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:
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”.
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.
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.
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.
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).
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.)
In response to the FAA’s Notice of Proposed Rulemaking (NPRM) regarding Remote ID of small UAS, at least one national organization urged members to urgently file comments and helpfully provided a form letter – which as I showed previously – were submitted by many people. Submitting form letters is a waste of your time, as I explained then.
Here is what happened when another agency with another NPRM was overwhelmed with form letter responses from the public – they ended up ignoring most public input!
In 2017, the Federal Communications Commission (FCC) solicited public comments on proposed rules regarding Internet “net neutrality”.
The FCC received about 23 million public comments.
“For example, Ars Technica reported in May 2017 that 128,000 identical comments were submitted through the portal for receiving public comments on this particular matter.”
In many cases, “bots” had harvested actual comments by actual people, and then generated dozens more comments using the same names and addresses of real people, creating false public comments.
Ultimately,
“According to Pew Research, only 6 percent of the roughly 23 million comments submitted to the FCC were actually unique. The rest were a combination of form letters and bots. The most popular form, submitted 2.8 million times, was a pro-net neutrality comment drafted by the advocacy group Battle for the Net.”
The FCC was so overwhelmed with these garbage comments that, according to Wired magazine,
“As a workaround, the FCC has decided to ignore the majority of comments submitted by the public in favor of lengthy legal arguments submitted by interest groups and corporations.”
The above is what happens when the public overwhelms the agency with form and template letters. It happened to the FCC. It could happen to the FAA as some groups have published form letters with instructions to “urgently” comment on the FAA NPRM.
How Should You Write a Comment to the FAA’s Remote ID NPRM?
The UK is proposing an annual fee of 16.5 pounds. The U.S. assesses a fee of US$5.00 per pilot, good for 3 years; the registration number is applied to all aircraft operated by the pilot.
Flights in and out of London’s second-busiest airport were halted after drones were spotted flying illegally nearby in what was described as an act meant to intentionally disrupt travel.
The British government described the overflights as deliberate and being conducted by “industrial” drones, not hobbyist quadcopters.
Update: latest development is that two unnamed people have been detained and the police have suggested “eco-warriors” were behind shutting down the airport, as part of opposition to airport expansion plans.
She said the amount of time the drone had been above the airport supported the idea that it was being flown there deliberately. “This very much points to this being planned and not just some rogue hobbyist,” she said.
The weather at the time was windy and rainy. Small consumer quadcopters are not usually water proof and can have difficulty in winds over 10 mph. (Similar to most consumer cameras, they will likely fail due to water ingress.) Further, consumer quadcopters generally have a useful battery life in the 10 to 20 minute range.
Yesterday a Guardian journalists said on Twitter. “Considering the public safety danger of drones, why should any be permitted to have one for any use other than business?”
(Change the word “drones” to “cars” or “trucks” or “knives” and see if you can see a problem with that line of thinking.)
Separately, much of the public is now saying things like this comment appearing in the NY Times:
The PR damage is immense and likely insurmountable. From social media comments, people are calling for the ban of all model aircraft. Yet this operation over Gatwick was already in violation of current law.
A ban will not happen but expect governments to enact a strict (and potentially expensive) regulatory environment that will create so many hurdles to flight as to be a de facto ban on many recreational operations. As I have written previously, expect the following:
Model aircraft will be permitted to fly at certified model airfields, possibly license free – and possibly restricted to age 16 or older.
Home built model aircraft will be required to be “certified” after an inspection similar to how home built aircraft are certified by a volunteer designee of an organization and will be required to meet specific design criteria.
Flight conducted outside of certified model airfields will require the operator to be licensed. Here in the U.S. this will require either the Part 107 Remote Pilot’s license or an as-yet-to-be developed Remote Recreational Pilot’s license, including passage of an exam and Department of Homeland Security background check.
A fee will be charged for the operator license and the background check.
Flights conducted outside model airfields will require each device to have an on board radio transponder or other mechanism for tracking and remote identification.
A fee will be charged for air traffic control services. This fee, combined with the background check cost, may be so high that it de facto bans most people from flying model aircraft at other than model airfields. It is possible that flights in Class G airspace will remain exempt from the air traffic service fee; however, transponders will likely still be required.
All commercially built model aircraft weighing more than 8 ounces (250 grams) will be required to have on board GPS and geofencing built in to prohibit flight within some number of miles of airports. But note there need to be ways to override this – for example, drones are used to conduct power line and roof inspections and these will, from time to time, need to be done, with permission, within the radius of airports. Of course, it may be that only “large” and expensive drones will allow override capability, thereby priced out of access by regular consumers. Additionally, there will be commercially operated package delivery drones within these areas.
Retailers of commercially-built drones will be required to log drone sales with the government, including the identification of the buyer.
All commercially built drones, and possibly certified home builts, may require control links that can be overridden by police or other government authorities to remotely take control of an errant flight. This would likely render existing control transmitters obsolete and require their replacement at great cost.
Police will routinely stop and ask drone pilots to see their license and aircraft certification paper work, and will log their contact with you in their criminal database.
None of this will stop a terrorist or anyone else inclined to cause mayhem. It will, however, dramatically reduce the number of recreational quadcopters in flight.
Separately, a week earlier a collapsed nose cone on an Aeromexico plane that landed at Tijuana Airport was blamed by the media as caused by a collision with a drone. The media made up that conclusion – no one involved in the investigation has made that claim. This web page has photos of about 30 collapsed nose cones, many of which look identical – but which did not involve a drone. From expert commentary on that page, there are numerous causes of collapsed nose cones including bird strikes (often leaving no blood or feathers behind), weather phenomena including hail, rain and wind, and structural failures of the non-metallic nose cone.
The public’s limited understanding of aviation causes them to jump to conclusions based on what they think they know – to them, everything looks like a quadcopter because they are unaware of other options. (In propaganda theory this is known as “What You See Is All There Is”.) As one airline pilot said in a newspaper comments section, it is amusing to see how many non-experts had become experts on social media. (For the record, while I am not an active pilot now, I do have a pilot’s license and have been around aviation since age 20. I have 5 quadcopters and 2 fixed wing model aircraft, belong to the EAA, AMA and my local flying club.)
Today’s 80+ year old model aircraft hobby, with a spectacular safety record is threatened to be regulated out of existence – depending on how nutty the politicians and regulators choose to act.
Guide to 3D and Drones
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