FAA NPRM: major purpose is to develop a nationwide aerial surveillance system

The FAA’s NPRM directly fosters the development of a nationwide aerial surveillance system, using the fleet of commercial and recreational drones to record data all over the country and log that data in real time.

This includes close in, low altitude detailed photos of your yard, your children, your pets, businesses and their inventories and finished products, their potential expansion, and data for law enforcement.

It is right there in the NPRM itself:

“However, the proposal does not prohibit designers, producers, or operators from including a capability for limited remote identification UAS to broadcast information or data unrelated to remote identification, such as a camera feed or telemetry data.” Page 97, Section X, A, 2, Paragraph 2

KittyHawk noted in a blog post that some Remote ID USS business models may be offered for “free”.

When a service is offered or “free” it means we or our privacy are being sold for a profit.

Imagine the market value of obtaining very low altitude high resolution images of your back yard, your children, the clothing you wear, the quality of backyard furniture you have, the types of automobiles you drive, how well you care for your yard, the types of toys your children are playing with – and so much more. This information can be used to discern your household income and wealth. With modern image AI techniques, much of this image analysis can be done automatically.

Commercial drone fleets can and will be mapping your Wi-Fi networks and identifying what Bluetooth services are located inside your homes. Your own recreational drone, flying in your backyard, might be simultaneously taking photos to share with your Remote ID USS – and you might not even be aware of it.

All of this information will be collected, analyzed, interpreted, and sold to third parties.

Law enforcement may use these close range aerial images to look for suspicious activities.

Local government will use these images to check for non-compliant property uses, code violations, and home modifications without a permit. I lived in a city where putting in a portable 3 x 5 foot garden shed is treated as permit-required event, and a taxable addition to one’s property. They hired a company to conduct aerial photography to find potential violators. Now, with the data paid for by drone operators, this information will be available at much lower cost.

In that same city, if your lawn grass exceeded six inches in height, you could be subject to a code enforcement officer. For now, they only enforce that rule if a neighbor calls in a complaint. With low cost data from drones, this can be determined automatically – does not even need artificial intelligence!

Businesses will purchase low altitude photos from drone companies to keep tabs on their competitors. Analysts can discern arrivals of inventory and departures of finished products, just by counting trucks. In some cases, inventory and finished products may be stored outside and will now be accessible to competitors.

I hypothesized in a post yesterday that something was missing in this NPRM process. This week, the FAA rejected requests from the EAA and AMA to extend the comment period, and did so using unduly harsh language, stating that they needed to enact the final rule as fast as possible.

The FAA is hell bent on enacting this NPRM – an NPRM that does not even solve the problems they say they are trying to solve due to numerous and necessary loopholes (indoor flight capable drones and COPPA).

Is this national aerial surveillance network the actual goal?

This is Orwell’s 1984 on steroids. This is the story the media needs to grab on to in regards to this FAA NPRM and future automated drone fleets. This is the story Congress needs to hear about.

The purpose of this FAA NPRM is the establishment of automated drone delivery AND nationwide aerial surveillance. The rest of the goals and claims seem like just noise.

Update: Imagine Remote ID USS collecting close in high resolution of your kids in your yard, or walking to school. All of this is violating COPPA and it will be very hard for parents to identify the offending drone operator, and then obtain the Remote ID USS, and then figure out how to contact them to remove those images from their database.

FAA NPRM: FAA denies request from AMA and EAA to extend the comment period

The FAA rejected separate requests from the AMA and the EAA to lengthen the comment period by a bit. The EAA was surprised at the stern language used by the FAA in their rejection:

“We are taken aback by the strident tone of the FAA’s letter,” said Sean Elliott, EAA vice-president of advocacy and safety. “If the agency does not act carefully and deliberately on this NPRM, it could forever jeopardize the freedoms enjoyed by countless modelers, who represent a significant pathway into manned aviation.”

My interpretation of the FAA wording, unfortunately, is that the FAA may be intending to ignore the public’s input and intends to ram this NPRM through regardless of legal (like violating Federal law) and technical issues, let alone practical and very costly impacts on the recreational community.

I found the wording very disturbing, particularly after my courteous exchange with the Office of Rulemaking two weeks ago. I now fear that if the FAA considers any public comments, they will, like the FCC did with net neutrality, only review comments from corporations, law firms and large, well known organizations – and ignore comments from individuals. If that. The FAA may, indeed, close the comments on March 2nd and issue the final rule on March 3rd after ignoring everyone.

I have 58 pages of written comments and notes (all single spaced). I have about 27 pages of that in near final form and was working to edit and reduce the remainder. However, after seeing this letter, I am now working to wrap up my comments and just summarize the remaining items as bullet points – because I fear all my hard work is for naught as the FAA appears to be signaling it will ignore public input.

This is disturbing as I am well qualified to make substantive and useful comments on this NPRM. In my comments, I have a brief biography statement:

I am a model aviation hobbyist, an FAA Private Pilot Certificate holder (currently inactive), member of the Experimental Aircraft Association, member of the Academy of Model Aeronautics and the Field of Dreams RC Club.

I have a B.S. in computer science (senior thesis on the FAA and automation in air traffic control), a Masters in Software Engineering (thesis on Android smart phone power management) an M.B.A. degree and an Amateur Radio license. I hold two U.S. patents (one in wireless communications and one in aviation technology), have written about a dozen books on tech subjects, and have had a career in the computer and tech industry working in both software and wireless technology areas.

Separately, an FAA insider who is an R/C modeler told an acquaintance that unfortunately, this rule making is likely to shut down traditional R/C model aviation in the United States.

UPDATED: Yesterday I wrote this hypothesis:

The FAA is not being straight with the public and appears to be acting on secret information. We do not know if this is being driven by secret requests from Homeland Security, or if this is driven by the not so secret lobbying of AmazonGoogleUPS who have expressed a desire to privatize the low altitude air over our heads for their business uses. What ever it is, the FAA is not being transparent with the public and I have lost all confidence and trust in the FAA. The FAA is acting as a renegade agency at this point – and looks to be working under contract to industry, to largely eliminate recreational use of the airspace for model aircraft.

UPDATE: Today, I think I figured this out. The goal is to establish a national, aerial surveillance system, collecting detailed marketing data for businesses and detailed data for law enforcement.

The FAA and the operators of Remote ID USS databases envision using your drone to collect aerial images and possibly much additional data – such as WiFi networks, Bluetooth devices sensed, and so on, and selling this data for marketing purposes, for city government code enforcement, and for low enforcement.

This is a very big deal. This is one of the two main drivers behind the push to enact this rule as fast as possible. The other, of course, is automated drone fleets – which will themselves be collecting aerial surveillance data, spying on our homes and backyards.

FAA NPRM: Effect of remote ID USS on Smart phone Batteries

Preliminary results: Battery drain impact of a Remote ID USS app on a smart phone

Summary: Adding a Remote ID USS data logging app to a smart phone being used to control a quadcopter is likely to increase the battery drain by 10 to 15 percentage points over 30 minutes of flying. The quadcopter control app itself may drain 30-40% of the battery over 30 minutes of flight; adding Remote ID USS mostly adds the power drain of additional GPS usage and cellular data transmissions.

The FAA envisions using a smart phone to relay data about a flight into an Internet-based Remote ID USS (logging database). This data includes information about the operator, including the operator’s location, and for Standard ID, the location of the small UAS. Remote ID only requires operator location and restricts the small UAS to flight within a 400’ radius of the operator.

I created a simple Android app to read the GPS location, once per second, and to transmit data over the cellular connection, once per second (data and destination simulated and not representative of an actual Remote ID USS). This simulates using a control app on the phone to both find the location and relay the data.

This app was run on a Google Pixel 2 phone, outdoors, for ten minutes, and connected to the Internet using T-Mobile service, which in my backyard, is a “2-bar” signal.

In ten minutes, this resulted in 13% of the battery’s capacity drained. A 30-minute logging sequence would presumably represent a 39% battery consumption.

In a second test, I used a Yuneec Breeze, which uses an app as the control interface for the quadcopter. Running this app for ten minutes drained about 10% of the battery, or an estimated 30% in 30 minutes.

Continue reading FAA NPRM: Effect of remote ID USS on Smart phone Batteries

Hysteria: The Colorado Mystery Drones Weren’t Real

The mysterious drone sightings that captured national attention were a classic case of mass hysteria.

Source: The Colorado Mystery Drones Weren’t Real – VICE

Most of the widely publicized “drone sightings” and even “drone collisions” turned out not to be real. But these fake news reports served two purposes:

  1. They created mass hysteria that resulted in more people reporting seeing “drones”. Years ago, we had “UFO sightings”. Today, every light in the night sky is a “drone” and every plastic bag blowing in the wind is a “drone”.
  2. These false reports, hyped to an extreme, result in calls for more regulation.

Read on to learn about how the FAA may have helped generate hysteria in order to get Congressional permission to over regulate, and potentially shut down R/C model aviation in the United States.

This week,  the FCC apparently rejected the AMA’s request for an extended comment filing period, and in their rejection letter hint they want to roll out this rule making as fast as possible, potentially intending to ignore public input. 

Continue reading Hysteria: The Colorado Mystery Drones Weren’t Real

FAA NPRM: 36% of all filed comments are the AMA’s form letter

I previously explained why filing form letters with the FAA NPRM on Remote ID is a waste of time.

On January 7th, the AMA sent out an email blast asking members to urgently file comments and conveniently provided a link to a form letter.

As of today, 36% of all filed comments in the NPRM are the AMA’s poorly executed form letter. Ryan, posting on a FB FPV group page found that 2,506 comments of 7,020 filed so far are copied from the AMA’s form letter.

Some allege that the AMA’s poor performance on this existential issue is that their main focus is on being the affiliated CBO whose membership is required for FRIA certified air fields. In other words, its a cash cow.

#FAA NPRM: Read this assessment by an aviation/UAS lawyer #RemoteID #NPRM #UAS #UAV

See  RID – Somebody’s Watching Me?

By Dawn M. K. Zoldi, (Colonel, USAF, Retired), attorney and expert on UAS law.

She identifies many of the issues I previously described including the failure of the FAA to meet the requirements of the Childrens Online Privacy Protection Act – and proposes a solution with some similarities to my proposal.

She discusses data retention issues (a topic I have in my notes but have not had time to write about on this blog), and privacy issues including the 4th amendment.