Spitfire76

FAA Issues Proposed Rule For Remote ID

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20 minutes ago, Stephen Yale said:

Has anyone prepared an answer to the FAA that we could send individually before the 60 day window expires?

Not yet, Stephen.  But I suspect there will be some good templates available in a bit.

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9 hours ago, Av8Chuck said:

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

Thinking about this.

I think it is definitely in @Alan Perlmans interest.  If this goes through, his business model in 4 years or less very well could need to be quite different.  Looking forward to his thoughts.

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At this point, the best thing to do is contact you elected officials and make comments on regulations.gov   The trade groups don't appear to be interested in helping anyone and the FAA can ignore us and push forward with this remote ID NPRM.  If I recall, there wasn't a lot of changes (to the proposed part 107) before it became law.  I believe bombarding our elected officials with comments will net us more favorable results.   The shear volume of letters to elected officials is the best way forward.

Edited by Martin Lachance
typo

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Hi Martin,  Contacting our reps is definitely a good idea.  Just be cognizant though that for the most part, joe public and main stream media are all for more restrictions on drones, whatever they may be.  That is a much larger pool of constituents for our reps to listen to than our #s.  Realistically, we need need a PAC, unfortunately.

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18 minutes ago, Spitfire76 said:

For what its worth the AMA have posted this template that can be used for the public comment

https://amablog.modelaircraft.org/amagov/2020/01/03/template-comment-on-uas-remote-id/

As an AMA member and RC fixed wing flyer I plan on using it.

Unfortunately, the AMA's primary concern is for their "model aircraft" members and not drone pilots.  They simply want more AMA fields to be allowed.  I belong to AMA but have tried unsuccessfully to drive home the fact that drone pilots' rights and needs are just as important as model builders.

Edited by Phochief

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4 minutes ago, Phochief said:

Unfortunately, the AMA's primary concern is for their "model aircraft" members and not drone pilots.  They simply want more AMA fields to be allowed.  I belong to AMA but have tried unsuccessfully to drive home the fact that drone pilots' rights and needs are just as important as model builders.

I am both a fixed wing RC and drone pilot/builder. I do fly planes at a local AMA club but typically fly my drones in a nearby park so I am for both keeping AMA fields as well as other areas to fly.

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2 hours ago, Dave Pitman said:

Bruce is going to volunteer his time to try and build a coalition to respond to this NPRM via a proxy on his youtube channel.

I'll hold off using the AMA template. 

Edited by Spitfire76

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 Bruce is certianly an interesting character, however,  I believe he’s making a mistake.  He’s making the same mistake that the CDA made of pitting commercial users and hobbyists against each other.  He also reduces the commercial segment to drone delivery.  

It’s great to claim that he accurately forecasted the failure of the Stevensen Jet Pack etc., it was easy to see the failure of startups such as AirWare, the SOLO disaster and that DJIs implementation of NFZ would lead to these types of regulations.  

There’s way more credibility for those who can forecast what works rather than what won’t.  Having said that,  Bruce is right about many of the points he makes but mostly the need for an organization that represents ALL unmanned operators.  

AOPA does not segregate between commercial or private pilots, all are welcome.  I think a real challenge for what Bruce maybe proposing is that even if he’s successful at getting the proxy for 200K users, and that’s a lot, why would he be any more successful than the AMAs 200K members?  

One of the things the FAA is very good at is “divide and conquer.”  All of this sounds the same as organizing prior the 107 NPRM.  I wish him luck but I don’t think the outcome will be any different.  It will be interesting.  

 

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Saying your comments represent the opinion of x# of individuals is somewhat useless, regardless of the one doing the representing. Whether that is AOPA, AMA, or Bruce Simpson.  The crux is, what leverage can you bring to bear.  Nothing moves without leverage.  The combined voices of the many are meaningless without leverage.

I don't know what the answer is.  Maybe there is no answer.

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Having 635K voting taxpayers is what gave AOPA its leverage.  If you can get 200K-300K memders you can probably get the best attorneys available.  It would be a place to start.

 

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You do not speak for me concerning remote ID.  The government is corrupt and inefficient.  I support private business remote id options and having insurance companies making flyers pay higher rates when not using remote ID.  Stop letting government run every aspect of  your life.  

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2 hours ago, Brazosrr said:

You do not speak for me concerning remote ID.  The government is corrupt and inefficient.  I support private business remote id options and having insurance companies making flyers pay higher rates when not using remote ID.  Stop letting government run every aspect of  your life.  

No one is claiming to speak for anyone. The suggestion is that forming a PAC with hundreds of thousands of members might be able to influence the outcome of the NPRM. 

Your entitled to whatever view of the government you like, but the idea of Insurance companies regulating RID is not an option, it is not part of the proposal. If you’d like the regulations to be the way you suggest, how to you propose to make that happen?  

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I've been watching the conversation about remote ID unfold on various forums from across the water in the United Kingdom. Essentially, we are going to get the same thing here in the UK. My first thought on remote ID is, if the intention of implementing remote ID is primarily a safety case is, why does it have to transmit an operators location, name and address and any other personal information that can identify an individual operator? Surely the one and only thing that needs to be transmitted and tracked, is that there is a UAV/drone in the air at any given time at any given location? No need for any other information to be transmitted than that. The whole idea is just to let other airspace users know that there IS a UAV/drone operating in any given part of the airspace at any given time. Why does anyone need to know any more than that if it is indeed just promoted as a safety case?

 

I've also heard rumblings about trying to establish some kind of formal body to represent/lobby for UAV/drone pilots and potentially how hard this could be. It will be hard and expensive! I look at it like this, to have any influence, you need to have political clout. And by that I mean the means to keep people out of office that are anti UAV/drone. There are 10 times the amount of UAV/drone pilots in the USA as there are in the UK, at an estimated 1.5 million. But even if someone could unite all those UAV/drone pilots together under one banner, it would still not be enough to have any significant political clout. 1.5 million people spread out across a massive country like the USA, in political terms is nothing. Just think what would happen if the US government decided it wanted to put remote ID on every firearm in the USA?! Have the ability to track every single firearm and individual firearm owner every second of every day! The NRA would be all over it like a rash and it WOULD be thrown out in about a week! Why? Because the NRA really does have political clout, they really do have the ability to keep out of office or vote out of office anyone who is more pro gun control. Not just in terms of a massive $250 million per annum budget but there are a hell of a lot of gun owners in the USA. Mess with them at your political peril! And that's why an organisation like the NRA will always be listened to and UAV/drone operators will just get lip service.. Which makes me think.... How many firearm owners are also UAV/drone pilots in the USA? If somehow the NRA could be gotten onside with our cause, then suddenly you have massive political clout. Just a thought.

Paul in the United Kingdom.

 

 

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26 minutes ago, Av8Chuck said:

No one is claiming to speak for anyone. The suggestion is that forming a PAC with hundreds of thousands of members might be able to influence the outcome of the NPRM. 

Your entitled to whatever view of the government you like, but the idea of Insurance companies regulating RID is not an option, it is not part of the proposal. If you’d like the regulations to be the way you suggest, how to you propose to make that happen?  

I read the article's quote wrong.  While I would comply, it is only done under fear of prosecution. 

 

As for regulations, I don't need to propose how that would happen.  That is for businesses to decide.  If they don't decide how to do it, then it doesn't need to be done.  Since there are companies working on that right now, it needs to be done and the best solution will be the one implemented instead of the cherry picked government backed organization with ties to lobbying.  There is no reason to think that the FAA will do this right, nor through any other method that government typically works.  

 

There are already laws on the books that take care of any issues.  If my drone hits something, I'm responsible for the damage if I can't prove it was the other person's fault.  Remote ID is to be able to identify the operator of the drone and make it easy for law enforcement.  I don't want to give up freedom to make governments life easier.  If I'm worried about accidents, I can buy a drone with technology to reduce those chances.  FAA Remote ID is asking the government for permission to do what you should be free to do in the first place.  

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I hope it is true that the DOT will de-rail this regulation, but I have very little faith in government bureaucracy  to do the right thing these days. I just submitted my comments to the FAA. As a 45 year licensed pilot I am very familiar with the FAA, the good, the bad, and the ugly. Many pilots call them "the society for the prevention of flight". I know many good people in the FAA, but I also know some whose mission it is to clear out the skies for whatever reason and that is most unfortunate. We cannot just sit with our hands in our pockets and hope that the right thing will be done. Many of us have considerable investments in our UAS equipment and peripherals, and it's not unrealistic to think this NPRM might pass and turn that investment into junk with the stroke of a government pen. Who has the biggest stick, us as a conglomerate or Amazon and their pals? I really don't know the answer to that, we can make a lot of noise if we choose to, whether the FAA will listen, who knows? One thing I do know, if we just stand by, the powers that be will be more than happy to usurp our privileges and run us out of business without blinking an eye. The fact that our suppliers, like DJI, seem to be only too happy to jump on this train is not in our favor and pretty disconcerting. 

 

I'm a P4Pro/Inspire 2 owner with a raft of peripherals so if the FAA got their wish, the only thing that would still have worth in my cases and cases of gear would be the iPad Mini's I use as monitors , the rest would instantly become paperweights. Needless to say the income stream that I have built from this gear would also vanish overnight. If this was a hobby I'd be disappointed in the prospects, as an integral part of my still photography and cinematography business I'm irate and everyone in our industry should be as well.

 

Respectfully,

 

Jim Wilson

Screen Shot 2020-01-05 at 1.30.03 PM.png

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Great conversation.

@Av8Chuck — I wasn't familiar with ACUAS.org. What kind of advocacy / actions did the group take over the last few years? I see you wrote "give it another shot" so will assume that no one is actively working on it right now. If that's the case...what happened?

@Dave Pitman — You wrote, "I think it is definitely in @Alan Perlmans interest.  If this goes through, his business model in 4 years or less very well could need to be quite different.  Looking forward to his thoughts." It's absolutely in my interest and wondering what you would advise me and my team do to help assist?

I hear you re: "individual comments will hit the round file with a thud" but choosing to be less cynical and would like to think that if a well-structured argument was made, with specific solutions proposed, that the comment would be read just as seriously as some larger group. Maybe I'm being too naive, but reading through this FAA infographic leads me to believe that they're truly looking for any and all "effective" comments.

image.thumb.png.1431da805e67ed5084457b6310208659.png

@Jim Wilson — thanks for sharing your comment. It's well-articulated, but I'm worried doesn't follow the FAA's directions above and won't be factored into their decision-making process moving forward.

@Stephen Yale — love this question. I imagine we'll see some of these templates surface over the coming weeks. Perhaps this is one area where we, as a company, can add some value. I'll need some help from folks in this thread to structure a response, following the suggestions in the infographic above (cc @Av8Chuck, @Dave Pitman, etc.)

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42 minutes ago, Alan Perlman said:

I hear you re: "individual comments will hit the round file with a thud" but choosing to be less cynical and would like to think that if a well-structured argument was made, with specific solutions proposed, that the comment would be read just as seriously as some larger group. Maybe I'm being too naive, but reading through this FAA infographic leads me to believe that they're truly looking for any and all "effective" comments.

Hey Alan,

I'm sorry for being a bit cynical with regard to how seriously the FAA will be taking comments.  I assure you that I will try to be positive, polite, and concise when I post my comment on the site. 

My cynicism is mainly born from watching the FCC's request for comments when the proposed dismantling the protections for net-neutrality (2017). I just went back and looked it up and there were 23,952,772 individual comments on the FCC's site. I didn't read them all, but I remember news agencies that were keeping track reporting that most were against the proposal, 20+ Million! The comments were ignored. 

This NPRM will receive no where near the scale of reaction, IMO.  So, I'll admit, I am indeed cynical that they don't plan on doing exactly what they want regardless of the comments.  Now, maybe it will all work out somehow.  Either it will be quashed by adults at DOT, as @Av8Chuck alluded to.  Or perhaps all of our craft (90%) will be easily up-gradable to meet the requirements as the NPRM says they will.  And maybe we won't be taken to the cleaners by the new network service we will be required to subscribe to.  And maybe all of the software handshaking that has to work perfectly to enable a mission to be flown will be solid.   And then, maybe it won't negatively impact all of our uas related businesses.

But that is a lot of maybes in there.  Dang,  more cynicism!  I will be delighted to be wrong and the FAA is malleable to the fine arguments and reason presented in the comments. However, reading the thing it looks like the FAA went even farther than even the suggestions of the ARC in some cases.  Not a great start.

Edited by Dave Pitman
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Dear Dave,

I have to say your "cynicism" is probably more than justified given the history of governmental entities rolling right over anything they have in their sights. 

 

JW

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Hi all. To paraphrase an old saying, I'm a long time reader, first time poster here.

As a Part 107 pilot who flies for an archaeological firm, a lot of the sites I'm mapping are out in the boonies where internet is nonexistent except via cell phone, and cell phone reception can be hit or miss if it exists at all. So the Remote ID issue is clearly something I'm keeping a close eye on.

I have a few questions I was hoping you all might be able to answer, just to make sure my understanding of the NPRM is correct:

A Standard Remote ID UAS would mean a transponder of sorts on the drone itself reporting it's location data and ID, as well as the hand controller/control station broadcasting via internet the same info to a Remote ID USS. So, there is definitely a hardware change needed to the drone itself, correct?

A Limited Remote ID UAS, on the other hand, would only require the hand controller/control station broadcasting via internet but the drone itself can remain as-is? Or would there be a needed software change to insure compliance with the 400 ft radius limit imposed by the new rule?

A related question regarding that 400 ft limit, as the NPRM was vague: is this a hemispherical 400 ft radius, or a cylinder 400 ft tall with a 400 ft radius? I presume the latter, but the NPRM just says "within 400 ft of the control station."

If my understanding is correct, it seems that as long as the tablet I use for flight has a cellular data connection, I should be able to continue to fly my current drone as a Limited Remote ID UAS as it is with just a software update for the data reporting and possibly limiting the flight to a 400 ft radius. The 400 ft limit is a burden, but for what I'm mapping it should be a manageable hindrance in most circumstances.

Now for the more speculative questions regarding implementation, should the new rule pass as it is written:

Does anyone have any idea what such an on-drone transmitter might look like? As in, will a bolt-on solution be available for existing drones, or is it likely to be some more substantial piece of hardware? I read something about tamper-proof, which seems to me to imply a hardwired internal component.

What happens if the internet connection fails during a flight? Does the drone automatically abort back to it's Home Point?

Has the FAA dictated power and transmission range requirements for the transmitter? Who exactly is receiving the drone-transmitted broadcast? Manned aircraft? If so, how will that be implemented for the pilots in the cockpit? Via their TCAS, or maybe TAWS? What about the lowly GA pilot in a C172 with standard analog dials, who we might actually encounter at 400 ft altitude? If GA cannot generally receive the drone transmission, and GA in most cases are the most likely to have a close encounter with a legally flown drone, then what's the point of transmitting from the drone directly?

So many implementation questions....

And of course, none of the above addresses the major hurdle for folks in an area with no available internet access. Surely the same software update needed to restrict a drone to within 400 ft of it's control station during Limited Remote ID flight can be employed to restrict flights to the same 400 ft limit outside of available internet coverage? How would that not be as safe? It's almost guaranteed those flights are in E or G airspace, and the odds of a close encounter with a commercial manned flight in such locations seem near minimal.

This whole issue is really fascinating to me. At first blush, the NPRM sounded like an intelligent plan, but it's the nuance of its implementation that make me pause and consider it more critically. I personally like the idea of remote ID broadcasting. I just don't know what benefit there is having the transmission coming from the drone itself, especially if the pilot is staying under the 400 ft altitude limit and within line of sight as they are required by current regs. And I see no real purpose for the active internet reporting at all if a drone/control station is transmitting an active radio signal. I mean, GA pilots aren't required to actively report their position in real time online in VFR flight, they just need to have an active transponder. So, why more stringent rules for drones?

My only conclusion is that the FAA is trying to clear a path for more expansive drone operations such as Amazon drone delivery by applying gross regulation to everyone, commercial operators and hobbyist alike. Would it not be much simpler to require all pilots to simply have the equivalent of a transponder on their person but keep the basic regulations as far as flight limits alone, and leave the heavy hardware components and active online reporting of in-flight assets to those entities looking to do more radical and potentially dangerous things such as beyond line of sight operations? I don't know, this whole thing just feels hugely overregulated, heavy-handed, and more complex than it really needs to be if the main goal is to make drone flights more readily apparent to manned aircraft.

Thanks for letting me vent/rant, and ask a few clarification questions. Looking forward to your thoughts.

-Jason

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20 hours ago, Jason Kovacs said:

A Standard Remote ID UAS would mean a transponder of sorts on the drone itself reporting it's location data and ID, as well as the hand controller/control station broadcasting via internet the same info to a Remote ID USS. So, there is definitely a hardware change needed to the drone itself, correct?

Yes, its proposing that the UAS would require "FAA certified" hardware/software to be able to provide 2 means of identification

  • The broadcast of the ID and location data directly transmitted by the drone itself that can be picked up by a device like a cell phone or other device. 
  • Transmission of ID and location data transmitted via the internet to an FAA approved USS  (3rd parties similar to those that provide LAANC) 

What's not clear to me at the moment is if the aircraft itself needs to be connected to the internet or if the transmission can be done via the ground control station. 

Now they also state that if there is no internet at take off it can still take off providing its broadcasting but if there is internet and the connection is lost during flight it should be reported to the remote pilot to take action like to land.

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Flitetest have built up a large community of RC model aircraft hobbyists over the years and have over 1.5 million subscribers to thier youtube channel. They just recently started this channel to help keep their community in the air. They are also asking to hold off on commenting on the FAA's proposed rule for the moment in order for them to have time to coordinate with other organizations and to come up with the most cohesive statement.

 

Edited by Spitfire76

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