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Jan 12, 2020, 06:53 PM
The Mr. Rogers of RC soaring
rdwoebke's Avatar
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What would building a Standard Remote ID RC Sailplane look like?


Fair warning this post is long. Anything in this post in red is a direct copy and paste from the FAA document. Nothing in this post is intended in any way to convey my support of the FAA’s Remote Identification proposal, to say that I believe it is justified to be required of RC Sailplanes in any way, or am I attempting to “minimize how bad it is”. I have read through the entire FAA Remote ID proposal at least once and would like to put down to paper what my read of what would be required to build a RC Sailplane that complies with the Standard Remote ID requirements as written in the proposal. I do this because the FAA specifically asks for feedback on “retrofitting” existing models in the proposal:

The FAA requests comments on the capability of retrofits to meet the proposed remote identification requirements. Specifically, the FAA requests information and data from producers of affected UAS in response to the following questions that can be used to inform this analysis. Please provide references and sources for information and data.



Note this might be a great time for the various RC Sailplane manufacturers/importers to make specific comments on the comments page specific to the questions that are posed in the document under the above text.

My read of the proposed RID rules is that what we in the sailplane community fly the document would largely describe as “amateur-built”. The term “amateur-built” is kind of confusingly defined two different ways. One being that the builder of the model builds more than 50% of the aircraft. The other way the document describes “amateur-built” describes it as being that the aircraft doesn’t come 100% complete either RTF or as a 100% ready to fly “kit” where some assembly may be required. Other than perhaps things like the RTF Radian most sailplanes even ARFs require that the modeler source at least some equipment. The document does explicitly say that “amateur-built” aircraft can be built to comply with the Standard Remote ID requirements.

One of the first requirements of Standard UAS is that each model has a unique serial number. The FAA has designed a serial number system that it appears it either intends to manage or outsource. The document says the builders of “amateur-built” models can apply for serial numbers. There is no mention of if there will be a cost of getting a serial number. My read is each model would require its own serial number. The serial number has to be permanently affixed to the outside of the model. The document explicitly states that it isn’t going to specifically prescribe how the serial number is displayed. My read is it could be accomplished by painting, sharpie, etc.




The FAA requires that for each aircraft design that the manufacturer (in the case of us that would be the builder) submit a “declaration of compliance” form to the FAA. The information on it would be the following:


(1) The name, physical address, telephone number, and email address of the person responsible for production of the UAS.
(2) The UAS make and model name.


The document states that for “amateur-built”models the builder can makeup whatever name/manufacturer name/etc.

(3) The UAS serial number, or the range of serial numbers for which the person responsible for production is declaring compliance.
(4) The means of compliance used in the design and production of the UAS and whether the UAS is a standard remote identification UAS or a limited remote identification UAS.
(5) Whether the declaration of compliance is an initial declaration or an amended declaration, and if the declaration of compliance is an amended declaration, the reason for the amendment.
(6) A declaration that the person responsible for the production of the unmanned aircraft system can demonstrate that the UAS was designed and produced to meet the minimum performance requirements of § 89.310 or § 89.320 by using an FAA-accepted means of compliance.
(7) A declaration that the producer complies with the inspection, audit, and notification requirements of § 89.510(b).


This could indicate that you are agreeing to let the FAA inspect your home.
(8) A declaration that the producer will perform independent audits on a recurring basis to demonstrate compliance with the requirements of subpart F of proposed part 89 and will provide the results of those audits to the FAA upon request.
(9) A declaration that the producer will maintain product support and notification procedures to notify the public and the FAA of any defect or condition that causes the UAS to no longer meet the requirements of subpart F, within 15 calendar days of the date the person becomes aware of the defect or condition.
The document doesn’t list the specific cost of this. The document does list an expected fee from the FAA for “ $313 for the purchase of a remote identification standard from a consensus standards body.” Which it indicates that all manufacturers of Standard Remote ID aircraft would pay. It doesn’t mention if this is per manufacturer or per design.


The definition of Standard Remote Identification aircraft is the following:
standard remote identification UAS would connect to the internet and transmit remote identification message elements through that internet connection to a Remote ID USS and broadcast those message elements directly from the unmanned aircraft. These message elements would include the UAS Identification (either the unmanned aircraft's serial number or session ID), latitude, longitude, and barometric pressure altitude of both the control station and the unmanned aircraft, a time mark, and an emergency status code that would transmit only when applicable.
More specific requirements for the airborne electronics:

Minimum message elements broadcast and transmitted by standard remote identification unmanned aircraft systems.
A standard remote identification unmanned aircraft system must transmit the following remote identification message elements through an internet connection to a Remote ID USS and must broadcast the following remote identification message elements:
(a) The identity of the unmanned aircraft system consisting of:
(1) A serial number assigned to the unmanned aircraft by the person responsible for the production of the standard remote identification unmanned aircraft system; or
(2) A session ID assigned by a Remote ID USS.
(b) An indication of the latitude and longitude of the control station.
(c) An indication of the barometric pressure altitude of the control station.
(d) An indication of the latitude and longitude of the unmanned aircraft.
(e) An indication of the barometric pressure altitude of the unmanned aircraft.
(f) A time mark identifying the Coordinated Universal Time (UTC) time of applicability of a position source output.
(g) An indication of the emergency status of the unmanned aircraft system.


More specific requirements for the “controller” or what we would usually refer to as the “transmitter”:


Minimum performance requirements for standard remote identification unmanned aircraft systems.
A standard remote identification unmanned aircraft system must meet the following minimum performance requirements:
(a) Control station location. The location of the control station of the unmanned aircraft system must be generated and encoded into the message elements and must correspond to the location of the person manipulating the flight controls of the unmanned aircraft system.
(b) Automatic Remote ID USS connection. From takeoff to landing, the unmanned aircraft system must automatically maintain a connection to the internet and transmit the message elements through that internet connection to a Remote ID USS when the internet is available.
(c) Time mark. The time mark message element must be synchronized with all other remote identification message elements.
(d) Self-Testing and monitoring. (1) When the unmanned aircraft system is powered on, it must automatically test the remote identification functionality and notify the person manipulating the flight controls of the unmanned aircraft system of the result of the test.
(2) The unmanned aircraft must not be able to take off if the remote identification equipment is not functional.
(3) The unmanned aircraft system must continuously monitor the remote identification functionality from takeoff to landing and must provide notification of malfunction or failure to the person manipulating the flight controls of the unmanned aircraft system.
(e) Tamper resistance. The unmanned aircraft system must be designed and produced in a way that reduces the ability of a person to tamper with the remote identification functionality.
(f) Connectivity. (1) If the internet is available at takeoff, the unmanned aircraft must not be able to take off unless it is:
(i) Connected to the internet and transmitting the message elements in § 89.305 through that internet connection to a Remote ID USS; and
(ii) Broadcasting the message elements in § 89.305 directly from the unmanned aircraft.
(2) If the internet is unavailable at takeoff, the unmanned aircraft must not be able to take off unless it is broadcasting the message elements in § 89.305.
(3) The unmanned aircraft system must continuously monitor its connection to the internet and the unmanned aircraft system's transmission of the remote identification message elements through that internet connection to a Remote ID USS. If the connection to the internet is lost or the unmanned aircraft system is no longer transmitting the remote identification message elements to a Remote ID USS, the unmanned aircraft system must notify the person manipulating the flight controls of the unmanned aircraft system.
(g) Error correction. The remote identification equipment must incorporate error correction in the transmission or broadcast of the message elements in § 89.305.
(h) Interference considerations. The remote identification equipment must not interfere with other systems or equipment installed on the unmanned aircraft system, and other systems or equipment installed on the unmanned aircraft system must not interfere with the remote identification equipment.
(i) Message transmission. (1) The unmanned aircraft system must be capable of transmitting the message elements for standard remote identification unmanned aircraft systems in § 89.305 through an internet connection to a Remote ID USS.
(2) The unmanned aircraft must be capable of broadcasting the message elements in § 89.305 using a non-proprietary broadcast specification and using radio frequency spectrum in accordance with part 15 of title 47, Code of Federal Regulations, where operations may occur without an FCC individual license that is compatible with personal wireless devices. Any broadcasting device used to meet the requirements of this section must be integrated into the unmanned aircraft without modification to its authorized radio frequency parameters and designed to maximize the range at which the broadcast can be received, while complying with 47 CFR part 15 and any other laws in effect as of the date the declaration of compliance is submitted to the FAA for acceptance.
(j) Message elements performance requirements. (1) The message elements in § 89.305 transmitted through an internet connection to a Remote ID USS from the unmanned aircraft system and broadcast from the unmanned aircraft must be identical.
(2) The reported position of the unmanned aircraft and the control station must be accurate to within 100 feet of the true position, with 95 percent probability.
(3) The reported barometric pressure altitude of the unmanned aircraft and control station must be accurate to within 20 feet of the true barometric pressure altitude for pressure altitudes ranging from 0 to 10,000 feet.
(4) The unmanned aircraft system must transmit through an internet connection to a Remote ID USS and broadcast the latitude, longitude, and barometric pressure altitude of the unmanned aircraft and its control station no later than 1.0 second from the time of measurement to the time of transmission and broadcast.
(5) The unmanned aircraft system must transmit through an internet connection to a Remote ID USS and broadcast the message elements at a rate of at least 1 message per second.
(k) Cybersecurity. The unmanned aircraft system must incorporate cybersecurity protections for the transmission and broadcast of the message elements in § 89.305.
§ 89.315
Minimum message elements transmitted by limited remote identification unmanned aircraft systems.
A limited remote identification unmanned aircraft system must transmit the following remote identification message elements through an internet connection to a Remote ID USS:
(a) The identity of the unmanned aircraft system consisting of:
(1) A serial number assigned to the unmanned aircraft by the person responsible for the production of the limited remote identification unmanned aircraft system; or
(2) A session ID assigned by a Remote ID USS.
(b) An indication of the latitude and longitude of the control station.
(c) An indication of the barometric pressure altitude of the control station.
(d) A time mark identifying the Coordinated Universal Time (UTC) time of applicability of a position source output.
(e) An indication of the emergency status of the unmanned aircraft system.

My read of these requirements is that sailplanes could be compliant with the Standard Remote ID requirements via one of the following:

1) Each sailplane would require a serial number and application for “declaration of compliance” – cost estimate $313
2) Each sailplane would need a brand new receiver that has built in telemetry to connect to the transmitter, has built in GPS and barometric pressure sensor, and has the ability to transmit via RF on a yet to be released set of technical speciation. We currently have some receivers with built in pressure sensors (and maybe a few with built in GPS). My read is none of the existing receivers would be able to meet the requirements of Standard RID so each receiver would need to be replaced. I say this because the Standard Remote ID requirements require additional pieces of info to be transmitted from “controller” to the aircraft that I don’t believe any existing “traditional” aircraft radio scheme has an easy way to include in what they are transmitting to the receiver that additional data such that it could be used by the system that has to broadcast it from the plane. My estimate of a the cost of a receiver that could meet these requirements is $100 at the low end (say what it would cost for FrSky stuff based on their prices for existing receivers with built in pressure sensors, the prices I have seen for small GPS chips, and the fact that essentially you need 2 “telemetry transmitters” because you have the one that transmits the data back to the TX and the one that broadcasts to the “world”) and $300 on the higher end (cost of higher end brand telemetry receivers times 2 since it is effectively 2 telemetry transmitters, what they charge for their altimeters, what they charge for their GPS units)
3) For tamper proof reasons the receiver needs to have embedded in it the serial number of the aircraft that it is sitting in. I believe this could be accomplished by the radio manufacturers providing us with a “programmer board” where we could connect the board to the RX and input the serial number we got from the FAA. Since we are the “manufacturers” of these aircraft we are making it tamper resistant by not storing the programmer board with the aircraft. I’m estimating these would cost about $50 each when you look at what programmer boards for F5J switches/ESCs/etc. cost.
a. Tamper proof is also handled by making it such that the serial number gets erased when the receiver is re bound to a different TX or different TX model memory
4) Each “controller” (what we usually call a transmitter”) would either need to be somehow upgraded (I find this extremely unlikely to be cost effective) or replaced completely. To my knowledge not many (maybe any?) of our transmitters have the ability to connect to a smart phone and continually during operation transmit data collected by the transmitter to a smart phone. And definitely I am not aware of any of our transmitters with built in GPS in the transmitter or built in pressure sensors in the transmitter. Since it seems unlikely to be cost effective to upgrade the transmitter my estimate of the cost of these new transmitters would be $250 (that’s a little over what a normal Taramis costs to account for the additional smart phone connection method, GPS, and pressure sensor) on the low end (Taranis type stuff) or $1500 on the high end.
5) The smart phone would need an app that connects to the USS system. I have no idea what the cost of that app would be. Maybe some manufacturers would offer it for free. Somebody would have to write it so I assume that somebody would want to be paid for it via some method. The FAA estimates $30 per year subscription fees to the USS.

The below section of the FAA proposal lists what the FAA thinks it would cost to upgrade our model aircraft:

The FAA estimates the incremental cost to a producer of standard remote identification UAS would include the cost of a computer chip for broadcasting the remote identification message elements ($5) and a cost to make the remote identification equipment tamper resistant ($15).

I find that a bit suspect given the cost of our electronics we use in our planes that a simple “$5 dollar chip” is going to be able to handle the message broadcasting and this estimate doesn’t include that we typically don’t have a GPS in either the model or the TX, we don’t have a pressure sensor typically in the model or the TX, and we don’t typically have any smartphone connectivity in our transmitters.

SUMMARY:

Based on my numbers above if a person has 25 models over 250 grams (I counted I have that many and I am sure I am far from atypical) that the cost to upgrade all of a person's planes to conform to Standard Remote ID and to purchase 2 transmitters (you always need a backup if you are taking the time to go to contests) would be about $3,500 (on the low end, if a person used more expensive brand gear it would be about double).

Price Break Down:

Cost to become a number a "declaration of compliance” manufacturer: $313
Cost for the "Serial Number Programmer Board": $50
Cost for a new transmitter: $250-$1500
Cost of each receiver: $100-$300
Subscription to USS system: $30 annually

If you have read this far first I would like to again offer my apologies for the length of this post and second I hope that those of you that have read this far will take the time to read through the proposal, read through my assessment, and let me know if you think I left anything out, made any wrong assumptions on costs, overlooked any costs, etc.


Ryan
Last edited by rdwoebke; Jan 13, 2020 at 10:06 AM.
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Jan 12, 2020, 11:07 PM
AMA 7224
Leadchucker's Avatar
If the above does in fact become law, I am done.
Latest blog entry: 1938 Rambler build
Jan 13, 2020, 12:05 AM
Registered User
Thanks for looking into the cost implications. For that kind of money, I could probably build a part 103 ultralight and skip all the trouble. Crashes would hurt a lot more, though, but at least it would still be fun (until the crash). With all this BS, recreational RC flying wouldn't be recreational any more. Do you think it would be productive to use these numbers when commenting to the FAA?
Jan 13, 2020, 12:10 AM
The Mr. Rogers of RC soaring
rdwoebke's Avatar
Thread OP
Quote:
Originally Posted by lincoln
Do you think it would be productive to use these numbers when commenting to the FAA?
That’s one of the main reasons I started this thread. The regulations.gov best practices lists a number of suggestions one being supply data. In the proposal from the FAA the document it frequently asks for comments on specific items.

I may have stuff wrong with the analysis I did or things wrong in my read of the proposal. Hoping for others to read and review.

That said. In the document the FAA estimates that the entire cost of the remote id, the requirements for new equipment, fees for this and that, gas that modelers will use driving further to established fields, cost for manufacturers to make new stuff, etc is a half billion dollars. The FAA acknowledged the costs and still felt that all of this is justified. So that’s something to be aware of.

Ryan
Latest blog entry: Supergee wing mount pylons
Jan 13, 2020, 02:10 AM
Rectal cancer survivor
I know a lot of people hunt and consider that their hobby. The firearms used are expensive, but it's part of the fee for the fun. Of course if they are lucky, meat will be part of that fun.
For RC flyers, the radios, electrics and the models are enough of an expense. If these fees from the FAA are per aircraft, as Leadchucker has already said, "I am done."
It will be a bitch for sure, but I will just go fishing more, lol. That's assuming Big Brother, FAA doesn't come after me for being a hazard to flying fish.
Jan 13, 2020, 06:21 AM
The Mr. Rogers of RC soaring
rdwoebke's Avatar
Thread OP
I hope you “I’m done” guys aren’t just telling me this. I hope you are telling the FAA and maybe while you are at it your elected representatives that info.


Ryan
Latest blog entry: Supergee wing mount pylons
Jan 13, 2020, 09:29 AM
Registered User
AMBeck's Avatar
Another question is what are the chances that a typical kit builder will be able to comply with all these requirements? I'm an EE and the configuration requirements look pretty challenging to me. Expecting a dad and his kid to comply simply so they can chuck a Gentle Lady into the air and have some fun together is asking a lot.
Jan 13, 2020, 09:43 AM
Mark LSF # 3792
Ryan,

The problem with your numbers are that most of them are estimates, though I admire your attempt to document the costs. It is unknown to us how much it would cost to retro fit an existing airframe, since most of the hardware for our use does not exist at this time and are "vaporware". What has happened is DJI, and the "Drone Delivery" groups have sold Legacy RC modelers down the river.

I for one have multiple 1/4 scale aerotow airplanes requiring more than 6 channels to operate them, amidst many other models. New receivers would most likely be at the higher end of your estimate for these, if not more. Additionally, the "controller" I use to fly those models is priced new, non-RID compliant, north of your $800 estimate. That would raise the cost for just one of them to possibly greater that $1500! That is a quite high discriminatory taxation to be allowed to fly a benign "toy" airplane out in the boonies.

Additionally, I would suspect that, with my little experience during my career seeing the FAA, the "declaration of compliance" fee will be per model design at least if not per unit. That would mean if one had the estimated 25 airframes each being a different design that number alone could be as high as $7,825 just to obtain a serial number for each one. It is also could be possible that many of those airplanes cost less that $313 to assemble...maybe obsoleting the model.

Lincoln, is correct it would probably be cheaper to build an ultralight and fly in it rather than fly RC!

Mark
Jan 13, 2020, 09:49 AM
Mark LSF # 3792
Quote:
Originally Posted by AMBeck
Another question is what are the chances that a typical kit builder will be able to comply with all these requirements? I'm an EE and the configuration requirements look pretty challenging to me. Expecting a dad and his kid to comply simply so they can chuck a Gentle Lady into the air and have some fun together is asking a lot.
Agreed AMBeck. The estimates mentioned in the document are shear fantasies in my mind. Low ball the costs and worry later after the #%*^ hits the fan...
Jan 13, 2020, 09:52 AM
The Mr. Rogers of RC soaring
rdwoebke's Avatar
Thread OP
Quote:
Originally Posted by AMBeck
Another question is what are the chances that a typical kit builder will be able to comply with all these requirements?
By the wording of the proposal my read is that they won't have to. My read is that only somebody that sold a complete kit with all components/materials to fly the plane would have too. The wording of the proposal indicates that if a person assembles a model from parts that they sourced from multiple sources that person is responsible for the compliance of the model.

Quote:
Originally Posted by Soarmark
The problem with your numbers are that most of them are estimates, though I admire your attempt to document the costs
Thank you for taking the time to read the proposal. I encourage you and everyone else to do a better job than I have with the estimates. The FAA is making estimates on "cost to upgrade" these devices. We should be doing the same.

Quote:
Originally Posted by Soarmark
I for one have multiple 1/4 scale aerotow airplanes requiring more than 6 channels to operate them, amidst many other models. New receivers would most likely be at the higher end of your estimate for these, if not more. Additionally, the "controller" I use to fly those models is priced new, non-RID compliant, north of your $800 estimate. That would raise the cost for just one of them to possibly greater that $1500! That is a quite high discriminatory taxation to be allowed to fly a benign "toy" airplane out in the boonies.
Great to know. Thanks for adding that additional data point to my analysis. Tell the FAA.

Quote:
Originally Posted by Soarmark
Additionally, I would suspect that, with my little experience during my career seeing the FAA, the "declaration of compliance" fee will be per model design at least if not per unit. That would mean if one had the estimated 25 airframes each being a different design that number alone could be as high as $7,825 just to obtain a serial number for each one. It is also could be possible that many of those airplanes cost less that $313 to assemble...maybe obsoleting the model.
I thought about that too. The wording of the proposal reads that the $313 fee would be per manufacturer. But the FAA proposal also said they only expect about $250 manufacturers to apply. They apparently don't expect hobbyists to attempt to build Standard Remote ID models.

Quote:
Originally Posted by Soarmark
ILincoln, is correct it would probably be cheaper to build an ultralight and fly in it rather than fly RC!
Everyone here knows that. Tell that to the FAA. Tell that to your elected representatives. Tell that to your friends and family so they can tell that to the FAA/elected representatives.



Ryan
Latest blog entry: Supergee wing mount pylons
Jan 13, 2020, 09:54 AM
AMA 7224
Leadchucker's Avatar
Quote:
Originally Posted by rdwoebke
I hope you “I’m done” guys aren’t just telling me this. I hope you are telling the FAA and maybe while you are at it your elected representatives that info.


Ryan
My elected 'representatives' are useless socialist twits on the take from Big Pharma. I would hold little hope that they would even read a communication on this especially given my past communications of other issues. Bottom line is that this whole thing is not about safety but about money. It's always about money somehow.
Latest blog entry: 1938 Rambler build
Jan 13, 2020, 10:05 AM
The Mr. Rogers of RC soaring
rdwoebke's Avatar
Thread OP
Quote:
Originally Posted by Leadchucker
My elected 'representatives' are useless socialist twits on the take from Big Pharma. I would hold little hope that they would even read a communication on this especially given my past communications of other issues.
You won't know unless you try. Also you may be able to get to a staffer that isn't a "twit" and maybe you can get that person to champion our cause. This is going to be a bit like telemarketing. We are going to get a lot of "no" before we get a "yes".

Quote:
Originally Posted by Leadchucker
Bottom line is that this whole thing is not about safety but about money. It's always about money somehow.
We all know this. We all know about being sold up the river. About being "done". About how I'm going to quit RC and take up pottery instead. Telling each other that isn't going to change anything. Telling the FAA/Congress/sharing our fight with your friends and family might.

Ryan
Latest blog entry: Supergee wing mount pylons
Jan 13, 2020, 10:59 AM
Registered User
tewatson's Avatar
Quote:
Originally Posted by rdwoebke
I hope you “I’m done” guys aren’t just telling me this. I hope you are telling the FAA and maybe while you are at it your elected representatives that info.
Well, judging by the rules’ complexity, I’d say this is exactly what the FAA wants - the systemic extermination of participants in the hobby.

Tom
Jan 13, 2020, 11:01 AM
The Mr. Rogers of RC soaring
rdwoebke's Avatar
Thread OP
Quote:
Originally Posted by tewatson
Well, judging by the rules’ complexity, I’d say this is exactly what the FAA wants - the systemic extermination of participants in the hobby.
Wether intentional or accidental we need to be telling everyone about this.

Ryan
Latest blog entry: Supergee wing mount pylons
Jan 13, 2020, 11:23 AM
Honorable Deplorable
woogie_man's Avatar
Anything the government assumes the cost of something will be...multiply that figure by 3 or 4 times. Being as the government cant get anything done at budget, or under for that matter.

The number of people they will need to hire to enact, enforce, watch, blah blah blah. Bureaucracy isnt cheap and they will bleed anything as much as they can for money.


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