Calvin

N.

, Fredericksburg

, Virginia

, United States

Posted on
2020-02-25 12:20:33
“Flying model aircraft and multirotors has been very important to me and my family for a long time. I remember being a 10 year old kid when my Uncle bought me all of the parts to build my first RC airplane and taught me everything I needed to know to build it and fly it safely. From that day on I have been hooked. I have since been able to pass this love of RC flight down to my 12 year old brother and 5 year old daughter. All week my daughter looks forward to the weekend when she can put on her pair of FPV goggles to ride along with me as I fly around the family property and through the woods around my grandparents house with my homebuilt FPV racing drone. She loves it, she says she feels like a bird flying around through the trees, and she can’t wait until she is old enough to help build her own mini drone and learn to fly it herself one day. Today though, I fear she may never get the chance to realize that dream. If the proposed Remote ID rules were to be passed as they are written in the current proposal, it would undoubtedly kill the hobby as we know and love it today, not to mention violate the privacy and safety of UAS pilots in the United States. Below are my views and findings on the subject, I hope they will be helpful in refining the idea of Remote ID and moving forward with rules that help to maximize safety in a way that will not destroy this great hobby and hurt those of us who have been safely enjoying it for generations. According to data provided by the FAA, there are currently over 1.3 million recreational UAS in operation today in the US. Flying recreational RC aircraft is a hobby that has been around for a long time, and in that time has proven to be extremely safe. According to information released during a freedom of information act request by the FPV freedom coalition, between 2013 and today there have been only 14 recorded incidents involving recreational UAS. Of those 14 incidents, none resulted in death or damage to manned aircraft. Remote ID as currently written would regulate recreational UAS more heavily than recreational manned aircraft, which are responsible for an average of 400 deaths per year in the US. Although there has been no proper risk assessment performed (as is required according to US lawmaking guidelines) before these proposed rules were drafted. There was a study performed by the FAA’s own Aviation Rulemaking Committee (ARC) which recommended that hobby UAS be exempt from remote ID due to their long record of safety among other reasons, but it seems that those findings have been largely ignored in this set of proposed rules. A major concern I feel the need to express is regarding the rule that states that the location of the ground station (pilot) is to be available to the general public. I have spoken to many people who have told me first hand accounts of instances where UAS operators were subjected to altercations, both verbal and physical, due only to the fact that they were flying a drone. This happened while they were flying the drone legally, and in some cases the operators were actually commercial pilots on the job at the time of the incidents. Even more accounts can be found online via a quick google search, you can even find some videos of these kinds of things happening. There have also been numerous reports of drones being shot at with firearms. I shudder at the thought of what could happen when those people, who clearly have no regard for the safety of others due to the fact that they are shooting up into the air not knowing where the bullets will come back down, are provided the location of the pilots of those drones. I can only see bad things coming from that. This rule would provide the location of pilots and their expensive equipment to anyone who might want to cause harm to the pilot or steal their equipment. The location of the ground station and pilot should absolutely not be made available to the public. This was also recommended by the ARC. The NPRM as currently written is extremely restrictive and I believe it to be a major privacy and safety violation. We need to eliminate the requirement of internet based Remote ID. If broadcast based RID is good enough for areas of no coverage, then it is good enough for use all the time. This would eliminate the unnecessary added costs and privacy concerns. All data required to be broadcasted to law enforcement can be broadcasted from the UAS via local broadcast ID instead of over the internet. Almost all current, homebuilt UAS could be retrofitted with a hardware module which would handle the RID Broadcast. This module could be an add on component produced by an FAA authorized manufacturer with a burned in serial number that can be registered and broadcasts the required information. This module would be registered to the pilot and should be allowed to be moved between all of the pilots aircraft, whichever one they are currently flying at the moment. This would also eliminate a very large compliance issue at the same time as saving pilots thousands of dollars by being able to continue using existing UAS by retrofitting them with hardware modules which would make them compliant. There should be exceptions for non-autonomous UAS as recommended by the ARC. Non-autonomous UAS should be allowed to fly within VLOS in uncontrolled airspace without remote ID (broadcast ID). If the operator of said non-autonomous UAS would like to fly within controlled airspace, they could submit a LAANC request as this is what LAANC was designed for and has worked very well thus far. Said pilot could also be required to enable his/her Broadcast ID module if deemed necessary, such as for BVLOS flight. This would eliminate the need for FRIAs and more importantly, recreational UAS operators would be allowed to continue flying our home built UAS as we have been doing for so many years without issue. Also, the registration weight limit should be increased from 250g to 1Kg. Both of these changes would also greatly increase the amount of compliance. Under the NPRM as it is currently written, there would no longer be a free way to fly. For example, I would not even be able to fly on my own property without being charged fees to do so legally. This is not right, and will never work. It will be a major contributing factor to mass non-compliance and to the failure of the rules as a whole. Instead of requiring all pilots to use Remote ID (broadcast ID), I believe the FAA should create a provision for shielded operations, where pilots who are flying within 100 meters of, and no higher than the height of surrounding obstacles such as trees in non-controlled airspace are not required to take part in broadcast ID. These types of flights are of no way a danger to manned aircraft because manned aircraft would never be flying that low. This would exempt any recreational UAS from any remote ID (broadcast ID) requirements when the following criteria are met: When the operation takes place in any airspace where it is safe to fly that is not controlled airspace (over air traffic controlled airspace). When the operation does not exceed an altitude of 50 feet higher than the tallest object within 1000 lateral yards of the location of the operators ground station. Low Altitude and Authorization and Notification (LAANC) approval would be required in controlled airspace. Shielded operations have worked well in places such as New Zealand for some time now and I believe it would work well here in the US for a large number of recreational pilots such as myself who primarily fly FPV drones and almost never fly higher than the trees, or other obstacles. I believe that LAANC should be expanded from controlled airspace to all airspace. LAANC currently works well, and if expanded, would be a much better option than remote ID. Expanded LAANC would meet the FAA goals of knowing where UAS are in the airspace, while not presenting all of the issues of the current remote ID proposal. It would cost less, and would have a much higher compliance rate due to the fact that all existing aircraft would be able to continue to be used. I think it is safe to assume that everyone who flies UAS also owns a cell phone, which means they already have the equipment needed to use LAANC. Expanded LAANC could be combined with broadcast ID for all BVLOS and Autonomous operations to give a complete picture. This would provide all of the information that the FAA wants from remote ID in a much cheaper way that would not pose such extreme privacy concerns and many more people will be able to comply with. One of the most, if not the most concerning parts of the existing NPRM is the fact that we hobbyists would not be allowed to continue building our own aircraft out of parts purchased separately. Flying the aircraft we build is only the final and most superficial part of the hobby as a whole. Model aviation includes aeronautics, electronics, mechanics, computing, programming as well as other disciplines. The value of model aviation is not just that it allows people to fly radio controlled aircraft, the value of model aviation is also that it teaches people to design and build aircraft. The NPRM takes the core of model aviation, the designing and the building, away from the individual hobbyist. The value that will be lost if the NPRM is implemented as currently written is immense. For a very large number of us, a very large and important part of the enjoyment of our hobby is being able to choose different parts for our builds in order to make the aircraft perform differently or to fit our budget. I personally have built approximately 20 multirotor aircraft, and approximately 10 fixed wing and rotary wing aircraft before that. One of the reasons why I have found myself building more multirotor aircraft than fixed wing aircraft lately is because of the large amount of options available to design the aircraft to meet my goals. I select the parts which will allow the aircraft to meet the operational requirements that I have chosen, I then assemble the aircraft myself, soldering all of the connections to the electronics by hand. I program the flight controller and other electronics via software on my computer, then I perform flight testing in my backyard so that I can adjust parameters to ensure the aircraft is operating safely and with the best performance possible. I am not a minority in this way of doing things. Millions of others like myself design and build their own aircraft every day. The self design and construction of these aircraft has taught me countless skills in the areas of engineering, aerodynamics, electronics, radio technology, and much more. Furthermore, many engineers, pilots and astronauts credit model aviation with inspiring them into those professions. Certainly not the only, but maybe the most well known of these people, was also the first man to walk on the moon. Neil Armstrong built and flew model aircraft as a kid, all throughout college, and as an adult. In a letter to John Worth, the Executive Director to the AMA (Academy of Model Aeronautics), Mr. Armstrong wrote: “My model building and flying activities significantly contributed to my interest in aeronautics and was a primary force in directing my education toward aeronautical engineering.” I believe this is a very powerful message coming from the first man to walk on the moon, and who is regarded by many people around the world as a hero. If the model aviation hobby was not available to young Neil armstrong when he was young, he may have never gained the interest and drive which led him to follow the path that he did, The path that led him to one day make history as the first man to walk on the moon. The NPRM as currently written would make it impossible for education programs such as STEM to continue teaching much of what they do today and have done safely for generations, denying future generations an invaluable resource of learning and inspiration. The solution I propose to this issue is to create an exemption for non-autonomous homebuilt aircraft. (those which are controlled by a human pilot and do not fly on a pre-programmed flight path). This was suggested by the ARC and would allow people like my kids and I, as well as schools to continue designing building and flying model UAS as we have done safely for many many years. This would also allow future engineers, pilots and astronauts to continue to be provided the resources that will inspire many of them into such professions. Without the resource of model aviation as we have it today, many of these future pilots and engineers may never have that inspiration, and in turn never pursue the path and realize those goals. This would undoubtedly put the United States at a large disadvantage in the future as it would severely shrink the number of engineers and pilots in the country in the coming years. As existing professionals retire, there will be less and less new ones to fill their places. The NPRM as currently written would also remove an invaluable resource from law enforcement who rely on highly skilled and knowledgeable hobbyists to stay on the cutting edge of drone technology and development in order to maximize the safety of their officers as well as the public. Recently I had a conversation with a Sergeant of the local Sheriff’s office in the county where I live. During our conversation the Sergeant described a program they are currently implementing which involves a member of their SWAT team who is also an active recreational FPV (First Person View) drone pilot when he is not on duty. The SWAT officer has used off the shelf parts along with his extensive working knowledge of drones to design and build purpose built mini drones. The mission of these drones is to be able to fly through a softball sized hole in a window, or small opening in a doorway while being controlled by the officer remotely via First Person View goggles in order to evaluate situations before the entry team is sent into a house or other potentially dangerous location. This program not only dramatically improves the safety and situational awareness of the SWAT team itself, but also any potential hostages or other civilians involved. This type of program would never be possible without the knowledge gained by this officer in his time spent off duty participating in the drone and model aviation hobby. The FRIA provision would not be an adequate solution to allowing homebuilt aircraft as many people do not live anywhere near what would be a FRIA. Also, the FAA directly states that FRIAs are designed to disappear over time, which will eliminate the possibility of home built aircraft altogether. The single most important thing I ask the FAA to consider is a mechanism which allows amature built aircraft to be flown legally in any area where it is safe to do so, not just at FRIA locations or other such approved locations. Another major problem with the rules as proposed, which relates to the above paragraph, is that the path to retrofitting existing aircraft is very unclear. No existing UAS meets the specific serial number format requirements because that format does not currently exist. There is no explanation of how this will be handled regarding retrofitting these existing UAS to meet the proposed requirements. The best solution I see to this issue is either to remove the ANSI serial number requirements, or change it so that we are able to retrofit existing models with a hardware retrofit module, or to grandfather in all existing models. The cost of the paperwork and process in order to receive approval for a remote ID system by manufactures would be over $20,000. Many manufactures would not be able to afford this, and would be forced out of business, which would mean hundreds if not thousands of people would lose their jobs. While some companies may be able to afford this, the cost will be passed down to the customer, drastically increasing the cost of UAS to the point where many people like me could no longer afford to buy them. Losing manufactures in the industry would also cause a stagnation of innovation due to the lack of competition, as well as give the surviving companies another reason to be able to raise prices. Not to mention the fact that all US parts and kit retailers would be at a major disadvantage to all foreign sellers, which would undoubtedly cause even more jobs to be lost. The solution to these problems would be to remove the internet requirement, which would make compliance much easier and less expensive, which would make it more achievable and better for all parties. Most UAS out there today would already meet requirements which means compliance would be very high from day one, instead of starting at virtually zero and staying very low as I foresee happening if the network requirements are not removed. Also relating to the issues presented by the network requirements is that the definition of “when the internet is available” is not provided in the NPRM. What happens in a situation where a pilot technically has internet coverage, but the signal is so weak it is impossible to upload or download any data? As currently stated, the pilot would be grounded, which does not make sense. The solution to this issue is again, to remove the internet requirement and use only broadcast ID. I see the act of phasing out FRIAs as a concerning issue. In the NPRM the FAA states that they intend to completely phase out FRIAs. Without a realistic path of retrofit for existing models, this will force a large portion of the population out of the hobby. It is stated in the NPRM that the average lifespan of a UAS owned by Community Based Organizations (CBO) members is 10 years, which I do not necessarily agree with as I own a number of models that were built almost 20 years ago and still operate perfectly to this day. Keeping the lifespan of 10 years for simplicity’s sake, the FAA plans on phasing out FRIAs long before these 10 years have passed. This will essentially deem a very very large number of UAS (almost all of them in operation today) unusable well before their lifespan has expired, essentially turning them into very large and expensive paperweights. Hobbyists by and large want to fly safely and comply with the law, but what will happen in this case where only viable options that people are given are to either give up the hobby altogether, or break the rules? Many people will simply disregard the rules, they will continue flying their old aircraft as they always have which will cause remote ID to fail entirely. Because the NPRM is so overly restrictive, it will encourage a culture of noncompliance and resentment against the FAA. The solution to this is to create an exemption for home built UAS, eliminating the need for FRIAs altogether and allowing hobbyists to continue building and flying model UAS safely as we have done for many years. I also believe the idea of an expanded LAANC-like system would work well, especially for BVLOS flight. Remote ID can only work if the majority of UAS operators are on board with it. As the NPRM is currently written, it removes at least 80 percent of all UAS operators from the picture. If we do not have a plan that works well for everyone in every part of the hobby, Remote ID will fail entirely because those operators who are discriminated against by these rules will simply disregard them. I know from speaking to local law enforcement personally that they have more important things to worry about than spending time going around looking for hobbyists who aren’t complying with rules like these, so the rules won’t be enforced and again, they will fail. In the NPRM there is no provision for indoor flight. Myself as well as many others across the country often attend indoor flight nights and similar events held at local school gymnasiums, skating rinks and other large open indoor locations, even our own houses with tiny indoor micro drones. The NPRM would make this impossible due to the fact that GPS signal is not available indoors, therefore no remote ID compliant aircraft would be able to operate in the venues used for these events. Recreational UAS pose no threat to the public or manned aircraft while flying indoors, while separated from all manned aircraft by walls and a roof. If the NPRM were to be passed as is, it would eliminate any possibility of all events like these. The solution to this issue is to eliminate the remote ID requirement and instead implement an extended LAANC type system with broadcast ID made available as an option for pilots who intend to fly BVLOS. A serious issue that was not talked about in the NPRM is the potential for nationwide grounding of UAS in the event of an outage of the network or USS. If the internet requirements are not removed from the rules, it would be possible for an attack such as a DDOS (Dedicated Denial Of Service) attack to shutdown all USS providers for potentially large amounts of time. This is just one example of many possible causes of the USSs going down which would ground all UAS under standard remote ID. The solution to this issue is, again, to remove the internet requirement and replace it with an expanded LAANC system, Shielded operations and the option of broadcast ID for BLVOS flights. The question has been raised regarding whether or not people who possess certain waivers should be required to comply with Remote ID before it is enacted to everyone. The simple answer to this question is no. Without a clear path to retrofit, this would not even be possible. If the retrofit issue is resolved by implementing changes such as the ones I detailed above, then early adopters could gain approval for waivers earlier on. This could act as an incentive for any operators seeking this type of special permissions to become early adopters which would help speed up the compliance process further. In the NPRM it is stated that USS may be allowed to discriminate based on the type of aircraft. By UAS manufacturers becoming USS, they could decide to only allow UAS from their brand onto their USS. For those of us who own multiple different UAS from multiple different manufactures it would mean that we would need to register with multiple different USS providers which would cause us to have to pay for multiple different plans, which would cost much more per month than the figure stated in the NPRM. This could also mean that the manufactures can restrict which USS aircraft they manufacture are able to connect to, essentially forcing the user to pay for their USS. This would present all sorts of problems and honestly does not make sense for the hobbyists. The solution to this problem is again, to remove the internet requirement altogether. This will eliminate the need for the USSs, eliminate the monthly fees associated with the USSs and through broadcast ID and LAANC, the FAA and law enforcement will still have access to the pilots and UASs information. The sources used in this NPRM in order to justify many of the proposed rules are unfounded or nonexistent. Some examples are: In the NPRM it is stated “On average there are 6 sightings of UAS conducting unauthorized operations each day”. – Source: None, no source was cited to prove this as fact. FAA reported that there were drones 10 miles from Newark Airport in 2019, when you follow the link that the FAA provided to describe the event, the drones in question were not 10 miles from the airport, they were actually 20 miles away at Teterboro airport which is a class D airport and is in LAANC which means that you are allowed to fly there under LAANC. The reports that there were drones near Newark were never actually confirmed, no further information was collected. The fact that the decision was made to shut down the Newark approach was an overreaction and mistake on the part of whoever made that decision. in reality there were never any UAS sightings anywhere near Newark itself. Gatwick Incident. The FAA quotes the Gatwick incident, there is still no proof that this ever happened. The article quoted in the NPRM states that two people were arrested in this case, but when you follow the story, the two people that were arrested were later released because it was found that they had no part in the incident. Of the dozens”
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