration process is a burden that becomes unacceptable for lighter and more common aircraft, even though they are no less a risk to the national airspace.
Replacing the registration process by a simple requirement that each aircraft have contact information on them achieves the stated goals of that process, without the expense of the database or burden of the process. This would allow it to be applied to all model aircraft flown outdoors, not just those over that arbitrary weight limit, making the national airspace safer. Allowing that contact information to be through a community-based organization would encourage model aircraft pilots to join such organizations, making them members of a community that values safety and has the history showing that their guidelines work. This would mean more aircraft would be flown with contact information, including those that the registration process exempt - making the national airspace safer.