Expert advice needed on drone registration for m4p
- Thread starter olderrookie
- Start date
This is correct, a drone cannot certify as standard remote ID if the ID function can be turned ON and OFF by the flyer.
The switch need only allow turning RID "ON" or "Off" when the regular battery is used. It would not allow turning RID "OFF" when the extended battery is used.
That would make RID available for flying with accessories attached when using the regular battery. It would have no effect when the extended battery is used and RID is required.
Honestly I think it's a great idea but the FAA process doesn't allow for that. Drones are RID approved based on model number and if the Mini 4 Pro [model number] is FAA RID certified (with a DOC) then it's not going to matter what battery is inserted, it has to follow the rules which says no manual ON/OFF switch. If DJI were to create two different drone models based on the battery then one model could be FAA certified and other model would not be FAA certified and this scheme would work but if you go strictly by the "not thought thru" FAA rules (as I understand them), doesn't appear to be an option which is why we are unlikely to see any further confusion on this with the next DJI software update.
They have probably already moved on to the Mini 5 so I guess we'll get to see yet another RID scheme in what will be known as the Mini3/Mini4/Mini5 RID cluster where each and every model has a different implementation; can't imagine what's coming up next: RID triggered based on Payload Mode? Likely most Mini drone pilots have no idea how it works and don't care because it's too confusing and too complex.
Hmm. There's a paradox there. The Mini 4 Pro is certified as a single model with a single Declaration of Compliance that indicates that it broadcasts RID, but it does not broadcast RID with the standard battery installed?
DJI could implement a software switch that allows RID to be switched ON when the standard battery is installed, with no OFF action. The switch would reset to the normal OFF position (when standard battery is used) when the drone is powered down and restarted.
Is there really an FAA document that says manual on/off switches are prohibited? If so, what is the actual language used?
yep, not sure how they got away with that
This might work because it's not a manual switch where the pilot is the one that determines for himself when RID is turned ON or OFF.
Honestly, the FAA documentation is poorly written and I wouldn't be the right person to defend it because if you do drill down into it and pull it apart, it likely won't hold up until scrutiny. Probably the reason why DJI has taken liberties and perhaps could do something like you mentioned and get away it. I can see where someone would interpret "the drone" and not "the pilot" being the one to manipulate the RID switch is not the same even if an edge condition results in an "illegal" flight. Even an external module doesn't permit the pilot to turn it OFF during flight.
It's in here somewhere: Federal Register :: Request Access
The idea suggested was a manual software switch which the pilot would use to turn RID ON when using a standard battery. No OFF function would be provided and the switch would not be active when extended an battery is used.
I don't see where the government has put anything in PART 89—REMOTE IDENTIFICATION OF UNMANNED AIRCRAFT to prohibit allowing the pilot to enable RID on a drone which does not automatically switch it one when needed. It doesn't seem confusing or poorly written, either.
(I loaded the page used the browser search feature to look for relevant content with keywords - switch, enable, disable, on, off, ....)
There's no mention of switches at all, much less a prohibition of switches.
The only mention of "disable" is here:
"A person may operate a standard remote identification unmanned aircraft only if the unmanned aircraft meets all of the following requirements:" ... Its remote identification equipment and functionality have not been disabled."
So this is a question that has been asked several times but I haven't seen the definitive answer to it yet. If you are a recreational flyer and you buy a sib-250g drone and you don't register (because you don't have to) but your drone has a certified FAA RID DOC and you turn ON the broadcast and you are emitting RID identification details while flying (in a non-FRIA area) but those details are nowhere to be found in the FAA database, are you in violation?
If you are a commercial flyer and your sub-250g drone is registered with a unique registration and standard RID and one day you decide to fly that drone recreationally so you do not switch on the RID function, are you in violation?
When I see language that specifies "from takeoff to shutdown"....to me you cannot legally fly any standard remote ID drone between those times unless it is broadcasting. The section that says you cannot legally fly once you determine you are not broadcasting basically means if you use a switch to turn it OFF or you fail to flip a switch to turn it ON then your flight is not legally. One could argue, if the pilot is honest, why not let him turn it ON at takeoff and turn it OFF at shutdown. If you look at the intent here, you get a better idea: https://www.faa.gov/sites/faa.gov/files/uas/getting_started/remote_id/RemoteID_Executive_Summary.pdf
Highlights of Standard Remote ID UA Performance Requirements:
o UA must self-test so UA cannot takeoff if Remote ID is not functioning
o Remote ID cannot be disabled by the operator
Personally, I believe the purpose of taking the switch function out of the equation prevents the commercial flyer on a job with a properly registered sub-250 drone (properly marked and logged in the database) from flying around without transmitting RID details until such time as they get ready to turn it ON if ever.
In my opinion, RID is pretty useless and the "laws" around it are pretty weak and largely unenforceable so again, I'm not the best person to defend the vague language AND the implementation. We wouldn't be talking about it if it were so clear and concise. The fact that none of it is tied together, there are multiple instances and duplicates in the database, entries don't establish ownership, records are perpetual and/or stale, and that's not even counting the mobile nature of the external modules....none of it can be enforced properly when it's most meant to be effective in a legal setting but it's perfect against those of us who are honest, law-abiding, and when it comes time for grounding and/or confiscation.
I care bc I want to play by the rules and comply. I dont believe anyone has answered my question completely. The mini pro 4 is only RID compliant when using the extended batteries (as I understand it) with a firmware update.
But I want to know if I switch back and forth to the regular batteries (which will put the drone at 249g) will I be compliant?
I think all of us who participate in forums like this one, we care about the rules and the laws. But DJI doesn't make the drones for those of us who are tiny minority. Let me understand what you are saying since I did not know exactly how the Mini 4 Pro handles RID. You are a recreational flyer with both standard (regular) and extended batteries which you switch back and forth with. When you switch, the standard battery does not transmit RID and the extended battery does transmit RID. We all agree the Mini 4 Pro with the extended battery is greater than 250g and with the standard battery is less than 250g.
A word about terminology: the Mini 4 Pro is always "RID compliant." There is an RID DOC on file at faa.gov and it lists your drone model and serial number (range) so it is technically "RID compliant." Your real concern is whether you are flying legally...or not. If your drone was not RID compliant, then you would need to look into attaching an approved external RID module to it when flying commercial or when flying with the external battery (which takes it over 250g).
When you register your Mini 4 Pro with the FAA as a recreational flyer, you are technically legal to fly it regardless if you fly with the standard battery or the extended battery. In my opinion, this is true because your drone is greater than 250g when you fly with the extended battery and your drone is registered and it transmits standard RID properly. In my opinion, this is true because your drone is less than 250g when you fly with the standard battery and there is no regulation that I am aware of that says you MUST be registered, even though you are currently registered. AND there is no law that says your drone has to transmit RID when you are flying recreational and under 250g.
The only exception I can think about is this; someone might say this but I don't necessarily agree with it: if your drone is registered in the FAA database and your drone is listed as standard RID-complaint, then you are obligated to transmit RID whenever you fly it. I believe that despite these facts, when you are recreational and you are under 250g, you are not required to transmit RID. My point is, the active database registration listing PLUS the FAA DOC does not decide whether you must transmit RID so therefore when you insert the standard battery into the Mini 4 Pro and it shuts off the RID as it brings the weight down under 250g, you are still good to fly.
Sorry for the long answer.
Sometimes a long in-depth response with excellent detailed explanation/information is appreciated.
This is exactly the expert advice I was seeking.
I appreciate all responses to my questions and hope it helps enlighten others like me.
Thank you so much!
You're welcome; but I'm not an expert. Trust me, if I said something wrong, folks will chime in....for sure.
The question was about flying with the standard battery and a strobe or prop guards. The drone does not transmit RID because it's using the standard battery. But the weight is above 250 grams, so RID is required. The admin in the DJI forum stated that the pilot should install a add-on RID broadcast unit to be compliant. Without an add-on RID unit, a Mini 4 Pro with a strobe or prop guards in not compliant.
The suggestion was that DJI add a software switch to allow the pilot to enable RID while using the standard battery. The pilot would not be allowed to switch RID off under any circumstances.
If I use the battery plus (which triggers rid) will I be able to use standard batteries and still fly legally?
Yes, RID is enabled with the extended battery and disabled with the standard battery, with no user action required.
If you install accessories that increases the drone's weight to more than 250 grams, RID is required, even with the standard battery. That's the conundrum that's discussed above. It appears that the only solution tom comply with the letter of the regulation is to change to the extended battery or add a stand-alone RID module.
I doubt that the FAA is very concerned about this.
My understanding is that once a drone is registered, it must broadcast RID, regardless of weight. The mini 4 pro only broadcasts with the extended batteries, so an external RID module would be required if using the standard battery and the drone is registered.
There's another aspect of the problem. And another argument for DJI to provide an ON switch for the Mini Pro 4 with standard battery, or to simply enable RID with the standard battery.
MARK (LI)
Well-Known Member
At less than 250 grams, there is no need to register it. If you add things like landing gear, prop guards or the extra life batteries you will go over 250 grams and place yourself into the category in which you will have to register the drone.
With the original batteries the drone does not transmit RID......if you use the extended life batteries it does transmit rid......if you never intend to use the extra life batteries or add anything like prop guards or landing gear or strobe lights you will not have to register the drone
As a recreational flyer, you are not permitted to fly over people, which would be the only situation in which you would need prop guards.
Adding a strobe light to the Mini4 will put you over the 250 gram threshold so you will not be allowed to fly at night...unless you do register...I am posting the link for the FAA Drone Zone, where you would register the drone
FAADroneZone
You will find all the rules here and can read for yourself what is entailed...it might be less confusing seeing it laid out logically and you can easily scroll back and forth to review what you are reading....good luck, with it and please do not hesitate to ask more questions if you are not sure
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