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May 14, 2018, 08:39 AM
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ARC report, Remote I.D. Exemptions


https://www.faa.gov/regulations_poli...Appendices.pdf

Hobby exemptions, page 31:

Option 1:

"Except for those members who strongly favor a weight-based threshold for applicability and those members who strongly
oppose an exemption for model aircraft operated in compliance with 14 CFR part 101 (see discussions above in 5.2.3), the
ARC recommends that all UAS be required to comply with remote ID and tracking requirements except under
the following circumstances:

1. The unmanned aircraft is operated within visual line of sight of the remote pilot and is not designed to have the
capability of flying beyond 400 of the remote pilot.

2. The unmanned aircraft is operated in compliance with 14 CFR part 101, unless the unmanned aircraft:
a. Is equipped with advanced flight systems technologies that enable the aircraft to navigate from one point to
another without continuous input and direction from the remote pilot.
b. Is equipped with a real-time downlinked remote sensor that provides the remote pilot the capability of navigating
the aircraft beyond visual line of sight of the remote pilot.

Option 2:

"Except for those members who strongly favor ..., the ARC recommends UAS with either of the following characteristics
must comply with remote ID and tracking requirements:

1. Ability of the aircraft to navigate between more than one point without direct and active control of the pilot.

2. Range from control station greater than 400 and real-time remotely viewable sensor."

Several members added dissents to the report (Appendix D) objecting even to these limitations, opting for the 250 gram
exemption or none at all.
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May 14, 2018, 09:19 AM
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A number of years ago we did some testing. Basically it amounted to how far could the average human see a typical 60 inch wing 40-60 sized trainer well enough to control it. We determined it was something right at 1/4 mile or 1320 feet. Pilot with 20/20 vision.

I dare say most everything beyond a Park Flyer, and then even many of them are fully capable of going well beyond 400 feet. Thus restoring the requirement for ID and Tracking for the average recreational flyer.
May 14, 2018, 06:44 PM
Registered User
Option 1 is a full exemption for models (14 CFR 101) without FPV or waypoint capability.

Option 2 is a full exemption for _anyone_ without FPV or waypoint capability.

It's true that the 400' capability is essentially always met except with really tiny stuff, but Option 1 paragraph 2 still exempts models.

The Commercial Drone Alliance is the big dissenter here, along with the General Aviation Manufacturers Association.


The Association Of Canada Geese doesn't give a crap.
May 14, 2018, 08:42 PM
Registered User
[QUOTE=nybbler;39656221The Commercial Drone Alliance is the big dissenter here, along with the General Aviation Manufacturers Association.[/QUOTE]

Another dissenter is the AMA, with Hanson complaining about getting the brush-off from the committee:

"AMA is also very concerned that its submission in regards to Part 101 (P.L. 112-95 Sec 336) that was requested and included in the draft
version of the report dated 9/24/2017, was subsequently removed by the writing committee and does not in any way appear in the final report."

Not hard to guess why (from GE):
May 14, 2018, 08:55 PM
Commander, U.S. Navy (Ret.)
franklin_m's Avatar
Quote:
Originally Posted by SFBC
Another dissenter is the AMA, with Hanson complaining about getting the brush-off from the committee ...
And AMA wonders why the rest of the aviation community doesn't take them seriously.
May 14, 2018, 09:21 PM
BFMAC Founding Member
Quote:
Originally Posted by SFBC
Another dissenter is the AMA, with Hanson complaining about getting the brush-off from the committee:

"AMA is also very concerned that its submission in regards to Part 101 (P.L. 112-95 Sec 336) that was requested and included in the draft
version of the report dated 9/24/2017, was subsequently removed by the writing committee and does not in any way appear in the final report."

Not hard to guess why (from GE):
Jeez, they forgot to include all the CBOs in the chart.
May 14, 2018, 10:04 PM
Registered User
looks like AMA's #550 will be outlawed & hobby FPV being the rogue
May 14, 2018, 10:16 PM
Registered User
This particular rule would only require that hobby FPV have Remote ID, which is an expensive pain in the ass but doesn't outlaw it. Anyway, who cares if it's rogue? I'll fly legal if they make it reasonably possible. If they don't, they'll find that an enforcement infrastructure designed to handle half a million pilots mostly doing the right thing isn't going to be near good enough to handle millions of rogue operators.
May 14, 2018, 10:58 PM
Registered User
Forget about FPV. Here is an excerpt from letter from Bob Violet Models
to the AMA President at the time ( July 2014 ):
http://www.bvmjets.com/Safety/AMA0714-1.pdf

From: Bob Violett
To: AMA President Bob Brown
CC: Dave Mathewson, Rich Hanson
Re: Response to FAA Model Aircraft Rule Interpretation
....

"In my opinion, the AMA will never reverse the FPV ban by the FAA. When a federal
agency is charged with "public safety", their easiest response, is to say "NO".

If we lose the battle with the FAA in trying to protect FPV (and we certainly will), we
may completely lose our freedom to operate model airplanes. If you truly want to kill a
hobby and associated legitimate businesses, let the government get involved. Do we
really want to have local police watching every model airplane activity?"

And where are we now? From the ARC report
May 14, 2018, 11:18 PM
Registered User
The reason remote I.D. would apply to RC aircraft equipped with a real-time downlinked remote sensor, or one able
to navigate from one point to another without continuous input and direction from the remote pilot, is not so you can
fly FPV anywhere you want. It's to bust you if you fly BVLOS,

I've read somewhere it was proposed as 1,300', approximately 1/4 mile as mentioned by KMK001.
May 15, 2018, 03:51 AM
RC Product Specialist
Scott Cuppello's Avatar
In Europe it is 400m OR VLS.......and you might be able to see a model as far as a 1/4 of a mile away, chances are however you are not in control of it.
May 15, 2018, 05:43 AM
Registered User
atreis's Avatar
First question:

Quote:
Originally Posted by SFBC
real-time remotely viewable sensor
All but the very smallest of my planes are equipped with flight pack voltage and altitude telemetry. It's a remote sensor on the plane, and I can view the flight pack voltage and altitude in real time. Does it qualify? (The first option implies FPV, but the second option doesn't specify the type of data ...)

Second question:

Quote:
flying beyond 400 of the remote pilot
I only know the altitude. How far the plane is from me is a pure guess. e.g. I might know that it's 250 feet up, but how far is it from my transmitter? I've no idea, but would be surprised if it's not often more than 400 feet away. The particular field is well over that to the tree line (about 1500 feet) and I always stay inside the tree line. Sometimes I might be 700-800 feet away laterally, while still being only 250-300 feet, or less, high. Given other factors that can cause signal attenuation, I don't know how one could possibly know how far away the plane actually is unless it's equipped with GPS as well as an altitude sensor.

So, do they really mean 400 feet away, or 400 feet up?
May 15, 2018, 06:25 AM
Multirotors are models too!
Quote:
Originally Posted by franklin_m
And AMA wonders why the rest of the aviation community doesn't take them seriously.
The rest of the Aviation community, or the lobbyist for those other members. Where has it been said the aviation community doesn't take AMA seriously?
May 15, 2018, 06:35 AM
Commander, U.S. Navy (Ret.)
franklin_m's Avatar
Quote:
Originally Posted by Rusty105
The rest of the Aviation community, or the lobbyist for those other members. Where has it been said the aviation community doesn't take AMA seriously?
ALPA - wants 336 abolished
A4A - wants 336 abolished

AMA EC complaining in EC minutes that FAA doesn't send decision makers to meetings with them (huge signal being sent by FAA)

AMA EC complaining in EC minutes that FAA hasn't acted on their CBO petition for years (another huge signal being sent by FAA)
May 15, 2018, 06:44 AM
Registered User
Quote:
Originally Posted by nybbler
This particular rule would only require that hobby FPV have Remote ID, which is an expensive pain in the ass but doesn't outlaw it. Anyway, who cares if it's rogue? I'll fly legal if they make it reasonably possible. If they don't, they'll find that an enforcement infrastructure designed to handle half a million pilots mostly doing the right thing isn't going to be near good enough to handle millions of rogue operators.
Depends on how hard the judges hit violators. Poaching slows dramatically when the judge(s) of a county hammer them hard when caught. On the other hand, minimal finds do little to deter such activity.

No law catches all, or even most violators. Often it is not the law itself that discourages violations but the potential penalty of being caught.


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