Australia appears to be taking a sensible approach with registration for a “reference number” as a first step to commercial certification. This is what the FAA should be doing right now.
The ATSM F38 proposals might be appropriate for larger, heavy UAS (eg, converted military drones for use by oil companies) but certainly not for the small time aerial photographer. If the much anticipated rules are shaped solely by F38 the current process will be broken. As has been stated, “Sense and Avoid” is only practical for the heavier (25 lb+) and larger craft and those operating outside of VLOS. If technology can make S&A or even ADS-B work on a DJI at some point without killing the battery, then fine, but absolutely not at this stage of the game.
If the FAA makes the fence too high for the thousands of small operators, or if they wait too long to provide for limited commercial use by the small operator and independent movie producer, the fence will be ignored and the FAA will be reduced to swatting flies with no hope of ever regaining order, and they will have utterly failed in their mission of “promoting safety in the national airspace”.