FAA Drone ID Proposal:

[Lon Denard]

Thanks. I think this point is important for those that think somehow the rules won't apply to them.

There will always be rules and there will always be ways around them. As of right now, the Mavic Mini is exempt. Period. In the future, paper airplanes, party balloons and kites may need ADS-B transponders... I guess we'll see.

 

[Phochief]

I finished reading the FAA's proposed rule-making document last night and believe that a method of transmitting a UAS's location is actually a good thing - BUT, I have a few concerns with the current proposal. I've written my concerns and will forward them to the FAA during the comments period. Rather than post my comments directly on the forum, I'm attaching a URL link to them HERE.

 

[Bob1956]

That’ll be the day I become a law breaker.

I truly think this will start a new industry of rouge, off the grid drones. Just like an RC plane, basic flight and camera controls, nothing else and with a dedicated controller, not a phone with an app.
The accidents will happen after this regulation not before.

And that has me wondering, what would make this machine different than an RC plane ? If I put a quality camera in my scale model P-51 what am I flying? I haven't kept up, do RC planes operate from phone apps now?

 

[Phochief]

Also, in case you think you can use any UAS that already has ADS-B:

"ADS-B Out equipment may not be used to comply with the remote identification requirements - 89.125"

 

[Deleted member 93449]

Somewhat unrealistic to expect to have the entire national airspace below 500 feet be given to hobbyists with toy airplanes. There is already a VLOS rule for UAV's that, as mentioned above, is doubtfully being followed. I know I can barely, if at all, see my dark grey Mavic Pro with unaided eyes when it's 400 feet away, that's really about the limit and only against the sky. It's virtually impossible to see against a landscape background such as hills or mountains. A few minutes of browsing YouTube will net you ample proof that the VLOS rule is regularly ignored.

It won't be given to just hobbyist. The major growth area will be the commercial use of drones.

I'm not buying that a sample of YouTube videos is an accurate accounting of how closely the VLOS rule is followed. Beyond that I seriously doubt this technology can't be bypassed by individuals that are bent on breaking the rules. But as mentioned, if the issue is really public safety check the statistic regarding how most aviation accidents and injuries occur. I can guarantee you (because I've checked) it's not manned aircraft collisions with drones. That being the case put the $500 million dollars in the direct of where safety is most lacking.

 

[Deleted member 93449]

I doubt there are enough active drones at any one time to saturate the system but I just put the cheapest ADS-B-out system available in my airplane and it was about three times the cost of a Mavic - just for parts and that's the add-on I had to already have a mode C transponder.

What does this thing do: Ping20si

And how much could the cost be reduced if a couple hundred thousand were ordered?

 

[Bob1956]

This is just my opinion but based on the public opinion of drones in general I have a feeling that this whole idea of filling the sky with commercial package delivery drones is destined to be an abject failure. People are simply not going to put up with these contraptions constantly flying over their houses to make noisy, intrusive deliveries of ridiculously non-essential products to residential properties. The operator will be potentially pissing off a swath of people along the entire flight path. It will be a nightmare. I don't know who came up with this idea but they're nuts.

As for recreational drones. Yes, there may be millions of them out there but the vast majority of those rarely or never get flown again a month or two past Christmas and spend the rest of their lives in a closet with all the other forgotten toys.. The size of actual enthusiasts that regularly fly them is relatively small and for non-enthusiasts they get boring pretty quickly.

As for the new rules - the idea is that a whole bunch of people are gonna make a whole bunch of money and you ain't one of them. That's the way it always is, get used to it. But refer back to my first paragraph, looks like a bust to me.

I live out in farmland straight line about 20 miles from the big city, 35 miles to drive but that's the way it is in hill country. We don't have enough people on our road for the cable TV companies to turn a profit so everybody has dishes. We're about 6 miles from two small towns.

I'm not expecting an Amazon delivery drone out here for another 20 years. A pizza drone maybe ten.

And that brings up VLOS. We have to obey it but the delivery drone operators won't. They'll just type in the address and hit "launch". That drone won't cross their minds again until comes back.

 

[BigAl07]

I truly think this will start a new industry of rouge, off the grid drones. Just like an RC plane, basic flight and camera controls, nothing else and with a dedicated controller, not a phone with an app.
The accidents will happen after this regulation not before.

And that has me wondering, what would make this machine different than an RC plane ? If I put a quality camera in my scale model P-51 what am I flying? I haven't kept up, do RC planes operate from phone apps now?

This isn't a MultiRotor restriction.. it's about all R/C aircraft planes, heli AND multirotors.

 

[Bob1956]

That’ll be the day I become a law breaker.

How do register your back yard as a sanctioned RC field? RC fields might start popping up like daisies soon.

 

[sar104]

Here is a great article written by our very own Vic Moss @Vic Moss

He tells it like it is and with experience and a vast knowledge of our industry under his belt. Vic isn't against Remote ID but he is for a smart approach and this article is the icing on the cake.

FAA Announces New Remote ID Technology...Why are We Disappointed?

How FAA's New Remote ID Proposal Will Endanger the Drone Pilot's Safety and End Up Hurting the Drone Industry As a Whole

www.thedroneu.com

I was actually a little disappointed in that article. His main objections seem to be:

1. Operator location data being made publicly visible by the USS could endanger operators;
2. Cost of the USS subscription ($2.50 / month);
3. Huge cellular data costs;
4. Inability to conduct some kinds of operations (especially commercial) under option 2 (Limited Remote Identification - internet connection only).

(1). That's arguable - the case can certainly be made that such information should be restricted to ATC/LE - but he weakens his case by saying that he and his VO always wear high-visibility vests and want people to be able to find them.

(2). $2.50 doesn't seem like it should be a significant cost to anyone flying a 0.55 + lb UAV, although by analogy with the LAANC system one could argue for it being a free service. Judging by the success of the Mini, I would expect that the low cost UAV market is rapidly going to be dominated by small aircraft that don't fall under this proposal at all.

(3). This is simply incorrect - the quantity of data proposed to be transmitted is tiny. The required elements are, conservatively, not going to exceed 15 bytes. Even if it transmits those at the ADS-B rate of 1 Hz, which seems unnecessarily high, that's just 15 kB over a 1000 second flight.

(4). Quite true, but no one attempting to conduct those kinds of operations is likely to be using a Limited Remote Identification aircraft.

Beyond that, he says that he is pro UAS Remote ID, but doesn't give any suggestions for how this could be done better other than limiting the use of operator location data.

 

[Deleted member 93449]

I finished reading the FAA's proposed rule-making document last night and although I agree that for safety's sake, a method to transmit a UAS's Remote ID is actually a good thing, I have a few concerns with the current proposal. I've written a response to the proposed rule-making and will forward it to the FAA during the comments period. Rather than post my thoughts directly on the mavic pilots website, I'm attaching a URL link to it HERE.

For safety's sake? Not to rehash this but what safety issue are we trying to mitigate. There have been no confirmed accidents between drones and manned aircraft. No injuries, no fatalities. On the other hand there have been scores of general aviation accidents and fatalities and the numbers according to one source is on the rise. Why are planning to spend upwards of $500 million dollars on a "problem" that has caused no injuries or deaths when there are known causes of hundreds of injuries and deaths associate with other aviation related activities?

 

[Phochief]

For safety's sake? Not to rehash this but what safety issue are we trying to mitigate. There have been no confirmed accidents between drones and manned aircraft. No injuries, no fatalities. On the other hand there have been scores of general aviation accidents and fatalities and the numbers according to one source is on the rise. Why are planning to spend upwards of $500 million dollars on a "problem" that has caused no injuries or deaths when there are known causes of hundreds of injuries and deaths associate with other aviation related activities?

Sorry, but did you read my comments? I point out exactly what you just said.

 

[Deleted member 93449]

I was actually a little disappointed in that article. His main objections seem to be:

1. Operator location data being made publicly visible by the USS could endanger operators;
2. Cost of the USS subscription ($2.50 / month);
3. Huge cellular data costs;
4. Inability to conduct some kinds of operations (especially commercial) under option 2 (Limited Remote Identification - internet connection only).

(1). That's arguable - the case can certainly be made that such information should be restricted to ATC/LE - but he weakens his case by saying that he and his VO always wear high-visibility vests and want people to be able to find them.

(2). $2.50 doesn't seem like it should be a significant cost to anyone flying a 0.55 + lb UAV, although by analogy with the LAANC system one could argue for it being a free service. Judging by the success of the Mini, I would expect that the low cost UAV market is rapidly going to be dominated by small aircraft that don't fall under this proposal at all.

(3). This is simply incorrect - the quantity of data proposed to be transmitted is tiny. The required elements are, conservatively, not going to exceed 15 bytes. Even if it transmits those at the ADS-B rate of 1 Hz, which seems unnecessarily high, that's just 15 kB over a 1000 second flight.

(4). Quite true, but no one attempting to conduct those kinds of operations is likely to be using a Limited Remote Identification aircraft.

Beyond that, he says that he is pro UAS Remote ID, but doesn't give any suggestions for how this could be done better other than limiting the use of operator location data.

The problem (or lack of one) is you begin your argument from the second floor. There have been ZERO confirmed collisions between drones and manned aircraft and no injuries or fatalities. Even if you credit the unconfirmed reports as being confirmed they amount to a handful with no injuries or deaths. So what are we mitigating with the $500 million dollars being spent?

We don't need to speculate about safety issues in aviation. There are real safety issues that are causing injuries and deaths. Before dollar one is spent on speculative disasters deal with the known issues that are causing injuries and deaths.

 

[Deleted member 93449]

Sorry, but did you read my comments? I point out exactly what you just said.

When your comments start with "I agree that for safety's sake..." it sort of throws me off that you're not claiming this system is needed for reasons of safety.

 

[dawgpilot]

How do register your back yard as a sanctioned RC field? RC fields might start popping up like daisies soon.

The proposal says that only recognized community organizations (such as the AMA) can apply for the establishment of "identification areas" where remote ID won't be required.

 

[Phochief]

When your comments start with "I agree that for safety's sake..." it sort of throws me off that you're not claiming this system is needed for reasons of safety.

Ok, I re-worded my original post. but was hoping folks would read my actual comments. Do you think it would be a good idea to have drones transmit our locations so that Air Traffic Controllers and other pilots know where we are flying?

 

[JAW]

There have been ZERO confirmed collisions between drones and manned aircraft and no injuries or fatalities.

Not true.
Confirmed collision was a DJI Phantom vs. a UH-60 Blackhawk helicopter operated by the NJ Army National Guard out of Teterboro airport.. The owner of the drone was identified via the serial number on one of its motors that was embedded in body of the helicopter.

NTSB Finds Drone Pilot At Fault For Midair Collision With Army Helicopter

The NTSB determines the drone operator was at fault in a collision with a U.S. Army Black Hawk in September.

www.forbes.com

 

[deleted member 877]

I'm not buying that a sample of YouTube videos is an accurate accounting of how closely the VLOS rule is followed.

Of course it's not going to represent an accurate accounting of how closely the VLOS rule is followed. But add in all of the relevant content from other sources such as this forum and you begin to get a pretty good idea of what is going on.

Apart from that, when quoting mid-air collision statistics, why are you apparently not considering the fact that there are a great many more manned aircraft sharing the airspace at any given time compared to drones? Also drone operators tend not to form groups that launch and land their aircraft in the same area (like a runway).

 

[Deleted member 93449]

Not true.
Confirmed collision was a DJI Phantom vs. a UH-60 Blackhawk helicopter operated by the NJ Army National Guard out of Teterboro airport.. The owner of the drone was identified via the serial number on one of its motors that was embedded in body of the helicopter.

NTSB Finds Drone Pilot At Fault For Midair Collision With Army Helicopter

The NTSB determines the drone operator was at fault in a collision with a U.S. Army Black Hawk in September.

www.forbes.com

Thank you for the one. Now go find a dozen more and a few that have caused and injury or death and you still won't come close to making a case for public safety in contrast to other causes of aviation accidents, injuries and deaths.

 

[Deleted member 93449]

Of course it's not going to represent an accurate accounting of how closely the VLOS rule is followed. But add in all of the relevant content from other sources such as this forum and you begin to get a pretty good idea of what is going on.

Apart from that, when quoting mid-air collision statistics, why are you apparently not considering the fact that there are a great many more manned aircraft sharing the airspace at any given time compared to drones? Also drone operators tend not to form groups that launch and land their aircraft in the same area (like a runway).

You make my cases for a solution looking for a problem.