Comments sent. Everyone needs to send in comments to the FAA. One and United.
The good, the bad and the ugly- Remote ID Proposal PRM
- Thread starter LUIS MARTINEZ
- Start date
Perhaps even better reading if you haven’t seen it yet. It pretty well lays out why the remote ID NPRM was created.
Amazon Prime Air is creating safe airspace for all drones, beyond delivery.
In the not so distant future, more and more drones will be flying around delivering packages, performing utility work, taking real estate photos, and helping with emergency services. When that time…
www.suasnews.com
that article states “For additional safety, drones will fly at low altitudes (for example, below 400 feet) so it would be very unlikely for them to be in the same airspace as aeroplanes or helicopters.”
Um.....helicopters can fly at any altitude.
“because it will connect via the internet, LTE, or another cloud-based connection so each system can talk to the other.”
Yeah....cause everyone knows how reliable cell service and the the internet is. Especially with near instant decision making with see and avoid.
Um.....helicopters can fly at any altitude.
“because it will connect via the internet, LTE, or another cloud-based connection so each system can talk to the other.”
Yeah....cause everyone knows how reliable cell service and the the internet is. Especially with near instant decision making with see and avoid.
To me, the real issue was Amazon even making an announcement of their intent to monitor and control drone traffic. It clearly implies such planning took place quite some time ago. Personally, I think they made a big mistake in going public about that as it also implies they, and other corporations, shaped, if not totally wrote, the law to benefit their financial interests.
Dave Pitman
Well-Known Member
I think we knew they and the other telecoms are the author and beneficiaries. For true enterprise operations, it makes sense. If I were Amazon or UPS or FedEx, I would be putting a network based operational management system in place for sure; 1000's or 10,000's of operations a day, it's a no-brainier.
Applying that same scale to everyone else is ridiculous, but the FAA is thinking that if they can get it and have us foot the bill, why not try. And Amazon, for example, will already have their platform in place. Any $$ they get by renting it out to others will just be frosting.
Copied from the Jan 23, 2020 document on page 15.
Key Elements of Analysis: Retrofits and Savings
Retrofits
An important assumption used in this analysis involves the availability of retrofits.
The FAA received information from industry on the potential to retrofit during Executive Order 12866 meetings from September through December, 2019.
Part of the existing fleet of UAS could be retrofit to comply with remote identification requirements with relative ease and minimal cost (e.g., by a software update or “push” through the internet) and this could be achieved within the first year after the effective date of the final rule given the availability of FAA-accepted means of compliance.
Savings
This proposal would provide cost savings for the FAA and law enforcement resulting from a
A variety of other entities involved with airport operations, facility and infrastructure security, and law enforcement would also save time and resources involved with UAS incident response and investigation.
This proposed rule, in concert with FAA’s proposed rule for operations over people, would create cost savings for the FAA and part 107 operators by avoiding the time expended processing waivers for these activities (about $25 million in annualized cost savings).
reduction in hours expended investigating UAS incidents.
Key Elements of Analysis: Retrofits and Savings
Retrofits
An important assumption used in this analysis involves the availability of retrofits.
The FAA received information from industry on the potential to retrofit during Executive Order 12866 meetings from September through December, 2019.
Part of the existing fleet of UAS could be retrofit to comply with remote identification requirements with relative ease and minimal cost (e.g., by a software update or “push” through the internet) and this could be achieved within the first year after the effective date of the final rule given the availability of FAA-accepted means of compliance.
Savings
This proposal would provide cost savings for the FAA and law enforcement resulting from a
A variety of other entities involved with airport operations, facility and infrastructure security, and law enforcement would also save time and resources involved with UAS incident response and investigation.
This proposed rule, in concert with FAA’s proposed rule for operations over people, would create cost savings for the FAA and part 107 operators by avoiding the time expended processing waivers for these activities (about $25 million in annualized cost savings).
reduction in hours expended investigating UAS incidents.
I get that they want a way to identify the outliers for law enforcement and I agree with that. Throwing all your expectations into one basket is not going to solve the problem for us, the pilots. An internet only solution works great if you are in an area that has reliable internet service. Not everyone does. Where do pilots in that area fall then? Business closed. They can't fly. I live in an urban setting and my 500MB service can be flaky as all get-out. So if I can't connect at the time of flight, then I am grounded? Or limited to within 400 feet of my base station? My workhorse almost takes that much space to get off the ground. I don't think so.
From another angle, the telecom industry was regulated in the mid-80s and the Federal government forced the big conglomerates to divest themselves. AT&T was broken up into the long distance service which they retained control of and Bell laboratories were split off from the company and further broken up into the Baby-Bell entities to be a regional service from intra-state and local calls. That leveled the playing field somewhat with GTE and other independants. As soon as the Federal government ceased regulation, the industry reverted right back to where it started and again, the giant telecom companies that emerged took control of the market and the consumer suffered and continues to do so.
The Federal government required a national health-care system....mandatory. The part that didn't make it affordable is that they failed to regulate the healthcare industry and especially the insurance industry who continues to rape the population unchecked. The same can be said for the auto insurance industry. You have to have it but cost are not regulated.
It might appear that I am in favor of a heavy-handed approach favoring government oversight but I am actually a little more practical. Big business is not a charitable organization. It doesn't give a flying ck (not the Louis variety) about the general consumer; only the shareholders and their bottom line. Any time, and history proves this if you bother to check for yourselves, you allow a corporation unchecked access to the marketplace, the consumer suffers. I see whomever (f'in telecoms) that get the contract to provide the service are going to at some point take advantage of us and that pisses me off to no end.
That is my rant for the day. Now back to crafting my response in more civil terms.
For those (like me) who have minimal to NO cell coverage in a large portion of your service area there is an allowance for that.
Standard Remote Identification UAS
* UAS transmits remote ID messages over the internet to a Remote IS USS, and
* Broadcasts remote ID messages from the UA via RF
* If no internet is available, then may broadcast only.
*No Operating Restrictions
(Color and bold applied by me for emphasis)
The downside is the UAS must have the ability to Self Broadcast. Until the rule goes into effect and the "parameters" of the broadcast are finalized and then manufacturers weigh in we can only hope most of our most current aircraft will be easily upgraded to this ability with little to no $$ investment.
Standard Remote Identification UAS
* UAS transmits remote ID messages over the internet to a Remote IS USS, and
* Broadcasts remote ID messages from the UA via RF
* If no internet is available, then may broadcast only.
*No Operating Restrictions
(Color and bold applied by me for emphasis)
The downside is the UAS must have the ability to Self Broadcast. Until the rule goes into effect and the "parameters" of the broadcast are finalized and then manufacturers weigh in we can only hope most of our most current aircraft will be easily upgraded to this ability with little to no $$ investment.
I have the ability to self-broadcast....its called ADS-B. The Ping 1090i plugs right in tomy Pixhawk and then all you have to do is configure it. 15 minutes tops. But the FAA is worried that we may overload the system. So, Federal government, talk to your cousin and free up more frequency bands to use your current system without having to re-invent the wheel; at least for those of us that can make the leap. The rest are going to have to rely on an RFI or (shudder) internet approach. But if that is the case (for the latter) then regulate the service providers to prevent them from price gouging the customer base....us.
One issue with the airspace safety thing is the fact that nothing relative to full scale aviation is changing.
We can broadcast ID and location until we are blue in the face but until a hard floor altitude limit is placed on full scale the collision risks experienced now will continue. A 500’ AGL floor for all manned aircraft would help considerably. Regulating the life out of drone operations while still holding them 100% responsible for separation from manned aircraft cannot work as long as manned aircraft have a free pass to generate conflict without concern of being levied a violation.
We can broadcast ID and location until we are blue in the face but until a hard floor altitude limit is placed on full scale the collision risks experienced now will continue. A 500’ AGL floor for all manned aircraft would help considerably. Regulating the life out of drone operations while still holding them 100% responsible for separation from manned aircraft cannot work as long as manned aircraft have a free pass to generate conflict without concern of being levied a violation.
Well put. They fail to understand that in class G any manned aircraft can go wherever whenever they want since they are not required to transmit ADS-B or in be contact with ATC. The only way to avoid conflict with another craft is to have line of sight and see and avoid.
Dave Pitman
Well-Known Member
Guys, while I agree with you, this NPRM is not really even claiming to address safety and conflict between unmanned and manned aviation. That is kind of the point why it is somewhat flawed. Read the SUMMARY again.
The summary says "It addresses safety and security concerns associated with expanded UAS operations." But for the reasons you mentioned, and additionally the fact that manned aviation would not have any more knowledge about a UAS flight that could effect them, nor would the UAS operation have any more information on manned flights near them, it is pretty clear this is about accountability and not about airspace safety.
I'm all for accountability, and live broadcast fulfills that quite nicely without additional cost in most cases. Even DIY solutions could live broadcast quite easily with off the shelf current tech.
The creation of a whole new marketplace that we will be tasked to pay for, is not needed for accountability, nor to make the airspace safer.
Dave,
You’re preaching to the choir. Although the NPRM references flight safety as purpose such reference is purely obfuscation as the true intent is to force a group of airspace users to fund and maintain for profit a new privatized airspace system. A system that was struck down for full scale operators. Discrimination?
Personally, I think it should be put in front of a Constitutional law scholar as I do not believe Congress has the authority to promote or endorse select private businesses or products, which this bill most certainly does. I have the feeling the FAA had very little input with the drafting of the NPRM, with that involvement only in integrating FAR/CFR section numbers in appropriate areas. To me this bill was written lock, stock and barrel by the companies that will profit from it, using the DOT as a means to promote private interests.
As you say, there are much easier ways to implement remote ID, and they are already in place. If the FAA’s equipment is too antiquated to deal with a massive expansion of TCAS, ADS-B, or even Mode C transponders, update the FAA equipment and ATC staffing accordingly. It’s not our fault, or the fault of manned aviation, the FAA is close to 30 years behind schedule in equipment upgrades. Or use those multi million $$ fines collected from commercial carriers to fund it.
If the FAA is concerned we don’t pay taxes specific to aviation to fund their services all that’s needed is a surcharge for each drone sold and an annual airspace user fee of some small amount. Then again, we do pay road taxes to both the states and Feds, which puts us in the same use tax class as full scales that use auto fuel.
You’re preaching to the choir. Although the NPRM references flight safety as purpose such reference is purely obfuscation as the true intent is to force a group of airspace users to fund and maintain for profit a new privatized airspace system. A system that was struck down for full scale operators. Discrimination?
Personally, I think it should be put in front of a Constitutional law scholar as I do not believe Congress has the authority to promote or endorse select private businesses or products, which this bill most certainly does. I have the feeling the FAA had very little input with the drafting of the NPRM, with that involvement only in integrating FAR/CFR section numbers in appropriate areas. To me this bill was written lock, stock and barrel by the companies that will profit from it, using the DOT as a means to promote private interests.
As you say, there are much easier ways to implement remote ID, and they are already in place. If the FAA’s equipment is too antiquated to deal with a massive expansion of TCAS, ADS-B, or even Mode C transponders, update the FAA equipment and ATC staffing accordingly. It’s not our fault, or the fault of manned aviation, the FAA is close to 30 years behind schedule in equipment upgrades. Or use those multi million $$ fines collected from commercial carriers to fund it.
If the FAA is concerned we don’t pay taxes specific to aviation to fund their services all that’s needed is a surcharge for each drone sold and an annual airspace user fee of some small amount. Then again, we do pay road taxes to both the states and Feds, which puts us in the same use tax class as full scales that use auto fuel.
For the good of our industry, maybe we should also state HERE, our recommendations on moving forward until we know more. I’m sure there are those that are wondering what to do to get into this industry, as well as what to do to maintain current flight status of both license and aircraft, as well as future purchases of aircraft systems.
I for one would appreciate some of you guys insight from across the country and within your circles. I have written a response to the Administration and continue to exercise my rights as Part 107 with existing sUAS.
I for one would appreciate some of you guys insight from across the country and within your circles. I have written a response to the Administration and continue to exercise my rights as Part 107 with existing sUAS.
Unfortunately it does address safety. The NPMR "provides situational awareness of UAS flying in the airspace of the United States to other aircraft in the vicinity of those operations and airport operators."
I think that at least one man's opinion failed to take into account that the information is being transmitted to a third-party vendor who is storing the information until the FAA or law enforcement request said information, UNLESS he knows something that he was not sharing. What Ben Walsh was describing in that simple line was ADS-B. Maybe he was confused. I certainly am. There is security built into the proposed system to an extent but no safety whatsoever.
Up until this point I was operating under the understanding that safety was the prime concern of the FAA. I am beginning to think that they forgot their mission on this rulemaking proposal and sold out to special interest. I hope I am wrong.
IIRC, the FAA has two prime mandates, flight safety and promoting air commerce.
Again, with my vast flight experience of 50 whopping hours I hope I overlooked the safety part or they just determined that it was not necessary reading on our part. Still, it is a cause of worry for me.
I get that the FAA is concerned that including the entire unmanned crowd under ADS-B might cause problems but give me a break. I've got a Ping 1090i plugged into my Pixhawk and it adds layers of safety to my operations. Not just from the added situational awareness but also the Sense and Avoid routine that I configured to bottom the aircraft out at 100 feet AGL in a holding pattern until the threat cleared my airspace. I do not think that you will get that level of situational awareness from the proposed system.
