I agree with everything EXCEPT 2 things: Must maintain visual, and restricted night flying. Though I think making slight changes in the rule would improve safety overall. I see that the process for regulations started YEARS ago, but perhaps a quick "snap-shot" of what today's technology brings may suggest to the FAA that technology CAN and DOES make things safer... they just have to ask for it.
MAINTAIN VISUAL:
With technology advancements, why not include exceptions to the rule allowing technology to make it safer:
- Must have live video feed, or,
- Must have craft telemetry relative to flight status, or,
- If none of the above, must have visual.
Describe what you (FAA) would make you feel safe and let technology come to the rule. In the rationale section, the FAA didn't allow it because miniaturized solutions didn't exist. Well... they can be if the manufactures knew what the FAA wanted.
Think of it in a practical sense. You just passed all the requisite testing to show competence, registered the craft, however,
- to inspect a bridge (example given by the FAA) you still won't be able to fly the craft. (You're on top of the bridge, craft is under it.)
- to fly around a property for real estate (example given by FAA) with trees, you will not maintain 100% visual, thus you cannot fly in that area
NIGHT FLYING:
Though I see the practical sense for hobby flying (currently hobby craft night flying isn't restricted at this point?), for commercial use, there HAS to be a reason why someone would risk a night flight.
- Search and rescue: From first hand experience, the public doesn't call for a lost person in the woods until THEY sense the urgency... usually darkness falling. Air support comes in with best value with its use with FLIR and Thermal video since ground crews have limited / no light for first person vision. This also ties into flying without visual of the craft.
I would suggest a "craft lighting requirement" to assure the device has proper safety lights for everyone.
LASTLY
By implementing the above advancements, it would entice the hobbyist to get their UAS certification to enjoy the advanced privileges, all while increasing safety and generating revenue.
Those are off the top of my head.