My first stupid question.

[MARK (LI)]

^Mark, it goes on to say "....within their inventory...." which I suspect means every device you plan to "operate" under part 107 which would exclude the devices outside your inventory that are not under part 107 (i.e. recreational).

For example, if you own 6 heavy drones and you plan to fly 2 under part 107 and 4 are recreational, you must have a unique registration number for the 2 drones under part 107 and one common registration number for all the other 4 recreational drones. However, if those 4 recreational drones consist of 1 lightweight drone, then you would need one common registration number for only the 3 recreational drones and the 1 drone could be unregistered (i.e. it does not have to get a unique registration number under part 107).

Good calm discussion going on ...but you can't "suspect" or assume that is what they mean....... there is no wording excepting from a 107 holder's inventory, those drones intended for recreational flights....What is in black and white....and what can be assumed are not necessarily the same thing.......Maybe I am interpreting too literally.....but for the 5 dollars each drone .... I would prefer to be covered than not

 

[msinger]

you can't "suspect" or assume that is what they mean....... there is no wording excepting from a 107 holder's inventory, those drones intended for recreational flights....What is in black and white....and what can be assumed are not necessarily the same thing

Right, one should never assume if the rules seem unclear. Ask the FAA if you have any doubts.

With that said, post #39 above confirms the example from post #37.

 

[MARK (LI)]

Agree to disagree

 

[msinger]

Agree to disagree

That isn't very helpful. FAA rules are not something that is open for interpretation.

Can you provide more details? More specifically, please share the FAA links showing what we're saying above is not correct.

 

[MARK (LI)]

I am trying to avoid an argument with you...you have ignored what I copied and pasted WORD for WORD and asking for me to post it again....it is obvious that you are reading the rules one way....maybe my "interpretation" is stricter, more literal than yours....I have gotten my information directly from the FAA Drone Zone...I am not assuming or suspecting anything to bend or make regs more favorable for my interest...

 

[msinger]

you have ignored what I copied and pasted WORD for WORD and asking for me to post it again

My apologies. That's not at all what I was attempting to ask of you. You pasted screenshots of a website and I was unable to find it. Some additional googling led me to Remote Identification of Drones page where you snapped those screenshots.

Please note that webpage is about RID and not registering drones. The single sentence you highlighted could certainly be taken out of context if that's all you read on the topic of registering a drone.

Take a look at the How to Register Your Drone page. It covers all of the common registration questions.

Here are a few highlights related to our discussion above:

• All drones must be registered (except those that both weigh less than 250 grams and are only flown under the Exception for Limited Recreational Operations).
  
  
• There are two types of registrations:
  • Part 107 registration
  • Exception for Limited Recreational Operations registration
    
    
• Part 107 registration costs $5 per drone and is valid for three (3) years.
  
  
• Exception for Limited Recreational Operations registration costs $5, covers all drones in your inventory, and is valid for three (3) years.
  
  
• Once a drone is registered, its registration cannot be transferred between operation types (Part 107 or the Exception for Limited Recreational Operations).
  
  
• Drones registered under the Exception for Limited Recreational Operations cannot be flown under Part 107.

Can you show me on that page where it states a remote pilot certificate holder may only register a drone with a Part 107 registration? I don't see that mentioned anywhere (not even vaguely) and cannot find that mentioned anywhere else on the FAA's website.

As for this sentence you mentioned above:
"This is not the case for Part 107 pilots who must register each individual device (Standard Remote ID drone or Remote ID broadcast module) separately within their inventory and each device will get a unique registration number"

A remote pilot certificate holder may also fly as a "recreational drone pilot". I don't see anywhere on the FAA site where it states someone who holds a remote pilot certificate can only fly as a "Part 107 pilot".

As the FAA mentioned in these emails, a remote pilot certificate holder has the opportunity to determine which type of pilot they are at the time of takeoff. They always have the choice between following Part 107 rules or recreational rules.

Lastly, if you still have any doubts, give the FAA a call tomorrow. They may even be able to point you to a better source of information than I was able to find.

BTW, I'm not trying to argue with you. You asked for my opinion and I'm sharing publicly available facts.

 

[Vic Moss]

Without going through 46 different posts, let me see if I can clarify somethings since I was tagged.

OP asked about wifi and it seems this turned into a few different threads.

1) As others have mentioned, you do not need wifi to fly. There is some discussions (not just here) about the apps (Fly only I believe) logging folks out of their accounts, meaning if you are in a wifi and cellular denied area, and you're logged out, you have an issue. I have not experienced this, and if it is happening, it's very isolated. But I did reach out to one of my DJI contacts to check on this. I'll post when I here back. Unless she's in China, she'll likely get back to me this morning.

2) RID is required for ALL drones that are registered. Obviously any drone flown under 107 requires RID. And any drone flown under 44809, and is over 250 grams, also requires RID since they require registration. If you have a Mini 3 or Mini 4 Pro, and use the smaller batteries, you are NOT RID compliant. So if it's registered, it must have RID. Even if you're flying under 44809. If it's registered, and you want to fly under 44809 and w/o RID, technically you must remove it from your dashboards in the Drone Zone to be compliant. Yes, I know that's stupid, but that's the way it is. Will anyone care? Very unlikely, I'm just telling y'all what the rules are.

3) Registration: Anyone can register a drone under 14CFR 107. You do not need to be a Remote Pilot to have a 107 dashboard on the Drone Zone. Same with manned aircraft.

4) Yes, if you have your 107, and want to fly under 44809, you must have TRUST. I'm not sure if this is part of the thread or not, I'm just hopefully cutting that inevitable part of these discussions off at the pass. But you need TRUST only if you're planning on flying under 107. It's rare that would happen, but here are a couple of scenarios where TRUST is required. First, if you want to fly your <250g drone recreationally and w/o RID. In that case it is a 44809 flight since in order to be a 107 flight, the drone must be registered under 107. Second, it's the same case if you want to fly your buddy's new drone that is registered under 44809. Same reason as above.

The main reason I suggest everyone get their TRUST is that if someone comes up to you and asks about flying drones under 107, you'll be able to discuss TRUST with them from a position of authority since you took the test.

I think that covers most, if not all, of the questions in this thread. If not, ask below and I'll try and answer them.

 

[MARK (LI)]

Thank you @Vic Moss and @msinger .....we all agree that any drone that is registered requires RID ...the question is what drones require registration?... Using a strict reading of the rules as they are published on the official FAA Drone Zone, it says all drones in the 107 holder's inventory....there is no wording that exempts any sub 250 gram drones....I fully do understand that a 107 holder does not always fly under 107.....the wording in the regs could be more defining...also @Vic Moss ...could you take a look at your item #4

4) Yes, if you have your 107, and want to fly under 44809, you must have TRUST. I'm not sure if this is part of the thread or not, I'm just hopefully cutting that inevitable part of these discussions off at the pass. But you need TRUST only if you're planning on flying under 107. It's rare that would happen, but here are a couple of scenarios where TRUST is required. First, if you want to fly your <250g drone recreationally and w/o RID. In that case it is a 44809 flight since in order to be a 107 flight, the drone must be registered under 107. Second, it's the same case if you want to fly your buddy's new drone that is registered under 44809. Same reason as above.

I find this confusing. Did you mean when NOT flying 107?....I do recall when TRUST was introduced there were discussions on this site in which some 107 holders thought that they were exempt

 

[msinger]

the question is what drones require registration?

That has been answered in post #46 above.

 

[msinger]

I find this confusing. Did you mean when NOT flying 107?....I do recall when TRUST was introduced there were discussions on this site in which some 107 holders thought that they were exempt

Anyone flying under 44809 (recreationally) must have TRUST (more details on that here). The fact that someone holds a remote pilot certificate does not mean they cannot fly recreationally.

 

[MARK (LI)]

That has been answered in post #46 above.

I do not see where where it specifically exempts those sub 250 gram drones in a 107 holder's
inventory You say what you believe the regs say .....I am pointing out the written word.

Anyone flying under 44809 (recreationally) must have TRUST (more details on that here). The fact that someone holds a remote pilot certificate does not mean they cannot fly recreationally.

I asked @Vic Moss to clarify it because I believe it is a Typo at his end.....please read what he posted that I highlighted in red "But you need TRUST only if you're planning on flying under 107" ......I think he meant to say when you aren't going to be performing a 107 flight.

 

[msinger]

I do not see where where it specifically exempts those sub 250 gram drones in a 107 holder's
inventory

That's this first bullet point above:

"All drones must be registered (except those that both weigh less than 250 grams and are only flown under the Exception for Limited Recreational Operations)."

If a drone is only going to be flown under the Exception for Limited Recreational Operations, it could have an Exception for Limited Recreational Operations registration. And then that would mean you could never fly that drone under Part 107 rules.

I also linked to the FAA website where you can read the same at the source.

This is not what I believe. I've linked you to the actual written word. What I shared above is a summary highlighting the actual written word. But, please, go read the actual written word in full as it will likely make more sense.

If you don't understand the written word and/or believe we are sharing opinions in this thread, then you should definitely call the FAA for help.

 

[MARK (LI)]

And the actual word says


Read that last paragraph......it does not break out any of the sub 250 drones that a guy with 107 may own...maybe it was inadvertently left out by mistake
I do get what you are pointing out.......but you are not even considering what I am pointing out...this is not from some drone enthusiast magazine or something...it is from the same source that you are referencing...I am using screenshots rather than links to save you reading through all the surrounding material...and I do believe that you recognize the pages I am posting to be bona fide......are the items you are posting and the ones I am posting contradictory..or just confusing?...Are we both reading too much into it?...in any event I have TRUST, 107, all my drones are registered...I stick to the rules and I keep out of trouble...in all sincerity

Fly safely

 

[msinger]

I do get what you are pointing out.......but you are not even considering what I am pointing out...this is not from some drone enthusiast magazine or something...it is from the same source that you are referencing...I am using screenshots rather than links to save you reading through all the surrounding material...and I do believe that you recognize the pages I am posting to be bona fide

You're taking the FAA's actual written word out of context.

Please re-read post #46 above. It includes relevant details that the single sentence you're laser focused on does not consider.

 

[Droning on and on...]

For UA weighing 0.55 lbs or less, remote identification is only required if the UA is operated under rules that require registration, such as Part 107.

Source:
Executive Summary Final Rule on Remote Identification of Unmanned Aircraft (Part 89)

Still unclear: If operated under rules that do not require registration, is it required to broadcast RID if nonetheless registered?

 

[msinger]

Still unclear: If operated under rules that do not require registration, is it required to broadcast RID if nonetheless registered?

Vic covered that in post #47 above here:

"RID is required for ALL drones that are registered."

"Obviously any drone flown under 107 requires RID. And any drone flown under 44809, and is over 250 grams, also requires RID since they require registration."

That is also mentioned here:

"All persons operating unmanned aircraft (UA) registered or required to be registered under 14 CFR Parts 47 or 48 must comply with the operating requirements of Part 89 by September 16, 2023."

 

[Droning on and on...]

That isn't very helpful. FAA rules are not something that is open for interpretation.

Can you provide more details? More specifically, please share the FAA links showing what we're saying above is not correct.

Well, I think that's the very problem. I disagree, all language in law is open to interpretation, and we have courts for that very reason.

Circumstances not anticipated by legislators and regulators occur all the time, and rules that didn't directly address the issue, but seem confusing, contradictory, or unclear must be interpreted by the courts nonetheless.

I don't know why we're where we are with this, but clearly there is some lack of clarity if this many unquestionably above average intelligence people can be in this much disagreement.

Interpretation by the FAA is controlling here, let's ask 'em.

 

[mavic3usa]

Still unclear: If operated under rules that do not require registration, is it required to broadcast RID if nonetheless registered?

...and this is where we are going to have a problem.

If you decide you want to register your DJI Mini drone but you are not required because it is less than 250g *and* you fly recreational only, you will need to somehow enable standard RID *or* attach a broadcast module.

If you don't register your Mini drone then you cannot put a strobe light and a broadcast module on it and fly without first having to register. Then once you register, you cannot remove the broadcast module unless you de-register because:

"RID is required for ALL drones that are registered."

"....And any drone flown under 44809, and is over 250 grams, also requires RID since they require registration."

Overall, this is going to be a difficult task for recreational pilots with a Mini drone to accomplish.

 

[msinger]

Interpretation by the FAA is controlling here, let's ask 'em

I did send an email today to get an official answer to the question @MARK (LI) keeps asking above. Will post the response here.

 

[Droning on and on...]

Just submitted to the help center:

"Hello, on mavicpilots.com, the question arises regarding the corner case of a sub 250g drone, individually registered by a p107 certified pilot and used for commercial purposes some times, but also flown recreationally.​

When being flown recreationally by this pilot, is this individually registered drone required to broadcast RID? If flown by a strictly recreational pilot under the 44809 exception, and not individually registered under its serial number, it appears RID is not required to be broadcast.​

​

Does the status of the pilot as p107 certified, and/or the status of the drone as being individually registered with the FAA change this requirement, or can this drone be flown recreationally under 44809 while under 250g without broadcasting RID by the p107 certified pilot? Emphasis that this is not a commercial flight.​

​

This is an issue for DJI Mini 4 Pro owners, as RID broadcast is turned off when using the lighter of two battery options that keeps it under 250g.​

​

Thank you for your help!​

​

[name elided]"​