M3P RFID disabled w/ 249gr battery?

[JDubyaM]

Since viewing this Pilot Institute weekly update, I've been searching in vain trying to find any details, including the update number. As reported, a "recent" update has removed RFID when using the 249g battery. Anybody have any information on this? If true, it's a really dumb ( or shrewd) change by DJI to force 107 pilots to buy the extended range batteries or a RFID module for their M3P.
Story starts at 5:50.

 

[mavic3usa]

I see this feature has been implemented in the latest software update to the Mini 3 and the Mini 4 Pro but I don't see the same for the Mini 3 Pro:

DJI Mini 3 Release Notes

DJI Mini 3 - So Fly - DJI

DJI Mini 3 is a compact, ultra-lightweight camera drone, ready for adventure. It features an extended battery life, stunning 4K HDR, and True Vertical Shooting.

www.dji.com

Copyright © 2024 DJI All Rights Reserved. 1
Date: 2024.01.25
Aircraft Firmware: v01.00.0410
DJI RC-N1 Remote Controller Firmware: v04.16.0500
DJI RC Remote Controller Firmware: v01.03.1200
DJI Fly App iOS: v1.12.8
DJI Fly App Android: v1.12.8
What’s New
 Added support for civil uncrewed aircraft owners to register their aircraft with CAAC using their real
names to comply with the uncrewed aircraft-related regulations in China.
 Added support for automatically activating the US Remote ID only when the aircraft is used with an
Intelligent Flight Battery Plus.
 Fixed some known issues.

 

[JDubyaM]

Listening again closely to Greg's narrative he did say " The Mini 3 and Mini 4 Pro", not "The Mini 3 Pro and the Mini 4 Pro", so maybe the Mini 3 Pro isn't affected? Confusing as the image used is of the Mini 3 Pro and the Mini 4 Pro.

 

[mavic3usa]

Since viewing this Pilot Institute weekly update, I've been searching in vain trying to find any details, including the update number. As reported, a "recent" update has removed RFID when using the 249g battery. Anybody have any information on this? If true, it's a really dumb ( or shrewd) change by DJI to force 107 pilots to buy the extended range batteries or a RFID module for their M3P.

The way I understand it, as of today the Mini 3 and the Mini 4 Pro arrive with the RID feature turned off. If you fly with the standard lightweight battery, the RID will remain off and the drone will not broadcast RID. This is what millions of US recreational drone flyers wanted; the ability to fly a sub 250g drone with no RID.

If you are a commercial pilot and you buy the same drone that millions of drone pilots are using for recreational purposes which contains no active RID, it sounds like you need to insert the extended battery which should activate RID for you. If you don't have access to the battery, you still have the option to attach an external broadcast RID module and continue with your commercial usage.

I don't see any of this for the Mini 3 Pro and it could be the case because there are so many M3P drones flying around with RID (especially being a Pro and commercial usage)....might be a confusing implementation. Being a Pro drone might be enough to keep the status quo. IMO, the Mini 3 is primarily a recreational drone and it should ship with RID deactivated; however, I'm not sure how DJI gets away with this since the M3 is listed as RID compliant on teh FAA RID database where you'll find a DoC with a valid serial number range:

Serial #: 1581F5YH000000000000 - 1581F5YHFFFFFFFFFFFF

What I don't know is once you activate RID, does it forever stay ON or does it turn off again once you go back to the standard lightweight battery. I don't believe using strobes or other accessories will cause the RID to activate, I believe it is only a battery-activated feature. So you'll need to trigger it with a battery....or use an RID broadcast model....or maybe revert back to older software?

 

[pilotinstitute]

Listening again closely to Greg's narrative he did say " The Mini 3 and Mini 4 Pro", not "The Mini 3 Pro and the Mini 4 Pro", so maybe the Mini 3 Pro isn't affected? Confusing as the image used is of the Mini 3 Pro and the Mini 4 Pro.

EDITING MY PREVIOUS RESPONSE. DJI confirmed that the Mini 3 Pro is not affected. So this only applied to the Mini 4 Pro and Mini 3 only.

 

[pilotinstitute]

Since viewing this Pilot Institute weekly update, I've been searching in vain trying to find any details, including the update number. As reported, a "recent" update has removed RFID when using the 249g battery. Anybody have any information on this? If true, it's a really dumb ( or shrewd) change by DJI to force 107 pilots to buy the extended range batteries or a RFID module for their M3P.
Story starts at 5:50.

I actually don't think it's a ploy to sell more battery but rather a way for DJI to try to satisfy the majority of people who fly the Mini, aka recreational users.
The problem is, DJI can't win on this one, they will either piss off the recreational flyers who don't like that they are forced into broadcasting RID when they legally don't have to, or piss off the part 107 pilots who will now need to use a module if they fly with the smaller battery. They decided to please the largest segment of the population.

 

[JDubyaM]

I actually don't think it's a ploy to sell more battery but rather a way for DJI to try to satisfy the majority of people who fly the Mini, aka recreational users.
The problem is, DJI can't win on this one, they will either piss off the recreational flyers who don't like that they are forced into broadcasting RID when they legally don't have to, or piss off the part 107 pilots who will now need to use a module if they fly with the smaller battery. They decided to please the largest segment of the population.

Thanks for this Greg. I hadn't dug into the sales demographics on the Mini 3 Pro and had guessed it was more evenly split between user types. Still, DJI should offer a user activated option to override the RFID off with the small battery. A Part 107 pilot has already gone to the trouble to learn and pass the Regs and should be trusted with that ability to stay in compliance with the FAR's.

 

[RetiredInFL]

I actually don't think it's a ploy to sell more battery but rather a way for DJI to try to satisfy the majority of people who fly the Mini, aka recreational users.
The problem is, DJI can't win on this one, they will either piss off the recreational flyers who don't like that they are forced into broadcasting RID when they legally don't have to, or piss off the part 107 pilots who will now need to use a module if they fly with the smaller battery. They decided to please the largest segment of the population.

They please them but sort of unknowingly force many recreational flyers to fly illegally when they don't read the details of every firmware update or ASSume RID is always being sent (or always not being sent). Tough choice DJI has to make but makes Mini4 rec flyers possible FAA targets (tin foil hat on). They should have to force all users to "agree" to this situation and clearly explain it at some point in the advertising->purchase->use chain.

 

[RetiredInFL]

My "suggestion" (for what it's worth which is likely nothing) is maybe DJI can have a software workaround by allowing the user to set a software switch saying they have the larger battery installed when they don't thereby turning RID on. That would avoid the illegality of allowing a consumer to turn RID off or on full time with either battery. When the drone senses it has the small battery, which it obviously can, having a popup option to "turn on RID" only when the small battery is in use.

 

[mavic3usa]

My "suggestion" (for what it's worth which is likely nothing) is maybe DJI can have a software workaround by allowing the user to set a software switch saying they have the larger battery installed when they don't thereby turning RID on. That would avoid the illegality of allowing a consumer to turn RID off or on full time with either battery. When the drone senses it has the small battery, which it obviously can, having a popup option to "turn on RID" only when the small battery is in use.

But that won't work.

A commercial pilot using their FAA registered Mini on the job can turn off RID, that's not good. If you can turn it ON, you can turn it OFF. That's what is happening, just because it doesn't have a direct OFF button....

In any case, such a switch violates the spirit of the FAA regulation and may even cause the Mini 3 to get it's DoC rescinded.

 

[RetiredInFL]

But that won't work.

A commercial pilot using their FAA registered Mini on the job can turn off RID, that's not good. If you can turn it ON, you can turn it OFF. That's what is happening, just because it doesn't have a direct OFF button....

In any case, such a switch violates the spirit of the FAA regulation and may even cause the Mini 3 to get it's DoC rescinded.

You are missing the point of my "fix". . Since DJI can sense from their intelligent battery (or the drone itself) that the small battery is installed and automatically and forcibly TURN OFF or basically LEAVE OFF RID (which I am sure the Feds would prefer to be on all the time anyway) they could also sense that when the small battery is installed to allow you a software option to turn ON RID. If you turned it back off it would be no change from the default setting so basically you can still be illegal if you so choose but at least you have the CHOICE to be legal.

I still say there will be some sort of fix for this by them. Sad part is, most folks who just buy these as "toys" have no clue or care whether RID is on or off no matter how they customize their toy unless they hang out on forums like this. And for me, again, HAD I KNOWN this was the path they were going to take BEFORE purchasing it (RID was always on at that time) I would have purchased the larger battery FMK because I don't give a hoot if I my RID is visible in fact I feel it should be all the time. They should swap out batteries for those of us who want to stay legal. Yea right.

 

[mavic3usa]

Reminder from the FAA:

A person can operate a standard remote identification unmanned aircraft only if: (1) it has
a serial number that is listed on an FAA-accepted declaration of compliance; (2) its remote
identification equipment is functional and complies with the requirements of the rule from
takeoff to shutdown; (3) its remote identification equipment and functionality have not been
disabled; and (4) the Certificate of Aircraft Registration of the unmanned aircraft used in the
operation must include the serial number of the unmanned aircraft, as per applicable
requirements of parts 47 and 48, or the serial number of the unmanned aircraft must be provided
to the FAA in a notice of identification pursuant to § 89.130 prior to the operation.

Source: https://www.faa.gov/sites/faa.gov/files/2021-08/RemoteID_Final_Rule.pdf

Ok, let's talk about this:

.....they could also sense that when the small battery is installed to allow you a software option to turn ON RID.

Keep in mind, RID doesn't appear to be your "thing" to play with as a pilot. The above statement tells you when your drone is allowed to broadcast RID. It cannot be left up to a switch. You are not supposed to broadcast RID unless you have a serial-number listed in the DoC and if so, that means you need to be in the FAA database.

And you know what that means? If you are listed in the FAA database, every time those props start, RID needs to broadcast. Honestly, I don't know if the current DJI implementation is compliant but it's not my call.

If you turned it back off it would be no change from the default setting so basically you can still be illegal if you so choose but at least you have the CHOICE to be legal.

This is what the FAA says about RID and a switch and it has less to do with being "legal" or not and more to do with whether there is a DoC for your serial number:

§ 89.310 Minimum performance requirements for standard remote identification unmanned aircraft.​

A standard remote identification unmanned aircraft must meet the following minimum performance requirements:

(a) Control station location. The location of the control station of the unmanned aircraft must be generated and encoded into the message elements and must correspond to the location of the person manipulating the flight controls of the unmanned aircraft system.

(b) Time mark. The time mark message element must be synchronized with all other remote identification message elements.

(c) Self-testing and monitoring.
(1) Prior to takeoff, the unmanned aircraft must automatically test the remote identification functionality and notify the person manipulating the flight controls of the unmanned aircraft system of the result of the test.
(2) The unmanned aircraft must not be able to take off if the remote identification equipment is not functional.
(3) The unmanned aircraft must continuously monitor the remote identification functionality from takeoff to shutdown and must provide notification of malfunction or failure to the person manipulating the flight controls of the unmanned aircraft system.

(d) Tamper resistance. The unmanned aircraft must be designed and produced in a way that reduces the ability of a person to tamper with the remote identification functionality.

Source: Federal Register :: Request Access

Disclaimer: The internet is full of FAA documentation and as a layperson and non-expert, I don't always find the latest and most current information to quote. Often the documents are in draft, have changed, or there is superseding information so please understand this caveat which basically says I could be way off base. I have no idea who is following the rules, or not.

 

[pilotinstitute]

FYI, we made a video to explain this mess.

 

[mavic3usa]

Excellent explanation, good discussion; appreciate the update!

You are correct I hadn't see anything yet on my Mini 3 Pro so as I suggested earlier, DJI is probably waiting to see how it goes, maybe still sorting out the FAA DoC, or considers the Pro more of a commercial than recreational drone. Honestly, as a recreational pilot, I prefer to broadcast and let it be.

Perhaps in your next video or when the right time comes in March, you can help us all understand the fiasco which is the DoC for these drones which presently makes no sense. You covered part of it with the segment on owning both batteries....but everyone has to know that no one will comply with that disaster. The ordinary person doesn't have the knowledge to be able to sort this, won't have a module or a scale handy, and after reading the regulations, I don't see anything that talks about ownership of batteries. I think you have to register if you *use* the heavy battery but you don't have to register just because you *own* it.

Anyway, I think where this is going to cause the most confusion is the part where you mentioned using the smaller battery (and therefore not transmitting) but your drone is registered in the FAA database....we talked about this many times in the past and the consensus was you didn't have to do anything extra. But I always thought if your drone is registered in the FAA database then at all times while it is registered (and not deleted), it must transmit those same details, regardless. Unless you substitute using an external module which will be transmitted. Either one...but you cannot fly without RID as long as it is registered and I think this is what you said in the video, right?

And then, you can take it one more step. If there is a DoC for your serial number, you cannot fly that drone unless it is registered. Not even with a broadcast module. A DoC means standard RID and the rules for standard RID means broadcast standard RID properly or don't lift off. You can't disable your standard RID and then substitute with a broadcast module (because you want to hide the control station). Is this true?

And finally, nobody wants to bring this up but there is this thing called "RID sticker" which is different than the registration sticker (but I understand some may debate this is the OEM responsibility).

So much confusion, hello FAA.

 

[Droning on and on...]

I actually don't think it's a ploy to sell more battery but rather a way for DJI to try to satisfy the majority of people who fly the Mini, aka recreational users.
The problem is, DJI can't win on this one, they will either piss off the recreational flyers who don't like that they are forced into broadcasting RID when they legally don't have to, or piss off the part 107 pilots who will now need to use a module if they fly with the smaller battery. They decided to please the largest segment of the population.

^^This.

However, they did it on the cheap, maybe driven by schedule, and we'll see a more complete implementation in a future release.

What am I talking about? A simple switch in DJI Fly to turn it on if using the 249g battery. This control would be ON and grayed out (unchangable) with the extended battery. It would be OFF with the lighter battery by default, but could be switched ON if you attach strobes, cages, or something that takes it over 250g.

That would require spending on the engineering in Fly, then having a simultaneous release with the drone firmware. Those of you involved in big multi-part software systems understand why this may not have been reasonable to do, especially if this was a feature not originally planned.

I hope they add the ability to turn it on in the future.

 

[mavic3usa]

What am I talking about? A simple switch in DJI Fly to turn it on if using the 249g battery. This control would be ON and grayed out (unchangable) with the extended battery. It would be OFF with the lighter battery by default, but could be switched ON if you attach strobes, cages, or something that takes it over 250g.

So with this implementation, when you insert the 249g battery, the pilot can turn the switch ON or turn the switch OFF depending on how he feels that day, correct? Regardless, the rotors will turn and you can take off whether the RID checks out or not, right? During flight, if you decide you don't want to transmit, turn off RID and go into stealth mode, ok? And none of this is tied into the FAA database or the drone's actual registration. Just how many of the FAA rules and regulations on RID implementation are we planning on overlooking here?

 

[Droning on and on...]

So with this implementation, when you insert the 249g battery, the pilot can turn the switch ON or turn the switch OFF depending on how he feels that day, correct? Regardless, the rotors will turn and you can take off whether the RID checks out or not, right? During flight, if you decide you don't want to transmit, turn off RID and go into stealth mode, ok? And none of this is tied into the FAA database or the drone's actual registration. Just how many of the FAA rules and regulations on RID implementation are we planning on overlooking here?

I'm not following you.

Unless I'm missing something in the regulations, a sub 250g drone is not required to broadcast RID. As I've seen nothing in the RID section of the regs saying it's prohibited to under 250g, nor have I ever seen such an idea ever mentioned by anyone, I'm assuming the FAA doesn't care if a sub 250g drone transmits RID.

I offer as further evidence that the Mini 3 Pro does transmit RID when under 250g, and is FAA compliant, so that's pretty convincing juju to me the FAA doesn't care.

So yes, every action you describe above if the feature I describe existed would be entirely legal.

I'm really not understanding your criticism.

 

[Droning on and on...]

And none of this is tied into the FAA database or the drone's actual registration. Just how many of the FAA rules and regulations on RID implementation are we planning on overlooking here?

Doesn't this describe every Mini 3 Pro flying out there right now under 250g? What rules are being overlooked?

Speculation: I think this all hinges on what the FAA defines as a, "standard remote identification unmanned aircraft" as the term is used in §89.310 and elsewhere in the regs.

I suspect the definition includes weight greater than 250g, and this is why compliant mini 3 aircraft can be flying around broadcasting incomplete RID information, and yet have been approved by the FAA: They don't care.

Really, this is a tiny corner case. I can see why the FAA would just ignore this little bit of ambiguity.

Where there is a meaningful problem for the pilot is using a Mini 3 with the lighter battery but made overweight with a strobe. This configuration can not be made flyable by adding an external RID module, as the regs require the built-in RID be used if present.

So, the extended battery must be used to turn on RID. Not a onerous workaround, but functionally no different than a switch in the app for situations where the drone is over 250g but you want to use the lighter battery.

Maybe it's the last battery you have after using your extended batteries.

 

[mavic3usa]

I'm not following you.

Unless I'm missing something in the regulations, a sub 250g drone is not required to broadcast RID. As I've seen nothing in the RID section of the regs saying it's prohibited to under 250g, nor have I ever seen such an idea ever mentioned by anyone, I'm assuming the FAA doesn't care if a sub 250g drone transmits RID.

I offer as further evidence that the Mini 3 Pro does transmit RID when under 250g, and is FAA compliant, so that's pretty convincing juju to me the FAA doesn't care.

So yes, every action you describe above if the feature I describe existed would be entirely legal.

I'm really not understanding your criticism.

Let's say DJI implements this switch.

The part of the video which covers this starts at 1:52 called Small Battery Only. When you attach a strobe to your drone and you turn ON the switch to transmit the details, you are legal when you go to the FAA database to register your details. No module needed, you have standard RID via a switch.

The next part of the video which covers a drone which can do both starts at 3:46 called Both Batteries. He says something along the lines "because the drone is registered, you need to follow the FAA rules regarding RID." Sounds like you cannot just switch OFF the broadcast (because you would be a registered drone which does not comply with RID). Obviously you can go into the FAA and remove your drone....but because the switch doesn't do this, I believe the switch is not allowed. The switch would permit drone flyers to fly a registered drone without transmitting the RID details and the switch would permit drone flyers to fly a drone which must be registered (because you have strobe lights) without transmitting the RID details (by setting the switch to OFF).

Bottom line I believe the FAA has a regulation that covers the use of a switch....I can't find it right now but I recall reading it is not allowed.

 

[mavic3usa]

Doesn't this describe every Mini 3 Pro flying out there right now under 250g? What rules are being overlooked?

Speculation: I think this all hinges on what the FAA defines as a, "standard remote identification unmanned aircraft" as the term is used in §89.310 and elsewhere in the regs.

I suspect the definition includes weight greater than 250g, and this is why compliant mini 3 aircraft can be flying around broadcasting incomplete RID information, and yet have been approved by the FAA: They don't care.

Really, this is a tiny corner case. I can see why the FAA would just ignore this little bit of ambiguity.

Where there is a meaningful problem for the pilot is using a Mini 3 with the lighter battery but made overweight with a strobe. This configuration can not be made flyable by adding an external RID module, as the regs require the built-in RID be used if present.

So, the extended battery must be used to turn on RID. Not a onerous workaround, but functionally no different than a switch in the app for situations where the drone is over 250g but you want to use the lighter battery.

Maybe it's the last battery you have after using your extended batteries.

I dunno, perhaps a drone which weighs 251g is also a tiny corner case to the FAA, no? If the FAA would just ignore this piece as well, I think most of this goes away. Also if the FAA "don't care" then none of this is relevant. I know one thing for sure, the majority of the public don't know or don't care.