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The good, the bad and the ugly- Remote ID Proposal PRM

The older I get, the more suspicious I become of government and their always-stated intent to "help". The fallen nature of man lends itself to tyranny ....... something the U.S. founding fathers clearly understood with their separation of powers in the U.S. government. But they didn't foresee the ingenuity of man in exerting every-increasing control.

My days with drones may be unfortunately numbered.
 
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It seems like we all agree that the FAA proposed regs have been generated for the automated corporate commercial drone delivery airways or the like and not for 107 commercial or regular drone pilots, who we all agree will suffer.

The AOPA and AMA appear to be present advisors and didn't do much to protect small drone users, so that is really a disappointment. But maybe that could be turned around if there is a groundswell of membership coup. I'm a member of both so at a minimum I wil cc them on a letter to the FAA.

If we are going to comment on the FAA proposed regs, I would like to get some common points I and hopefully others could write about or I fear our voices will go unheard. to be honest I don't feel like our voices will be heard anyway but you have to try. Maybe a petition is in order we can all sign?

Anyway, trying to get some consensus of what everyone is saying here, and what our letters might object to, it seems the following points are common (but correct me if I'm wrong):

1. Although objectionable it seems that identification of the drones in flight is something we can live with;
2. Having a mandatory internet connection and another service that we need to hook into so our every flight record is recorded and downloaded is objectionable.

After that I am not sure what the consensus is. Maybe someone else would be able to summarize it better.

Some of the things that are important to me personally are:

1. That I can maintain the right to fly on or over my own property as unencumbered as possible.

2. That equipment doesn't have to be FAA certified...That people can still build their own drone just like general aviation (think EAA). If drones require FAA certification it will skyrocket costs just as it did in General aviation. The alternator example someone gave above is accurate FAA approved = 10X the cost.

3. That I can fly a drone and have a reasonable certainty that I am not violating a law or regulation in doing so. I hate all this legislation!

4. That our equipment in use is grandfathered in so that it doesn't become outdated any sooner than it already does.

I guess that is an outline of a letter I might write to our friends at the FAA, AOPA and AMA.

I had a question too:

The FAA has based this on on huge number of drones sold (I think that is what they did right?). On a day to day basis I really don't see many flying anywhere around here (granted it is winter in Michigan). It seems the local hobby shops have really reduced what they are showing and selling in drones. It seems that use of drones is not what it once was but I could be wrong. It seems FAA legislating in favor of the big companies by saying the genereral usership is a problem because of the numbers out there (which are probably inaccurate). Does anybody have any knowledge of any actual information of the numbers of drones actually being flown on a current basis? Maybe there are NTSB statistics? It would be nice in the letter to point out the flaws in the basic FAA assumptions.
 
Much of where the business I work for will need to fly the drone has no service ! Most of these people that sit in D.C., or wherever the FAA is, have no comprehension of how vast and remote parts of the west landscape is.

I am sure FAA will require whoever gets the contract for all of this install towers to assure service to remote areas. I am also sure the world is flat.
 
Going beyond the RID internet tether aspect, does anyone else question the FAA's assumption that the craft have only a 3 year viable lifespan?

Sure, new cameras and obstacle avoidance technology has been pretty fast moving till now. But I think that will slow down, especially with all of this that manufacturers have to consider. Actually, the pace of new gear has slowed considerably already.

So the FAA is telling us that the DJI M210, for example, with full compliment of batteries and accessories, visual and infrared cameras, gas sensors, and who knows what else, should only be expected to be in service for 3 years? I think that is ridiculous.
 
Remote ID DJI White Paper attachment below. Remote ID has been available on the DJI GO4 app for some time. But who is monitoring if turned on in the GO4 app except maybe DJI? Pretty much the same as if you have ever uploaded your flight files to DJI but with the new proposed FAA rule, your flight files (along with controller location information) would be available to any organization the FAA deems necessary to have the flight information for review in real time.
 

Attachments

Still a lot we don't know about the proposed FAA rule proposal for Remote ID.

Actually, No. You can read the NPRM for yourself and then you will know whats in it.

Yes, you will see new COMMENTS on the NPRM come out, but the NPRM has not changed and you can know everything in it by reading it. Whether or not it is understood is another matter.
 
Actually, No. You can read the NPRM for yourself and then you will know whats in it.

Yes, you will see new COMMENTS on the NPRM come out, but the NPRM has not changed and you can know everything in it by reading it. Whether or not it is understood is another matter.
So what is your point other than a negative connotation about someone's understanding of what they have read? I don't believe we have seen the final ruling which does not mean I have not read the NPRM or don't understand what I have read.
 
So what is your point other than a negative connotation about someone's understanding of what they have read? I don't believe we have seen the final ruling which does not mean I have not read the NPRM or don't understand what I have read.

Hey JD,

I didn't mean to cause any negativity (other than the smelly NPRM). I was simply replying to your comment
"Still a lot we don't know about the proposed FAA rule proposal for Remote ID. "
The NPRM has not changed since it was released to the public a few days ago. Maybe I mis-understood your statement and you meant something else?
 
I started in aviation 33 years ago with my pilot's license and a degree in aviation management. Over the last 33 years, I've heard all kinds of episodes of GA's or airports' or the travelers' impending doom from some proposed change in rule making by the FAA. The one thing they all have in common, is the doom never materialized.

Get involved in the process. Let the FAA and other involved organizations know about your concerns. This is a very plastic situation right now. If the UAS community is involved, you're going to find in 5-10 years, that the angst you feel today was not necessary at all.
 
Interesting this FAA proposed rule is slanted to be needed for safety. But the FAA’s own tweet clearly shows the intent is BVLOS and package delivery....

#RemoteID will do more than pinpoint a #drone’s location, it will unlock ops like #packagedelivery & #BVLOS. Continue the conversation, but know that the #FAA can ONLY consider your official comments submitted through the Federal Register at http://bit.ly/37bXJca #DronesDeliver

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Interesting this FAA proposed rule is slanted to be needed for safety. But the FAA’s own tweet clearly shows the intent is BVLOS and package delivery....

#RemoteID will do more than pinpoint a #drone’s location, it will unlock ops like #packagedelivery & #BVLOS. Continue the conversation, but know that the #FAA can ONLY consider your official comments submitted through the Federal Register at http://bit.ly/37bXJca #DronesDeliver

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For more detailed information, see our cookies page.

This touches on exactly my thoughts (still trying to wrap words around them.) Remote ID should be an absolute necessity for BVLOS (which would likely include package delivery) but our current line-of-sight system for smaller area surveys, fpv flying, real estate photography, cinema, etc. seems to be working fine for those that are following the rules.

Side note 1: remote id doesn't solve BVLOS because it doesn't address see and avoid of other aircraft, but it would be a necessary step.
Side note 2: I'm sorry but I still think that "package delivery as an important UAS use-case" is complete bunk ... if this is what ends up driving FAA rules then that is just dumb.
Side note 3: If the FAA intends this as an enforcement tool to catch all the rule breakers, then I think they will be largely disappointed.
Side note 4: I still think the FAA drone numbers/expectations are massively over inflated. How many drones are sitting on people's shelves collecting dust after they flew them 3 times and then got bored when their youtube site only has 42 subscribers? How many were crashed and never repaired? How many of these fly a handful of times a year at most?
Side note 5: I'm still concerned about privacy. I know airspace is different from other things, but would we want the gov't recording every phone call? Recording every movement of our phone? Recording everywhere we drive (along with speeds). Recording every purchase? I know a lot of that info is out there, but at least the gov't presumably has to pass through some checks and balances to get access to it. From a gov't perspective it would be great to feed all this into a cloud with deep learning and automatically bust everyone who strays out of their figurative lane for a moment. I know some full scale aviation telemetry data is recorded and public (someone wrote a tweet bot to flag flights that looked like they were circling and comes up with lots of interesting flights.) But I wonder how full scale pilots/AOPA would feel about all their flight telemetry data being sent to the cloud in order to automatically catch anyone breaking a regulation.
Side note 6: I'm a DIY builder and it's frustrating to me that DIY flights will probably be severely limited, or suddenly I'm illegal and made a criminal if I stray a tiny bit out of my little radius. I hate when regulations make normal people illegal or makes them afraid of doing normal stuff because it might be a little near the edge of all these draconian regulations. I think the freedom and privacy advocates should speak up too.
Side note 7: what about kites and really long poles? Shouldn't they be tracked too?

I don't know anything really for sure, but regulations should flow with the sorts of things that normal/good people want to do.
 
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If you search for "drone" or "sUAS" in the NTSB data base of reports since 2015, 15 reports come up. Of these maybe 5 or 6 actually related to drones or drone strikes. I think a couple of those may be repeats of the same incidences:

(I cut and paste them below but if this is improper in the forum please edit as necessary)

Drone search:

Factual
12/17/2019
Factual Report PDF | HTML10/19/2019Safford, AZZenair CH 701N3784AGAA20CA039Nonfatal
Preliminary
09/19/2018
Preliminary Report PDF | HTML09/05/2018Jean, NVCommander 114N6064CWPR18FA253Fatal(1)
Factual
08/23/2019
Final
08/23/2019
Final Report PDF | HTML
Data Summary (PDF)
08/14/2018Blacksburg, VADJI PhantomFA3HCWCR4XDCA18IA269Incident
Preliminary
10/21/2019
Preliminary Report PDF | HTML08/10/2018Driggs, IDLindstrand 105AN1410CDCA18IA264AIncident
Preliminary
10/21/2019
Preliminary Report PDF | HTML08/10/2018Driggs, IDDJI MavicUnregDCA18IA264BIncident
Factual
07/16/2019
Final
11/06/2019
Final Report PDF | HTML
Data Summary (PDF)
07/17/2018Miami, FLPiper PA34N16281ERA18FA194AFatal(4)
Factual
07/16/2019
Final
11/06/2019
Final Report PDF | HTML
Data Summary (PDF)
07/17/2018Miami, FLCessna 172N6428DERA18FA194BFatal(4)
Factual
05/08/2019
Final
11/06/2019
Final Report PDF | HTML
Data Summary (PDF)
02/14/2018Charleston, SCROBINSON HELICOPTER R22N337HGAA18LA131Nonfatal
Factual
05/15/2019
Final
07/08/2019
Final Report PDF | HTML
Data Summary (PDF)
01/17/2018Raton, NMBELL UH-1HN658HCEN18FA078Fatal(5)
Factual
07/08/2019
Final
09/09/2019
Final Report PDF | HTML
Data Summary (PDF)
07/01/2017Catawba, WICESSNA 421CN2655BCEN17FA248Fatal(6)
rone search at NTSB 1/2/2020:

12

Page size:
select
11 items in 2 pages
Factual
08/08/2016
Final
09/01/2016
Final Report PDF | HTML
Data Summary (PDF)
08/25/2015Ketchum, OKROBINSON HELICOPTER COMPANY R44 IIN444KDCEN15LA379Nonfatal


sUAS search

Factual
08/23/2019
Final
08/23/2019
Final Report PDF | HTML
Data Summary (PDF)
08/14/2018Blacksburg, VADJI PhantomFA3HCWCR4XDCA18IA269Incident
Preliminary
10/21/2019
Preliminary Report PDF | HTML08/10/2018Driggs, IDLindstrand 105AN1410CDCA18IA264AIncident
Preliminary
10/21/2019
Preliminary Report PDF | HTML08/10/2018Driggs, IDDJI MavicUnregDCA18IA264BIncident
Factual
12/14/2017
Final
12/14/2017
Final Report PDF | HTML
Data Summary (PDF)
09/21/2017Hoffman Island, NYDJI PhantomNoneDCA17IA202AIncident
Factual
12/14/2017
Final
12/14/2017
Final Report PDF | HTML
Data Summary (PDF)
09/21/2017Hoffman Island, NYSIKORSKY UH60R20087DCA17IA202BIncident
 
Going beyond the RID internet tether aspect, does anyone else question the FAA's assumption that the craft have only a 3 year viable lifespan?

Sure, new cameras and obstacle avoidance technology has been pretty fast moving till now. But I think that will slow down, especially with all of this that manufacturers have to consider. Actually, the pace of new gear has slowed considerably already.

So the FAA is telling us that the DJI M210, for example, with full compliment of batteries and accessories, visual and infrared cameras, gas sensors, and who knows what else, should only be expected to be in service for 3 years? I think that is ridiculous.

Dave,

What establishes drone life cycle? What are they using as limiting factors?

The only item that establishes the “useful life” of a DIY or custom built drone that employs “industry standard” batteries is the battery or batteries. They age and wear out or become damaged through improper use practices. As this battery type is common and widely available, replacing a worn battery with new fully resolves that minor problem. The critical flight components like the FC, motors, props, ESC’s, and transmitter do not have a known useful life as life cycle duration studies have not been documented. They don’t wear out sitting on a shelf so if infrequently used they can last and remain functional almost indefinitely.

Brand specific consumer drones using proprietary battery case or battery monitoring devices are another matter as the battery design is a means for a manufacture to force obsolescence in order to encourage new model purchases. One a consumer drone maker discontinues battery production the life cycle of a model is limited to the remaining supply of batteries that fit a particular model. The same is applicable to the supply of spare parts for a given model as consumer drone makers prefer parts from one model will not cross over to serve on a different model.

Some of us have drones aged in excess of 5 years and they still function fine. I anticipate some of mine will still be fully functional when the RID rule is implemented.
 
Dave,

What establishes drone life cycle? What are they using as limiting factors?

Pat,

My comment to 3 years was in regard to the FAA's calculations on cost to existing owners of craft that will become obsolete. They use 3 years as the period of amortization. In other words, if you've been able to use the craft for 3 years and the rule makes it obsolete, the FAA figures you've lost no $$ because you got your 3 years of life out of it. That is the point I think is flawed. But it makes their user cost of the proposed rule less (better for them).
 
According the the FAA, based upon their conversations with manufacturers, the majority of the newer craft we use can be made to meet the remote ID requirements with a software update. (NPRM Page 189)

The FAA reviewed UAS registered to part 107 operators and found 93% of the existing part 107 UAS fleet may have technical capabilities to be retrofit based on information received by industry (i.e., could support software updates through internet).
The FAA identified the top-10 registered aircraft by producer and researched registered model specifications online. The FAA found each of the registered models within this group had internet and Wi-Fi connectivity, ability to transmit data, receive software uploads, and had radio frequency transceivers, among
other technology such as advanced microprocessors.

Figure 1 provides the breakdown of manufacturers of registered part 107 UAS that could retrofit representing 93% of part 107 registered UAS fleet.

1.JPG
 
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This touches on exactly my thoughts (still trying to wrap words around them.) Remote ID should be an absolute necessity for BVLOS (which would likely include package delivery) but our current line-of-sight system for smaller area surveys, fpv flying, real estate photography, cinema, etc. seems to be working fine for those that are following the rules.



Side note 5: I'm still concerned about privacy. I know airspace is different from other things, but would we want the gov't recording every phone call? Recording every movement of our phone? Recording everywhere we drive (along with speeds). Recording every purchase? I know a lot of that info is out there, but at least the gov't presumably has to pass through some checks and balances to get access to it. From a gov't perspective it would be great to feed all this into a cloud with deep learning and automatically bust everyone who strays out of their figurative lane for a moment. I know some full scale aviation telemetry data is recorded and public (someone wrote a tweet bot to flag flights that looked like they were circling and comes up with lots of interesting flights.) But I wonder how full scale pilots/AOPA would feel about all their flight telemetry data being sent to the cloud in order to automatically catch anyone breaking a regulation.

I hate when regulations make normal people illegal or makes them afraid of doing normal stuff because it might be a little near the edge of all these draconian regulations. I think the freedom and privacy advocates should speak up too.

The concerns you reference above are things that, unfortunately, I believe a great many people don't understand with respect to the current state of data collection technology, government, and business.

Currently, every phone call from a foreign country to or from the U.S has some portion of it recorded and retained by government agencies. ALL digital media transmitted is recorded and retained by government agencies. First Class mail is (and has been for quite a long time) being opened and inspected without first obtaining a search warrant. Cellular data is routinely extracted, tracked, recorded, and used by government agencies at whim. Our military captures and utilizes cellular data outside of the U.S. for identifying, tracking, and remotely killing high value targets. Anything you cell phone contains, from data you are aware of to data you are not aware of, like the name and location of all towers accessed, can be extracted in seconds as an aircraft flies nearby. Police agencies employ cell tower "spoofers" to capture data from cell phones passing nearby without a warrant. Your travel via private vehicle is tracked through the use of license plate readers mounted on traffic lights and other elevated platforms. Vehicle contents are scanned using back scatter technology as vehicles, both private and commercial, pass by select highway locations. Airports, shopping centers, Amazon Ring security systems, are constantly capturing facial images that are shared with government agencies and private security business for the purpose of developing a vast facial recognition, instantly accessible database. Post a facial image of Facebook and their facial recognition programs will provide a name. Amazon is so aggressive with this they provide Ring systems to police departments to be used in public give away programs under the guise of improving community safety. Personal credit card use is tracked by the IRS to assure spending habits are not out of line with reported income. With the exception of data collected by a couple of high level, extremely secretive government agencies, all this information, and more, is being commonly accessed or shared between businesses and government agencies.

Pretty much everything we do is recorded, either by private entities as a source of salable data, of by government agencies where it is routinely exchanged with other agencies without need of a request.

Data is power. With enough data we can identify, track, predict, isolate, restrict, destroy anyone at will. It requires only a few weeks of monitoring to capture enough data to establish a "pattern of life". From that point you have all you need to manipulate someone's future, without ever leaving the confines of an office cubicle. Iraq and Afghanistan have been great learning tools in the development of these practices, which are employed daily in many locations around the world.

The tracking and retention of flight data for every flight for every drone is something that troubles me greatly. This is not done with full scale aviation. Even after 2020's ADS-B mandate there are a great many places a manned aviation pilot can hop in a plane and fly as desired with no filing of a flight plan, no broadcasting of identity or position, nobody recording time, position, movement, altitude. If the government is seriously concerned with public safety it makes sense to closely monitor the segment of aviation that has the potential to do the most damage or destruction with any individual flight. But that is not what is being done.

The acronym for remote identification of drones, RID, can't be coincidental. "Rid" is pretty much what will be done with most of the equipment currently in use.
 
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