Remote ID Proposal Outlaws Home-built RC Aircraft

I want to clear up a myth about the FAA's proposed remote ID rules that I've been seeing floating around. People think that amateur home-built model aircraft will be largely unaffected by this, since they can just fly at AMA fields. Or people think that to build and fly model aircraft outside of AMA fields, all they would have to do is slap some kind of transponder on their model and they are good to go. This is completely wrong. This proposal will effectively outlaw home-built model aircraft as most people actually build them. 

The reason for this is the production standards. The proposal contains two completely different types of rules: operational rules and production rules. The operational rules allow UAS without remote ID to be flown at a FRIA site. The production standards prohibit anyone from producing a UAS that does not comply with the remote ID rules, regardless of whether it is even flown. Just building a UAS for private use that does not comply with remote ID is a violation of the law, unless one qualifies for an exemption from the production rules.

Many people (including the AMA apparently) read that amateur-built models are exempt from the production requirements and think that means they're fine. However, the devil is in the details, which in this case is the definition of amateur-built, which "means an unmanned aircraft system the major portion of which has been fabricated and assembled by a person who undertook the construction project solely for their own education or recreation.

The FAA's proposal clarifies that this means more than 50% of the total components in the Unmanned Aircraft System (which includes the ground control station) must be fabricated and assembled by the hobbyist. Home-built models using mostly parts that are pre-fabricated and purchased separately are expressly excluded from this exemption:

UAS assembled completely from pre-fabricated parts. The FAA anticipates that some model aircraft enthusiasts may assemble UAS entirely from pre-fabricated parts and that commercial vendors may wish to sell UAS parts, including packages that contain more than 50 but less than 100 percent of the parts necessary to build a UAS. The resulting UAS would not qualify as amateur-built because the person building it would be fabricating and assembling 50 percent or less of the UAS. The UAS would not qualify as built from a kit because it did not include 100 percent of the necessary parts. Under these circumstances, the person assembling the UAS would be considered the producer and would be required to comply with the design and production requirements of proposed subpart F. (NPRM p. 152.)

We’ll leave aside the fact that the proposed regulation provides no way to quantify parts. Raw number of all components down to individual chips on circuit boards? Number of black-boxed components like receivers and flight controllers? Total mass? As currently written, the amateur-built exception to the production requirements would not apply to the vast majority of modelers. 

Even assuming parts are quantified by black-boxed components, most amateur model aircraft would fall into the pre-fabricated, rather than amateur-built category, as most people assemble model aircraft from a collection of pre-fabricated parts they buy separately from various manufacturers. They might buy the airframe as a pre-cut styrofoam body (for planes) or carbon fiber sections (for quads), then glue/screw it together and mount and wire up motors, flight controllers, speed controllers, receivers, and cameras and video transmitters for FPV craft.

The most anyone ever fabricates themselves is the aircraft body. Nobody is fabricating their own receivers, speed controllers, lithium batteries, motors, or remote controllers, so virtually no model aircraft hobbyists would actually qualify for the amateur-built exception which requires more than 50% of parts (however that is quantified) to be fabricated and assembled by the builder.

The vast majority of RC hobbyists would fall under the category of using more than 50% prefabricated parts that do not come as a single kit with 100% of the parts necessary to fly. The proposed regulation would treat such modelers as UAS producers, and would require them to comply with all the production standards to produce and certify a UAS as RID compliant. This process is long and convoluted, and is clearly contemplated to only be used by large corporations developing mass produced UAS to be sold to consumers (the proposal estimates this process would only ever be used by a few hundred corporate entities).

Let’s assume a hobbyist could even comply with the technical requirements to equip a model with remote ID (doubtful given the tamper-resistant requirement which would at minimum prohibit the use of open source flight controllers and could be interpreted to require the person who built the model to somehow prevent himself from bypassing the remote ID system). The certification process requires the purchase of multiple standards that could cost hundreds of dollars to even read, and the filing of extensive forms and reports with the FAA that is estimated to exceed over 50 pages and take hundreds of man hours to produce. It would be completely impossible for any individual hobbyist to comply with these procedures for their home-built model aircraft.

Thus as written in the currently proposal, building your own home-built model aircraft the way the vast majority of hobbyists actually do that would be illegal. It doesn’t matter where you fly them, or even if you fly them at all. Merely building a UAS without equipping it with remote ID and following the process to certify it with the FAA would be an independent violation of the law. It goes without saying that this would be completely unenforceable, but that’s not the point. Legally at least, this proposal will completely outlaw home-built RC model aircraft as they are actually made by hobbyists.

The FAA attempted to disguise this by putting in the amateur-built exemption, and then defining it in such a way as it will be impossible to actually qualify for. I fully expect the AMA to fall for this trick and act like everything is fine because of the amateur-built exemption and the FRIA sites, because they have always sucked at statutory interpretation and anticipating how regulations affecting model aircraft will actually be applied (Sec. 336 anyone?). That’s even without considering that the FRIA exemption for AMA fields is only intended to be temporary and will be phased out over time, leaving hobbyists with nowhere to fly where they are not subject to the operational remote ID requirements.

No matter what the AMA says, this regulation will be the death of amateur home-built model aircraft, period. It doesn’t matter if it’s a quadcopter or traditional RC plane, flown by an AMA member or not. We’re all affected by this equally, and all RC hobbyists have a duty to oppose this regulation wholesale as bringing about the extinction of our hobby. 

Views: 1633


100KM
Comment by DavidJames on December 31, 2019 at 12:38pm

It is possible that with ardupilot and the mission planner any drone could be compliant with the FAA identification standards and not be limited just to local flying fields.   The tamper resistance requirement looks like the biggest road block.   Currently ardupilot telemetery provides all the information need for the standard remote identification.

Mission Planner could be extended to provide Standard remote identification

A Standard remote identification UAS system in the Mission Planner would have to broadcast and transmit the following remote identification message elements via the internet:

• The identity of the UAS consisting of one of the following:

○ The serial number assigned to the unmanned aircraft by the producer.

○ Session ID assigned by a Remote ID USS.

• An indication of the latitude and longitude of the control station and unmanned aircraft.

• An indication of the barometric pressure altitude of the control station and unmanned aircraft.

• A Coordinated Universal Time (UTC) time mark.

• An indication of the emergency status of the UAS, which could include lost-link or downed aircraft.

https://www.faa.gov/uas/research_development/remote_id/


100KM
Comment by DavidJames on December 31, 2019 at 1:17pm

I noticed that Altitude Angle is already incorporated into Mission Planner.     It already provides the Standard remote identification.

https://www.altitudeangel.com/news/posts/2018/august/introducing-fl...

Comment by Greg Fletcher on January 1, 2020 at 9:47am

David, I am sad to say that he is 100% correct. The devil is in the details, which have a section explicitly calling out a UAV made from 100% store bought parts. Do you carve your own props, machine and wind you motors. They are trying to pull a fast one by exempting "amateur built aircraft" and then go on to define this class as impossible to achieve when building any type of multicopter. It is questionable weather they would consider a scratch built balsa or foam air frame as >50%. Don't take my word for it read it yourself. Start reading on page 152. Keep in mind that the requirements of subpart F are not possible for the average RC modeler.

This is an emergency!!

Here is the link to the proposed rule, FAA-2019_1100. Remember page 152.

https://s3.amazonaws.com/public-inspection.federalregister.gov/2019...


100KM
Comment by DavidJames on January 1, 2020 at 5:20pm

I agree that the "amateur built aircraft"  is being defined in a way that makes pretty much every model aircraft non-compliant.   

It forces "amateur built aircraft" producers(us) into the same category as UAV producers for the purposes of UAV Remote ID systems.  

My point is that having Standard Remote Identification  is not so bad.   Anyone flying Ardupilot, with mavlink telemetry and the Mission Planner already has a Standard Remote UAV Identification System that is compliant with the FAA requirements(With the possible exception of the anti-tamper).   You can setup an Altitude Angel account today and be fully operational on your next drone flight.

All we need as an  FAA-accepted means of compliance that is straightforward like a preflight check that is automatically included in the Ardupilot telemetry logs.


100KM
Comment by DavidJames on January 5, 2020 at 10:59am

I noticed that the  Academy of Model Aeronautics has a good Template Comment on UAS Remote ID.

https://amablog.modelaircraft.org/amagov/2020/01/03/template-commen...

Comment by RCvertt on January 5, 2020 at 11:08pm

I'm concerned about the 50 % or less build requirement for amateur-built status. In some of my planes, all I do is replace the FC with my own custome one. In my current build it's a Flip32 with custom code. 

Makes more sense to me if there was a cap on the number of units you could produce a year instead of a build percentage. If you are producing less than 500 flyable aircraft a year and you're not allowed to make a profit on them by selling them or use them in a profit making way, then more likely than not you are using them for amateur purposes.

That AMA template doesn't address the 50% amateur-built requirement at all.

Comment by Patrick McKay on January 5, 2020 at 11:10pm

Like I figured, the AMA completely missed the most important part of the proposed rule that affects them the most. Because the AMA's government relations people are absolute idiots who know nothing about statutory interpretation, and just see what they want to see. 


100KM
Comment by DavidJames on January 8, 2020 at 9:45am

Does anyone have a link to copy or summary of the:

ASTM WK65041 New Specification for UAS Remote ID and Tracking

https://www.astm.org/DATABASE.CART/WORKITEMS/WK65041.htm


100KM
Comment by DavidJames on Tuesday

I noticed this  OpenDroneID Project that is compatible with Mavlink data.

Looks like there are some development kits that will provide BlueTooth5 ID.

https://www.opendroneid.org/

Comment by Ivan R 12 hours ago

i agree the AMA has totally missed out on everything the last 10 years...they are a complete waste

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