Where to comment on the FAA’s proposed rule for Remote ID.

Earthman · Jan 3, 2020

Here’s a link to the proposed rule for Remote ID on the Federal Register’s webpage:

Remote Identification of Unmanned Aircraft Systems
This action would require the remote identification of unmanned aircraft systems. The remote identification of unmanned aircraft systems in the airspace of the United States would address safety, national security, and law enforcement concerns regarding the further integration of these aircraft...
www.federalregister.gov

There is a link/button near the top of that page that can be used to leave your comments on the proposed rule.

The proposed rule has a comment period that ends on March 2, 2020.

Please leave constructive comments, which are more likely to be read, appreciated, and incorporated into the rule by the FAA.

Tips for leaving formal comments:

https://www.regulations.gov/docs/Tips_For_Submitting_Effective_Comments.pdf

Direct link to FAA comment page:

Remote Identification of Unmanned Aircraft Systems

This action would require the remote identification of unmanned aircraft systems. The remote identification of unmanned aircraft systems in the airspace of the United States would address safety, national security, and law enforcement concerns regarding the further integration of these aircraft...

www.federalregister.gov

graywoulf · Jan 4, 2020

DONE!! And glad to do it. I even registered an account for further updates on this proposal. Thank you Earthman for posting the link. ?

Northwood Mediaworks · Jan 4, 2020

I too have commented, I was surprised that they let a Canadian submit a comment, but it accepted mine.

graywoulf · Jan 4, 2020

Northwood Mediaworks said:
I too have commented, I was surprised that they let a Canadian submit a comment, but it accepted mine.

Thank you for your support Robin! ? I have no problems with most of the regulations on flying drones but this one seems to be on the extreme side for most if not all drone pilots. I can only hope that a very large number of people will do this.

Koala Tails · Jan 5, 2020

There is a New Zealand guy, Bruce Simpson, who is encouraging people from around the world to submit comments to the FFA to try & stop the destruction of the RC aviation hobby in the USA. He also plans to send a petition type of letter with as many email signatures as possible on it.
The Utube channel is called “Xjet”, I think everyone should have a look at what Bruce is saying, then what you do is your choice.
Remember, whatever regulations the FFA instigate is likely to be copied by aviation authorities everywhere.

Spark 317 · Jan 5, 2020

Koala Tails said:
There is a New Zealand guy, Bruce Simpson

I enjoy his channel and his rants.

"Model aviation is not a crime"

RotorWash · Jan 5, 2020

graywoulf · Jan 5, 2020

Too late for me to watch that. ?

I B Spectre · Jan 5, 2020

NPRM Section XXIII.A says:

The most helpful comments reference a specific portion of the proposal,explain the reason for any recommended change, and include supporting data. To ensure the docket does not contain duplicate comments, commenters should send only one copy of written comments, or if comments are filed electronically, commenters should submit only one time.

I've been going through the copy I downloaded when the FAA sent out the notice on 12/26/2019. Then we were told on 12/31/2019 the NPRM was now published in the Federal Register. The two documents say the same thing, but the format used by the Federal Register is far more condensed, making citing specific portions to address by Section and page number more difficult than the pre-published version. Which one do they want us use?

Edit: I think I found the answer to my question in the Commenter's Checklist on page 1 under "Detailed Recommendations" paragraph 3 which states:

If you are commenting on a particular word, phrase or sentence, provide the page number, column, and paragraph citation from the federal register document.

Earthman · Jan 5, 2020

I made the attached one-page flyer that contains info and links about the FAA's proposed Remote ID rule with the intent to post it at area flying fields and local hobby shops to help inform those who may be interested.

Any suggestions or comments? Otherwise, feel free to distribute the flyer yourself.

Koala Tails · Jan 6, 2020

graywoulf said:
Too late for me to watch that. ?

It’s not too late, you can submit a second comment if you believe that your original is invalid because one of your objections has been addressed after the proposal’s 1st draft. You can always choose to add your name to the Xjet petition. I will also add my name to a letter from the Penrith Electric Model Aviation Club, of which I’m a member, when they write to the FFA.
Take a few minutes to hear what Bruce Simpson has to say, it may be all for nothing, or it could help save the hobby for everyone around the world.

graywoulf · Jan 6, 2020

Thank you Koala Tails for the heads up on that. I did watch Bruce's video and I like his views and commentary. I could not find the specific information on the Xjet petition but I will assume that the information is in his newest video titled "Rant". I have not watched it yet but I will soon. Then, I probably will submit a second comment based on the newer information that Bruce provides. Thanks again.

RotorWash · Jan 13, 2020

In this video FlytPath has Brendan Schulman, Vice President of Policy & Legal Affairs at DJI talk about the new Remote ID Proposed Rule.

I B Spectre · Jan 13, 2020

Thanks for posting that link, RotorWash. I've been monitoring the internet to see how various stakeholders are responding to the NPRM. Back in November, DJI demonstrated their drone-to-phone RID system at the United Nations International Civil Aviation Organization's third annual Drone Enable Conference. DJI Director of Technical Standards Javier Caina stated, "Our direct drone-to-phone solution is an easy and elegant solution for drone pilots. They will be able to comply with Remote ID expectations simply by updating the software on many drones already in widespread use, without any extra cost or equipment. In contrast, remote ID solutions that require pilots to add telecommunications equipment, subscribe to an ID service provider, connect to a cell tower or buy a data plan for their drone will create new costs and barriers for beneficial drone operations. DJI's direct drone-to-phone solution uses the latest technological advances to make remote ID compliance as easy and inexpensive as possible." DJI's system was built to conform to the ASTM international standard using Wi-Fi Aware protocol for mobile phones.

You can see why the half dozen or so companies hoping to cash-in on USS contracts would not be in favor. However, I think the two methods could coexist if the FAA applied the USS requirement to some commercial drones (i.e., delivery drones), rather than their current one-size-fits-all approach.

One aspect of concern to me with the drone-to-phone method currently proposed is showing the operator's position. In the age of road rage, the last thing we need is some paranoiac with unfounded suspicions thinking they are being surveilled or thieves looking to steal an expensive drone for some nefarious purpose. The authorities should be the only ones with access to that information. If contacted, they can address any concerns without putting the safety of the drone operator in jeopardy.

Earthman · Jan 13, 2020

Although it can be part of the proposed Remote ID database, there is no reason that the system needs to make the PIC’s ID available to the public. Law enforcement can have private access to it, but the public doesn’t need it and shouldn’t have it since it’s an invasion of privacy for the PIC. If the FAA is going to do that, they should include the pilots of manned aircraft and publish the IDs of those using the database to ID the PIC.

In any case, the privacy issue is pretty low on my list of concerns about the proposed rule. I’m more concerned about the cost of participating in Remote ID, the forced-obsolescence of my existing aircraft, the 400-ft horizontal distance limit, the loss of ordinary neighborhood flying sites, the eventual loss of approved flying fields, the eventual end of recreational flying, the loss of jobs and new development that recreational flying drives, and the fact that the supposed “need” for Remote ID is driven by a few commercial interests who may profit at our expense assuming that their commercial dreams materialize. I’m also irked about the fact that the commercial interests are building their aircraft and systems using technology largely developed for and by hobbyists.

Maybe this should be framed as the FAA and commercial interests interfering with our pursuit of happiness.

I B Spectre · Jan 16, 2020

The comment site is approaching 5700 responses at this hour. I saw a huge number of comments that all started with, "I am writing in response to the FAAs notice of proposed rulemaking on remote identification of unmanned aircraft systems (UAS). I am deeply concerned that some elements of the... ". The AMA is a large organization and their members look to be one of the most adversely affected by the FAA proposal, so it's understandable many would use their form letter. The FAA decision is not going to be made based on the number of yea/nay votes, which is too bad since those not in favor would win hands down. One well crafted comment speaking on the personal impact and specific unworkability of the proposal will carry far more weight than a hundred form letters.

RotorWash · Jan 19, 2020

The latest update from xjet:

I B Spectre · Jan 20, 2020

More information to consider while developing your NPRM comment:

FAA Releases UAS Remote Tracking & ID ARC Report

Background: The Aviation Rulemaking Committee (ARC) was chartered by the FAA in June of 2019 and consisted of 74 members representing entities with a stake in providing guidance and recommendations to the FAA which has been directed by the U.S. Congress to develop ways to identify UASs. The above link has embedded links to the actual report.

As for those companies wanting to get FAA contracts to perform USS functions, NASA has released a report,
NASA report USS performance trials

Earthman · Feb 1, 2020

What pilots of manned aircraft think and say about recreational drones is alarming and only partially wrong. Read the comments to the following post at Air Facts:

Drones: a clear and present danger? : Air Facts Journal

I recently had an encounter that highlights some of my concerns regarding the exponential proliferation of civilian UAS. It has nothing to do with the operator’s “flying skills;” it’s the potentially dangerous attitude(s) and culture that are growing along with the number of machines.

airfactsjournal.com