FAA Drone ID Proposal- Round Two

[brettbrandon]

Manned aircraft fly below 500ft quite often like for takeoff and landings, search and rescue, fighting fires, locating fugitives, crop inspections, building inspections, dam inspections, surveying, installing large HVAC on roofs, etc etc.

Thus the reason I stated "most places". The amount of airspace they stay above 500 agl is a heck of alot more than not... I'm out...

 

[Camino Ken]

Thus the reason I stated "most places". The amount of airspace they stay above 500 agl is a heck of alot more than not... I'm out...

I was not disagreeing per se but trying to add specificity and detail. Your comment as written might have given novices the impression that the area below 500ft was free from manned aircraft.

 

[sar104]

So @sar104: Do you think DJI's drones in their current state can easily meet the Standard Remote Identification UAS rules?

USS via internet - obviously yes.
Broadcast - current DJI equipment has radios on the proposed bands, and I would expect that they are proposing standards that would be compatible, but I have no inside information on that.

I have been thinking about this over the past few days. Here would be my markups:
Delete "Limited Remote Identification UAS" rules altogether.

Why?

"Standard Remote Identification UAS" rules: Range restricted to 0.25 nautical mile (1,519 ft.) radius. From the law enforcement perspective, this should be OK because the home point is broadcasted, right?

That would defeat part of the object of the proposal, which is to enable BVLOS. Range is restricted anyway to VLOS without a waiver.

Create a new category, "Enhanced Remote Identification UAS" rules, which requires:

ADS-B in (e.g. DJI AirSense)​

Something that emulates Traffic Collision Avoidance System.​

They don't want sUAS using ADS-B - it would potentially overwhelm the system and result in too much clutter.

As a pilot, if I were flying beyond visual line of sight, I would want to know about what other aircraft are doing so that I can avoid them, and vice-versa.

The proposed system should provide that.

 

[cavenger]

What drones would this ground in their current state? All of them? Is the remote Id aspect of this something on the drone itself or in the controller?

 

[sar104]

What drones would this ground in their current state? All of them? Is the remote Id aspect of this something on the drone itself or in the controller?

The broadcast is from the drone. The USS transmission is via the RC and mobile device. It's likely at least to require firmware updates.

 

[cyeung]

USS via internet - obviously yes.
Broadcast - current DJI equipment has radios on the proposed bands, and I would expect that they are proposing standards that would be compatible, but I have no inside information on that.



Why?


That would defeat part of the object of the proposal, which is to enable BVLOS. Range is restricted anyway to VLOS without a waiver.


They don't want sUAS using ADS-B - it would potentially overwhelm the system and result in too much clutter.


The proposed system should provide that.

To clarify, I would like ADS-B in, not out ... receive, but not transmit ... listen, but not speak. My only beef with the "Limited" rules is their definition of VLOS at 400 ft. I can see the aircraft at 1,000 ft.

 

[sar104]

To clarify, I would like ADS-B in, not out ... receive, but not transmit ... listen, but not speak. My only beef with the "Limited" rules is their definition of VLOS at 400 ft. I can see the aircraft at 1,000 ft.

The 400 ft limit was not implemented as an estimate of VLOS - it was proposed as a distance from the control station that would permit LE to identify the operator visually.

Page 75:

The ARC identified a range of 400 feet as the maximum distance that an unmanned aircraft could be operated from its control station where a law enforcement officer could reasonably locate and identify the operator of the unmanned aircraft by visual means only. The FAA agrees with the ARC determination that 400 feet is a reasonable distance for visually associating an unmanned aircraft with the location of its control station, and has included a 400-foot range limitation in the requirements for limited remote identification UAS.​

 

[Huckleberry]

That's not correct - the 400 ft limit is for Limited Remote ID when you can access the internet.

View attachment 89573

I’m confused with the limited remote ID. What might be a scenario in which one would fall under limited remote ID?

 

[Neil Reid]

Gang- I might recommend you read the essential parts of the proposed law (it's an 87 page document).

We have FOUR YEARS before this law begins to actually take effect. Kindly read as follows which is pasted from the proposed legislation, found on page 72488 (it's a weird gov numbering thing- the actual doc is 87 pages), Section XVII. Highlights are mine from the paste section below.

"Requirements that prohibit operation of UAS without remote identification would begin 36 months after the effective date of the rule. This 36-month period runs concurrently with the 24- month period provided for the development of means of compliance, and for the design, production, and sale of UAS with remote identification.

Once UAS with remote identification are widely available, this proposal would allow an additional one- year period of time for UAS owners and operators to purchase and transition to operations of UAS with remote identification."

Hope this is helpful and positive in tone. I'm not an expert or an attorney, just a guy who believes in due diligence before I believe publicly shared information.

Best-

Neil Reid
Dallas, TX

 

[sar104]

I’m confused with the limited remote ID. What might be a scenario in which one would fall under limited remote ID?

Limited Remote ID is defined in the table that I put in post #13 - aircraft that can communicate with a RID USS via the internet but have no radio broadcast capability.

 

[DanMan32]

How would the proposed system allow me to see nearby MAS traffic? Are they going to retrofit so I see them with my equipment?

As it is, FlightAware and FlightRadar24 are useless. A plane can pass me by long before it shows up in those apps, if they even show up at all. I need advance notice, not notice after the fact.
flightradar24 refuses to include a class D airport near me.

 

[sar104]

How would the proposed system allow me to see nearby MAS traffic? Are they going to retrofit so I see them with my equipment?

As it is, FlightAware and FlightRadar24 are useless. A plane can pass me by long before it shows up in those apps, if they even show up at all. I need advance notice, not notice after the fact.
flightradar24 refuses to include a class D airport near me.

Eventually I'd expect all sUAS to include onboard ADS-B-in hardware for real-time data.

 

[badaxed]

found this in the id documents.
"The proposed rule requires remote identification UAS to automatically connect to a USS. If the UAS cannot connect to the USS, the unmanned aircraft will not take off."

 

[sar104]

found this in the id documents.
"The proposed rule requires remote identification UAS to automatically connect to a USS. If the UAS cannot connect to the USS, the unmanned aircraft will not take off."

As you will see in the table in post #13, that only applies to Limited Remote ID equipment.

 

[Multi-Rotor Pilot812]

I'm going to give EVERYONE reading this who intended to respond to the NPRM.... think ahead be sure to make your response fit into this bubble:

• concise
• specific
• respectful

I've been reading a batch of the current "Comments" and I've gotta say... it doesn't look good so far. Reasoning like:

"FPV isn't a crime"
or
"Freelancers and content creators should be able to perfect their craft and expand opportunities without unreasonable limitations "
or
"This legislation will kill a hobby that isn't actually harming ANYONE. Maybe instead of bothering people that aren't hurting anyone you actually protect people "

is not going to have any effect what so ever. Take the time to give suggestions/options rather than just being completely negative and critical. Details are IMPORTANT!!

In other words don’t be like the FAA is what you’re trying to say?

 

[badaxed]

i like this comment from an experienced pilot from the comment section of the federal register on drone Id rule.

Comment from Brett Tossell

The is a Comment on the Federal Aviation Administration (FAA) Proposed Rule: Remote Identification of Unmanned Aircraft Systems For related information, Open Docket Folder Comment As a 10,000+ hour ATP, former flight instructor, and Part 107 certificate holder this proposed NPRM is poorly reasoned, based on fallacy, harmful towards an emerging industry, and a detriment to education and our future. As a professional pilot, aircraft owner, and UAS operator - I fail to see the unsolvable safety risks posed by UAS operation. I've not been able to find the accidents, the fatalities, or the damages caused by UAS. This burdensome regulation punishes, and inhibits the growth of an emerging industry by onerous, overreaching regulation. Flying in my private aircraft, or in the jets at work - I wouldn't fear hitting a UAS any more than I'd fear a bird strike. See and avoid seems to be working. Altitude segmentation and separation works. I don't fly my UAS above our current limits, nor do I expect to see aircraft flying at or below treetop height. We already have exclusion around airports by regulation - and requiring transponders won't stop someone from operating nefariously by intent. The technology that is UAS is rapidly developing. No doubt commercial interests will earn huge profits by capitalizing off this market - in delivery of goods and services, and the sales, operation and service of the UAS themselves. However the garage tinkerer, the students, and amature engineers that experiment and play with these technologies should not be inhibited in their pursuits. Mandating transponders (or other means of electronic ID) will be a burden of compliance that only raises the barrier to entry. FPV, drones, Remote Controlled aircraft and the like are a tremendous draw for young people. They excite kids about science, math and engineering. They're open and accessible to kids, and something that really engages students well - capturing their minds and perhaps helping to shape their career choices. Locking these hobbies down to only certain areas closes the door to this opportunity. I can speak from experience - as my local AMA flying field is fenced in, closed off, and only open to those that have gate access, not the general public. Kids can't even come spectate. However when I fly my FPV and model aircraft at the local park, I get asked daily by children and adults about the hobby, and how they can become involved. Closing the door to this opportunity will do to UAS what product liability did to General Aviation in the mid 1980's. You'll kill it, and lock it out to the general public leaving it only for the corporations and the wealthy. I think you're potentially closing off opportunity for the organic growth and development of a burgeoning technology. You're taking the hobby away from children and hobbyists, and citing threats that have never materialized and can be addressed by other technology. Leave a door open to the tinkerers. Let the garage innovators build, test and fly things in their backyards, the local parks, and at schools. Put the burden on commercial operators to fly higher, above where the amature builders and student projects fly. Internet access isn't everywhere - and those places where networks haven't yet reached shouldn't be off limits to the general UAS flying public - they're our skies too. I hope you take these thoughts into consideration, and don't simply bow to the commercial interests and lock out the general public citing risks and threats that are being used to close the door on an exciting field of innovation.

 

[Mavic Air Head]

So, in other words, do you mean that we'll have to fly illegally in remote areas in the hope that there won't be any law enforcement around to bust us?

Not really. From my interpretation software would be updated that would reduce you to a 400" maximum radius and 400" maximum AGL no matter where you are. For me it would be a return to my youth and the blue and yellow COX trainer airplane with a string lanyard spinning around in circles till I fall down dizzy.

 

[sar104]

Not really. From my interpretation software would be updated that would reduce you to a 400" maximum radius and 400" maximum AGL no matter where you are. For me it would be a return to my youth and the blue and yellow COX trainer airplane with a string lanyard spinning around in circles till I fall down dizzy.

That's only for Limited Remote ID aircraft.

 

[Mavic Air Head]

That's only for Limited Remote ID aircraft.

Why of course it is. I thought that was what I was talking about. If your aircraft can self identify there's no problem, "Fly on Garth."

 

[sar104]

Why of course it is. I thought that was what I was talking about. If your aircraft can self identify there's no problem, "Fly on Garth."

Fair enough - you didn't specify that in your comment.