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sUAV Rules & Regulations
FAA (USA) new proposed rules for UAV Remote-ID and location
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<blockquote data-quote="I B Spectre" data-source="post: 107828" data-attributes="member: 18605"><p>Good points, SirThomas, particularly since DJI has by far the largest drone products in the U.S.. Still, while they are the elephant in the room of drone producers, they are but one stakeholder that we would like to see influencing the regulatory outcome.</p><p></p><p>This NPRM is huge and takes a while to review, but I'm seeing certain items that pertain to those of us in this forum and I apologize in advance for the lengthy post, but it is important we understand the proposals to which we can respond:</p><p></p><p>Page 188:</p><p><em>Based on industry information and market research, the FAA estimates at least 93% of the current part 107 fleet and at least 20% of the current recreational fleet would be eligible for retrofits, thus minimizing the costs for operators and producers. This is based on industry information suggesting that small UAS at a certain level of design specification and operational capability would likely have system and connectivity capabilities that could be retrofit through a software update.</em></p><p></p><p>Page 190: </p><p><em>The FAA has limited information on the manufacturers and types of UAS in the recreation fleet because part 48 registration currently allows limited recreational flyers to register multiple small unmanned aircraft under a single Certificate of Aircraft Registration. However, published market information finds 36% of the North America fleet is manufactured by one producer (DJI) that provided information to the FAA suggesting they could retrofit. The FAA estimates that about 20% of the recreational fleet is comprised of aircraft manufactured by DJI that could be retrofit. This estimate was developed by multiplying the combined part 107 and recreational unmanned aircraft fleet by 36%, and then subtracting DJI aircraft registered under part 107.</em></p><p></p><p>Page 191:</p><p><em>Therefore, the FAA assumes UAS purchased in year 1 that are retrofit would allow the aircraft to “continue flying ”under the limited or standard remote identification requirements after the compliance date of the final rule. UAS sold in year 1 that could not be retrofit would likely not meet the limited or standard remote identification requirements after year 3. <strong>Persons that own unmanned aircraft in this group of “legacy” UAS without remote identification equipment would have potential “loss of use” associated impacts since this proposal does not include grandfathering.</strong> The retrofit assumptions above were used in this analysis to estimate the effects of retrofits on the costs of the proposal and its compliance period.</em></p><p></p><p>Anticipating the kickback this would cause, the FAA asks the following on Page 192:</p><p></p><p><em>- Would it be possible to retrofit by a software or firmware update through an internet download?</em></p><p><em></em></p><p><em>- How would a retrofit solution meet the proposed tamper resistance and labelling </em></p><p><em>requirements? Would a software push be able to meet requirements for tamper </em></p><p><em>resistance or would it require hardware? How would you meet labelling requirements under a retrofit scenario (e.g., would you mail the label)?</em></p><p><em></em></p><p><em>- Would retrofits meet the limited or standard remote identification requirements?</em></p><p><em></em></p><p><em>- What are the costs of retrofits to the producer and the owner/operator?</em></p><p><em></em></p><p><em>- In lieu of a software push through the internet, what other methods could producers use to facilitate retrofits (e.g., mail-in programs or physical retrofit drop-off locations)?</em></p><p><em></em></p><p><em>-If retrofits are not an option for certain makes and models, would you offer operators “buy-back” or “trade-in” incentives to replace UAS without remote identification equipment? If so, please describe the incentive and the process.</em></p><p></p><p>As additional pertinent information is understood, it will be posted.</p></blockquote><p></p>
[QUOTE="I B Spectre, post: 107828, member: 18605"] Good points, SirThomas, particularly since DJI has by far the largest drone products in the U.S.. Still, while they are the elephant in the room of drone producers, they are but one stakeholder that we would like to see influencing the regulatory outcome. This NPRM is huge and takes a while to review, but I'm seeing certain items that pertain to those of us in this forum and I apologize in advance for the lengthy post, but it is important we understand the proposals to which we can respond: Page 188: [I]Based on industry information and market research, the FAA estimates at least 93% of the current part 107 fleet and at least 20% of the current recreational fleet would be eligible for retrofits, thus minimizing the costs for operators and producers. This is based on industry information suggesting that small UAS at a certain level of design specification and operational capability would likely have system and connectivity capabilities that could be retrofit through a software update.[/I] Page 190: [I]The FAA has limited information on the manufacturers and types of UAS in the recreation fleet because part 48 registration currently allows limited recreational flyers to register multiple small unmanned aircraft under a single Certificate of Aircraft Registration. However, published market information finds 36% of the North America fleet is manufactured by one producer (DJI) that provided information to the FAA suggesting they could retrofit. The FAA estimates that about 20% of the recreational fleet is comprised of aircraft manufactured by DJI that could be retrofit. This estimate was developed by multiplying the combined part 107 and recreational unmanned aircraft fleet by 36%, and then subtracting DJI aircraft registered under part 107.[/I] Page 191: [I]Therefore, the FAA assumes UAS purchased in year 1 that are retrofit would allow the aircraft to “continue flying ”under the limited or standard remote identification requirements after the compliance date of the final rule. UAS sold in year 1 that could not be retrofit would likely not meet the limited or standard remote identification requirements after year 3. [B]Persons that own unmanned aircraft in this group of “legacy” UAS without remote identification equipment would have potential “loss of use” associated impacts since this proposal does not include grandfathering.[/B] The retrofit assumptions above were used in this analysis to estimate the effects of retrofits on the costs of the proposal and its compliance period.[/I] Anticipating the kickback this would cause, the FAA asks the following on Page 192: [I]- Would it be possible to retrofit by a software or firmware update through an internet download? - How would a retrofit solution meet the proposed tamper resistance and labelling requirements? Would a software push be able to meet requirements for tamper resistance or would it require hardware? How would you meet labelling requirements under a retrofit scenario (e.g., would you mail the label)? - Would retrofits meet the limited or standard remote identification requirements? - What are the costs of retrofits to the producer and the owner/operator? - In lieu of a software push through the internet, what other methods could producers use to facilitate retrofits (e.g., mail-in programs or physical retrofit drop-off locations)? -If retrofits are not an option for certain makes and models, would you offer operators “buy-back” or “trade-in” incentives to replace UAS without remote identification equipment? If so, please describe the incentive and the process.[/I] As additional pertinent information is understood, it will be posted. [/QUOTE]
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FAA (USA) new proposed rules for UAV Remote-ID and location