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Is your Controller FCC compliant?

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#1
Just a comment. I know everybody does it, but according to the FCC the end user is not allowed to modify the antenna on a Part 15 certified device. You can only use the antenna(s) used to certify the transmitter. Now, having said that, there is almost zero chance of getting caught. But I can absolutely guarantee you that if you ever end up in a legal case the opposing attorney will absolutely take note of it. Goes to a potential pattern of negligence. I've been an expert witness in a couple of RC hobby related cases and one of the first thangs asked is if the equipment was being used legally and without modification.

See Part 15.203

§15.203 Antenna requirement.
An intentional radiator shall be designed to ensure that no antenna other than that furnished by the responsible party shall be used with the device.
 
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#2
Just a comment. I know everybody does it, but according to the FCC the end user is not allowed to modify the antenna on a Part 15 certified device. You can only use the antenna(s) used to certify the transmitter. Now, having said that, there is almost zero chance of getting caught. But I can absolutely guarantee you that if you ever end up in a legal case the opposing attorney will absolutely take note of it. Goes to a potential pattern of negligence. I've been an expert witness in a couple of RC hobby related cases and one of the first thangs asked is if the equipment was being used legally and without modification.

See Part 15.203
Hi Phaedrus,
We are not changing the antenna or GPS of the Craft but merely moving them to a more productive position on the craft. all the ORIGINAL COMPONENTS stay the same but in a different position. It is an alteration not a modification of the equipment or introduction of new equipment. This is very interesting to know how this will be looked at, meaning LEGALLY. Johnno Hennessy
 
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#3
I was looking at the transmitter in the first post. Sorry, I can see how my comment was a little off topic. As far as moving antenna locations I cannot say. But shielding has no legal implications that I can think of. Just need to be extra careful with conductive copper and proximity to components on the PCBs.
 
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#4
Hi Phaedrus,
You must be looking at the 4 Hawks Range extender for the Hplus and all other UAV's. several companies make these for all UAV's and what you are saying is that if there should be an incident it is better not to have one of these on your Transmitter. By the way that is not me in the Photo but I have been chatting with RPR privately about an alteration that I do to shift the standard GPS to a better location.
So all these range extenders are illegal if they are not tested and PASSED by the FAA or similar body. This is only if an INCIDENT should occur. They sell a huge amount of these things, I have kept mine standard but can see why RPR has one for better reception at all times over the standard issue. This is very interesting, especially being in Australia, as we are the highest number of litigants per head of population in the world. Johnno Hennessy. Keep flying on the green side of the GRASS.
 
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#5
Yep. I know all that. Plus it does not matter if the new antenna has been tested, etc. And the FAA has nothing to do with it. Here in the US it is the FCC that does those things. And the antenna needs to be the one that was installed at the time the unit was certified. What matters is Part 15.203 which clearly states you cannot change an antenna to one that was not used at the time the original device was certified. The fact that people sell them is immaterial.

As I said, first you would need to get caught, which is a low probability is where the real liability is at. But again, that is also (hopefully) a low probability event. I am always a bit amused by the angst we show wondering if we (in the US) are complying with FAA regulations, but then give not a moment's thought to the FCC regulations.

I post these things mostly to make people aware. No judgement involved. And it can be argued that many such modifications can help increase safety by making the connection more robust.
 
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#6
I am with you all the way, everybody thinks just because Carolina Drones sells a product it must be OK. Well as you have just pointed out it is not STRICTLY OK by the interpretation of the LAW. We should have these things bought to our attention more often and for that, I thank you and the enlightenment of our fellow fliers. Please keep posting them as we all need to be informed of our responsibilities and safe flying. Thanks, Johnno Hennessy
 
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#7
That is in line with the fact that range extenders which are clearly sold with the intention of allowing BVLOS operation are commonly sold despite the fact that all hobby pilots and most Part 107 (US Commercial) pilots are prohibited from flying BVLOS.
 
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#8
Antenna range extender/ the FAA.

The intended use is to achieve a better signal in an rf-noisy environment, rather than fly the thing beyond VLOS. Pretty much every electrical device needs to pass a FCC certification test to make sure it is within the limits of spurious emissions and will not interfere with other technology that is in the same frequency range or any harmonic of that frequency. I think even my new toaster has a FCC certified label on it. I doubt that "Larry, Curly, and Moe's range modification" posses these certificates that being said, I dont think you will ever get into trouble using amplification can increase range, but more importantly it can make for a MUCH more stable connection at short range in a RF noisy environment. The regulation states that the replacement antenna, must exhibit the same in-band and out of band ERP and must be permanently connected or utilize a proprietary connector. If the FCC was actively pursuing "pirates", they would be monitoring buyers of household range extending antennas that attach to wifi routers, with standard connectors for external antennas.

The FAA BVLOS. The ability to fly drones Beyond the Visual Line of Sight (BVLOS) represents the next big opportunity for commercial drone operators. Most commercial drone applications would benefits from BVLOS to operate more efficiently and cost-effectively, and some applications would remain impossible to execute without BVLOS. At the moment, no one is allowed to fly BVLOS in U.S. airspace without obtaining a special waiver from the FAA. My clients such as Lennar, INOVA, Mortenson, PG&E are able to get such waiver, but for the BVLOS to be effective the PIC has to have a VO for the operation to successful and if not... There are consequences. Clauses in the waiver are tailored to the needs of the client(s) and in my case, my drones are limited to 3k LAT and follow the FAA ALT. under the safety code and if flying 3 miles away from an airport, I have to check NOTAMS and communicate with tower...... and again the PIC "MUST" have a VO.

What is interesting about @John Hennessy modification is that it is a mere relocation and my simple mod. is that is legal if met/pass the safety foreman's inspection noted in a clause of my waiver, and my simple mode passed the inspection and has provided a report, even for this simple mod.
 
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#9
Antenna range extender/ the FAA.

The intended use is to achieve a better signal in an rf-noisy environment, rather than fly the thing beyond VLOS.
Certainly that is one reason. But again, how many videos do you see posted saying "look at my great flight in a high RF environment" versus "look at my 5 mile out and back flight"? But the intended use is irrelevant. The plain fact is the FCC, not the FAA, NTSB or anyone else, prohibits changing the antenna on a Part 15 certified device. Internal modifications like adding shielding are not an issue. Relocating the antenna in the aircraft probably not an issue. But removing the antenna(s) the the main transmitter was certified with and replacing it with anything else, not ok according to the FCC. Part 15.203 again for reference. Just like the FCC has nothing to say about how you fly, the FAA has nothing to say about the certification and use of the radio equipment used to operate the aircraft.

And again, this is all FYI. In all probability the FCC will never catch you. And if you never get involved in any kind of legal liability case you will have very little to worry about with respect to the antennas.

But FWIW, here's a blurb from an antenna advertisement:

Unit now has improved third port for maximum distance and video quality.
Others specifically say they are intended to extend the range, up to 4 times in some cases. For the Yuneec Typhoon H+ that would mean 4 miles versus 1 mile. Emphasis is clearly on increasing range. Signal quality is a secondary advantage.

It is ironic to me that we will often twist ourselves into knots trying to figure out if we are operating legally with respect to the FAA, but most never give a moments notice to what is legal in the eyes of the FCC, an agency that actually does go after people.

Orders
 

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#10
So, @Phaedrus would not intent, as RPR has pointed out, play into the legal interpretations of whether specific laws were violated? If the incident was in fact close quarters, such as the conditions RPR flies in... as opposed to an incident involving, say the 3 mile BVLOS scenario?
 
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#11
@Phaedrus I agree with you fully. The FAA is aware of antenna extenders. The FAA considers extenders as safe to use “IF” it aids the safe during sUAS operation.

Reverting to my experience in Las Vegas, Nevada where the pit is close to the airport, during inspection the YUNEEC typhoon H+ passed the inspection as well as the controller, with 4hawks extender was cleared.

I have other drones before my H+, with extended antennas and they too has passed the FAA and worksite safety inspection.

I don’t do a lot of personal flying, therefore, I cannot share any knowledge pertaining to the rules and regulations outside of work.
 
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#12
@Phaedrus I agree with you fully. The FAA is aware of antenna extenders. The FAA considers extenders as safe to use “IF” it aids the safe during sUAS operation.
I guess I am not making myself clear. It does not matter what the FAA, or anyone else other than the FCC, thinks relative to the antenna. It is the FCC that specifically prohibits changing the antenna from the one used to certify the device.

Not sure what else to say. Part 15.203 is crystal clear. Also see Part 15.204.
 
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#13
I guess I am not making myself clear. It does not matter what the FAA, or anyone else other than the FCC, thinks relative to the antenna. It is the FCC that specifically prohibits changing the antenna from the one used to certify the device.

Not sure what else to say. Part 15.203 is crystal clear. Also see Part 15.204.
We can police this all day.. If it is deemed safe for work, then it is safe for work. And if theoretically illegal and unsafe, what is the next step?
 
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#14
We can police this all day.. If it is deemed safe for work, then it is safe for work. And if theoretically illegal and unsafe, what is the next step?
It is not "theoretically" illegal. It is clearly and specifically illegal. Which almost everybody chooses to ignore. Which is fine. Just passing along information. People are free to do what they wish to do. It just amazes me that people will so willingly ignore FCC regulations.
 
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#15
It is not "theoretically" illegal. It is clearly and specifically illegal. Which almost everybody chooses to ignore. Which is fine. Just passing along information. People are free to do what they wish to do. It just amazes me that people will so willingly ignore FCC regulations.
Not a whole lot really knows about the FCC and I only know that I need to know on how to avoid getting into trouble.
 
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#16
The topic of antennas and the FCC introduced by Phaedrus is one well worth creating a new thread for and moving the applicable posts to it for educational purposes. His understanding of FCC regulations, and who enforces them, is correct and apparently many don’t understand the distinctions between the FAA, FCC, and how advertising terminology would be used to separate fact from fiction in a court of law.
 
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#17
So, @Phaedrus would not intent, as RPR has pointed out, play into the legal interpretations of whether specific laws were violated? If the incident was in fact close quarters, such as the conditions RPR flies in... as opposed to an incident involving, say the 3 mile BVLOS scenario?
Intent has nothing to do with it. Read Part 15.203. Nothing about intent there. You are either in compliance or you are not. Changing antennas from the one used to certify the device places you outside compliance.
 
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#18
Antenna range extender/ the FAA.

The intended use is to achieve a better signal in an rf-noisy environment, rather than fly the thing beyond VLOS.
I’ll be among the first to debate that statement as it was developed by the DJI team to deflect and obfuscate the clear and plainly marked advertising of their products declaring long or extended range to obtain a market advantage and increase sales. Had DJI not developed and marketed long range systems they would not have become the market leader they are today. Prior to providing long range systems their products were pretty much ho-hum in performance and fell well behind Ardu based and Mikrokopter systems in performance capability. Initial DJI f450 and f550 systems, Wookong and Naza among them, used after market cameras, after market gimbals with later early DJI brand cameras and gimbals being low in performance. Finding video components that would even be compatible with DJI stuff was often a problem. They also set records for loss of aircraft control and fly aways. Only their advertising of, and providing multi mile range kept them in the game long enough to create more advanced camera systems.

It was only after DJI was publicly challenged for actively promoting general public illegal BLOS flights through promotion of multi mile systems that the “qualifier” of improved rf signal was tossed out there. In any court case where the operator of an aircraft was found to be conducting their activities well beyond visual range the plaintiff only needs to provide copies of DJI’s advertising and a box the product was sold in for conclusive evidence of intent of both the user and the manufacturer.

As there are alternative devices that provide video transmission and reception having extremely good reliability that are limited to only a couple thousand feet, requiring an amplifier to obtain longer range, there is little or no defense to be had in stating a more powerful rf transmission signal is necessary for safety. Using the “safety” argument to defend a long range system is but a weak, defensive smokescreen. If users were not provided long range systems, or easy access to devices that can extend range, they would be far less prone to using them at long range. A jury would probably be very quick to agree.

As for the FAA inspecting an aircraft and approving it for use, they only inspect to assure an aircraft meets FAA regulatory compliance. As there are few or no FAA equipment specifications pertaining to the certification of drones they cannot enforce FAA regulations that as yet do not exist. Whatever we use on a drone is not subject to an FAA inspection at this moment in time. However, the FCC does have authority in this area and use of equipment that violates FCC regulations would put the user at fault for use of illegal equipment should the user end up in a liability/fault case. With full scale certificated aircraft they can ground aircraft for non compliant communication systems as there are FAA regulations that specifically define such components, with associated FAA, PMA, and STC certification requirements to back stop compliance. Any device failing to meet FAA certification or operability standards is cause to ground the aircraft.h
 
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#19
However, the FCC does have authority in this area and use of equipment that violates FCC regulations would put the user at fault for use of illegal equipment should the user end up in a liability/fault case.
Basically the point I have been trying to make. I think 99%+ of sUAS pilots have no idea about the FCC regulations and how they impact our flying. They assume, wrongly, that if something is for sale then it is legal to use. follows on to the point about DJI, etc. advertising their range capabilities despite the fact that BVLOS operations are not legal for most all of us.

Ultimately we are all responsible for knowing all the rules that apply to us. If we choose to ignore them then we need to be ready to bear the consequences, which may, or may not, ever come to pass.
 
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#20
The way FCC penalties work can be very draconian. In the past they have been able to seize any and all equipment and/or structures that were employed to enable use of illegally operated radio frequency broadcasting. There have been cases entire homes were forfeited because antennas were attached to them.

As things currently stand we are getting away with it because nobody with political or monetary power is complaining, and there have only been a couple of BLOS incidents that have generated significant alarm. We should not expect the current permissiveness to continue. I suspect when the NTSB completes and publishes their report for the Long Island Blackhawk/Phantom incident the ensuing publicity will force a rapid change in FCC enforcement policies. The FAA won’t get involved until the corporate aerospace BLOS players get the rules they are developing made law. Included in those are equipment certification requirements which will provide the FAA enforcement capability. At that point they will begin to leverage the FAA and other government entities to severely limit the range of common citizen level drones to prevent business competition. Public safety to prevent mid air collisions between drones will be the soap box they will stand on. Local LEA’s will add “friend of the court” support as they currently are flying drones at the same levels and in the same areas we do, and as most of them have acquired CoA’s, some with drone manufacturer assistance, they have stronger legal standing than we do.
 
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