Remote Identification of Unmanned Aircraft Systems
- Thread starter Steve Carr
- Start date
Thanks for posting this!
It is quite obvious that this whole debacle revolves around the commercial drone delivery industry. I still fail to see why anyone is for this. The only billions being made by it will be the Amazon, UPS, FedEx, etc. and will be putting gainfully employed people out of work. As far as other types of delivery such as fast food, they can’t even get my order right half of the time when I use the drive thru, I sure as heck don’t trust them to fly a drone BVLOS to my house.
Oh I forgot! The other billions of dollars will be reaped by the communications industry charging us for data plans to fly as well as the USS’s we’ll have to subscribe to. Yep the ones that were in on all of the planning like AirMap and KittyHawk.
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PatR
Premium Pilot
You also have the “total surveillance” side of this to consider. We harp about the way China monitors their citizens but statistically we (the U.S.) are but marginally behind China in the number of surveillance cameras per capita. Toss in the surge in images being collected for facial recognition purposes, license plate readers, etc., and you end up with a population monitored in almost everything they do.
Information is power and when you have enough info to accurately predict what people do, where, and when, you can have control. Control is almost the ultimate power.
Information is power and when you have enough info to accurately predict what people do, where, and when, you can have control. Control is almost the ultimate power.
If you don't have reliable internet, none of this will work. Thus those of us here in Northeastern Montana, will not be able to fly at all. There aren't any CBO areas here, and, as far as I know no plans for one. This is why this whole thing is flat out bad from the get go. I will be sending my comments against this rule as currently written.
When those two are worried about the outcome I would hope many start preparing their comments before March 1st. If this actually goes through and very possible can if not enough respond then forums like this might as well change the name to "Yuneec BBQ forum" as we will have nothing to talk about LOL
PatR
Premium Pilot
I can't repeat enough all this was planned a long time ago. To understand how and why it is coming about all we have to do is run a search to find the membership of the FAA's Drone Advisory Committee. Those are the people and companies that have been advising the FAA rule making committees.
https://www.faa.gov/uas/programs_pa...ory_committee/media/DAC_Membership_Roster.pdf
https://www.faa.gov/uas/programs_pa...ory_committee/media/DAC_Membership_Roster.pdf
We are in deep kimchi:
Gur Kimchi, Co-Founder and Vice President, Amazon Prime Air
This explains why ADS-B is out and internet is in:
Christopher Penrose, Senior Vice President of Emerging Devices, President of Internet of Things, AT&T (you already get enough of my money each month for your less than stellar, spotty cellular coverage, and your landlines are over fifty years old in my area)
Mariah Scott, President, Skyward (a Verizon company)
Brendan Schulman, Vice President of Policy and Legal Affairs, DJI Technology
This helps explain the reactionary press:
Greg Agvent, Senior Director of National News Technology, CNN
Todd Graetz, Director, Technology Services, UAS Program, BNSF Railway
What is a railway employee doing on a UAS advisory committee? Oh! They can’t have anyone else flying near their rails so they can inspect the rails BVLOS and lay-off employees that do that on the ground. Are you ready for more train derailments because the cameras didn’t catch what a ground based inspector would have seen?
Gur Kimchi, Co-Founder and Vice President, Amazon Prime Air
This explains why ADS-B is out and internet is in:
Christopher Penrose, Senior Vice President of Emerging Devices, President of Internet of Things, AT&T (you already get enough of my money each month for your less than stellar, spotty cellular coverage, and your landlines are over fifty years old in my area)
Mariah Scott, President, Skyward (a Verizon company)
Brendan Schulman, Vice President of Policy and Legal Affairs, DJI Technology
This helps explain the reactionary press:
Greg Agvent, Senior Director of National News Technology, CNN
Todd Graetz, Director, Technology Services, UAS Program, BNSF Railway
What is a railway employee doing on a UAS advisory committee? Oh! They can’t have anyone else flying near their rails so they can inspect the rails BVLOS and lay-off employees that do that on the ground. Are you ready for more train derailments because the cameras didn’t catch what a ground based inspector would have seen?
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ADS-B Out Explained
ADS-B is business jet technology that will eventually replace radar as the primary method for Air Traffic Control (ATC) monitoring and separation of aircraft worldwide.
txtav.com
I have not been keeping up on whats happening on your side of the pond but is this not going to be applied in Europe in July 2020 ?
This is just a copy and paste By Gary Mortimer from suasnews. Interesting how he feels all this fuss with remote ID for those companies wanting a share of the airspace for their own will fail anyways.
"There will be several big drone fails before 2030 arrives. All stuff currently touted as the next big wave by folks wanting to make some easy money.
Flying Cars, or Urban Air Mobility (UAM) and drone delivery to the home. Neither will make any financial sense.
Several UTMs will not make it out of 2022, most of them are BSware that rely on lobbying for bits and bobs that they want to monetize. They are burning through VC funding at an unsustainable rate that won’t survive much more of a delay to remote ID.
All of this UTM airspace lobbying is having very intended consequences. Amazon is busy removing the freedoms of model aircraft fliers worldwide to make sure they have a clear airspace run to failure.
I am not sure the hobby will ever see the freedoms put back once they have been removed.
Having said drone delivery will fail, three drone delivery airframes are the ones I am paying attention to.
They are operating in a niche that Amazon and Google don’t want to play.
Humanitarian and medical deliveries in hard to reach places."
"There will be several big drone fails before 2030 arrives. All stuff currently touted as the next big wave by folks wanting to make some easy money.
Flying Cars, or Urban Air Mobility (UAM) and drone delivery to the home. Neither will make any financial sense.
Several UTMs will not make it out of 2022, most of them are BSware that rely on lobbying for bits and bobs that they want to monetize. They are burning through VC funding at an unsustainable rate that won’t survive much more of a delay to remote ID.
All of this UTM airspace lobbying is having very intended consequences. Amazon is busy removing the freedoms of model aircraft fliers worldwide to make sure they have a clear airspace run to failure.
I am not sure the hobby will ever see the freedoms put back once they have been removed.
Having said drone delivery will fail, three drone delivery airframes are the ones I am paying attention to.
They are operating in a niche that Amazon and Google don’t want to play.
Humanitarian and medical deliveries in hard to reach places."
“Humanitarian and medical deliveries in hard to reach places."
I wholeheartedly agree with this type of delivery system. But it should be integrated into the airspace from 500 to 700 feet AGL and require Transponder capability so it is tracked by ATC and manned aircraft.
I wholeheartedly agree with this type of delivery system. But it should be integrated into the airspace from 500 to 700 feet AGL and require Transponder capability so it is tracked by ATC and manned aircraft.
What about Africa.South America,India. Russia etc etc?ADS-B Out Explained
ADS-B is business jet technology that will eventually replace radar as the primary method for Air Traffic Control (ATC) monitoring and separation of aircraft worldwide.
Our PM wants out of everything EU, no alignment with any EU regulations, he wants to leave EASA and negotiate similar to other non EU block countries, I suspect something will happen, but these things will take time, I don't think they've thought it through.
PatR
Premium Pilot
The problem with that is that transponders are essentially fead after 2020, ADS-B on a couple different frequencies is being incorporated worldwide. Next we have to navigate through the allowances, prohibitions, approvals, and conditions for the use of either transponders or ADS-B as written in the RID proposal.
As for BNSF being on the DAC, they, in combination with Insitu/Boeing, along with at least one other drone provider, have been doing a lot of railway inspection trials. They started on that back around 2014 using Insitu’s Scan Eagle to fly somewhere between 30-70 miles of tracks in Arizona or New Mexico.
Without specifically saying who said what, internal conversations I had in 2014 with a couple people directly involved with the DAC and an FAA advisory group plainly stated that recreational RC would have to be sacrificed in order to integrate commercial BVLOS drone operations into U.S. airspace.
Commercial Drone Alliance responds to the FAA’s Remote ID proposal
Remote ID Proposal Outlaws Home-built RC Aircraft
PATRICK MCKAY·MONDAY, DECEMBER 30, 2019·
I want to clear up a myth about the FAA's proposed remote ID rules that I've been seeing floating around. People think that amateur home-built model aircraft will be largely unaffected by this, since they can just fly at AMA fields. Or people think that to build and fly model aircraft outside of AMA fields, all they would have to do is slap some kind of transponder on their model and they are good to go. This is completely wrong. This proposal will effectively outlaw home-built model aircraft as most people actually build them.
The reason for this is the production standards. The proposal contains two completely different types of rules: operational rules and production rules. The operational rules allow UAS without remote ID to be flown at a FRIA site. The production standards prohibit anyone from producing a UAS that does not comply with the remote ID rules, regardless of whether it is even flown. Just building a UAS for private use that does not comply with remote ID is a violation of the law, unless one qualifies for an exemption from the production rules.
Many people (including the AMA apparently) read that amateur-built models are exempt from the production requirements and think that means they're fine. However, the devil is in the details, which in this case is the definition of amateur-built, which "means an unmanned aircraft system the major portion of which has been fabricated and assembled by a person who undertook the construction project solely for their own education or recreation."
The FAA's proposal clarifies that this means more than 50% of the total components in the Unmanned Aircraft System (which includes the ground control station) must be fabricated and assembled by the hobbyist. Home-built models using mostly parts that are pre-fabricated and purchased separately are expressly excluded from this exemption:
UAS assembled completely from pre-fabricated parts. The FAA anticipates that some model aircraft enthusiasts may assemble UAS entirely from pre-fabricated parts and that commercial vendors may wish to sell UAS parts, including packages that contain more than 50 but less than 100 percent of the parts necessary to build a UAS. The resulting UAS would not qualify as amateur-built because the person building it would be fabricating and assembling 50 percent or less of the UAS. The UAS would not qualify as built from a kit because it did not include 100 percent of the necessary parts. Under these circumstances, the person assembling the UAS would be considered the producer and would be required to comply with the design and production requirements of proposed subpart F. (NPRM p. 152.)
We’ll leave aside the fact that the proposed regulation provides no way to quantify parts. Raw number of all components down to individual chips on circuit boards? Number of black-boxed components like receivers and flight controllers? Total mass? As currently written, the amateur-built exception to the production requirements would not apply to the vast majority of modelers.
Even assuming parts are quantified by black-boxed components, most amateur model aircraft would fall into the pre-fabricated, rather than amateur-built category, as most people assemble model aircraft from a collection of pre-fabricated parts they buy separately from various manufacturers. They might buy the airframe as a pre-cut styrofoam body (for planes) or carbon fiber sections (for quads), then glue/screw it together and mount and wire up motors, flight controllers, speed controllers, receivers, and cameras and video transmitters for FPV craft.
The most anyone ever fabricates themselves is the aircraft body. Nobody is fabricating their own receivers, speed controllers, lithium batteries, motors, or remote controllers, so virtually no model aircraft hobbyists would actually qualify for the amateur-built exception which requires more than 50% of parts (however that is quantified) to be fabricated and assembled by the builder.
The vast majority of RC hobbyists would fall under the category of using more than 50% prefabricated parts that do not come as a single kit with 100% of the parts necessary to fly. The proposed regulation would treat such modelers as UAS producers, and would require them to comply with all the production standards to produce and certify a UAS as RID compliant. This process is long and convoluted, and is clearly contemplated to only be used by large corporations developing mass produced UAS to be sold to consumers (the proposal estimates this process would only ever be used by a few hundred corporate entities).
Let’s assume a hobbyist could even comply with the technical requirements to equip a model with remote ID (doubtful given the tamper-resistant requirement which would at minimum prohibit the use of open source flight controllers and could be interpreted to require the person who built the model to somehow prevent himself from bypassing the remote ID system). The certification process requires the purchase of multiple standards that could cost hundreds of dollars to even read, and the filing of extensive forms and reports with the FAA that is estimated to exceed over 50 pages and take hundreds of man hours to produce. It would be completely impossible for any individual hobbyist to comply with these procedures for their home-built model aircraft.
Thus as written in the currently proposal, building your own home-built model aircraft the way the vast majority of hobbyists actually do that would be illegal. It doesn’t matter where you fly them, or even if you fly them at all. Merely building a UAS without equipping it with remote ID and following the process to certify it with the FAA would be an independent violation of the law. It goes without saying that this would be completely unenforceable, but that’s not the point.
Legally at least, this proposal will completely outlaw home-built RC model aircraft as they are actually made by hobbyists. The FAA attempted to disguise this by putting in the amateur-built exemption, and then defining it in such a way as it will be impossible to actually qualify for. I fully expect the AMA to fall for this trick and act like everything is fine because of the amateur-built exemption and the FRIA sites, because they have always sucked at statutory interpretation and anticipating how regulations affecting model aircraft will actually be applied (Sec. 336 anyone?). That’s even without considering that the FRIA exemption for AMA fields is only intended to be temporary and will be phased out over time, leaving hobbyists with nowhere to fly where they are not subject to the operational remote ID requirements.
No matter what the AMA says, this regulation will be the death of amateur home-built model aircraft, period. It doesn’t matter if it’s a quadcopter or traditional RC plane, flown by an AMA member or not. We’re all affected by this equally, and all RC hobbyists have a duty to oppose this regulation wholesale as bringing about the extinction of our hobby.
PATRICK MCKAY·MONDAY, DECEMBER 30, 2019·
I want to clear up a myth about the FAA's proposed remote ID rules that I've been seeing floating around. People think that amateur home-built model aircraft will be largely unaffected by this, since they can just fly at AMA fields. Or people think that to build and fly model aircraft outside of AMA fields, all they would have to do is slap some kind of transponder on their model and they are good to go. This is completely wrong. This proposal will effectively outlaw home-built model aircraft as most people actually build them.
The reason for this is the production standards. The proposal contains two completely different types of rules: operational rules and production rules. The operational rules allow UAS without remote ID to be flown at a FRIA site. The production standards prohibit anyone from producing a UAS that does not comply with the remote ID rules, regardless of whether it is even flown. Just building a UAS for private use that does not comply with remote ID is a violation of the law, unless one qualifies for an exemption from the production rules.
Many people (including the AMA apparently) read that amateur-built models are exempt from the production requirements and think that means they're fine. However, the devil is in the details, which in this case is the definition of amateur-built, which "means an unmanned aircraft system the major portion of which has been fabricated and assembled by a person who undertook the construction project solely for their own education or recreation."
The FAA's proposal clarifies that this means more than 50% of the total components in the Unmanned Aircraft System (which includes the ground control station) must be fabricated and assembled by the hobbyist. Home-built models using mostly parts that are pre-fabricated and purchased separately are expressly excluded from this exemption:
UAS assembled completely from pre-fabricated parts. The FAA anticipates that some model aircraft enthusiasts may assemble UAS entirely from pre-fabricated parts and that commercial vendors may wish to sell UAS parts, including packages that contain more than 50 but less than 100 percent of the parts necessary to build a UAS. The resulting UAS would not qualify as amateur-built because the person building it would be fabricating and assembling 50 percent or less of the UAS. The UAS would not qualify as built from a kit because it did not include 100 percent of the necessary parts. Under these circumstances, the person assembling the UAS would be considered the producer and would be required to comply with the design and production requirements of proposed subpart F. (NPRM p. 152.)
We’ll leave aside the fact that the proposed regulation provides no way to quantify parts. Raw number of all components down to individual chips on circuit boards? Number of black-boxed components like receivers and flight controllers? Total mass? As currently written, the amateur-built exception to the production requirements would not apply to the vast majority of modelers.
Even assuming parts are quantified by black-boxed components, most amateur model aircraft would fall into the pre-fabricated, rather than amateur-built category, as most people assemble model aircraft from a collection of pre-fabricated parts they buy separately from various manufacturers. They might buy the airframe as a pre-cut styrofoam body (for planes) or carbon fiber sections (for quads), then glue/screw it together and mount and wire up motors, flight controllers, speed controllers, receivers, and cameras and video transmitters for FPV craft.
The most anyone ever fabricates themselves is the aircraft body. Nobody is fabricating their own receivers, speed controllers, lithium batteries, motors, or remote controllers, so virtually no model aircraft hobbyists would actually qualify for the amateur-built exception which requires more than 50% of parts (however that is quantified) to be fabricated and assembled by the builder.
The vast majority of RC hobbyists would fall under the category of using more than 50% prefabricated parts that do not come as a single kit with 100% of the parts necessary to fly. The proposed regulation would treat such modelers as UAS producers, and would require them to comply with all the production standards to produce and certify a UAS as RID compliant. This process is long and convoluted, and is clearly contemplated to only be used by large corporations developing mass produced UAS to be sold to consumers (the proposal estimates this process would only ever be used by a few hundred corporate entities).
Let’s assume a hobbyist could even comply with the technical requirements to equip a model with remote ID (doubtful given the tamper-resistant requirement which would at minimum prohibit the use of open source flight controllers and could be interpreted to require the person who built the model to somehow prevent himself from bypassing the remote ID system). The certification process requires the purchase of multiple standards that could cost hundreds of dollars to even read, and the filing of extensive forms and reports with the FAA that is estimated to exceed over 50 pages and take hundreds of man hours to produce. It would be completely impossible for any individual hobbyist to comply with these procedures for their home-built model aircraft.
Thus as written in the currently proposal, building your own home-built model aircraft the way the vast majority of hobbyists actually do that would be illegal. It doesn’t matter where you fly them, or even if you fly them at all. Merely building a UAS without equipping it with remote ID and following the process to certify it with the FAA would be an independent violation of the law. It goes without saying that this would be completely unenforceable, but that’s not the point.
Legally at least, this proposal will completely outlaw home-built RC model aircraft as they are actually made by hobbyists. The FAA attempted to disguise this by putting in the amateur-built exemption, and then defining it in such a way as it will be impossible to actually qualify for. I fully expect the AMA to fall for this trick and act like everything is fine because of the amateur-built exemption and the FRIA sites, because they have always sucked at statutory interpretation and anticipating how regulations affecting model aircraft will actually be applied (Sec. 336 anyone?). That’s even without considering that the FRIA exemption for AMA fields is only intended to be temporary and will be phased out over time, leaving hobbyists with nowhere to fly where they are not subject to the operational remote ID requirements.
No matter what the AMA says, this regulation will be the death of amateur home-built model aircraft, period. It doesn’t matter if it’s a quadcopter or traditional RC plane, flown by an AMA member or not. We’re all affected by this equally, and all RC hobbyists have a duty to oppose this regulation wholesale as bringing about the extinction of our hobby.
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