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Remote Identification of Unmanned Aircraft Systems

PatR

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We cannot see any resolution to this mess unless the FAA, AOPA. and ALPA agree to a 500’ hard deck for manned aviation. That includes helicopters. The uneducated like to think manned aircraft has a 500’ AGL lower limit but they most certainly do not. That only applies around structures and semi inhabited areas. In unpopulated areas they can fly inches off the ground.

What is taking place has unmanned systems shouldering 100% of the load for airspace safety. Absolutely no concessions are being made by manned aviation.
 
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We cannot see any resolution to this mess unless the FAA, AOPA. and ALPA agree to a 500’ hard deck for manned aviation. That includes helicopters. The uneducated like to think manned aircraft has a 500’ AGL lower limit but they most certainly do not. That only applies around structures and semi inhabited areas. In unpopulated areas they can fly inches off the ground.

What is taking place has unmanned systems shouldering 100% of the load for airspace safety. Absolutely no concessions are being made by manned aviation.
"In aviation (particularly in air navigation), lowest safe altitude (LSALT) is an altitude that is at least 500 feet above any obstacle or terrain within a defined safety buffer region around a particular route that a pilot might fly."

What is a "defined safety buffer region"? I understand taking off and landing, but we regularly have to watch out for single engines at 200-300ft!
 

PatR

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Might want to read a bit more of those regulations pertaining to unpopulated areas. You can’t fly any lower than what is required to make a safe landing should a power unit fail. If you’ve got the speed needed to trade for altitude when a power unit fails that means your aircraft just has to remain clear of the ground or surface.
 
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Might want to read a bit more of those regulations pertaining to unpopulated areas. You can’t fly any lower than what is required to make a safe landing should a power unit fail. If you’ve got the speed needed to trade for altitude when a power unit fails that means your aircraft just has to remain clear of the ground or surface.
I'm guessing this is where that came from?

§ 91.119 Minimum safe altitudes: General.
Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface.

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation is conducted without hazard to persons or property on the surface -

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA; and

(2) A powered parachute or weight-shift-control aircraft may be operated at less than the minimums prescribed in paragraph (c) of this section.

[Doc. No. 18334, 54 FR 34294, Aug. 18, 1989, as amended by Amdt. 91-311, 75 FR 5223, Feb. 1, 2010]
 

PatR

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Makes it pretty clear that a 500’ minimum altitude is not applicable everywhere. Even that 500’ separation in uncongested areas is not an altitude separation, it’s a distance separation, which could be a height, lateral, or tangent.

I used to teach that stuff...
 
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I'm not sure why you keep answering like we're having a debate. I am obviously asking questions to understand this. Especially since you're an expert... I will say however that since we are on a UAV forum that the majority of people are most likely talking AGL and as (c) states "altitude of 500 feet above surface" then i'm not quite sure what the problem is. When several different pilots fly 300ft AGL over our construction sites for no apparent reason and no airport within 5 miles then I think that's not good.
 

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I read your earlier reply as one being more statement of fact instead of a question. Had there been a question mark instead of a period I would have understood it was a quest for clarification.

Pilots violate the law all the time, and like most everyone else deny it. Unlike highways where we can get tagged by radar, a traffic cop, or a speed camera there’s bot a lot to go on to catch the manned aviator. To pull an ATC tape you need a hull number to reference for s time/position check. Hill numbers are rarely observed with aircraft in flight. Worse, witness altitude estimates ate ALWAYS grossly inaccurate unless a plane passes them at head height. So manned aviators rarely get caught.

Yes, this is an sUAS/UAV forum but when the FAA declared us “pilots” we lost much of the differentiation that separated us from manned.aviation. Therein lies the problem; we are being treated differently from manned aviation while having to abide by special and extremely limiting drone regulations in addition to manned regulations and manned aviation without benefit of the same airspace access.

Worse, we are being held 100% responsible for assuring manned aviation’s safety when manned and unmanned share airspace. If a manned aircraft is flying low, too low, even if in violation of the regulations, and they hit a drone 20’ off the ground it is OUR fault.

So unmanned people are in a crappy spot, we have to learn all the manned aviation rules without gaining the benefits of manned aviation. Manned aviation is insulated from our rules as we are responsible for separation from them. They have no legal responsibilities in this regard. We even get stuck with paying for a new, for profit, ATC system not yet in existence through a monthly access/service fee. If we don’t happen to live in an area with high cell tower density we get to spend a bunch more money on special transmission equipment. At the moment that equipment is made by Iridium. It’s not affordable.
 
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I read your earlier reply as one being more statement of fact instead of a question. Had there been a question mark instead of a period I would have understood it was a quest for clarification.

Pilots violate the law all the time, and like most everyone else deny it. Unlike highways where we can get tagged by radar, a traffic cop, or a speed camera there’s bot a lot to go on to catch the manned aviator. To pull an ATC tape you need a hull number to reference for s time/position check. Hill numbers are rarely observed with aircraft in flight. Worse, witness altitude estimates ate ALWAYS grossly inaccurate unless a plane passes them at head height. So manned aviators rarely get caught.

Yes, this is an sUAS/UAV forum but when the FAA declared us “pilots” we lost much of the differentiation that separated us from manned.aviation. Therein lies the problem; we are being treated differently from manned aviation while having to abide by special and extremely limiting drone regulations in addition to manned regulations and manned aviation without benefit of the same airspace access.

Worse, we are being held 100% responsible for assuring manned aviation’s safety when manned and unmanned share airspace. If a manned aircraft is flying low, too low, even if in violation of the regulations, and they hit a drone 20’ off the ground it is OUR fault.

So unmanned people are in a crappy spot, we have to learn all the manned aviation rules without gaining the benefits of manned aviation. We even get stuck with paying for a new, for profit, ATC system not yet in existence through a monthly access/service fee. If we don’t happen to live in an area with high cell tower density we get to spend a bunch more money on special transmission equipment. At the moment that equipment is made by Iridium. It’s not affordable.
If your talking about the beginning of post #102 then there were quotes because those weren't my words. From the FAA.
Regardless I don't know anything about manned which I s why I asked. We're lucky to have someone so knowledgeable.
 

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Thanks, but you’re not necessarily lucky. You get to find out the rules assigned sUAS are not all we need to know. In ways we have to know our rules and “their” rules. We no longer have any choices in the matter. For some very dry reading, dig into FAR Part 91. Toss in most of the Airman’s Information Manual. Consider anything noted as “advisory” or “suggested” to be regulatory.
 
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here is a part on another comment I made to the nprm
While I support the FAA and their efforts to ensure a near absolute safe environment for national air space. I do welcome realistic and reasonable methods to Identify uas in the growing of the uas population in the coming years. As of now I do believe 400 AGL is appropriate flight level mark.With man aircraft low level mark at 500 AGL which gives 100 ft separation

With that be said I do have concerns. For aircraft with remote id the remote id must not hinder in anyway of the following. 1st the entire air space under FAA jurisdiction normal for UAS Minus any and all prohibited areas and or any TFR for man and Uas flights. That airspace must be made without any obstruction in any way shape or form be made available for Legal Uas operators both recreational and commercial. 2ND financial and or other burdens to comply must be minimalized to the greatest extent possible. 3rd There must be means to ensure full compliance and those who fly rouge must be held fully accountable. 4th In current form this will have massive pilot safety issues with some general public folks will harass (verbal or with weapons knives or firearms) or use law enforcement to needlessly harass legal flying pilots who are fully with in the laws. Changes must be made to protect pilots from harm. As the unmanned aircraft as been defined as actual aircraft
not as a toy or a model of a aircraft. The following suggestions are being presented for the 4th concern. 1st shooting at or downing of (in any method) a LEGAL FLIGHT uav that is in the air or on the ground needs to have severe civil and criminal penalties attached that are actually enforced and prosecuted. 2nd Interfering with a LEGAL FLIGHT uav operation also must have severe civil and or criminal penalties that are actually enforced. 3rd If civilian for federal law enforcement agents and other official security personnel (such as state for federal park rangers) are to help the FAA enforce Unmanned Air System regulations they must be fully professionally trained and certified on the all the laws regarding the use of Unmanned aircraft systems.

The 400ft AGL limit for flights I mentioned before was pre remote id. With remote Id enabled I would like to make a few requests. 1st request increase the flight AGL to 200 ft from the floor of controlled E airspace outside of controlled airspace of airports. 2nd increase distance flying from ground station from 400ft to 1000ft in a sparsely populated area (farm field or other low population area). if limited remote id must be had. 3rd CBO such as AMA can have new fixed flight sites approved beyond proposed 12 month period after rules takes effect. 4th CBO such as AMA can request waivers that can be granted easily to hold contest or challenges at areas that more suitable for the events than at the existing fixed flight site. 5th to enable request 1 require abd-s in (not adb-s out) module for remote pilots to track and have a heads up advantage for manned flights near them that is not In visual range of the ground station site that will flyover where they are at so they can move the unmanned aircraft out of the way. before the man aircraft comes into visual sight.
I'm glad to see that you submitted well thought-out comments.

I will be submitting my comments very soon. One of the things I'm commenting on is the extremely wide weight range of these regulations. I'm suggesting that larger/heavier UAS comply with the standard remote ID rules (internet and all) and smaller/lighter UAS only comply with the local broadcast remote ID rule. I'm suggesting that small UAS are those weighing less than 2 kg (4.4 lbs). This will cover almost all consumer drones.

Attached is a draft copy for your comment. Be sure to look at page 2 to see how absurd it is to lump all UAS weighting from 0.55 to 55 lbs. into one category.
 

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I have made contact with yuneec to see what there take is on the faa nprm. they replied they sent my questions to head production team management and they said when they have further info they relay it to me.
 
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I have made contact with yuneec to see what there take is on the faa nprm. they replied they sent my questions to head production team management and they said when they have further info they relay it to me.
When is a short word, that can mean a long time or never, especially where Yuneec are concerned.
 
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heads up I just got a copy of ansi cta2063 standard for serial numbers mandated to be used with remote id. a compliant serial number is 4 character alphanumeric code for manufacturer then followed by length code that is a signal alpha character corresponds to number of characters in the serial number in the physical serial number range is from a to t then comes the serial number from the manufacture of the uas. here the fun part serial number for the aircraft we have now can not be updated to the new serial numbers those are for new aircraft only .yuneec serial numbers are not compliant with ansi cta2063
 
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Actually there may be a easy path way for yuneec to be remote id ready. It going to require integrating two parts one Sky Drone 4G/LTE Upgrade for Yuneec H520 integrated into the h520 air frame. second is Mobilicom Yuneec H520 SkyHopper LTE for the controller. and with correct serial number format as required by the nprm plus a few minor mods to the two parts mention above and you have a standard remote id yuneec uav.
 
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Actually there may be a easy path way for yuneec to be remote id ready. It going to require integrating two parts one Sky Drone 4G/LTE Upgrade for Yuneec H520 integrated into the h520 air frame. second is Mobilicom Yuneec H520 SkyHopper LTE for the controller. and with correct serial number format as required by the nprm plus a few minor mods to the two parts mention above and you have a standard remote id yuneec uav.
It says join the list and nearly a year ago. Has the controller ever been launched? Personally I thought support from third parties for Yuneec was dying.
 

PatR

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AOPA’s NPRM Response;


 
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just got confirmation from sky hopper it is released and is for sale on there web site only for now. they stated they have h520 users in the usa now.
Hi Terrence,

thanks for your mail.
The product is already available and on stock when purchasing directly from our web store (Sky Drone 4G/LTE Upgrade for Yuneec H520)

US based resellers do not have it yet, as it has not finished the certification process yet.
This might still take a few months.

That said, we have US customers using it as we speak. If you want to use it now, you can purchase it on our web store or you might want to wait for finished certification and can probably purchase it through Vertigo Drones and other US based outlets.

Regards

Pete
 
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AOPA’s NPRM Response;
Thanks for posting this, Pat. I agree with much of their comments. I encourage everyone in the consumer/commercial drone community to send their comments to the FAA in the form of respectful concerns and constructive alternatives. Deadline is less than a month from now.
 

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