The EAA is the Experimental Aircraft Association, a global organization of aircraft builders, innovators, hobbyists and aviation enthusiasts:
EAA is very concerned that the FAA’s proposed rule on remote identification of unmanned aircraft systems could have a severe detrimental impact on traditional model aviation, and is preparing a full package of comments on the Notice of Proposed Rulemaking.
Source: Proposed Remote ID Rule Contains Concerning Requirements
Read the entire linked post from the Experimental Aircraft Association, a leading aviation group concerned with all aspects of aviation including home building aircraft, education, flight and much more. They call out problem areas in the FAA’s NPRM on Remote ID, including the indoor flight restriction problem that I first identified on this blog.
Note their ending comments:
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.
By comparison, the R/C modeling association, the AMA, urged members two weeks ago to quickly file comments and offered a form letter to send or use as a template. Which was absolutely the wrong approach, as I have described in posts on this blog (see here and here).
Keep an eye out for the EAA’s guidance and check out the guidance from others such as Drone U. (Downloadable information is located here).
I am proud to be a member of the EAA; I have stopped following the AMA on this critical issue (I am also a member of the AMA).
(I am in the midst of a two week period where I have almost no time to spend on the NPRM – I do have notes on more NPRM issues but will not have time until the middle of next week to resume research on these items.
For example, what is the real world impact on smart phone battery life of a once-per-second real time tracking system?
Smart phones extend their battery life by keeping electronics switched off as much as possible. This NPRM would require that the GPS be active continuously, the cellular transmitter be fired up every second, and the display and CPU/GPU likely in use simultaneously for running the R/C model control software. The display, the cellular transmitter and the GPS receiver are among the greatest power drawing components on the smart phone. This real time reporting requires the phone be operated in a maximum high power state continuously for the duration of flight. It is possible, especially in marginal cellular coverage areas, that the FAA’s Internet-based real time tracking system could use 30-50% of the phone’s battery in 20 to 30 minutes of flight. You’d have to recharge your phone’s battery before a 2nd or 3rd flight later in the day, creating yet another obstacle to flight. If I have time, I would like to test this and measure the impact on batteries.
I wrote my 2012 Masters thesis in Software Engineering on power management issues in Android phones.)
I fly with a tablet that has no cellular capability. Since there is no WiFi (and often no cellular either) in the areas I fly how is that internet connection supposed to work exactly?
Good point. Tablets could no longer be used. I think I will need to add a 3rd addendum to my previous filings. I didn’t mention that.
The FAA has asserted that Wi-Fi can be used to log to the Internet but that is technically infeasible. When Wi-Fi is used to link a tablet or phone flight controller to an aircraft, the aircraft is implementing a Wi Fi Access Point. Your tablet or phone, however, can only connect to one AP at a time. It cannot then connect to another access point to send data through the Internet. Consequently, the FAA’s notion of using Wi-Fi is technically infeasible.