Spitfire76

FAA Issues Proposed Rule For Remote ID

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On December 26, 2019 FAA issued a proposed rule for remote ID and will be published for public comment on December, 31, 2019.

https://www.faa.gov/uas/research_development/remote_id/

https://www.federalregister.gov/documents/2019/12/31/2019-28100/remote-identification-of-unmanned-aircraft-systems

1180454507_ScreenShot2019-12-27at7_03_36AM.png.1151de58e0fa64ba51770d985064d540.png

Edited by Spitfire76

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When you consider:  “Less than 7% of the members of the ARC were stakeholders who would primarily face burdens and/or costs from a future Remote ID requirement, while 75% of the members stood primarily to gain from a future Remote ID requirement, either because of their interest in law enforcement tools or in thefurtherance of their business objectives or prospective sale of Remote ID technologies or service.”

That is a quote from DJI commenting on this NPRM found here:

https://www.dropbox.com/s/brcukg8t4j0agic/DJI Remote ID Discussion Paper.pdf?dl=0

Companies and people are spinning this like crazy while brushing past the real issues.  How does Remote ID make drones safer?  Is it necessary? If so why?  Does it infringe on my civil liberties to make a living with UAVs? How much additional cost is associated with this policy for the UAV operator?  How is this enforced?  

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"Safety" is only a hot-button word to sell whatever they want to sell.  In the case with Remote ID as it is written, safety is not a factor at all.  Perfect for the likes of AirMap and Verizon, though.

A quick commentary.

https://www.thedroneu.com/blog/faa-announces-drone-remote-id/?fbclid=IwAR3_-NGXh1G58yjIuxpMFvCbCzYL75C2VBTlQc2HKt8eEtJUOEauxJ7oeG8

Edited by Dave Pitman

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12 minutes ago, Spitfire76 said:

AMA's blog on the subject

If you only fly at designated and approved flying fields, I suspect you will be exempt from live broadcast from your equipment.  Other than that, not so much.  AMA seems to consider this a win for recreational flyers.

Do the majority of AMA members generally just fly from and within designated fields?

Edited by Dave Pitman

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1 minute ago, Dave Pitman said:

Do the majority of AMA members generally just fly from designated fields?

I believe that a lot do but some don't always live close to one. Also, since land is becoming more developed there are less places to establish one.

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The whole Remote ID rule was concocted by DJI, AirWare, the FAA and any other organization that stands to benefit from user fee’s.  I know that sounds like a conspiracy theory, but thankfully it doesn’t matter.  

The DOT has rejected all four of the proposed FAA NPRM’s.  Apparently they don’t agree with the premise of this rule.  This issue appears to be dead on arrival and isn’t going anywhere.  Thankfully. 

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2 hours ago, Av8Chuck said:

The DOT has rejected all four of the proposed FAA NPRM’s.  Apparently they don’t agree with the premise of this rule.  This issue appears to be dead on arrival and isn’t going anywhere.  Thankfully. 

Is there a statement to this effect from the DOT published somewhere ?

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The DOT isn’t going to express it that way so there’s no statement but they’ve delayed it since May.  There are othe federal agencies questioning DJI’s involvement in the DAC for this NPRM, it’s going to be increasingly difficult for the DOT to depend on RID technology manufactured in China.  

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8 hours ago, Av8Chuck said:

The DOT has rejected all four of the proposed FAA NPRM’s.  Apparently they don’t agree with the premise of this rule.  This issue appears to be dead on arrival and isn’t going anywhere.  Thankfully. 

I hope you are right, Chuck.  Remote ID is fine with me.  The simple, over the air broadcast of who I am.  Creating an NSA-PRISM like infrastructure to track and log small uas operations seems entirely overthought to me.

Edited by Dave Pitman

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Reading what Patrick Egan writes can be a challenge, I don’t always understand his inside references and sarcasm.  But this is an article about putting many of his post in context of when he posted them.  Although it borders on sounding conspiratorial and I don’t agree with all he says, you have to hand it to him for confronting the problems of our industry. 

https://www-suasnews-com.cdn.ampproject.org/c/s/www.suasnews.com/2020/01/foresight-can-also-be-2020/amp/

 

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Bruce does a brilliant job of explaining the consequences to our hobby if this rule is allowed to go into law. He challenges the FAA on its pretense to be in the name of safety. He also doesn't believe that the AMA will be effective in influencing the FAA's decisions based on its inability to stop the repeal of 336. I would encourage anyone in this hobby to watch it.

 

 

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For those of you looking for more information on the Proposed Rule, we've put together this article that explains the FAA's proposal, why it concerns us, and what you can do to help change the proposed rule before it’s finalized: We’re Concerned About the FAA’s Proposed Rule on Remote ID (Here’s Why And How You Can Help)

What I found concerning about the NPRM was the cost analysis.  The NPRM describes a data subscription plan that drone users would purchase from designated UAS Service Suppliers (probably some of the same players who offer LAANC access). The FAA has estimated that the subscription would cost drone pilots $2.50/month on average per operator. That doesn't sound like much, but what will the initial cost be to upgrade equipment if your old drone isn't compatible? It sounds like cell phone data plans, which have gotten very expensive over the years, especially for "unlimited" plans. 

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There’s a false narrative taking place here regarding the NPRM, I, like many other professionals are for accountability and safety but this NPRM does not address those concerns. 

Over the past 18 months while much of the ARC was formed, suggestions made about requirements for this NPRM, the AMA was conspicuously absent from the process.  Now the FAA has opened up the NPRM for comments and most of the comments are from hobbyists expressing their views about their hobby.  At this point the views and concerns of individuals is kind of pointless.  

Bruce is right about much of what he says, especially about the AMA.  The same thing is going to happen to DJI.  DJI seems to think that because they are part of the process of developing the NPRM and they have developed technology that helps ID (their) drones that they will be in a position to manage user fees.  They won’t be be.  DJI is the “sacrificial lamb,” the FAA will not work with DJI for the same self preservation reasons they didn’t work with the AMA.  For all those DJI owners that think DJI will work with the FAA and this will not effect you, the FAA is about to turn your drone into a paperweight.  

It will be interesting to hear what Bruce is planning.  We need numbers to form a Political Action Committee PAC similar to AOPA.  

 

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3 hours ago, Av8Chuck said:

For all those DJI owners that think DJI will work with the FAA and this will not effect you, the FAA is about to turn your drone into a paperweight.  

I actually have not heard 1 person in all the chatter voice hopes that DJI will save them from this, for what that's worth.

 

3 hours ago, Av8Chuck said:

We need numbers to form a Political Action Committee PAC similar to AOPA.  

This, on the other hand this is repeated over and over.  But I don't hold out much hope.  Some think "we" would have a chance if a few hundred thousand of us were to join AOPA and then they might advocate for "us" as well as manned aviation since that would equal their current membership.  But's thats a pretty tall order.  They do have the machine already though. (BTW, I and many other cross-over guys are already AOPA members).

Do you have any solution proposals?

Edited by Dave Pitman

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1 hour ago, Dave Pitman said:

Do you have any solution proposals?

I gave it a shot when we founded ACUA.org.  

There are far too many armchair quarterbacks who thought this type of regulation is a necessary step and that the AMA, DJI, AirMap and The Commercial Drone Coalition would represent commercial interest with the FAA.  

1 hour ago, Dave Pitman said:

This, on the other hand this is repeated over and over.

It certainly has been recently over the past six months but at ACUAS.org we were making this pitch four years ago.  Most people just laughed at it.  I’d give it anothe shot if we could get some adults to work with, if Alan were interested in working on such a cause and a couple of attorneys were interested in volunteering

1 hour ago, Dave Pitman said:

Some think "we" would have a chance if a few hundred thousand of us were to join AOPA and then they might advocate for "us"

The thing to keep in mind is that AOPA has been against drones since day one.  

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I'll copy a comment I made to PatR on another board:

"We are clearly on the exact same page.

To put together a group voice in a short time to supply an initial group response to this NPRM with a meaningful voice to follow in the future is doable with a commitment from enough of our ranks. A crowd-source campaign that could start collecting monetary commitments from us but would hold them in escrow to ensure there was enough to make it happen before anyone's $$ would be taken.

It would involve some trust, and the ability, if that minimum commitment goal was reached, to hire a skilled attorney or 2, hopefully from within our extended ranks, to get started.

50,000 commitments of $75 = 3.75mil,$ There are at least some of us willing. Another $75 toward this adventure is insignificant at this point. Enough of us willing though???

If we could reach the commitment, who or what mechanism could be put in charge in order to be trusted with that commitment? In a short time? Without the ability to trust, the commitment won't happen. Tough questions."

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I think that’s a great idea. Might be harder to get a commitment for $75 than you think, but I don’t think that matters.  

Did you know that PatR, David and I were the founders of ACUAS?  

Alan, you or UAVCoach have any interest in this sort of thing?

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On 12/27/2019 at 6:58 AM, Spitfire76 said:

On December 26, 2019 FAA issued a proposed rule for remote ID and will be published for public comment on December, 31, 2019.

https://www.faa.gov/uas/research_development/remote_id/

https://www.federalregister.gov/documents/2019/12/31/2019-28100/remote-identification-of-unmanned-aircraft-systems

1180454507_ScreenShot2019-12-27at7_03_36AM.png.1151de58e0fa64ba51770d985064d540.png

I have worked in the environmental compliance arena for many years. The first lesson I leaned early on is to ‘ make compliance easy’ both for the regulated and for the regulators.  We spent many hours interpreting regulations only to find out that the newbie regulators had not been trained and misinterpreted their own requirements.  The UAV Coach article appropriately calls us, the drone community, to action.  I am also concerned about 2 additional consequences of the proposed FAA rule:  who at FAA will analyze the voluminous data and at what rate will that happen?  In the environmental world, lots of data is collected and reported, yet regulators are short staffed, so legitimate regulatory actions are often delayed.  Additionally, in our current climate to balance transparency, cyber security, and privacy, the proposed FAA rules could affect all 3 negatively at huge expense.  Small companies will not be able to afford the FAA  ‘notification’ system, thus stifling the drone industry growth.

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My biggest issue/concern is that complying with this reg requires internet connection. I'm just getting into the industry and will be flying missions in remote areas mapping habitat for restoration. No internet connection out in these areas. Drones are being used more and more for wildlife surveys, forest health mapping, etc so if this rule is implemented how is that work going to get done?

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Pat mentioned the other day that he was part of it.  In fact he floated your name when I posted my previous comment in regard to "who could we trust".   I'm not sure I know who David is.

Anyway, 

In the various boards I follow, (I"m a 'never Facebooker')  there is definitely concern.  But no where near enough by a long shot to make something like this work.  Even if there were a 100 that would commit for every 1 that posts, there would realistically be nowhere near enough.

The # of part 107 holders is supposed to be in the 150k range. Recreational in the 1mil range.  You would think it was important enough that 4.3% would be willing to commit.  But right now, I have my doubts.  How would we reach out to present the question.  I doubt AMA is going to broadcast this or let their contact list be used. 

I guess we just might have to watch as Rome burns, so to speak.  I really think that all of our individual comments will hit the round file with a thud.

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