Category Archives: Radio-control

U.S. government “Tips for Submitting Effective Comments” regarding FAA NPRM on Remote ID

Here is the Federal government’s official guideline for submitting comments regarding notices of proposed rulemaking:

Tips for Submitting Effective Comments (PDF)

Some organizations have encouraged their members to submit “Form letters” and barely modified “Templates” as a submission. As noted on this blog last month, this is the wrong way to go about making a difference in the rule making proceeding.

Here is the official statement from the U.S. government on the Regulations.gov web site:

Form Letters
Organizations often encourage their members to submit form letters designed to address issues common to their membership. Organizations including industry associations, labor unions, and conservation groups sometimes use form letters to voice their opposition or support of a proposed rulemaking. Many in the public mistakenly believe that their submitted form letter constitutes a “vote” regarding the issues concerning them. Although public support or opposition may help guide important public policies, agencies make determinations for a proposed action based on sound reasoning and scientific evidence rather than a majority of votes. A single, well-supported comment may carry more weight than a thousand form letters.

Of course as showed previously, many comments were filed by those that followed some organizations’ misdirection to file form letters.

When I checked this morning, I found this in the comment file including the first one labeled “Template”.

From the linked PDF above:

8. The comment process is not a vote. The government is attempting to formulate the best policy, so when crafting a comment it is important that you adequately explain the reasoning behind your position.
9. Identify credentials and experience that may distinguish your comments from others. If you are commenting in an area in which you have relevant personal or professional experience (i.e., scientist, attorney, fisherman, businessman, etc.) say so.
10. Agency reviewers look for sound science and reasoning in the comments they receive. When possible, support your comment with substantive data, facts, and/or expert opinions. You may also provide personal experience in your comment, as may be appropriate. By supporting your arguments well you are more likely to influence the agency decision making.

If you still wish to file a form letter and submit a template letter with “Template” as the first word of your comment, go right ahead and waste your time.

FAA NPRM Summary of key points and recommendations, in my comments

Updated on February 12, 2020.

Summary of Key Points and Recommendations

The NPRM eliminates most indoor flights of small UAS

The NPRM envisions that only Remote ID compliant craft will be sold. Remote ID compliant craft are unable to take off if they cannot receive a GPS signal. As a GPS signal is not receivable in most indoor locations, this de facto eliminates indoor flight of small UAS and implies the FAA is regulating the indoor airspace, over which it has no jurisdiction. This indoor flight restriction violates PL 115-254 Sec. 354. Or maybe not – comments on Page 8 and 22 of the NPRM suggest anyone can sell non-compliant drones by adding a “For indoor use only” sticker since the FAA cannot regulate indoor airspace nor the products on the shelf at Walmart. Which makes much of this NPRM moot.

FAA’s Proposed Use of FCC Part 15 Spectrum Will Cause Interference and Crashes

The FAA proposes to use 47 CFR Part 15 of the FCC rules and regulations for transmission of Remote ID broadcast beacon signals and requires that transmitters “must be designed to maximize the range at which the broadcast can be received”. The requirement to “maximize the range” mandates that small UAS transmit at the 4 w ERP level (1 watt spread spectrum, 6 db gain antenna) – from aircraft potentially located hundreds of feet in the air. This is not how Part 15 bands are intended to be used, will cause interference to residential consumer devices, and may lead to receiver desense and loss of flight control signals, causing SUAS to crash, when multiple SUAS are flown in close proximity to each other.

The FAA Envisions Using Wi-Fi in a way that is Not Technically Feasible

The NPRM proposes using Wi-Fi, if available, to log flights with the Remote ID USS, particularly with a presumably lower cost Limited Remote ID system. Small UAS that use a flight control app on the smart phone are communicating with the SUAS craft using Wi-Fi. Currently existing small UAS implement a Wi-Fi Access Point (AP) on the aircraft and the phone connects to this AP. The phone cannot simultaneously connect to a second AP that has Internet access; the phone can connect to only one AP at a time. Thus, Wi-Fi cannot be used to provide a Remote ID USS connection. The NPRM proposes a Limited Remote ID that appears intended for low cost consumer quadcopters that would be controlled via a smart phone flight control app, logging the flight to the Remote ID USS over Wi-Fi. As envisioned, this is not technically feasible. The flight control app would have to log the flight over a smart phone Mobile Data connection. This means the concept of a low cost Limited Remote ID small UAS is unobtainable. The Limited Remote ID should be dropped and replaced with a broadcast beacon Remote ID for Visual Line of Sight (VLOS) and Internet-based Remote ID USS retained only for Beyond Visual Line of Sight operations (BVLOS). Related: Based on my own tests, the addition of a Remote ID USS data logging app, transmitting once per second, may reduce smart phone battery capacity by 10%. When combined with a smart phone-based flight control app, this may drain 40-50% of the battery in 30 minutes of flying.

The NPRM violates the Children’s Online Privacy Protection Act (COPPA)

COPPA specifies strict protections regarding the collection of data related to children, including geolocation data and data from “toys and Internet of Things”. An age restriction or permission from a parent or guardian to collect data does not resolve the problem. If a child flew a quad with or without permission, the parent or guardian is legally entitled to contact the data collector and ask to review, delete or suspend future data collection. The NPRM, however requires logged data be retained for at least six months – but COPPA applies to the Federal government – there is no exemption for the FAA. This is a problem for the use of the Internet to log operator information to a Remote ID USS.

The NPRM violates the 4th Amendment

In the event a small UAS (SUAS) can receive a GPS signal indoors, when that SUAS is flown inside a home, it is required to log its activity in the Remote ID USS. The FAA is mandating the installation of a surveillance device inside a home, which lawyers tell me is not permitted by the 4th Amendment to the U.S. Constitution. Others suggest there may conflicts with the 5th Amendment, and the Foreign Intelligence Surveillance Act prohibition on collecting electronic signals of Americans.

Click the “Continued reading” link, here, to continue reading my full Summary of FAA NPRM Remote ID issues. There are a lot!

Continue reading FAA NPRM Summary of key points and recommendations, in my comments

#FAA #NPRM #REMOTEID: Conclusions and recommendations

This is a draft of my concluding comments in what will be my filing with the FAA’s Remote ID proposal. My final comments will not be done, however, until later in February.

My focus is to attack the Internet logging requirement head on. Because of their proposed mandate for Internet-based real time tracking, there are serious scenarios where the FAA runs afoul of the Children’s Online Privacy Protection Act, the 4th Amendment, and State laws on privacy.

The FAA envisions that only compliant craft will be sold. If true, this means that most indoor flight is eliminated because the FAA requires a functioning GPS to fly. Obviously, this is not only unacceptable but implies the FAA is regulating indoor airspace. Not only that but Federal law prohibits the FAA from regulating small UAS used inside mines.

The FAA’s requirement that only compliant small UAS be sold is not only infeasible, but they admit it on Page 8 when they write that this refers only to craft “for use in the airspace of the United States”. This means there will be small UAS for sale labeled “For indoor use only”, which is a major loophole over which they can do nothing. People will buy these and fly wherever they want.

The FAA has little understanding of Internet availability and has managed to word its NPRM in such a way that if your T-Mobile service has no coverage but Verizon does have coverage, then you are required to subscribe to Verizon service to fly. In an extreme interpretation, the FAA’s wording could require you to purchase satellite-based Internet access.

Worse, the NPRM defines a proposed use of Wi-Fi for Remote ID USS data logging that is technically infeasible. The FAA has no understanding of what it is doing here.

My comment filing is now about 45 pages in length with extensive reference material and cited references. This is a draft of my Conclusions and Recommendations section.

Conclusions and Recommendations

  • Congress directed FAA to develop standards for “remote identification” but did not specify what features that requires. Congress wrote:

SEC. 2202.  IDENTIFICATION STANDARDS.
(a) In General.–The Administrator of the Federal Aviation
Administration, in consultation with the Secretary of Transportation, the President of RTCA, Inc., and the Director of the National Institute of Standards and Technology, shall convene industry stakeholders to facilitate the development of consensus standards for remotely identifying operators and owners of unmanned aircraft systems and associated unmanned aircraft.

The FAA has gone beyond the intent of Congress to require mandatory Internet-based logging of all flights, in real-time.

  • The FAA ignored its advisory committee of stakeholders. The UAS-ID Aviation Rulemaking Committee recommended that model aircraft (“limited recreational operations”) be excluded from any remote identification requirement. Instead, the FAA developed rules limited existing model aircraft to FAA-recognized identification areas (FRIAs), which will, over time, be shut down and lead to the eventual prohibition of the flight of homebuilt model aircraft. These steps go well beyond the intention of Congress which directed the FAA to develop Remote ID standards only.

    The only Congressional requirement is the development of Remote ID.
  • The FAA actively sought to reduce the public’s opportunities to influence this proceeding. The FAA established an Advisory Committee that was, per a report from DJI, “stacked” almost entirely with those who stand to benefit professionally and financially from a substantial increase in regulations. The Committee, per DJI, had almost no representation from the public that would bear the greatest burdens of the regulation. According to DJI:

“Less than 7% of the members of the ARC were stakeholders who would primarily face burdens and/or costs from a future Remote ID requirement, while 75% of the members stood primarily to gain from a future Remote ID requirement, either because of their interest in law enforcement tools or in the furtherance of their business objectives or prospective sale of Remote ID technologies or services.”[1]

  • The FAA ignored key recommendations from its Advisory Committee of stakeholders.
  • The FAA released this NPRM on December 26, 2019, the day after Christmas, at time when media coverage is on vacation, and when resources at organizations are out of the office on vacation.
  • The NPRM went in a direction substantially different than that which the public was led to believe was coming, based on the Advisory Committee. Thus, the public was caught off guard and ill prepared to respond.
  • The NPRM is a complex rule making proposal, 319 pages in length, with thousands of pages of supporting documents. Yet the FAA provided only 60 days for the public to review, analyze and comment on this proposal. Members of the general public do not have staff available to assign the task of conducting this review – we can only do what we can, in our spare time. The AMA and the EAA both requested extensions to the public comment period, which the FAA sternly denied using harsh wording suggesting it did not have time for public input.

    At every opportunity, the FAA has attempted to minimize public input in this proceeding.
  • There is no requirement in PL 114-190 that Congress requires real time location tracking or that the FAA should eventually ban homebuilt model aircraft.
  • The Advisory Committee even suggested having bolt on remote ID transponder upgrades for existing aircraft. There is no technical reason this cannot be done. The FAA (or Homeland Security) mistakenly believes it can limit future small UAS sales to “compliant” only craft and eliminate home built aircraft. However, due to the “indoor use only” problem, the requirements of COPPA to permit deletion of collected data and suspension of data collection, and that many non-compliant craft will be widely available, the FAA is engaged in an illusion of security and compliance that will never happen. Thus, there is no reason at all to not permit adding remote ID to existing small UAS.
  • The FAA has, in its illusion of security, said that only compliant aircraft with functioning GPS and Remote ID may be sold. The NPRM further says that if GPS is not working, then Remote ID is not working, and therefore, the craft may not take flight. This effectively eliminates indoor flight of small UAS – and the FAA is de facto regulating indoor airspace over which it not only has no authority, but in the case of mines, violates Federal law.
  • Alternatively, per the description on Page 8 of the NPRM, vendors may place a “for indoor use” only sticker on the side and sell anything they want as the FAA has no authority to restrict sales, nor regulated indoor airspace. This is a necessary loophole that means the FAA’s attempt to lock down all aircraft fails.
  • In the event that a GPS signal is received indoors, say inside a home, the NPRM generally requires that this flight transmit, in real time, once per second, operator information and lat/long to an FAA subcontracted Internet database. This means the FAA is mandating surveillance inside one’s private home, in violation of the 4th Amendment. It may also be in conflict with the 5th Amendment and the Foreign Intelligence Act and State laws.
  • In the event that a child is at the controls (which there is no way to prevent), this results in collection of personally identifiable information including geolocation in violation of the Children’s Online Privacy and Protection Act.
  • If a parent discovers the child has flown the craft (indoors or outdoors, with or without permission, in the backyard), the parent has a legal right under COPPA to notify the collector of the data, to request to review that data, and to request to delete that data. COPPA adds significant complexity to the implementation of the Remote ID USS database. Effectively, anyone could request review, deletion and suspension of collected data by asserting their rights under COPPA. This too becomes a major loophole that means the FAA’s attempt to lock down all aircraft fails.
  • The Remote ID USS requires the use of an Internet connection which the FAA mistakenly believes is readily available. As our comments have shown, this is not true.
  • The FAA defines “Internet is available”in a way that if your cell service does not have coverage, but another service does, then you are required to purchase that additional service if you wish to fly in that location. This is completely unacceptable. Taken to an extreme, this could require purchasing satellite-based Internet access.
  • The FAA further defines Internet is available to include Wi-Fi. This however is technically infeasible. When a small UAS control app running on phone connects to the craft using Wi-Fi, the craft is configured as a Wi-Fi Access Point – which has no Internet access. The phone has no feasible way of connecting to a separate Wi-Fi AP to gain Internet access; the phone is technically capable of connecting to one AP at a time. The FAA’s suggestion to use Wi-Fi is technically infeasible.
  • The FAA is badly misinformed on Internet access availability, has written its NPRM to potentially mandate higher cost (if not extremely high cost) Internet access, and has specified a technically infeasible use of Wi-Fi for Remote ID USS operation. In addition, the Internet data logging will, in certain situations, violate COPPA and the 4th Amendment (and possibly additional Federal and State laws and other amendments), and establishes a nationwide, aerial-based real-time surveillance system of Americans. Page 97 describes using the Remote ID USS data logging feature to collect other data “such as a camera feed or telemetry data” from small UAS. This can and will be used to create a nationwide surveillance system, photographing our homes and our children, in high resolution, from 100′ to 200′ overhead.
  • There are so many problems with mandated Internet data logging that it is infeasible both legally and technically. The FAA – and other Federal laws and regulations – have established a contradictory set of constraints such that it is not possible to implement this NPRM as defined.
  • This leaves a limited set of alternatives to satisfy the Congressional directive to implement Remote ID.
  • The only viable solution is to implement a broadcast beacon-based Remote ID system.
  • As described in my comments, this broadcast beacon ID could be used in conjunction with automated drone fleets relaying such received beacon broadcasts into the Internet, or the use of ground-located beacon ID receivers. This can be constructed in a way to greatly reduce the likelihood of COPPA and 4th Amendment violations.
  • The fact the FAA itself defines Standard Remote ID to operate in a broadcast beacon mode only illustrates that even the FAA recognizes that broadcast beacon ID is sufficient.

[1] A DJI Technology Discussion Paper: Understanding the U. S. Federal Aviation Administration UAS Identification & Tracking ARC Report, DJI Policy & Legal Affairs Office December 19, 2017

FAA seeks cancellation of Advisory Circular AC 91-57 concerning model aircraft

Cancellation Memo AC 91-57.

The FAA says it is in process of developing a new advisory circular. Oddly, the FAA cites its authority to do this as the 2012 FAA reauthorization act, section 336 which actually says the FAA “may not promulgate any rule or regulation regarding a model aircraft, or an aircraft being developed as a model aircraft, if –” basically, its a hobby model aircraft. Thus, they will issue a new set of voluntary guidelines.

SEC. 336. SPECIAL RULE FOR MODEL AIRCRAFT.

Continue reading FAA seeks cancellation of Advisory Circular AC 91-57 concerning model aircraft

How to file comments on FAA proposal to ban FPV model aircraft

See FAA proposes ban on First-Person View (FPV) model aircraft operation

Then, file your comments on the proposed regulation by going to: Regulations.gov – Rule Document. Then click on the Comment Now button in the upper right.

Your comments become part of the public record which the FAA must consider in implementing its proposed rule interpretation or rule making procedure.

How-To: Learning to fly a quad copter

Thinking of flying a quad copter but you have no experience? And you need to teach yourself?

My recommendation, and that of others, is to start with an inexpensive radio controlled toy. You will crash. You will break stuff. And fixing an inexpensive RC toy costs a lot less than a $1,000 or $4,000 multi-copter.

I have the Hubsan X4 with its integrated 720p video camera. They are available at Amazon:


The camera is okay but its not anything fantastic. It’s a fun to have feature but if your goal is learning to fly, you can get a version without the camera for about half the price:

I also recommend a “crash pack” or at least an additional set of blades, plus spare batteries:

I have this set of 5 extra batteries and they work just fine. Keep in mind that on a small quad copter like this, your battery life may be only 5-8 minutes, depending on whether the camera is turned on, the LED lights are turned on, or if you have the rotor protection ring installed (adds weight). You will be changing batteries frequently.
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In spite of your best intentions, you will hit stuff and a blade or two will go flying and may become very hard to find.  I once hit the ground hard out in front the house and one of the blades hit a brick and just vanished. I had the video camera going at the time and watched that frame by frame in hopes I’d spot the blade, but didn’t. Not until a week later did I find it about 25 feet away.  Order a set of extra blades.

I need to put together a tutorial on setting up and configuring the Hubsan as the instruction booklet was not very clear to me – and I even have a pilot’s license:)

The key is that you need to calibrate the control system so that everything is balanced. This basically means setting the “trim” tabs for roll, pitch and yaw. And you do that by briefly powering up on grass or indoor carpet (if indoors USE THE BLADE PROTECTOR that is hidden underneath the plastic packaging in the box).

If the quadcopter drifts sideways or forwards or back, you’ll need to adjust the trim tabs on the flight controller. There is no easy way to describe this in words – I really need to make a tutorial video.  Once you figure out how to do this, the process is simple. And the goal is that the quadcopter will roughly hover and drift very slowly once it is trimmed up properly.

After that, start practicing. It took me many flights to reach a point where I could stationary hover and maintain altitude. And then more practice flights to learn to maneuver. And that was all done in the living room. Then more practice outdoors in the yard.

ALWAYs move the controls slowly. Don’t let the aircraft get away from you. If you feel you are about to crash and perhaps fly off, reduce the throttle and land. Get yourself re-oriented and start over.

I really need to make a tutorial video to explain this!

“Drones” and telepresence for the mobility limited

Last night I thought of a novel application for “drones”. (“Drone” is a bad word – R/C aircraft, UAV or remotely piloted model aircraft are all benign and accurate terms and have been used to describe civilian applications for a long time.)

Some of the new R/C n-copters (quad, hex or octo-copters) have very advanced flight control systems that simplify flying and provide safety features (like automatic return in case of loss of control signal).

Once these are easy and small enough to operate, they could provide a type of telepresence to someone who is unable to have much mobility. Many R/C pilots have added First Person Video (FPV) links that send a video signal from the craft back to the pilot; a very few even have 3D video links.

Crazy as it sounds, such capabilities could give a telepresence mobility to those who are, say, confined to a wheel chair or worse, provided they have the ability to operate the flight controls. That, in turn, could open up their surroundings to an exploration that they are presently unable to do.