Help me out here

[I B Spectre]

I've been poring over the NRPM since its release and trying to formulate a response that conforms to their suggested "Commenter's Checklist" to maximize effective input. To do that, I need input from knowledgeable forum members on specifics of how our drones work and how the FAA's proposal may have a negative impact. I will recite from the NPRM published in the Federal Register and reference page number(s). My first question for you pertains to drone operation under the Standard Remote I.D. method, is specific and limited to how the drone communicates with the controller. Let me know your thoughts and how I can strengthen my response.

XIX. Regulatory Notice and Analyses - 3. Cost and Savings Summary -.iii. UAS Producers (Pg 62 para. 1)
Operators of limited remote identification UAS must transmit message elements to the Remote ID USS from the control station, which could be an electronic device such as a smart phone or tablet. For purposes of this analysis, the FAA determines that operators of limited remote identification UAS would already have a cell phone or electronic device capable of transmitting the message elements through an internet connection to the Remote ID USS and thus incur no additional costs for the purchase of a device to transmit messages to a Remote ID USS.

Response: Many drones communicate over 2.4 GHz and 5.8 GHz frequency bands via Wi-Fi. The 2.4 GHz band is particularly congested in urban areas and can experience interference potentially causing loss of command communication. While the 5.8 GHz band is less congested, the potential for interference exists. Most users have found that reducing the Wi-Fi interference by using a direct cable connection between the "control station" (remote control) and their electronic device (i.e., cell phone or tablet) and putting the electronic device in Airplane mode enhances control connection and reduces the likelihood of loss of control communication to the drone. The electronic device does not require a connection to the internet or cell provider service. Moreover, such connections invite unreliable control issues.

 

[PhantomFandom]

Response: Many drones communicate over 2.4 GHz and 5.8 GHz frequency bands via Wi-Fi. The 2.4 GHz band is particularly congested in urban areas and can experience interference potentially causing loss of command communication. While the 5.8 GHz band is less congested, the potential for interference exists.

I see where you are going with this but I can't say that I fully agree.
This whole part about communications frequencies and potential interference has nothing to do with the section you referenced, regarding communication over the Internet from the mobile device. That communication would most likely be over the device's built-in mobile data network. In the cases where you are not using a cellular enabled device then yes the device would most likely be using WiFi to communicate with another device (i.e. a WiFi Hot Spot) which has Internet connectivity. In those cases, the potential interference would only apply to drones that use WiFi between the mobile device and the remote. In the DJI line (starting from the Phantom 3 and up), that includes only the P3S and the Spark. All other models connect natively with a USB cable between the remote and the mobile device.

Most users have found that reducing the Wi-Fi interference by using a direct cable connection between the "control station" (remote control) and their electronic device (i.e., cell phone or tablet) and putting the electronic device in Airplane mode enhances control connection and reduces the likelihood of loss of control communication to the drone.

The communication between the remote controller and the drone is independent of the communication of your mobile device with the Internet, and also independent of the communication between your mobile device and the remote controller. Unless you are using your mobile device directly connected to the drone without a remote controller, then even a completely locked up/frozen mobile device will not prevent you from controlling your drone with the remote controller. True that you would not have FPV view, but you still have full control and the ability to initiate RTH. By law you should only be flying within VLOS so you do not lose the ability to control your drone in any way.
So Airplane Mode does indeed make the mobile device more reliable and less prone to distractions (like phone calls, text messages, etc) but it still does not cause "loss of control communication to the drone".

The electronic device does not require a connection to the internet or cell provider service. Moreover, such connections invite unreliable control issues.

Very true that our drones do not require Internet connectivity. Also true that a locked up mobile device will make the task of flying a bit more difficult. However it generally does not " invite unreliable control issues". The drone is still completely under full control of the remote controller. You can try this at any time by just powering off your mobile device. You will not lose control of your drone in any way.

So overall do I like the requirement to be connected to the Internet during flying? NO I certainly do not. I typically never use my normal cell phone. I use a dedicated cell phone (without cell service) or a dedicated tablet. However, I don't see the points you made as very strong arguments for objecting to the proposal. I have on a few occasions (very few) used my normal cell phone (with Internet service) or flown without a mobile device at all. In both cases, there were no control issues between my remote and the drone.

If this proposal becomes law then it will force me to either use a device with built-in cellular connectivity or to have a mobile hot spot with me to connect my tablet to. I have on occasion used this scenario when I needed the Internet to complete a mapping mission. Not the best scenario but it did work without consequences.

 

[I B Spectre]

Thanks for the feedback, PhantomFandom. I need input from people more knowledgeable than myself on several subjects. I, too, use a dedicated cell phone without a SIM card as the device I connect to the RC via OTG cable.

So that I understand correctly, are you saying that drones such as Spark that use Wi-Fi communication would not be more prone to signal loss in Wi-Fi congested areas when broadcasting the required message elements to the Remote I.D. USS?

I ask because I've read numerous explanations, accurately or not, that talked about Wi-Fi band interference as a probable cause for flyaways. (The subject of availability of internet connections in more rural places will be a separate discussion.)

 

[PhantomFandom]

I ask because I've read numerous explanations, accurately or not, that talked about Wi-Fi band interference as a probable cause for flyaways. (The subject of availability of internet connections in more rural places will be a separate discussion.)

Yes there can definitely be issues with WiFi connectivity in congested areas. This is true for the connection between remote controller and drone for the basic WiFi drones (P3S, Mavic Air, Spark, Mavic Mini) but that issue exists with or without this proposed FAA requirement. It is the connectivity between the remote and the drone that is susceptible. It has nothing at all to do with the mobile device. Even then, if total signal loss occurs then the fail-safe RTH should kick in and bring the drone home. Signal loss should not cause a fly-away.

So that I understand correctly, are you saying that drones such as Spark that use Wi-Fi communication would not be more prone to signal loss in Wi-Fi congested areas when broadcasting the required message elements to the Remote I.D. USS?

Apples and oranges. The mobile device would be using a cellular signal (not WiFi) to send its information to the FAA service provider. The remote is communicating with the drone via WiFi and that has nothing to do with the mobile device.

 

[I B Spectre]

Apples and oranges. The mobile device would be using a cellular signal (not WiFi) to send its information to the FAA service provider. The remote is communicating with the drone via WiFi and that has nothing to do with the mobile device.

I'm trying to get a handle on how these systems work for Standard RID operation.
Agreed, the mobile device uses a cell signal for (data) connection to the internet, but per X.A.1 (Pg 28 para. 1), "Standard remote identification UAS would be required to transmit certain message elements through the internet to a Remote ID USS and to broadcast the same message elements directly from the unmanned aircraft using radio frequency spectrum in accordance with 47 CFR part 15, where operations may occur a Federal Communications Commission (FCC) individual license".

Is it safe to assume that the broadcast capability "directly from the unmanned aircraft using radio frequency spectrum" would most likely be via Wi-Fi?

Para. 4 - If a standard remote identification UAS experiences an in- flight loss of broadcast capability, regardless of whether it is connected to a Remote ID USS, the operator would have to land the unmanned aircraft as soon as practicable.

I really appreciate your patience in trying to help me have a better understanding.

 

[Scottalmas]

Is it safe to assume that the broadcast capability "directly from the unmanned aircraft using radio frequency spectrum" would most likely be via Wi-Fi?

Para. 4 - If a standard remote identification UAS experiences an in- flight loss of broadcast capability, regardless of whether it is connected to a Remote ID USS, the operator would have to land the unmanned aircraft as soon as practicable.

No, I don't think that is a safe assumption at all. My assumption was that drones capable for Standard RID use produced 2 years after the passing of the proposed rules would have something akin to a SIM card onboard and you would have a separate internet service plan for that SIM card. Hopefully, you could move the card from UAS to UAS if you have multiple bird in your fleet. Without this capability, you would be restricted to flight under the Limited Identification rules, which means you would be limited by firmware to keeping your UAS within 400 feet from you.

 

[PhantomFandom]

Is it safe to assume that the broadcast capability "directly from the unmanned aircraft using radio frequency spectrum" would most likely be via Wi-Fi?

I dont' think it is ever safe to assume anything. Until the standards are flushed out, we don't know what type of broadcast signal this will be.

My assumption was that drones capable for Standard RID use produced 2 years after the passing of the proposed rules would have something akin to a SIM card onboard and you would have a separate internet service plan for that SIM card.

I don't think this is correct either. We are talking about two different broadcasts here. The remote is the only one that is required to send the information to a UD ISS provider. The aircraft is simply broadcasting its information to the immediate vicinity (like a beacon, transponder, or ADSB-Out) so that anyone in that area is aware that the craft is there.

 

[Scottalmas]

The remote is the only one that is required to send the information to a UD ISS provider. The aircraft is simply broadcasting its information to the immediate vicinity (like a beacon, transponder, or ADSB-Out) so that anyone in that area is aware that the craft is there.

The language in the NPRM is "Standard remote identification UAS would be required to broadcast identification and location information directly from the unmanned aircraft and simultaneously transmit that same information to a Remote ID USS through an internet connection." [Emphasis added].

I read that to mean that the aircraft, the actual UAS, would have to bet able to transmit the information to a RID USS through an internet connection. I see now that the NPRM also says "The FAA is proposing that unmanned aircraft system (UAS) means an unmanned aircraft and its associated elements (including communication links and the components that control the unmanned aircraft) that are required for the safe and efficient operation of the unmanned aircraft in the airspace of the United States.

I can see how the proposed rule could be read to mean that the internet connection only needs to be on the controller, which would be great.

 

[RotorWash]

I don't think this is correct either. We are talking about two different broadcasts here. The remote is the only one that is required to send the information to a UD ISS provider. The aircraft is simply broadcasting its information to the immediate vicinity (like a beacon, transponder, or ADSB-Out) so that anyone in that area is aware that the craft is there.

This is my understanding of broadcast as well. It's a one way radio signal from the craft to be picked up by local receivers. On the other hand the term transmit is used only when referring to an Internet connection to a RID USS which requires two-way communication. With SRID it could be possible (sim card) to have the drone itself do both but the FAA seems to be leaning towards the control station handling the Internet connection to the USS which makes the most sense at this time and may help in regards to retrofits of legacy craft.

Pg 39 - Sec 9 Para 1
... The FAA envisions that remote identification broadcast equipment would broadcast using spectrum similar to that used by Wi-Fi and Bluetooth devices. The FAA is not, however, proposing a specific frequency band. Rather, the FAA envisions industry stakeholders would identify the appropriate spectrum to use for this capability and would propose solutions through the means of compliance acceptance process. This requirement would ensure that the public has the capability, using existing commonly available and 47 CFR part 15 compliant devices, such as cellular phones, smart devices, tablet computers, or laptop computers

Pg 39 - Sec 9 Para 6
For both standard and limited remote identification UAS, at this time the FAA has not proposed any requirements regarding how the UAS connects to the internet to transmit the message elements or whether that transmission is from the control station or the unmanned aircraft. The FAA understands, however, that there are concerns about the impact that connecting to the internet directly from the unmanned aircraft (as opposed to the control station) could have on networks that use radio frequency spectrum, including interference, network stability, or other effects. The FAA seeks comments on these potential effects, recognizing that issues of interference or other impacts to communications networks are independently reviewed by the FCC. The FAA requests that comments indicate any drawbacks or impacts to users or license holders of either licensed or unlicensed spectrum. Additionally, the FAA seeks feedback regarding whether any existing UAS are capable of connecting to the internet from the unmanned aircraft, and if so, what methods are used for those connections.

 

[I B Spectre]

Pg. 53 of the NPRM states: "...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". The word "fleet" is not clearly defined and may or may not refer to the total aggregate of UAS. The DJI estimated retrofit of 20% of recreational fleet is encouraging and would allow a number of DJI drones currently flying to continue under RID.

The NPRM, especially the Federal Register version, is difficult to read and discusses the same subjects in multiple places throughout the document albeit with minor, but sometimes significant, differences.

I have a hunch that, since the subject of remote identification, has been discussed since 2016, the FAA felt pressured to finally put forth some kind of a proposal to show the process was still moving forward. The fact that the NPRM includes ALL unmanned aircraft is too big a bite to chew. In my opinion, everyone would have been better served had it been broken down into separate proposals for autonomous drone delivery systems championed by big business, commercial drones as used today, recreational drones and RC modeling.

What has emerged is a proposal that pits one group against another. The companies behind drone delivery see it as an important, though unproven, advancement of business without regard for the impact on the other entities.

The RC modelers, many of which have been flying for decades, look to be the most adversely impacted. The FAA allows only 1 year to submit applications for adding recognized identification areas. Many RC modelers see drones as the catalyst driving this change and likely have no interest in having to share their flying areas. Since many RC modelers build their aircraft from scratch or kits, there is no avenue to upgrade them with the FAA certified required capabilities to allow them to fly anywhere else.

Those flying drones under part 107 have gone to the trouble to pass the certification allowing monetization. This is a smart use of the technology and serves an important function on many levels. Unfortunately, they suffer the same potential impact as the recreational fliers.

It's easy to look at the proposal as an impossible mountain to climb. The frustration of sifting through the document trying to find the most important issues on which to comment can be overwhelming. It's not hard to throw up ones hands and say, "They're gonna do what they're gonna do". When I read many of the comments submitted already and listen to YouTube vloggers putting in their two cents, my optimism sinks further because it's obvious they have not done their homework, but are treating it as if it were a poll. Still, this may be our one and only important shot at saving the hobby. It deserves serious study, dispassionate discussion and thoughtful responses.