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: Proposal creates threat to national security

The NPRM says data sent to and collected by a Remote ID USS is not restricted to the basic message elements of operator and craft identification and location. The FAA specifically suggests a Remote ID USS could also collect “a camera feed or telemetry data”. (See Page 97, Section X, A, 2, Paragraph 2).

In effect, the NPRM establishes a baseline for a national, real-time, aerial surveillance network having significant implications for personal privacy and safety and exposes a significant national security risk.

In January 2020, the U.S. Department of the Interior grounded all of its foreign made drones over concerns that such drones could hypothetically conduct surveillance and transmit intelligence data over the Internet[1]. In reality, a drone that is not connected to the Internet or whose SD card is never accessible to the Internet, is incapable of “spying”. The US Army grounded its Chinese-made drones in 2017, over fears of espionage.

Yet simultaneously, the FAA is mandating all drones be connected to the Internet in real time – and most of those drones will be made in China – and the Remote ID USS will be located who-knows-where.

Per the government’s own statements, the FAA is mandating a threat to national security by establishing an Internet connected fleet of aerial drones collecting data across the entire country.


[1] https://dronedj.com/2020/01/29/interior-department-grounds-drone-fleet-with-new-order-issued-today/

#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 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.

EAA says “Proposed Remote ID Rule Contains Concerning Requirements” regarding #FAA #NPRM

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.)

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