Spitfire76

FAA Issues Proposed Rule For Remote ID

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On 1/5/2020 at 3:06 PM, Alan Perlman said:

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?

We launched ACUAS.org in response to the debate over what would become Part107 and the need for someone to protect our right to chose to become a commercial operator. 

It was founded on a simple premise that it wasn't up to the operator to prove that it was legal to operate commercially but the FAA to prove that it wasn't.  Its against the law for the FAA to promulgate rules that are arbitrary and capricious so we felt there was value to holding the FAA accountable to the NPRM process and questioning many of the proposed suggestions from the "expert" alphabet organizations like Commercial Drone Alliance (who has never met a regulation they didn't like).  https://www.linkedin.com/pulse/commercial-drone-alliance-2018-legislative-priorities-gretchen-west-1/ 

At the time we took a lot of flack over that stance, most of the alphabet coalitions and user groups, made all sorts of promises, collected a lot of money, held concerts for congressional staffers etc..  Trouble was NONE of them represented the interest of either the hobbyists or the commercial operator.  Most of them were formed by attorneys trying to stake a claim in the "wild west" of the new commercial market, magazine's and forums trying to build marketshare for their trade shows, or already established groups like AUVSI or the AMA pandering to their existing members to preserve the status quo.

Most of these organizations had a seat at the table, so to speak, you might remember Colin Guinn flying at the House of Representatives: https://www.theverge.com/2015/1/21/7868315/congress-drones-unmanned-aircraft-hearing.  Trouble was, wrong table.  The table that mattered was at the Office of Management and Budget OMB.  That wasn't open to the public and you had to be invited (subpoenaed) to attend.  We were asked to submit a paper about the risk versus regulations and what effect we thought it would have on innovation and costs.

On 1/5/2020 at 3:06 PM, Alan Perlman said:

so will assume that no one is actively working on it right now. If that's the case...what happened?

Once the NPRM was public and Part 107 became a reality, there really wasn't much for us to do.  We discussed the possibility of working at the state level to address the over reach that was sure to follow at the local level but we didn't think we had the numbers to be effective.  

So we left the site up and it kind of languished.  But a couple of months ago we started getting people signing up.  In an informal market study it appeared that there were two categories:  People disillusioned with the AMA and secondly, people concerned about how RID might effect their ability to make a living commercially in the future.  

The reason I'd be willing to start this up again has a lot to do with what @Spitfire76 posted about Flitetest.  What they have built has been totally organic without political or corporate motivation.  They have created a movement simply for the love of doing something.  Whether you love to fly as a hobby or professionally should not matter.  

There are far too many wannabe pundits online that don't love it.  They just want to make a name for themselves or support some ideology. 

I'm not interested in telling the FAA how to do their job, I'm interested in representing people who love to fly RC/UAVs to make sure that our right to do that is not infringed upon.  Maybe if we joined together we could create a PAC that would have enough members to influence the regulations to protect our evocation. 

I hope this is something you would be interested in helping with.

 

 

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On 1/4/2020 at 11:08 AM, 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.

Although I think you are close to the mark in that statement, but perhaps more accurate is the AMA's primary concern is supporting the AMA's revenue stream and continuity of director salaries.  Had they been just a little forward thinking those would have been assured had they chosen to support commercial sUAS and "drone" operators in general.  Doing so would have created a vastly larger representative body.

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It was so great to see Josh Bixler, the president of FLITETEST on this CES 2020 panel discussion. Although they don't get to talk about remote ID until the very end its worth watching the entire video. 

 

Edited by Spitfire76

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10 minutes ago, Dave Pitman said:

BTW, the AMA gal was pretty weak, IMHO.

I agree.  

I have not watched the whole thing yet by my impression of the first half is the women from DARTDrones and the AMA represent the old of way of thinking and I think Josh represents the future.  The other woman just represents the FAA...

When Josh speaks about FlightTest there's this sense of naïveté as compared to the other panelists.  It was interesting to watch their reactions when the interviewer mentioned his son was a fan and had shared flightTest videos with him. 

The real challenge for Josh will be can he keep his level of enthusiasm and wonder for RC after becoming a CBO and dealing with the likes of the AMA and the FAA.  Its clear from the first half that none of the other organizations the panelists represented did... 

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5 hours ago, Dave Pitman said:

BTW, the AMA gal was pretty weak, IMHO.

 

4 hours ago, Av8Chuck said:

I agree.  

Like most AMA members I pay $75/year (there are slightly lower fees for young and old) membership. Ok, it provides insurance and is mandatory for me to fly at a local RC club which I pay a further $120/year. I understand that they have around 200,000 members and so lets say the average fee for AMA membership is $60. That is an annual revenue of $12 million if my math is correct. Apart from buying stuff from FliteTest I don't pay anything but I feel like many others they seem to better represent all of the recreational hobbyist from young to old flying traditional RC planes or the latest drones than the AMA. I am interested in seeing what Josh can do with his recently established FliteTest Community Association and would be quite willing to pay for membership or volunteer my time to help out. 

Edited by Spitfire76

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Many groups over time loose those attributes that made them a good choice when they were younger.  Why it happens?  Probably a lot to do with human nature, I guess.  

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1 hour ago, Dave Pitman said:

Many groups over time loose those attributes that made them a good choice when they were younger.  Why it happens?  Probably a lot to do with human nature, I guess.  

I guess your right and I know that the AMA has been around for a long time and have done a great deal for the hobby in the past. Maybe they became somewhat complacent over the years since they were the only RC model association in the US. I also think that they realize that they have let their members down by failing to protect the hobby and are trying their best to correct the situation but it can only help things by having more representation with associations like Josh is establishing. If you notice he mentioned on that video they have 800,000 US youtube subscribers. That's 4 times the AMA membership. Ok maybe not all would be willing to pay for membership but even if it 2x or 3x that is still a lot more than the AMA.

I already have introduced my 2 year old grandson to the hobby by building him a chuck glider from FliteTest out of one sheet of Dollar Tree foam board. I hope to introduce him to build and fly more advanced aircraft as he gets older - FAA permitting!

 

Edited by Spitfire76

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On 1/8/2020 at 2:01 PM, Av8Chuck said:

It was founded on a simple premise that it wasn't up to the operator to prove that it was legal to operate commercially but the FAA to prove that it wasn't. 

That's a powerful statement.

On 1/8/2020 at 2:01 PM, Av8Chuck said:

I hope this is something you would be interested in helping with.

Really appreciate you sharing the backstory. Yah, interested in helping to push forward, keep me posted. We're putting together some talking points to help folks more effectively comment on the NPRM, will share those here when complete.

On 1/7/2020 at 12:12 PM, Jason Kovacs said:

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.

Yes, well said. You raised some really good implementation questions in your original post.

If we assume that 80% of the flights out there are already compliant under the existing Part 107 rules, LAANC airspace authorization and Waiver processes, I don't understand why there isn't more of an attempt in this NPRM to acknowledge that and to let those folks continue to fly without too many additional hurdles to jump through. I understand that we have to regulate for the other 20%, and to mitigate fears around counter UAS / drones showing up at airports and penitentiary systems, but when the overwhelming majority of both hobbyist and commercial drone operations are being conducted safely and responsibly each and every day, the proposed framework makes little sense on SO many levels.

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8 hours ago, Alan Perlman said:

don't understand why there isn't more of an attempt in this NPRM to acknowledge that and to let those folks continue to fly without too many additional hurdles to jump through.

Just some food for thought. I think your trying to make sense of these rules from a 107 perspective. 

This NPRM was highly influenced by people and organizations that are not interested in Part107 or hobbyists.  The FAA has been trying to implement user fees for decades, DJI, AirMap, UTM and RID is providing the technology to implement it and use it as an excuse to cover the additional expenses to justify it.  

Hobbyists and most of the low flying 107 are in the way.  Why do you think there was not true commercial representation on the DAC?

@Spitfire76 would you happen to know josh Bixlers email address?  Alan I would like to talk to you.  

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8 hours ago, Av8Chuck said:

@Spitfire76 would you happen to know josh Bixlers email address?  Alan I would like to talk to you.  

I don't have his direct email but these are the contact pages on FT websites.

https://www.flitetest.com/pages/contact-other

https://www.edgewaterairpark.com/contact/

Edited by Spitfire76

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It’s interesting how we all see this through our own prism.  The idea that everyone would own the airspace above their property to 200 feet would cripple this industry yet people who fly FPV think it’s what will save them from the RID rule.  As if all of a sudden they’ll be aloud to fly in parks etc..  

 

 

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45 minutes ago, Dave Pitman said:

I disagree with their policies often but agree this time.

Me too, but I agree with what I’ve read so far.  

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Here is the AMA's second podcast on the remote id NPRM. Don't bother with the first one as it seems that it was too early as they likely had not had a chance to fully digest it.

 

Edited by Spitfire76

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On 1/3/2020 at 9:24 AM, Isabella | UAV Coach said:

...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?...

In my experience with the FAA, their estimates on the financial impact on those regulated by a rule is way off the mark. They are required to put a financial impact justification in any proposed rule, but they are regulators not users and often don't understand the actual real world economic impact of what they propose.

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On 12/28/2019 at 9:58 AM, Dave Pitman said:

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?

AMA only wants people to fly at/with an AMA affiliated club site. Personally, I want nothing to do with a club. I got into flying helicopters and quads because I wanted to be able to fly in my own back yard, which I did for years. The government continues to make this harder and harder to do.

From what I've seen online, flying a UAV in Canada is even worse.

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Here is the lasted video from the Flite Test Community Association (FTCA) with their advice on how to comment on the FAA's proposed rule for remote ID.

 

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There was a special episode of the AMA podcast with an update on remote id.

https://www.modelaircraft.org/podcast

They are getting together with several manufacturers and retailers to form a Government Advocacy Coalition.

 https://www.modelaircraft.org/govcoalition

Also they and others had requested an extension to the public comment period but its been denied by the FAA so March 2 is still the deadline for public comment.

Edited by Spitfire76

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On 1/29/2020 at 7:34 AM, Spitfire76 said:

They are getting together with several manufacturers and retailers to form a Government Advocacy Coalition.

There idea of a coalition is for organizations to join the AMA and they would speak on behalf of their membership.  Adding more organizations to a voice that has already proven ineffective is pointless isn't it?

They're backhanded comments aimed at Flitetest and other non AMA members is a bit sophomoric. 

The AMA cannot seem to comprehend that they are part of the problem.  They are the ones who have divided the community that they now profess for unite.  

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And people wonder where dumb regulation take form, such as this new remote ID regulations? In my opinion (as much as it’s worth) there are lobbying going on from big buck businesses (such as amazon) to be able to break every rule imposed on those that want to make a few extra sheckles and have to get things like a 107 certification. Large companies will have ability to fly over crowds, and fly at night, all over the farce of calling it “necessary business practices” (ever wonder why a UPS truck can double and triple park, and totally block a road, doing what you would get a $5000 ticket for?). Business practices like this are nothing more than big business and their puppets in the government being able to kill off the little guy that won’t be able to afford the new fees or equipment needed to abide by such laws.  I can guarantee the first death from a drone falling out of the sky will come from these non restricted drone delivery services. JMO.

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Members are voicing concerns about the Proposed FAA Rule regarding drone usage and monitoring and the seemingly lack of awareness and interest in responding to the Rulemaking. I'm attaching a pdf document that I prepared and that hopefully will make followers of this forum better prepared to comment on the pro[posed Rule. Also, my hope is that the Guidance I prepared can be circulated to other websites, Forums and other venues where drone enthusiasts communicate.

Feel free to share, provide comments and discuss with others. As I observe in the Guidance article, this Rule as proposed will hinder the sue of drones, fail to achieve the goals set forth, and create burdensome costs to  everyone flying drones and model aircraft.

Guidance for providing Comments on Proposed FAA Drone Regulations_final.pdf

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