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Jan 31, 2020, 01:10 PM
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aeronaut999's Avatar
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Brainstorming suggested changes to proposed RID regulations


I'm in the process of starting to brainstorm and draft an actual comment to the RID NPRM.

I'll save a discussion for what should go into the part of the comment that talks about what is wrong with the current proposed regs for another thread. (Or just see 99% of the posts since Jan 1 in "Model Aircraft and Drone Advocacy".)

As far as suggested changes go-- that is what I want to talk about in this thread. Your feedback/ suggestions are welcome

My comment will likely include suggestions to change the proposed rules to

1) Make it clear that the > 50% amateur builder "fabricated and assembled" requirement is NOT a requirement that the amateur builder actually fabricates / manufactures more than 50% of the required PARTS, page 153 of the preamble to the NPRM notwithstanding.

2) Exclude the transmitter / ground station from the items to be considered when determining amateur-built status, at least in the case of traditional non-multicopter model aircraft lacking automatic stabilization and / or automatic guidance.

3) Exclude all electronic components (eg transmitter, receiver) from the items to be considered when determining amateur-built status, at least in the case of traditional non-multicopter model aircraft lacking automatic stabilization and / or automatic guidance.

4) Exclude all propulsion system components from the items to be considered when determining amateur-built status, at least in the case of traditional non-multicopter model aircraft lacking automatic stabilization and / or automatic guidance.

5) Alternatively (or "Also?"), in recognition that strict compliance with the "amateur-built" requirement will be difficult for most hobbyists to achieve, change Part 89 Subpart F -- the production requirements-- so that they do NOT apply to traditional non-multicopter model aircraft lacking (or intended to be flown without) automatic stabilization and/ or automatic guidance. Thus there would be no barrier to new production of RID-less ARFs, BNFs, kits of balsa parts, scratch-built models, etc that could be flown in the FRIAs.

(Possibly omit words "traditional" and/ or "non-multicopter" from 2,3,4, and 5 above?) (Probably will change "model aircraft" to "UASs" but that is so annoying I'd rather not use that terminology in the draft right now.)

6) Remove the ban on creating new FRIAs after the one-year period ends.

7) Make it much easier to create a FRIA. An individual should be able to create a FRIA. Alternatively (or "Also"?), enable a way for an individual to create a temporary FRIA via LAANC or a similar system.

8) Recognize that the FRIAs (both "permanent" and "temporary") solve the problem of deconflicting the airspace used by hobby rc pilots with that used by commercial drones. Recognize that continuing to have Subpart F ban production of RID-less multicopters (or should I just say RID-less model aircraft?) that feature automatic stabilization and / or automatic guidance largely solves the "rogue operator" problem. As far as the issue of terrorism etc goes, recognize that if traditional model aviation is completely destroyed in order to slightly reduce the chance of an incident, then "the terrorists have won".

9) Provide a list of well-known full-scale designers and innovators, test pilots, combat pilots, astronauts, etc whose career paths have been heavily influenced by involvement in model aviation. Model aviation is an important part of our country's heritage, and future.

Still kind of in a brainstorming mode, but that's what I'm thinking. Updates to follow. Again, your comments/ suggestions are welcome.

Steve
Last edited by aeronaut999; Jan 31, 2020 at 01:20 PM.
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Jan 31, 2020, 02:41 PM
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I would strongly encourage you to rethink your stance on stabilization systems.

While i agree (albeit begrudgingly) that autonomous capabilities should fall under strict RID, a distinction between autonomous operation capability and automated stabilization (gps vs gyros) would mean that rc helicopters are not left out in the cold (this would also save significant portion of racing and freestyle multirotors).

While in principal I wholeheartedly agree with your ideas for FRIAs. I personally feel the time would be better spent fighting for a new type of "limited remote ID" that would allow for scratchbuilding etc.

Their wording and intentions for phasing out FRIAs is very deliberate, i think its a lost cause to fight for it. In the future i believe they intend for all the future "FRIAs" to have a "limited remote ID" transmitter to identify themselves. This seems unnecessary to us modelers, but such "no fly zones" without an active signal are a nightmare to get through the scull of some manned aviation pilots. Autonomous commercial craft will also greatly suffer.

Think about it, if a new FRIA spawns somewhere sometime in the future, all automated commercial traffic would have to be manually updated to accommodate for that, seems reasonable at first glance, but unfortunately unrealistic. Compared to the purposed "limited remote ID" where every amazon/fedex drone would automatically know where to avoid, it becomes a nobrainer for rulemaking.
Jan 31, 2020, 04:45 PM
It flies? I like it!
Oaf, how would adding a FRIA be any more dynamic than an ad-hoc RID? Whatever database they interrogate to see "realtime" (a pipe dream) location of other craft could very easily contain the new FRIA with a single update. Remember, there is NO craft-to-craft broadcast in this proposal (thus the prohibition on ADS-B).

As far as scratchbuilding, the limited RID does not forbid this (that I can find) since there is no transponder on the vehicle. The location and ID are sent by an "app" on a phone, or presumably, some sort of future Transmitter that also has a SIM card and data plan to report the GPS coordinates and ID into the Internet. The inconsistency in the NPRM is that even though the notification will come from an "app" on a phone, it mentions a takeoff interlock so that a flight cannot commence without Internet connectivity.

I feel the best approach today is to regularize (add/delete/modify) the existence of FRIAs. Allow temporary ones to be established. This relieves individual participants from having to report into the system. For locations where a FRIA is not established use the current single ID (I can only fly an airplane at once and you want to know who I am, not whether it's the green plane with the white stripe or the white plane with the green stripe) via phone App to the Internet (or the intention to fly at a location between certain times prior to losing Internet connection) together with a VLOS envelope (not the 400' currently proposed). This would allow me to fly in my own yard or at a park or schoolyard where it's not prohibited.

And yes, #2 would suffice by itself but may put a club field in jeopardy, if compliance was spotty (a FRIA is a better means for "compliance" by all present).
Jan 31, 2020, 05:14 PM
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kingwoodbarney's Avatar
FRIA's should be permanent until WE cancel them.

New FRIA's should be allowed even after the first 12 months. (Because Clubs sometimes must move)

Let me build and fly kits, scratch, ARF's, BNF, PNP, everything in FRIA's.

All AMA club fields should automatically be approved FRIA's.
Jan 31, 2020, 05:40 PM
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I am possibly under the mistaken impression that there was a pipe dream of craft-to-craft communication, albeit oneway (TX) for us...

Regardless, FRIAs would create permanent/temporary nofly zones, which as mentioned: fullscale pilots, or at least "bad actors" in their ranks, are hopeless at identifying and avoiding, i get a strong sense that regulators are trying to make this part foolproof. (in addition to my paranoid/conspiratorial sense of "they are just trying to kill the hobby")


In regards to scratch building and limited RID: i think its been stated in other threads that it does indirectly outlaw diy, due to essentially geofencing tech that the model would have to have installed in order to force it to fly within the 400' limited ID bubble, then you have the tamper proof requirement the said tech, the immobilizer, and the fabrication requirements that need to be followed in order to get certification and be compliant etc.etc... its all very confusing and poorly worded and barely explained in the proposal...

But the gist of it seems that, sure the model doesn't need to have a on board ID transmitter, but it needs tamper proof and approved tech, and verified and approved installation, that would make it impossible for the user to exceed the operational boundaries set by the Limited RID beacon. (or phone app, or whetever that thing might end up being).
Jan 31, 2020, 07:35 PM
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Quote:
Originally Posted by aeronaut999
I'm in the process of starting to brainstorm and draft an actual comment to the RID NPRM.

I'll save a discussion for what should go into the part of the comment that talks about what is wrong with the current proposed regs for another thread. (Or just see 99% of the posts since Jan 1 in "Model Aircraft and Drone Advocacy".)

As far as suggested changes go-- that is what I want to talk about in this thread. Your feedback/ suggestions are welcome

My comment will likely include suggestions to change the proposed rules to

1) Make it clear that the > 50% amateur builder "fabricated and assembled" requirement is NOT a requirement that the amateur builder actually fabricates / manufactures more than 50% of the required PARTS, page 153 of the preamble to the NPRM notwithstanding.

2) Exclude the transmitter / ground station from the items to be considered when determining amateur-built status, at least in the case of traditional non-multicopter model aircraft lacking automatic stabilization and / or automatic guidance.

3) Exclude all electronic components (eg transmitter, receiver) from the items to be considered when determining amateur-built status, at least in the case of traditional non-multicopter model aircraft lacking automatic stabilization and / or automatic guidance.

4) Exclude all propulsion system components from the items to be considered when determining amateur-built status, at least in the case of traditional non-multicopter model aircraft lacking automatic stabilization and / or automatic guidance.

5) Alternatively (or "Also?"), in recognition that strict compliance with the "amateur-built" requirement will be difficult for most hobbyists to achieve, change Part 89 Subpart F -- the production requirements-- so that they do NOT apply to traditional non-multicopter model aircraft lacking (or intended to be flown without) automatic stabilization and/ or automatic guidance. Thus there would be no barrier to new production of RID-less ARFs, BNFs, kits of balsa parts, scratch-built models, etc that could be flown in the FRIAs.

(Possibly omit words "traditional" and/ or "non-multicopter" from 2,3,4, and 5 above?) (Probably will change "model aircraft" to "UASs" but that is so annoying I'd rather not use that terminology in the draft right now.)

6) Remove the ban on creating new FRIAs after the one-year period ends.

7) Make it much easier to create a FRIA. An individual should be able to create a FRIA. Alternatively (or "Also"?), enable a way for an individual to create a temporary FRIA via LAANC or a similar system.

8) Recognize that the FRIAs (both "permanent" and "temporary") solve the problem of deconflicting the airspace used by hobby rc pilots with that used by commercial drones. Recognize that continuing to have Subpart F ban production of RID-less multicopters (or should I just say RID-less model aircraft?) that feature automatic stabilization and / or automatic guidance largely solves the "rogue operator" problem. As far as the issue of terrorism etc goes, recognize that if traditional model aviation is completely destroyed in order to slightly reduce the chance of an incident, then "the terrorists have won".

9) Provide a list of well-known full-scale designers and innovators, test pilots, combat pilots, astronauts, etc whose career paths have been heavily influenced by involvement in model aviation. Model aviation is an important part of our country's heritage, and future.

Still kind of in a brainstorming mode, but that's what I'm thinking. Updates to follow. Again, your comments/ suggestions are welcome.

Steve
Steve -

I would add the provision that the FAA certify RID at the electronic component level as well as, or in addition to certification at the system (UAS) level. Regardless of the percentage of labor that is considered (I would remove the amateur built provision in its entirety) we canít build or refit anything without access to certified RID electronics. Now if FRIAís are maintained forever, then this is less of a concern.
Jan 31, 2020, 08:32 PM
Registered User
kneesaknockin's Avatar
The Hobby is changing its tune, finally...
FAA Remote ID NPRM Response Guide (47 min 38 sec)
Feb 01, 2020, 02:37 AM
lurking in the HOLE :)
KCV6's Avatar
Sort of shakes head a bit.

Why is it everyone keeps assuming the FAA when it cites what happened at Gatwick etc. is saying it was a drone? The issue was it may have been a drone. Without me saying why I'm shaking my head a bit, can anyone else here put together 1 and 1 and come up with 2? 2 meaning why the FAA sees RID may have had an impact in these situations. Hint, you have to take the emotion out and just think about it from a neutral point of view.
Feb 01, 2020, 09:49 PM
Registered User
The FAA does not care whether Gatwick or any of the other incidents was a drone. They're not using data to regulate; they've decided what the regulations should be and are using anything they have as support for it.


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