NEW FAA MARKING RULE

[The Safari Guy Usa]

I am sorrybif I missed the thread, but do we now need to mark the FAA registration number on the outside where it is visible? I marked each battery with a label and clear tape. Will that be fine?

 

[msinger]

Yes, you must mark your aircraft on an external surface.

I marked each battery with a label and clear tape. Will that be fine?

The FAA does not have a list of approved marking locations. The requirement is for "the registration number marking [to] be readily accessible and maintained in a condition that is readable and legible upon close visual inspection". See more details here:

External Marking Requirement for Small Unmanned Aircraft

This interim final rule requires small unmanned aircraft owners to display the unique identifier assigned by the FAA upon completion of the registration process (registration number) on an external surface of the aircraft. Small unmanned aircraft owners are no longer permitted to enclose the...

www.federalregister.gov

 

[JAW]

THE FOLLOWING INFORMATION IS NO LONGER CURRENT

The FAA says you have to place it in an area that can be accessed without the use of tools so I guess the old inside the battery compartment is good for the Mavics.

Q38. How do I mark my unmanned aircraft with the unique registration number?

A. You may use any method to affix the number, such as permanent marker, label, engraving, or other means, as long as the number is readily accessible and maintained in a condition that is readable and legible upon close visual inspection. If your unmanned aircraft has an easily accessible battery compartment you may affix the number in that compartment.

 

[msinger]

The FAA says you have to place it in an area that can be accessed without the use of tools so I guess the old inside the battery compartment is good for the Mavics.

That is the old rule and is no longer allowed. See the new rule I linked above.

 

[Mr. Salty]

More information: FAA Makes Major Drone ID Marking Change

 

[JAW]

That is the old rule and is no longer allowed. See the new rule I linked above.

I just finished the Part 107 Small Unmanned Aircraft Systems (Small Uas) Initial course, course number ALC-451. In the prep portion for the test, it stated you could place it in a compartment so long as it's accessible without tools. I'll go back and see if I can find it.
OK, here it is:

 

[msinger]

I cannot explain why course ALC-451 contains that information, but here's the current 14 CFR Part 48 reference from the sources listed in that course:

§ 48.205 Display and location of unique identifier.

(a) The unique identifier must be maintained in a condition that is legible.
(b) The unique identifier must be affixed to the small unmanned aircraft by any means necessary to ensure that it will remain affixed for the duration of each operation.
(c) The unique identifier must be legibly displayed on an external surface of the small unmanned aircraft.

14 CFR § 48.205 - Display and location of unique identifier.

www.law.cornell.edu

 

[JAW]

The rule allowing easily accessible locations was amended in February 2019. I guess the FAA never updated the test. I found this regarding putting your reg # in an easily accessible compartment. Once again, we are driven by potential terrorist threats:

Citing an sUAS’s possible payload of booby-trapped explosives, the FAA published the interim final rule earlier this month with “good cause for immediate action.” Clearly visible external registration will enable law enforcement officers and first responders to start the identification process without handling the drone to find a hidden registration number.

FAA Requires Clearly Visible External Registration Numbers on Drones | NBAA - National Business Aviation Association

To address security and safety concerns, owners and operators of small unmanned aircraft systems must clearly display the FAA-issued registration number on the exterior of their drones.

nbaa.org

I sent them an email regarding the inaccurate course information.

 

[PhantomFandom]

As already stated above, the current ruling is that it cannot be hidden in an inside compartment.

Although not specifically stated in the regulation, I would go further and say that it should be on the body of the drone itself and not on the battery. I say that because:
(b) The unique identifier must be affixed to the small unmanned aircraft by any means necessary to ensure that it will remain affixed for the duration of each operation.
Batteries do and have come loose either in flight or during an impact. If the battery comes loose then the identifier will not remain affixed for the duration of the operation.

(c) The unique identifier must be legibly displayed on an external surface of the small unmanned aircraft.
This one is iffy. Is the battery considered an external surface of the SUA? Yes I guess it can be considered as such. It could also be considered a removable part and not integral, and as such not really an external surface of the SUA itself.

Regulations aside, I always put the identifier (and my phone number) on the drone body itself. If something happens and the battery is separated from the drone, I want someone to be able to find it and be able to contact me.

 

[msinger]

Although not specifically stated in the regulation, I would go further and say that it should be on the body of the drone itself and not on the battery

FAA rules are often vague, but that's what I'm reading too.

There was another related thread a while back where someone (a few people actually) thought it was a brilliant idea to mark the number on the props. So, I emailed [email protected] to see what the FAA thought about that. Here's how they responded:

The intent of the new marking requirement is for a first responder to be able to approach a drone and identify it without having to pick it up. I think having the number on the prop meets the intent and the requirement.

SF

The fact that "SF" answered the question by stating he/she "thinks" doesn't give me much confidence in the reply.

 

[The Editor]

As already stated above, the current ruling is that it cannot be hidden in an inside compartment.

Although not specifically stated in the regulation, I would go further and say that it should be on the body of the drone itself and not on the battery. I say that because:
(b) The unique identifier must be affixed to the small unmanned aircraft by any means necessary to ensure that it will remain affixed for the duration of each operation.
Batteries do and have come loose either in flight or during an impact. If the battery comes loose then the identifier will not remain affixed for the duration of the operation.

(c) The unique identifier must be legibly displayed on an external surface of the small unmanned aircraft.
This one is iffy. Is the battery considered an external surface of the SUA? Yes I guess it can be considered as such. It could also be considered a removable part and not integral, and as such not really an external surface of the SUA itself.

Regulations aside, I always put the identifier (and my phone number) on the drone body itself. If something happens and the battery is separated from the drone, I want someone to be able to find it and be able to contact me.

The battery would not be considered as an external surface of the SUA. It would be classed as “Fuel” or power source

 

[tcope]

It is very important to get this correct... given the numerous times that the registration has been used to identify the illegal use of a drone over the past several years.

It changes so often... what is the number at this time?

 

[brett8883]

FAA rules are often vague, but that's what I'm reading too.

There was another related thread a while back where someone (a few people actually) thought it was a brilliant idea to mark the number on the props. So, I emailed [email protected] to see what the FAA thought about that. Here's how they responded:




The fact that "SF" answered the question by stating he/she "thinks" doesn't give me much confidence in the reply.

I dunno sounds like a thumbs up to me.

The battery would not be considered as an external surface of the SUA. It would be classed as “Fuel” or power source

Says who?

 

[msinger]

I dunno sounds like a thumbs up to me.

To me, it sounds like I only have the thumbs up from "SF" (whoever that is). I'd rather follow the official FAA rules as they are meant to be followed.

 

[brett8883]

To me, it sounds like I only have the thumbs up from "SF" (whoever that is). I'd rather follow the official FAA rules as they are meant to be followed.

I’m not really trying to argue I get your point but the rule say...

PART 48—REGISTRATION AND MARKING REQUIREMENTS FOR SMALL UNMANNED AIRCRAFT
1. The authority citation for part 48 continues to read as follows:

Authority: 49 U.S.C. 106(f), 106(g), 40101, 40103, 40113-40114, 41703, 44101-44103, 44105-44106, 44110-44113, 45302, 45305, 46104, 46301, 46306.

2. In § 48.205, revise paragraph (c) to read as follows:

§ 48.205 Display and location of unique identifier.
* * * * *
(c) The unique identifier must be legibly displayed on an external surface of the small unmanned aircraft.

Issued under the authority provided by 49 U.S.C. 106(f), 41703, 44101-44103, in Washington, DC, on December 21, 2018.

Daniel K. Elwell,

Acting Administrator.”

Would a prop not be an external surface by anyone’s definition? Surely no one would argue it’s an internal surface correct? Surely no one would argue the prop is not “of the drone” correct?

A FAA official authorized to speak on behalf of the administration who specifically answers questions from UAV pilots regarding clarification of rules regarding UAV regulations has also confirmed that, it in her view, it meets not only the language of the rule but also the intent of the rule.

What more are you looking for? Does acting director Elwell need to personally answer this question?

I get where you are coming from and I hope I don’t come off the wrong way but it seems you have provided us with a definitive answer to this question thank you.

 

[msinger]

Would a prop not be an external surface by anyone’s definition?

I'm not sure a removable aircraft accessory should be considered the aircraft. Even if it is, the rule also states the following:

"The unique identifier must be affixed to the small unmanned aircraft by any means necessary to ensure that it will remain affixed for the duration of each operation"

Since the props (and battery) can become detached mid-flight, one could not ensure the number will remain affixed if attaching it to an accessory that is commonly lost mid-flight.

A FAA official authorized to speak on behalf of the administration who specifically answers questions from UAV pilots regarding clarification of rules regarding UAV regulations has also confirmed that, it in her view, it meets not only the language of the rule but also the intent of the rule.

As you can see, this authorized FAA official did not seem to be sure his/her answer was correct or was giving his/her personal opinion. I wasn't looking for what someone "thinks" is the answer. I wanted to know exactly what the rule was stating.

What more are you looking for?

An answer from someone who is knowledgeable. The person who emailed me was clearly not qualified to answer this rather easy question.

it seems you have provided us with a definitive answer to this question

Someone who "thinks" they have the answer is not giving an answer that was reached decisively and with authority. So, no, it's not a definitive answer at all. Furthermore, since there is no guarantee the prop will remain attached to the aircraft, the FAA should probably never be recommending it as an okay location to affix the number (since that would be in violation of their rule).

I’m not really trying to argue I get your point but the rule say...

No worries. I'm not arguing either -- just sharing my point of view

 

[AMann]

I’ve worked with UXO teams at a ordinance test site, and the first thing they will tell you is to not move, pick up or take apart anything if you want to keep your life or your body parts. Just mark both the top and bottom of the outside and report it to authorities if it ever gets lost.

 

[brett8883]

I'm not sure a removable aircraft accessory should be considered the aircraft. Even if it is, the rule also states the following:

"The unique identifier must be affixed to the small unmanned aircraft by any means necessary to ensure that it will remain affixed for the duration of each operation"

Since the props (and battery) can become detached mid-flight, one could not ensure the number will remain affixed if attaching it to an accessory that is commonly lost mid-flight.


As you can see, this authorized FAA official did not seem to be sure his/her answer was correct or was giving his/her personal opinion. I wasn't looking for what someone "thinks" is the answer. I wanted to know exactly what the rule was stating.


An answer from someone who is knowledgeable. The person who emailed me was clearly not qualified to answer this rather easy question.


Someone who "thinks" they have the answer is not giving an answer that was reached decisively and with authority. So, no, it's not a definitive answer at all. Furthermore, since there is no guarantee the prop will remain attached to the aircraft, the FAA should probably never be recommending it as an okay location to affix the number (since that would be in violation of their rule).


No worries. I'm not arguing either -- just sharing my point of view

Again just friendly debate here but if a drone loses a prop or a battery inflight then this leads to no other result then a crash at which point there is no part of the aircraft that would meet your criteria.

I’m not sure what kind of flying you do but I could not characterize “losing a battery or prop” as common. This is usually the last flight of that particular drone.

It could lose a leg, a gimbal, a top cover etc. I think the “remains attached” part just means you can’t stick it on with one piece of scotch tape and call it good.

The props and battery remain attached through out flight barring a catastrophic failure just like any other part.

 

[brett8883]

I'm not sure a removable aircraft accessory should be considered the aircraft. Even if it is, the rule also states the following:

It’s not an accessory it’s a vital part of the aircraft and is required for flight. You wouldn’t characterize a prop driven planes prop as an accessory correct? They are also removable and replaceable no?

As you can see, this authorized FAA official did not seem to be sure his/her answer was correct or was giving his/her personal opinion. I wasn't looking for what someone "thinks" is the answer. I wanted to know exactly what the rule was stating.

An answer from someone who is knowledgeable. The person who emailed me was clearly not qualified to answer this rather easy question.

Someone who "thinks" they have the answer is not giving an answer that was reached decisively and with authority. So, no, it's not a definitive answer at all. Furthermore, since there is no guarantee the prop will remain attached to the aircraft, the FAA should probably never be recommending it as an okay location to affix the number (since that would be in violation of their rule).

If someone from the FAA replying to an email that was sent to [email protected]v is not qualified to answer questions about UAS regulations there is nobody who meets that criteria.

All this from one word? Could this be a case of you mistaking this person’s tone perhaps? I’ll give them a small amount of blame for not being more careful but you seem to not see the rest of the message.

If I called ATC at SLC and asked permission to land my drone on the runway and he says, “I don’t think that is a good idea,” that doesn’t mean that person is unqualified and doesn’t know what they are talking about.

You’ve done us a great favor by asking the highest authority we could ever hope to answer this question and they have!

 

[msinger]

I’m not sure what kind of flying you do but I could not characterize “losing a battery or prop” as common. This is usually the last flight of that particular drone.

The battery and props are two of the most commonly lost drone accessories. I didn't mean most people lose them.

It could lose a leg, a gimbal, a top cover etc

It could. But, those parts of the aircraft are rarely lost. And they are actually part of the aircraft since they are attached in a way that is not meant to be removed.

If someone from the FAA replying to an email that was sent to [email protected]v is not qualified to answer questions about UAS regulations there is nobody who meets that criteria.

So, you're saying the FAA has no employees that probably shouldn't be working there? I'm sure you can find such employees at any company

All this from one word?

Yes, sir. If you're explaining the law to someone and you work for the company that created the law, you should never (ever) be using the word "think" in a response. "I don't know" or "I'll find someone who knows and get back to you" would be a perfectly acceptable answer though.

You’ve done us a great favor by asking the highest authority we could ever hope to answer this question and they have!

Unfortunately, they haven't answered the question at all. They've only allowed someone to provide a confusing response. If the answer was clear, you and I wouldn't be discussing our opposing viewpoints.