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Remote ID approved for US launch in Sept 2022


MattyB
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Sorry all, but there is another regulation story emerging that we all should be keeping an eye on, as it could influence what happens in the UK and Europe in the coming years...

 

A major legal hurdle for the FAA's remote ID deployment in the US has been passed - the sources below explain the background to the RaceDayQuads vs. FAA lawsuit and how the judges ruled, though apparently there could still be an appeal...

 

 

If we assume this is not successfully appealed (by far the most likely outcome), this gives the US modelling industry (including HH with their many RTF and BNF products) and part 107 operators who derive income from model flying (including aeromodelling Youtube reviewers) with some major issues...

 

  • All RTF/BNF (and possibly even ARTF - that requires clarification) models >250g are supposed to have remote ID fitted as standard by Sept 16th in order to be legally sold. DJI say they can do it via software updates, but for everything else on shelves and in the supply chain that is clearly impossible in the timescale, especially as it appears the full specs of how remote ID must be technically implemented have not been published by the FAA.
  • Part 107 (commercial) operators appear to need "standard" remote ID fitted to everything they make (even scratchbuilts and <250g models) because the way the rules are worded means that the exceptions for homebuilt models don't seem to apply to commercial operators.

 

So what does this all mean? Bruce (of course) has a view... Hold your nose 😉 and watch this 12 min video, as it is a bit more accessible than reading the 470 page Remote ID regulations in full...!

 

 

I know Bruce is a marmite character for many and prone to hyperbolae. In this case I doubt the shelves will become bare overnight (comments against that video indicate the rule applies to products manufactured after Sept 16th, not those already in the supply chain), but there are undoubtedly some worrying signs here. If Remote ID is pushed ahead this quickly in the US without specs being fully defined and with manufacturers and pilots unprepared, it could criminalise both vendors and pilots at a grand scale overnight. It could also turn the heads of politicicians in the UK and Europe to accelerate their Remote ID legislation.

 

I don't have enough information to know if his pointed views on the AMA are valid, but looking at the AMA site today it is surprisngly absent of content on the upcoming regulation changes. A bit of further googling did dig up this blog which has their view on the latest announcements - it appears they agree with Bruce and see a delay as likely given the amount of missing information on how this will actually be implemented from the FAA. Even so, it does appear the BMFA, FPV UK etc have clearly been more active than them in defending our corner to the authorities for which we should all be thankful. Let's hope they continue to be successful in the future as the pressure from authorities inevitably increases...

 

Edited by MattyB
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Fair enough @Don Fry(though perhaps not from the perspective of your dog...😉). However, the AMA blog from Jul 16th does clarify that the no process for egistration of the FRIAs has yet been established...

 

Quote

The FAA Final Rule stated that the FRIA application process and manufacturer requirement to implement standard Remote ID will begin September 16, 2022. However, at the time this article was written, the FAA has yet to publish AC 91-57C, which establishes a process to recognize CBOs.

 

Because CBO status is a requirement to apply for FRIA status, it is likely that the FAA will miss this September deadline. Please keep in mind that UAS operators have until September 16, 2023, before Remote ID compliance is required, and that date could be extended if the agency fails to meet current and future deadlines.

 

In addition the FAAs own information page for Industry and Standards bodies confirms that the final rule does not explicitly state the means of compliance, but that kit manufacturers will need to comply (see bold italics)...

 

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Declaration of Compliance

A declaration of compliance is a record submitted to the FAA by the producer of a Standard Remote ID Drone or remote ID broadcast module to attest that all production requirements of the final rule have been met. The final rule establishes minimum performance requirements describing the desired outcomes, goals, and results for remote ID without establishing a specific means or process.

 

The final rule requires drones and remote ID broadcast modules manufactured for operation in US airspace, regardless of where the module or drone is manufactured, to meet the performance requirements for a Standard Remote ID Unmanned Aircraft or remote ID broadcast module. Manufacturers will produce drones and broadcast modules that meet these performance requirements by following an FAA-accepted means of compliance. See below for information on FAA-accepted Means of Compliance.

 

Manufacturers of remote ID broadcast modules and most producers of Standard Remote ID Drones are then required to file a "declaration of compliance" with the FAA stating that their product meets the remote ID performance requirements and has been produced using an FAA-accepted means of compliance. Manufacturers of Standard Remote ID Drones who are seeking a design or production approval under part 21 will show compliance with the remote ID requirements through that process rather than filing a declaration of compliance.

 

The FAA has developed an advisory circular on the declaration of compliance process for remote ID of drones. This advisory circular 89-2 provides guidance on the declaration of compliance process described in part 89, and outlines the required information for submitting a declaration of compliance. Please visit our DOC website to submit a declaration of compliance.

 

Also, producers of a kit that contains all of the parts and instructions necessary for a drone must meet the production requirements of the remote ID rule and submit a declaration of compliance. The person that puts together a "kit" drone does not need to submit a declaration of compliance if they are building it for their own recreation or education but must still meet the operational requirements of the remote ID rule when flying it.

 

Means of Compliance
A person designing or producing a Standard Remote ID drone or broadcast module for operation in US airspace must show that they have met the requirements of the remote ID rule by following an FAA-accepted means of compliance. A means of compliance describes the methods by which the person complies with the performance-based requirements for remote ID.

 

It's important to note that producers do not need to develop and submit their own means of compliance for FAA acceptance. They can use any means of compliance accepted by the FAA, including one developed by a third party.

 

How to Submit a Means of Compliance
A means of compliance describes how a manufacturer may comply with the performance requirements for a Standard Remote ID Drone or a remote ID broadcast module. Anyone may submit a means of compliance for FAA evaluation and possible acceptance. In particular, the FAA encourages consensus standards bodies to develop means of compliance and submit them for acceptance because these bodies generally incorporate openness, balance, due process, appeals process, and peer review.

 

However, FAA-accepted consensus standards are just one way, but not the only way, to show compliance with the performance requirements of this rule. The FAA emphasizes that although a means of compliance developed by a consensus standards body may be available, any individual or organization can submit its own means of compliance for consideration and potential acceptance.

 

Make of that what you will, but it's not clear to me what would be required if I were sitting down to design a Remote ID broadcast module. With ~6 weeks to go it will be interesting to see ow many of the BNF/PNF manufacturers have been preparing behind the scenes, my bet is that HH in particular may be releasing a raft of new products to comply...

Edited by MattyB
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As you say, as clear as mud. I read, paragraph 5, that the inclusion of a module is needed if all the bits for a machine are in the box. ARTF does not to me seem to get to that point. 
But as you say, no technical spec, no module design.  If they want ultra long wave broadcast, then the 150 meter aerials might be a problem. DJI say it’s a software change. So that would suggest something on the hardware side of the drone is already compliant. And they have the technical specification. 
 

I still think that American authorities have been suboptimal it their performance. I will wait and see,  before I dust a Wot 4 off to join my fellow revolutionaries, as we put a squadron up the Champs Elysee

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4 hours ago, Andy Stephenson said:

This appears to mean that any amateur home built models over 250g won't require remote ID. In which case, how would they differentiate between an ARTF model and one that's been constructed from to look identical to one.


From that doc it does appear that way, but that isn’t the case - it’s just that the dates of compliance are different for manufacturers versus pilots flying self and kit built aircraft:This doc is a bit clearer…

 

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There are three ways drone pilots will be able to meet the identification requirements of the remote ID rule:

  • Operate a Standard Remote ID Drone (PDF) that broadcasts identification and location information about the drone and its control station. A Standard Remote ID Drone is one that is produced with built-in remote ID broadcast capability in accordance with the remote ID rule's requirements.
  • Operate a drone with a remote ID broadcast module (PDF). A broadcast module is a device that broadcasts identification and location information about the drone and its take-off location in accordance with the remote ID rule's requirements. The broadcast module can be added to a drone to retrofit it with remote ID capability. Persons operating a drone with a remote ID broadcast module must be able to see their drone at all times during flight.
  • Operate (without remote ID equipment) (PDF) at FAA-recognized identification areas (FRIAs) sponsored by community-based organizations or educational institutions. FRIAs are the only locations unmanned aircraft (drones and radio-controlled airplanes) may operate without broadcasting remote ID message elements.

 

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Effective Dates

Almost all of the final rule on remote ID becomes effective April 21, 2021. The subpart covering the process for FRIA applications from community-based organizations and educational institutions becomes effective September 16, 2022.

Here are other dates of note:

  • September 16, 2022:
    • Drone manufacturers must comply with the final rule's requirements for them.
  • September 16, 2023:
    • All drone pilots must meet the operating requirements of part 89. For most operators this will mean flying a Standard Remote ID Drone, equipping with a broadcast module, or flying at a FRIA.

 

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13 hours ago, Don Fry said:

So that means 16/9/93, onwards, non broadcasting machines are confined to registered sites?

 

12 hours ago, Outrunner said:

You're living in the past Don, I think you mean 16/9/2023

 

Yes, essentially after 16th Sept 2023 all aircraft without a broadcasting module that are >250g can only be flown at a FRIA, IF the FAA have actually sanctioned any Community Based Orgs to run them and registered any FRIAs by then... 🤔

 

Precise current status regarding <250g machines here...

 

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At the end of December 2020, the FAA released the final rule on Remote ID. In this regulation the FAA says that the Remote ID requirements apply to any UAS that is required to register with the FAA. This means that recreational use of a sub 250g UAV will not be required to comply with the remote ID regulation because they are not currently required to register. However this could change at any time. The rules for operating a UAS in compliance with Remote ID will take effect in October of 2023.

 

The rules are different for anyone flying commercially, often called Part 107 after the certification required. If you are flying under Part 107, the aircraft you are using must be registered with the FAA no matter how little it weighs. This means that under the current remote ID rule, even a 50g UAV, if flown under Part 107, would be required to comply with the remote ID and registration regulations.

 

Edited by MattyB
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28 minutes ago, MattyB said:


For what? Posting on the topic this forum is actually about rather than spam sales posts?! Hilarious. 

They are amongst us all the time unfortunately 🙄

 

Thanks Matty for keeping us informed on the important things, I knew it was floating about but like all things in life and with all people I have a lot going on so it is much appreciated that you take the time and trouble to make us aware of to ensure it is out there.

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NP at all. I think it is important to watch what is happening in other countries, as legislation in this space does tend to have a strong global alignment - look at how registration has become ubiquitous across the world in the last few years. Certainly I am worried about the US Remote ID implementation because UK and European governments already have it on their roadmaps (France is already there), and will be watching their progress with earnest. Hopefully it will bomb(!) and they will decide to postpone their implementations for now, but lets watch and wait...

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NP at all. I think it is important to watch what is happening in other countries, as legislation in this space does tend to have a strong global alignment - look at how registration has become ubiquitous across the world in the last few years. Certainly I am worried about the US Remote ID implementation because we know that UK and European governments already have it on their roadmaps - France is already there, and this is from the Transport Minister Grant Schapps in 2020:

 

Quote

Modernising airspace:

 

As co-sponsor of modernisation, the CAA has a vital role in ensuring the successful delivery of the Airspace Modernisation Strategy. The need to modernise the UK’s airspace remains clear despite the impact of COVID-19 on the programme. Airspace modernisation will create sufficient airspace capacity to deliver safe and efficient growth, whilst reducing the noise and carbon emissions of individual flights. Modernised airspace is also essential to opening up airspace for all users, and an important initiative being led by the CAA is an airspace classification review and reform project to look at the release of controlled airspace. It is vital that all airspace users can access airspace where it is safe to do so. As part of this, I consider the timely and effective deployment of Electronic Conspicuity to be a priority for delivering safety.

 

Hopefully the implementation will bomb in the US (it certainly sounds like the FAA are doing everything in their power to turn it into a car crash...!) and other countries will postpone their implementations for now, but let's watch and wait...

 

Edited by MattyB
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  • 1 year later...
3 hours ago, Peter Jenkins said:

Looks like Spektrum are introducing a module for less than $100 to allow US modellers to abide by the FAA rules for Remote ID LINK

 

If Spektrum is already offering an ID module and Futaba is also developing one (page 15 n below link: "RC user-specific remote ID").... I think it is for sure that it will mandatory to us all over the world!

 

A free idea to developers and manufacturers: why not integrating the remote ID function within the receivers?......

 

business_reconstruction_plan_en_2024.pdf

Edited by Jesus Cardin
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You may have received a CAA Skywise email a few days ago 'a call for input CAP2569'  A review of UK UAS regulations. Worth reading and responding. I get the feeling that the CAA is moving toward a light touch as far as conventional model aircraft are concerned. I think they have realised that conventional model aircrft and helicopters fly round in circles and operate from well known locations. There is no mention of BVLOS operations as such although they are saying that they need to bring rules up to date and be able to respond to emerging technologies. There also seems to be a realisation that those who would be using a UAS for criminal endeavours won't be fitting remote ID. I think remote ID being applied to commercial UAS is inevitable and probably sensible. It will allopw the police and CAA to respond in  measured way to the Karens who will see  Drones spying on them at every corner.

 

Interesingly in other news. You may have seen in the news this week a report of a prototype air taxi crash during testing in the UK. Looking at the size of the machine I won't be using one to get from the town centre to my home in the suburbs unless ther is some serious remodelling of the town centre and the suburbs to create enough space for take offs and landings. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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1 hour ago, Martin Dance 1 said:

You may have received a CAA Skywise email a few days ago 'a call for input CAP2569'  A review of UK UAS regulations. Worth reading and responding. I get the feeling that the CAA is moving toward a light touch as far as conventional model aircraft are concerned. I think they have realised that conventional model aircrft and helicopters fly round in circles and operate from well known locations. There is no mention of BVLOS operations as such although they are saying that they need to bring rules up to date and be able to respond to emerging technologies. There also seems to be a realisation that those who would be using a UAS for criminal endeavours won't be fitting remote ID. I think remote ID being applied to commercial UAS is inevitable and probably sensible. It will allopw the police and CAA to respond in  measured way to the Karens who will see  Drones spying on them at every corner.

 

Interesingly in other news. You may have seen in the news this week a report of a prototype air taxi crash during testing in the UK. Looking at the size of the machine I won't be using one to get from the town centre to my home in the suburbs unless ther is some serious remodelling of the town centre and the suburbs to create enough space for take offs and landings. 


Interesting…. I’ll be reading and absorbing the full doc, but my gut feeling is that you are being a little too optimistic about how the authorities will approach the next phase of UAS integration and regulation.

 

https://publicapps.caa.co.uk/docs/33/Call for Input Review of UK RPAS Regulation v3_1 (CAP2569).pdf

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9 hours ago, MattyB said:


Interesting…. I’ll be reading and absorbing the full doc, but my gut feeling is that you are being a little too optimistic about how the authorities will approach the next phase of UAS integration and regulation.

 

https://publicapps.caa.co.uk/docs/33/Call for Input Review of UK RPAS Regulation v3_1 (CAP2569).pdf

 

EDIT - I've changed my mind, let's start for a new topic on this...

 

OK, I've taken a look at this this morning, and I'm afraid my gut feel was right - there is lots in here to be worried about. I will post up a few key sections below that are definitely of concern, but the BMFA have asked members to hold off responding until they have had a chance to look at all the details. This will need to come fairly quickly though, as timescales to respond are relatively short (responses have to be in by Sept 7th):

 

image.thumb.png.e1dd941667b7a18f1edcfcc387ced1e9.png

 

CAA response info:

 

image.png.33c027a53345edca44b13ad84d2ed4f1.png

 

Everything else will go in the new topic here:

 

 

Edited by MattyB
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May not be a bad idea to add our comments to our local MP, Councillors. In addition recommend increase of weight from 250g to 500g or 1kg. Also point out we dont have to follow the USA or indeed the EU  despite the latter implementation of the Regs.

And if we do respond perhaps get Government to have Councils ID areas to allow flying. 

If you want to beat us with a stick at least offer a carrot!!

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26 minutes ago, Zflyer said:

May not be a bad idea to add our comments to our local MP, Councillors. In addition recommend increase of weight from 250g to 500g or 1kg. Also point out we don't have to follow the USA or indeed the EU  despite the latter implementation of the Regs.

 

See my summary in the other thread... It's clear the CAA and UK Gov are thinking of going in the opposite direction and reducing or eliminating the exceptions for lightweight models below 250g, presumably because their capabilities have increased in recent years. 😞

 

 

Edited by MattyB
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