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

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).

I understand Dave. Something else also interesting in their data breakdowns is the average cost of a drone. It seems that DJI was the primary company consulted for drone data (imagine that) and somehow the average cost of a drone is well under half of what most pay for a camera drone, and less that 1/3 of what DJI charges for their most popular models.
 
My company will continue to fly our fleet with the standard equipment whether they pass this or not. My future equipment will have these capabilities, but our current equipment will continue to be utilized, no matter what..
 
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My company will continue to fly our fleet with the standard equipment whether they pass this or not. My future equipment will have these capabilities, but our current equipment will continue to be utilized, no matter what..
" but our current equipment will continue to be utilized, no matter what.. " Not sure what that means but ok.
 
Seemed pretty clear to me. Despite all the changes in full scale regs over the years the feds haven’t legislated a class of aircraft out of the sky, or restricted them to football field sized flying areas dedicated to financing a “non profit” organization. They are still allowed to fly in a large portion of the NAS. In fact, the feds have made it easier for new classes and pilots to develop that don’t have to communicate with anyone. Paraglider, light sport, ultralight. Toss in Piper Cubs, T-Craft, Luscombs, kit builts without transponders, ADS-B, or radios. They only need to remain clear of ATC controlled or restricted airspace.
 
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Anyone can jump in a part 103 ultralight and blast off into the wild blue with no license, no training, no announcement, no tracking, no remote id. Maybe we need to switch from quads to ultralights ... would be a lot more fun than standing on the ground squinting at the sky and we could carry a lot better camera gear.
 
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If a law was passed that we could not be outside of our homes without government permission, would you obey?

Yea, such a law is quite a stretch, but then again, the way our freedom is being progressively restricted, perhaps not. When the law becomes unjust the only certain result is some level of anarchy.
 
If a law was passed that we could not be outside of our homes without government permission, would you obey?

Yea, such a law is quite a stretch, but then again, the way our freedom is being progressively restricted, perhaps not. When the law becomes unjust the only certain result is some level of anarchy.
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Here is a great read with some degree of background for Remote ID for UAS.

Thanks for posting, I'll have a read. But I would advise caution at any positive spin since they could be one of the companies to profit greatly from a server-based requirement.

AirMap and Skyward (Verizon) as well.
 
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Thanks for posting, I'll have a read. But I would advise caution at any positive spin since they could be one of the companies to profit greatly from a server-based requirement.

AirMap and Skyward (Verizon) as well.

I strongly suspect the "Stakeholders" they spoke with all have vested financial interests in RemoteID. The author(s) of the paper left out the most important "benefit" on page 7 of RemoteID: $'s to line the pockets of those with vested interests. Kittyhawk is deeply embedded with the commercial and government groups pushing this initiative (look at the last page) ... and no doubt at the head of the line to receive huge taxpayer and public $'s with its' implementation. Take with a grain of salt what they say.

"Avoiding over regulation"? Ha! For those idealists that naively believe this, study the history of government laws enacted to "avoid over regulation". Read the excellent and pertinent paper here entitled "Government Regulation: The Good, The Bad, & The Ugly."

As the authors point out, "

"...... despite the best intentions, government regulation too often disrupts the marketplace or picks winners and losers among companies or technologies. When regulators behave this way, they invariably cause unintended harms. Poorly designed regulations may cause more harm than good; stifle innovation, growth, and job creation; waste limited resources; undermine sustainable development; inadvertently harm the people they are supposed to protect; and erode the public’s confidence in our government .......... As the size and reach of the government has grown dramatically over the last century, so too have concerns about the costs and unintended consequences of regulatory programs. At the end of the nineteenth century, government accounted for less than ten percent of the U.S. economy. Today, government consumes or directs nearly half of the economy, with direct government spending alone reaching on the order of one-third of U.S. gross domestic product. Regulatory costs, while off-budget and less visible, are no less real. At the federal level alone, there are over 70 federal regulatory agencies, employing hundreds of thousands of people to write and implement regulations. Every year, they issue about 3,500 new rules, and the regulatory code now is over 168,000 pages long ....... The regulatory dilemma is this: On the one hand, regulation can be critically important to our welfare. Federal and state regulatory agencies have contributed to great improvements in air and water quality, highway safety, public health, honest commerce, racial and gender equality, and many other central aspects of American life. On the other hand, regulatory actions often have come at a cost that exceeds their benefits and sometimes actually have been counterproductive. These failures are abetted by the structure of the regulatory process: regulation operates outside our usual system of checks and balances, where policies are enacted directly by our elected representatives and disciplined by taxing and budgeting. Regulatory agencies have too often fallen short of public expectations and disappointed public trust."


The paper makes a very important point that is applicable to the RemoteID proposal: "

...... it is important to understand that the special resource of the government—which private entities do not possess—is the power to coerce. Interest groups that can convince the government to use its coercive power to their benefit can profit at the expense of others. As a result, regulation tends to get “captured” by well-organized interest groups acting to maximize their own well-being, often at the expense of broader society."


*******​

"Remote ID is necessary to gather data and inform better policy-making". Yup. Of course the government's purpose for "gathering data" is unquestionably different (and far more nefarious) than John Q Public's.

I can see some form of RemoteID for drones that are BVLOS. But for drones that are VLOS (as currently required), it's merely another unwelcome, unnecessary and expensive government intrusion designed to exert increasing control. (Note the irony that government drones are of course exempt from this proposed requirement. Congress excels at passing laws from which they themselves are exempt.)

As was already pointed out, you can buy and fly an ultralight in the national airspace without any kind of license or any form of RemoteID.

I can see some form of RemoteID for commercial drones that are BVLOS. Leave the rest of us alone. This will almost certainly kill DSAR. The vast majority of locations in this country where SAR occurs have no cell service.
 
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Rcdancer,

I like the way you think. Clearly you view practicality being more beneficial to the industry than excessive control.

Your mention of corporations benefitting directly from regulation to the detriment of smaller companies and the population ties directly with recent media reports of corporate players writing new, self serving regulations that are placed in front of Congressional members at both state and federal levels to be rubber stamped into law. That practice is clearly evident in the remote ID NPRM.

In California, PG&E already provides a tracking device for every drone used to inspect power lines. That device transmits a discrete ID, along with constant position data to PG&E’s aviation unit. The device is very small, light, battery powered, and is attached to the outside of a drone with Velcro type material. Transmission range is evidently quite long as I’ve used them well in excess of 40 miles from their aviation group offices. If dedicated data transmission repeater devices were added to existing cell towers the transmission range could be extended enough to be received by area centric receivers for transmission to a central federal location. As electricity and RF signals move at the speed of light any lag in positional accuracy would be minimal.

Conflict with manned aviation would be significantly reduced if the FAA imposed a “hard deck” on manned aviation. With the exception of specific conditions, we (drones) already have a 400’ max operating ceiling. Impose a 500’-600’ AGL hard deck on manned aircraft, including helicopters. Include LEA operations in that limitation. With the exception of take off and landing manned aircraft need not operate at “nap of the earth” levels, and the imaging equipment on law enforcement aircraft is way more than adequate to compensate for a 300’-400’increase in operating altitude. The public would no longer be subjected to disruptive police operation rotor noise as well.

Statistically, manned aviation is far more likely to run into themselves than with us, especially near an airport. If a “sterile” environment was maintained around airports, excepting only those drones equipped with TCAS or ADS-B systems for use in terminal (B, C, and D) areas the risk of a mid air becomes extremely small. Make the penalties for unauthorized operation in terminal areas a federal felony, locally enforceable, with first offense fine structures that would be painful to even wealthy operators.

For informational reference, TCAS was employed on drones in Iraq and Afghanistan with great success. Manned aircraft pilots tended to freak out when seeing a TCAS display representing a drone but there were few actual conflicts. TCAS was simply informing that a drone was in the area, typically on a known flight plan, and never straying into approved manned aircraft airspace. The greatest conflict with drones in “conflict environment” airspace originated with manned helicopter pilots, a group that, for some reason, flies like rules and airspace restrictions don’t apply to them.

In short, corporate aerospace drones have been using remote ID systems for over a decade in wartime environments, and select U.S. airspace, which has been the proving ground in developing the regulations being put in front of us now.
 
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Rcdancer,

I like the way you think. Clearly you view practicality being more beneficial to the industry than excessive control.

Your mention of corporations benefitting directly from regulation to the detriment of smaller companies and the population ties directly with recent media reports of corporate players writing new, self serving regulations that are placed in front of Congressional members at both state and federal levels to be rubber stamped into law. That practice is clearly evident in the remote ID NPRM.

In California, PG&E already provides a tracking device for every drone used to inspect power lines. That device transmits a discrete ID, along with constant position data to PG&E’s aviation unit. The device is very small, light, battery powered, and is attached to the outside of a drone with Velcro type material. Transmission range is evidently quite long as I’ve used them well in excess of 40 miles from their aviation group offices. If dedicated data transmission repeater devices were added to existing cell towers the transmission range could be extended enough to be received by area centric receivers for transmission to a central federal location. As electricity and RF signals move at the speed of light any lag in positional accuracy would be minimal.

Conflict with manned aviation would be significantly reduced if the FAA imposed a “hard deck” on manned aviation. With the exception of specific conditions, we (drones) already have a 400’ max operating ceiling. Impose a 500’-600’ AGL hard deck on manned aircraft, including helicopters. Include LEA operations in that limitation. With the exception of take off and landing manned aircraft need not operate at “nap of the earth” levels, and the imaging equipment on law enforcement aircraft is way more than adequate to compensate for a 300’-400’increase in operating altitude. The public would no longer be subjected to disruptive police operation rotor noise as well.

Statistically, manned aviation is far more likely to run into themselves than with us, especially near an airport. If a “sterile” environment was maintained around airports, excepting only those drones equipped with TCAS or ADS-B systems for use in terminal (B, C, and D) areas the risk of a mid air becomes extremely small. Make the penalties for unauthorized operation in terminal areas a federal felony, locally enforceable, with first offense fine structures that would be painful to even wealthy operators.

For informational reference, TCAS was employed on drones in Iraq and Afghanistan with great success. Manned aircraft pilots tended to freak out when seeing a TCAS display representing a drone but there were few actual conflicts. TCAS was simply informing that a drone was in the area, typically on a known flight plan, and never straying into approved manned aircraft airspace. The greatest conflict with drones in “conflict environment” airspace originated with manned helicopter pilots, a group that, for some reason, flies like rules and airspace restrictions don’t apply to them.

In short, corporate aerospace drones have been using remote ID systems for over a decade in wartime environments, and select U.S. airspace, which has been the proving ground in developing the regulations being put in front of us now.
It’ an old article, but remember this? Pre-TCAS bloopers: C-130 Cargo Plane Hits RQ-7 Shadow in Afghanistan – New Photos – UAS VISION
 

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