Summary of EAA response to FAA Remote Identification*
January 16, 2020 – EAA is very concerned that the FAA’s proposed rule on Remote Identification (RID) of Unmanned Aircraft Systems (UAS) could have a severe detrimental impact on traditional model aviation, and is preparing a full package of comments on the Notice of Proposed Rulemaking (NPRM).
The rule would require most UAS, no matter whether they are “drones” or traditional model aircraft, to carry equipment that identifies the device and broadcasts its location. Additionally, many would be required to be equipped with “geofencing” systems that autonomously contain the craft within a defined altitude and lateral boundary.
While EAA is primarily an organization that fosters and supports passion for manned flight, we recognize the modeling community as an important pathway into aviation. In fact, last year we launched the Young Eagles Build and Fly Program, a chapter activity to guide youth in building their own electric RC model, which they can then fly with a local Academy of Model Aeronautics (AMA) club. …we are concerned that regulatory overreach in the modeling world could easily set a precedent for future action against general aviation, such as an equipment mandate for the benefit of commercial UAS integration into the airspace.
EAA’s first action on this rule was to request a comment period extension from 60 to 120 days to allow time for the public to adequately evaluate this complex and sweeping proposal. Since then we have been carefully reading through the NPRM and working with industry partners in the modeling community. So far, these are our top concerns:
This rule is based on an imagined security and safety threat that simply is not proven in relation to traditional modeling. …
The rule would require every modeler to uniquely register every aircraft they own. Models come and go from modelers’ collections on a regular basis, which would necessitate frequent changes to the registry. A prolific modeler could easily own more than 100 models – a truly unwieldy number to maintain valid registrations, especially if there is a per-aircraft fee involved.
The FAA has based some of this rule on an assumption that the average UAS has a lifespan of approximately three years. This is wholly inappropriate in relation to model aircraft, which may last for 20 or more years or may crash on the first flight.
The NPRM has a narrow exemption to the RID requirement, but only for aircraft that are more than 50 percent amateur-built and flying at a recognized model field. The “51 percent rule” works well for full-size amateur-built aircraft, but cannot simply be adapted to modeling without a large amount of unnecessary bureaucracy. Adopting the rule as written could easily cause major consequences for builders of almost-ready-to-fly kits, which account for a majority of new model aircraft. These kits still involve extensive assembly and customization, but would likely fall short of the proposed 50 percent standard.
Under the NPRM, model fields (termed “FAA recognized identification area,” or “FRIA”) would be approved in a one-time, 12-month window. This is clearly meant to “grandfather” existing facilities, with no mechanism for approving new ones. From time to time, modeling clubs can and do relocate their operations for a variety of reasons, and new clubs are established. Additionally, EAA believes that anyone operating under the guidelines of a community-based organization should be able to establish a FRIA, such as individuals in rural areas who wish to fly from their own property.
Under “limited remote ID,” in circumstances where a model is not flown at an approved FRIA or is not compliant with the amateur-built carve-out and lacks onboard reporting equipment, a geofencing system is required. These are difficult to engineer and would severely hamper operations away from FRIAs or the use of prebuilt commercial models.
The rule mandates technology that is not available in large numbers and is not yet fully mature. In the case of the ADS-B mandate, for example, extensive testing took place prior to the 2008 NPRM that mandated its use (and the mandate was not in effect until a decade after the publication of the rule).
There is ambiguity about whether this rule applies to control line and free-flight modeling, and it could even cause complications for indoor modeling.
EAA will provide guidance to members who wish to comment in the coming weeks. When you do comment, please be respectful and use rational, fact-driven arguments in your own words. Form letters and emotional comments have much less impact on the regulatory process. More updates will be provided as they become available.
* (Excerpts posted with permission of EAA)
Important Message from AMA.
Click Here for 3 Minute Video on where to get your FAA Number and how to visibly show on aircraft AMA Short Video
FAA Recognized Identification Area (FRIA)
FAA Recognized Identification Area (FRIA) – This section is for the recreational fliers and will essentially be those fields that are recognized flying areas covered by a community based organization (CBO) like the Academy of Model Aeronautics (AMA). Interestingly enough they indicate that 90% of established fields will be approved for this designation, with 10% being denied due to being in a sensitive operating area. This process is also not automatic. The area wishing this designation must submit an application within 60 days of passage into law of this proposal. If approved, aircraft operating in that area are exempt from the hardware and transmitting requirement and may fly as long as they remain within 400’ from the control station.
A Conversation on the New Remote ID Proposal
Inability to Fly Beyond 400 Feet Lateral Distance Will Greatly Limit Drone Operations
In my view, the biggest change to our operations is the further definition of “Line of Sight.” This proposal puts a hard number of 400’ lateral distance from the control station as the limit to line of sight. I am sure there are more than a few operators that will take umbrage to this definition because it is easy to maintain an effective visual and provide deconfliction at 2, 3, or even 4 times that distance.
Unstable Internet Connection? You Might Be DENIED Permission to Takeoff
This statement appears on page 22 – Standard Remote Identification – 89.110. If the internet is unavailable at takeoff, or if during the flight, the unmanned aircraft can no longer transmit through an internet connection to a Remote ID USS, the UAS would have to broadcast the message elements directly from the unmanned aircraft from takeoff to landing.Paragraph
It is further clarified in the document that dependent upon whether the aircraft is even capable of sending the message determines whether it can even take off. Stated differently, if your aircraft reports a malfunction in the transmission of the message, it will NOT BE ALLOWED TO EVEN TAKE OFF. Most UAS will have to be retrofitted to include this monitoring/diagnostic system to report this condition. (As a side note, this element is significantly more onerous than manned GA requirements utilizing ADS-B. Even after the 2020 mandate, I can take off in my Cessna 172 without having to report my position as long as I stay out of controlled airspace.)