FAA Remote I.D.

[Dave Pitman]

I don't see any coherent theme to the objections posted other than "I don't want to be tracked".

I can't speak for anyone else but a few of my objections to the proposed rules as written are: (not in any order)

• Regulations in general should be as little restrictive as possible while getting the desired result. They should result in the most simple and least expensive regulation as practical. Elements of the regulation should actually address what the agency says is reason for the regulation.
  • This rule, as proposed, is far more complex and expensive than in needs to be.
  • The FAA says we need Remote ID in order to enhance safety, particularly between manned and unmanned aerial vehicles. This proposal does not directly do that at all.
  • Laws and regulations exist for a reason. The FAA has not offered any data to suggest such a complicated and expensive system is even necessary. Since they propose that others pay for it all, then I guess they have nothing to loose by trying. There are much simpler and inexpensive ways to enhance safety in the NAS. I propose we try those first.
• The proposal establishes a "Pay for access" to the NAS.
  • With a broadcast only scheme, it would place the cost of accessing information about uas flight in the area to those that are interested in the knowing, not the operator. RID is likened to a license plate for uas. But you don't stream your car's location onto a network to enhance safety or accountability on the roadway. Why then do we need to do something similar to make the NAS safer? If someone thinks that a uas in the area is flying where they shouldn't be, they can acquire and check their scope. If they want to record all the traffic in a particular area, they can install equipment to record the broadcasts. Again, it places the burden and cost on the one wanting to know.
  • General aviation has fought long and hard against paying for access to the NAS. General aviation does contribute $ to the system through fuel tax. uas could contribute through registration fees. or some other fair system. The FAA expects USS to cost $2.50 per month. But that is simply a guess and they would retain no control over those fees.
• The FAA wants accountability from those flying uas.
  • There is almost no way to enforce this proposed regulation. Operation under this proposed regulation would be policed exactly the same as it is now. Almost not at all.
  • Broadcast RID would provide the same accountability at little to no cost to the operator.
  • Admittedly, a live broadcast only system would not result in a database of all flights in order to be able to look back in time. But the FAA has not offered any data as to why they need such a database.
• The proposal makes no less restrictive allowance for operation in uncontrolled airspace areas,. Not even over private property.
  • This is far more restrictive than even manned aviation which actually has a history of killing people.
  • Again, before we give up freedoms that we enjoy now, show us the data suggesting it is needed. Spoiler alert; It doesn't exist.

I'm not against reasonable regulation of suas. I am against complex and restrictive rules that go beyond their demonstrated justification.

 

[sar104]

I can't speak for anyone else but a few of my objections to the proposed rules as written are: (not in any order)

• Regulations in general should be as little restrictive as possible while getting the desired result. They should result in the most simple and least expensive regulation as practical. Elements of the regulation should actually address what the agency says is why it is necessary.
  • This rule, as proposed, is far more complex and expensive than in needs to be.
  • The FAA says we need Remote ID in order to enhance safety, particularly between manned and unmanned aerial vehicles. This proposal does not directly do that at all.
  • Laws and regulations exist for a reason. The FAA has not offered any data to suggest such a complicated and expensive system is even necessary. Since they propose that others pay for it all, then I guess they have nothing to loose by trying. There are much simpler and inexpensive ways to enhance safety in the NAS. I propose we try those first.
• The proposal establishes a "Pay for access" to the NAS.
  • With a broadcast only scheme, it would place the cost of accessing information about uas flight in the area to those that are interested in the knowing, not the operator. RID is likened to a license plate for uas. But you don't stream your car's location onto a network to enhance safety or accountability on the roadway. Why then do we need to do something similar to make the NAS safer? If someone thinks that a uas in the area is flying where they shouldn't be, they can acquire and check their scope. If they want to record all the traffic in a particular area, they can install equipment to record the broadcasts. Again, it places the burden and cost on the one wanting to know.
  • General aviation has fought long and hard against paying for access to the NAS. General aviation does contribute $ to the system through fuel tax. uas could contribute through registration fees. or some other fair system. The FAA expects USS to cost $2.50 per month. But that is simply a guess and they would retain no control over those fees.
• The FAA wants accountability from those flying uas.
  • There is almost no way to enforce this proposed regulation. Operation under this proposed regulation would be policed exactly the same as it is now. Almost not at all.
  • Broadcast RID would provide the same accountability at little to no cost to the operator.
  • Admittedly, a live broadcast only system would not result in a database of all flights in order to be able to look back in time. But the FAA has not offered any data as to why they need such a database.
• The proposal makes no less restrictive allowance for operation in uncontrolled airspace areas,. Not even over private property.
  • This is far more restrictive than even manned aviation which actually has a history of killing people.
  • Again, before we give up freedoms that we enjoy now, show us the data suggesting it is needed. Spoiler alert; It doesn't exist.

I'm not against reasonable regulation of suas. I am against complex and restrictive rules that go beyond their demonstrated justification.

Right, but your objections are mostly based on unsupported assumptions, false comparisons, and straw man arguments. In my opinion your only substantive suggestion is to restrict the system to the broadcast part. While it's pretty clear why they included the USS side of the system, that's not an unreasonable suggestion and I'd focus just on that.

 

[2edgesword]

I agree that with those that are of the feeling that the NPRM is not really about safety in the NAS. In fact, it really has a very small amount to do with safety, and that is only through (hopefully) accountability. That is, if you know that everyone will know who you are when you're flying, then you will be responsible when otherwise you would not be. This is pretty flawed, IMO, because anyone that chooses to be a "bad actor" will not be prohibited in the least by this proposal.

Some of you have used the ideal that eventually, this proposed "PRISM" like server/storage scheme can be put into use by a UTM and THEN it could (probably would) lead to greater situational awareness in the NAS. But that aspect is just speculation at this point and is not even part of the NPRM.

Getting back to safety through accountability. That level of accountability can easily be provided for with the over-the-air broadcast (wi-fi is just a frequency band) that DJI and probably the other manufacturers can do right now. If LLE (for example) wants to know who "that is" showing up on their scope. That technology is available right now. I personally have no problem with this form of RID and believe that the live broadcast is sufficient for the safety through accountability that I think we all want.

This grand scheme is most certainly aimed at enterprise operators that hope to have 10s of thousands of operations per day, each.

For safety, I like the idea of manned aircraft being required to stay 1000' or higher unless taking off or landing. Drones would stay below 400' and there would be 600' minimum separation. I know, this wouldn't create huge piles of money for VCs, and it could be implemented immediately with almost no cost and that it is just not right for a gov't project. We also wouldn't need a new screen in out manned airplane showing where all those drones are which is a plus!

I hope we can put to bed the idea that this NPRM is about aviation safety. We're talking about a tiny slice of the NAS where drones have been responsible for no deaths, injuries or accidents in the U.S. and only a few collisions with only a couple of those confirmed. If aviation safety was the concern that $500 million plus that is the estimated cost could be better spend on the real causes of aviation accidents, injuries and deaths.

This isn't really about LE. I do not see many if any agencies setting up drone monitoring and enforcement divisions. They have enough on their hands monitoring surface vehicle traffic and real crimes. I don't see Officer Smith monitoring an app to chase down a rogue (spelled it right) drone that's not flashing ID on the app.

This is about setting up the system for commercial use of drones by the major players and the recreational drone users are a blip on the screen if that. I seriously doubt the FAA has any concern for the folks flying "toy" drones other than to get as many of them out of the way so the airspace below 500' can be reserved for serious players. The "threat" of implementation is going to drive some folks out of the hobby and it will be a big stumbling block to others who may have thought about getting in unless some slice of airspace other than AMA FAA recognized fields are open for recreational or small business commercial use (photography, real estate, agriculture, etc.).

As for the NPRM, the discussion of who is broadcast what to whom with or without an internet connection to transfer the ID information to the FAA via some unknown network to some unknown service providers for some unknown fee is a dog chasing its tail.

 

[RKBA]

Then message him and ask him.
.

I thought that’s what I was doing

 

[Dave Pitman]

Right, but your objections are mostly based on unsupported assumptions, false comparisons, and straw man arguments.

The FAA needs to provide justification for a regulation first before I or anyone needs to provide justification against. You've kind of got it backwards.

 

[skymonkey]

911

 

[Dave Pitman]

911

haha..False alarm!

 

[RKBA]

The FAA needs to provide justification for a regulation first before I or anyone needs to provide justification against. You've kind of got it backwards.

Exactly!
The burden is on them

 

[sar104]

The FAA needs to provide justification for a regulation first before I or anyone needs to provide justification against. You've kind of got it backwards.

The proposal is pretty heavy on the justification part, but your comments suggest that you simply didn't read it.

 

[dirkclod]

I thought that’s what I was doing

No you posted. Message him is what I meant.
He has 15 forums to look over . He can’t read all
thats posted.

 

[Dave Pitman]

The proposal is pretty heavy on the justification part, but your comments suggest that you simply didn't read it.

I've read most of it. What justification data are your referring to? BTW, you can link directly to it from the federal register.

Federal Register :: Request Access

www.federalregister.gov

 

[Dave Pitman]

@sar104 I'm not trying to convince you. If you are in favor of the proposal as written, that is certainly your right. No hard feelings!

 

[sar104]

@sar104 I'm not trying to convince you. If you are in favor of the proposal as written, that is certainly your right. No hard feelings!

I'm in favor of the principle. The implementation seems sub-optimal, but wasn't part of the planning so it's possible that I'm missing significant information. This conversation, from my perspective, wasn't about that specifically though - it was about how to effectively comment on this type of proposal.

 

[sar104]

I've read most of it. What justification data are your referring to? BTW, you can link directly to it from the federal register.

Federal Register :: Request Access

www.federalregister.gov

I A & B, IV.

 

[Adamborz]

I said my peace...

 

[RKBA]

No you posted. Message him is what I meant.
He has 15 forums to look over . He can’t read all
thats posted.

No thanks. This is the hottest topic in the two busiest forums, if they are not reading these threads at least then that pretty much answers my question.

 

[Dave Pitman]

I A & B, IV.

Yes, I've reviewed those areas. My position is that just because the FAA says that there is a specific need, and their's is the correct answer to fulfill those needs does not necessarily validate either.

 

[bsartist]

The broadcast is for local use by others in the area. It will be done on Wifi frequencies. It conceivably could be received by anyone in the area who had a smartphone or computer that has Wifi. The broadcast won't need to be received by anyone or passed on to the internet/service provider.

The connection to the internet and service provider will be entirely separate from the broadcast. It can be done by connecting your mobile phone to your controller and sending the data via your mobile phone.

Yes. Thank you. After @sar104 comments and @skymonkey shared a white paper it started to come into focus for me. Then I reread the NPRM without my initial cloud of misunderstanding and it all made sense. Do you know how you get a certain idea in your head and you interpret what you read through that lens? I think that happened to me.

Thanks for helping to clear it up.

 

[bsartist]

I didn't see anything in the rules that addresses this issue, and that means that the manufacturers will have to decide how to implement that part of the rule when they update their apps. I suspect that the app could easily check to see if the phone is in airplane mode.

As I alluded to before, this is an interesting question and one that requires more research. For example, I know that, a long time ago, iOS did not allow apps to test for airplane mode. The api just wasn’t there for it. Some people came up with a private API but code using it wouldn’t be allowed into the App Store. So clearly at one point Apple didn’t want to expose this state to developers. This could have changed but I don’t know at the moment. Of course maybe the feds can twist apple’s arm to make the state available to the apps. Because obviously the ability to turn on airplane mode undetected would thwart the app ability to know if internet was available in the area. At least that’s how I see it at the moment.

 

[Philsmith76]

Regarding standard ID and the “if internet is unavailable“ provision. I wound plan on using a phone and pulling the SIM card or fly with tablet without cellular ability.