FAA Remote ID NPRM Response Guide

[@PilotInstitute]

Please read our Remote ID response guide for more info: pilotinstitute.com/nprm/

[@richardhopkins5338]

Greg, Thanks’ for Explaining everything I Tried reading the NPRM but couldn’t understand it. You helped me so I could submit my comment to the FAA. I am a beginner 65 years old I build airplanes, FPV Quads and just bought a Mavic Mini. Flying is my passion, about to retire so I could do it full time. I wrote my comment but I was waiting to learn more about the NPRM and how to write a comment. Thank you I have the information I need now! Richard

[@PilotInstitute]

Richard, if I was able to only help one person like you, then this was totally worth it!

[@jamescaron6465]

Professor, you did a great job. I plan to use your notes a blueprint for my own response. I would like to add something. As somebody who has managed large programs and acted as an agent of change, you have to ask yourself some questions before a solution can be implemented. First "What is the problem we are trying to solve?" Second "What is the simple most cost effective solution we can successfully implement?" Third "How can we make people want to embrace the change and want to be compliance?" and Fourth "How can we make it easy for them to do so?" Those questions have to be answered before a solution implemented. A broken solution is worse than none.

[@PilotInstitute]

Spot on, James! Wish you had been in the room when the NRPM was crafted, the FAA needs smart people like you...

[@jamescaron6465]

@@PilotInstitute Thanks Professor, you are too kind.. After all these years I have come to realize that if you make an effort to make it easy for people to change they will. If it appears you are just going to jam any solution down their throats regardless of its practical application, they will resist, passively if nothing else, but they will resist.

[@PilotInstitute]

@@jamescaron6465 I think the ARC was pretty clear about this point specially. Many who were involved in the ARC mentioned online that they warned the FAA that if this is not accepted by the majority, it will be a failure.

[@jamescaron6465]

@@PilotInstitute They are not wrong.

[@PilotInstitute]

@@jamescaron6465 Most of the recommendations from the ARC were pretty much spot on. The FAA needs to go back and reconsider not listening to them.

[@johnsanders3454]

Thanks for your very nice video on this Greg. Your detailed information is very interesting and I just hope the FAA truly is interested in the comments and will take our concerns seriously.

[@FaceBoydFamily]

Thanks for all the research you put into this video. I think it's the best explanation I've heard so far. I've already submitted my comment to the FAA and surprisingly I mentioned each of your 4 big picture items. I emphasized the compliance issue, as I feel this is the only real leverage we have over the FAA. Thanks. Subscribed

[@PilotInstitute]

Outstanding! Thank you, Dave.

[@WilzDezignPhotography]

Thank you for your insight! I provided my comments too adding my thoughts but taking consideration 4 of your main points. Thanks Greg!

[@TomShamblin]

Thanks for your brake down of these rules and regulations that will greatly effect Hobbies drone flyers and put a huge expense for those that want to fly commercial. As it is already!!! As A GA license pilot I have multiple issues with the current commercial requirements. I can go rent a airplane and take off with less BS, This is just a big money grab, revenue generator!!!! Makes you want to sell your drone and say the hell with there rules. But i will be making my comment to the FAA about Remote ID and contacting my local Representatives and possibly send my FAA comment to them. Again thanks for the brake down of there BS, hope they listen to us!!!!

[@paulshampay4468]

Thank you for the very well thought out comment proposal. 1 thing I still haven’t seen is the impact of an internet connection on the battery life of a drone. When my cellphone only has 1 or 2 bars the battery drains very quickly. If that happened to a drone at 200+ feet of altitude that would very unsafe. So I think the internet proposal actually makes drone flights less safe.

[@PilotInstitute]

Good thought, didn't think about that one!

[@triskellian]

You've done a great job compiling a credible list of the problems and the solutions of the NPRM. I do have to point out one of the things missed in your presentation.In the NPRM there was a change to registration requirements .For commercial operators,registering each UAS may or may not negatively impact the operator in terms of cost and valuable time.For the recreational flyer,it definitely would be an unworkable cost burden.Most hobbyists have anywhere from 5 to dozens of aircraft.Some models may last just one test flight or 10- 20 years. I would be remiss in not mentioning that much of our problems started with drone registration in 2015.This should never have happened,especially without well thought out planning.Mere registration requirements also puts the user in peril because their personal information can be hacked. A revival of part 336 would better serve the recreational user. As for commercial flyers, registration may or may not have been a good idea .As you mentioned,the FAA's risk assessment sources are dubious at best.It doesn't appear that the reasons given (safety,national security, ect.) are real but rather perceived. My friends and I have submitted comments to the FAA as well as our state representatives.Something else that could be done is to contact local news television and radio to reach the public.Thank you for the effort put in on the video and the comment!Blue Skies from the USA.

[@PilotInstitute]

Thank you for the suggestion, I will add it to our list under the financial burden. I thought about the additional cost but didn't think about it in terms of cost over lifespan for dozens of drones with 10 year lifespan.

[@FAIF3A]

Thanks for the informative video. One question: At 2:34 of the video you state that do no COPY/PASTE template responses and that they only count as a single response in the FAA's eye's. You are not alone in stating this, but I would like to know where there is official FAA language that references this? In the recent AMA podcast, Tyler addresses this directly and says that it is not so. He stated that they have contacted several FAA Attorneys and all have said that they DO NOT count them as one comment, they all count individually. I agree that personalizing the comments is best, but I fear that many will not take the time and stating that template copy/paste won't count will discourage many form commenting at all. I would rather that we have a large turnout for the comment period just to increase our number of comments.

[@PilotInstitute]

Good question. While it doesn't say specifically to not copy/paste comments, the FAA does mention the fact they don't want to see duplicate comments. Here's the text: "To ensure the docket does not contain duplicate comments, commenters should send only one copy of written comments, or if comments are filed electronically, commenters should submit only one time. " While this may be interpreted as the fact one person shouldn't send the same comment more than once, it sounds a lot to me that the FAA doesn't want to see the same comments. The idea of not copy/pasting comes from the fact that 1000 comments will be reduced to 1 comment. The office in charge of reading and responding will certainly remove all duplicate comments before going through each. If everyone submits a unique comment, it will take them a lot longer to review and respond. That's the way I look at it.

[@FAIF3A]

@@PilotInstitute Thanks for the prompt reply. Thank you.

[@jerrylhales]

Great points about Broadcasting and Internet connection. Have you considered a squawk code? Flying VFR in manned aircraft require a standard code. How about a proposal for a sUAS designated squawk code? A transponder on the sUAS so to speak.

[@NathanChisholm041]

You can thank Amazon for this! No doubt offering kick backs and other perks..

[@MikeKinney8675]

Hello, I thought your response was very good and thorough. I am working on mine. My fear is they will ignore our comments, like they did the ARC recommendations.. . . .

[@PilotInstitute]

They might ignore the comments but it's worth trying. I've been involved in many NPRMs over the years, including one that reshaped the training industry years ago and changed the requirements for Airline Pilots. We submitted comments, like most of the training industry, but in the end, we lost. The only thing we can do is try.

[@joenaylor3626]

18:30 exception for home built non-autonomous UAS to fly line of sight. I like the concept of excluding home builders, but I don’t really see a basis to exclude non-autonomous craft. Also FPV is just as safe and unlikely to interfere with other airspace users as line of sight, especially if limited to say 400 feet altitude.

[@PilotInstitute]

The idea of the exemption for non-autonomous is because they can't be preprogrammed by terrorist who want a drone to fly to a target.

[@innovationsurvival]

Excellent video. Instead of an internet connection, have the FAA create its own tower network that the public cannot access. If there is a data breech, the FAA pays each affected user $600,000. Responsible people for the data breech are subject to a two year prison sentence. FAA must purchase drones that cannot be retrofitted with equipment meeting their requirements similar to eminent domain land seizures. Commercial delivery drones are restricted to altitudes between 400 and 450 feet, must have redundant airborn collision avoidance systems, and yield to non-commercial delivery drones. Vendor operators violating this altitude range are subject to six years in prison and a $600,000 fine. Hey, let's really make the skies safe. I'm all for it.

[@PilotInstitute]

Brilliant! But you're assuming this is about safety :P

[@innovationsurvival]

@@PilotInstitute Please trust me on this: I do not believe this is about safety. This is a FAA "drone grab" conceived of by mediocre, ordinary people who either have a complete lack of initiative and imagination or they have been bribed by lobbyists or will be employed by commercial drone service companies in the near future. The FAA is attempting to transfer convenience and cost to the public. Sorry FAA, this comes out of your budget which deserves to be seriously reduced based on the Kobe Bryant death in the helicopter crash following the FAA ignoring NTSB recommendations for helicopter safety equipment requirements. The FAA is derelict in their duty to serve the public. I won't suggest any of that in my comments to them, but I will make the other recommendations to them because the skies need to be safe and they need to start building their communication towers to fulfill their duty to keep the skies safe.

[@jimnorth9902]

Senator Kyrsten Sinema (Arizona) is the ranking member Senate Committee on Commerce, Science & Transportation: Subcommittee on Aviation and Space. I sent her a copy of my comment along with a cover letter. There are other Senators on this committee, and there is also the House Committee on Transportation and Infrastructure: Aviation Subcommittee where you may have a representative from your state. Even if you don't have a rep from your state, you can still contact them and write, at the top of your letter, that you do not live in their state/district, but are contacting them in their capacity as a committee member. I don't know if these committees have any influence over this rule making process, but It certainly doesn't hurt to make them aware of the issues at hand, and of the excellent solutions compiled here by Greg and Pilot Institute. You can find the names of the members here: House Aviation Subcommittee: www.congressweb.com/thoracic/legislators/committee/cmte_id/188#/legislators/committee/cmte_id/189/ Senate Aviation Subcommittee: www.congressweb.com/thoracic/legislators/committee/cmte_id/36#/legislators/committee/cmte_id/36/

[@PilotInstitute]

Thank you for sharing, Jim!

[@mattfoley7881]

The FAA ignores our comments; I’ll ignore their rules. Ok, to be honest, I’ll ignore their RID rule no matter what they do.

[@innovationsurvival]

Oh, I forgot to add the FAA must provide a geographically disbursed, conveniently accessible FRIA for every 10,000 citizens. If no FRIA is available, the UAS can fly unrestricted except near major airports.

[@joenaylor3626]

You mention there are more details “in the blogpost”. Can you please provide a link to this?

[@PilotInstitute]

www.pilotinstitute.com/nprm

[@JohnSwitzer]

Excellent points. Unfortunately, I was initially under the impression that we could make multiple unique comments. So I may have invalidated my comments by making more than one even though they are each on a different issue. I was one of your part 107 students and am now enrolled in your FPV build course. I would be truly disappointed if This remains as it is proposed.

[@PilotInstitute]

I'm not sure how the FAA handles multiple comments but the NPRM does mention: "commenters should submit only one time". Hopefully they don't disregard what you had to say!

[@JohnSwitzer]

@@PilotInstitute I do hope so. Particularly since each comment was a separate point and not a re submission of a previous comment.

[@substratum3d]

Thank you for this very well put together video, it has helped me a lot. Using this video as well as other sources, I have put together my comment which has turned out to be 5 pages long. Is 5 pages too long to submit in your opinion? I wanted to make sure I hit all the key points but I also don't want them to see how long it is and hit the NEXT button...

[@PilotInstitute]

There's no limit for the comment. It's gonna be over 5000 characters so make sure you submit it as a PDF. That's what I'm gonna do for ours.

[@substratum3d]

@@PilotInstitute Gotcha, sounds good. Thanks for the reply.

[@wbuttry1]

So is this going to effect me flying my easystar out in the country side.

[@PilotInstitute]

If it's remote-controlled then sadly yes...

[@erospawn]

And by the way.. Even if you do copy paste, we were later informed that it still counts as a comment. It is unknown how that rumor got started.

[@PilotInstitute]

An incorrect rumor that needs to be squashed. Those of us who have been involved with FAA NPRMs for a long time know duplicate comments count as 1. Spread the word! The AMA actually updated their article to ask people not to copy/paste comments anymore.

[@LouisMcCarthy]

Technically my RC hovercraft is "navigating the airways" right?

[@highestvirtue1892]

Hi the link took me to a comment submittal page but automatically refreshes into a another screen where I am not able to submit a response plz fix

[@PilotInstitute]

There is a "Comment now" blue button. Did you try that?

[@clockenessmnstr]

You're reading of the "Amateur built" section incorrectly. Building from parts on the internet is a "Kit Build" and MUST comply to RID. and could have the same costs you mentioned. You must manufacture your RC to be Amateur built. This means it's worse. The FAA even went as far as to "Seek comments" on whether they should "Allow" the manufacture of kits that are not compliant. (wouldn't be able to fly indoors without RID)

[@PilotInstitute]

I think we're on the same page, there are several scenarios. In Section XIII on page 72480, the FAA considers a UAS to be amateur-built if "the person building it fabricates and assembles more than 50 percent of the UAS". In this case, the UAS would NOT have to comply with Remote ID (but be limited to FRIAs). If you wanted to comply with Remote ID in this case, you'd have to spend the $$$. The FAA also says in the same section that "UAS assembled completely from pre-fabricated parts". In this case, the UAS would not qualify as Amateur built because the FAA says "the person building it would be fabricating and assemble 50 percent or less of the UAS'. In this case, Remote ID would be required and the person is the producer and would have to spend the $$$. The last scenario is building from a kit, which is not considered an amateur built, as mentioned by footnote 53 on page 72461. This means kits would be required to have Remote ID.

[@clockenessmnstr]

@@PilotInstitute sorry, just saw the other half of the video.

[@PilotInstitute]

@@clockenessmnstr No worries at all.

[@erospawn]

The NPRM as written provides no path way for Model Aviation. We build and fly are stuff at a fixed location. The plan allows for FAA recognized sites to be approved during a 12 month period. However, no new applications will be accepted after that. Meaning, fixed flying sites will disappear leaving people in Model Aviation no place to fly. As I stated, Building and Flying/crashing/repairing is Model Aviation. There is no pathway for remote id for Model Aviation. So we get the short end of the stick despite having proved safe operations for decades.

[@PilotInstitute]

I totally agree with you. Model aviation will be the most impacted by this NPRM and the FAA provided zero solutions. Even worse, they actually state that 80% of current hobbyist UAS won't be able to be retrofitted. I foresee very low compliance rate from the model community, and for the right reasons!

[@f15sim]

When the FAA ignores the comments and does this anyway (realistically, that's what is most likely to happen), those of us that fly safely will simply refuse to comply.

[@PilotInstitute]

Agreed, most will ignore. And Remote ID will be a failure. Which is sad because the concept has merit.

[@f15sim]

@@PilotInstitute When it comes to my recreational foam & balsa airplanes, it has no merit whatsoever. This kind of thing is fine for commercial efforts, but it has absolutely no place with hobbyists. The "safety" angle is pure nonsense backed by nothing but hot air. George Mason University did a study a few years ago that worked out the fatality rate for "drones" was around 1 death every 1.87 million years. Until the FAA shows me an evidence based risk assessment to back up this nonsense of theirs, I'm not buying what they're selling. (I can email you a link to the study if you like.)

[@PilotInstitute]

@@f15sim That's exactly why we need an exemption for certain aircraft (foam and balsa included). Someone else shared the study you mentioned.

[@erospawn]

I can also tell you..Model Aircraft don't last for 10 years..and we do not own just 2. I myself have a garage, truck and storage unit full. I fly them all. Some aircraft last 25 years and some don't even make it past the first flight.

[@felixruiz2838]

thanks for this great video Im a hobbyist so the new rules would affect me greatly.Can u post the actual site address for making comment to FAA. It's true about these fake drone sightings too much fake news . I live not far from Teterboro I fall within 5 miles circle . I get permission from a Laanc to fly no more than 200ft and have no problem. where can find section on Faa and Military drones

[@PilotInstitute]

Thanks, Felix. Here's the link to comment: www.regulations.gov/docket?D=FAA-2019-1100 Click on the "Comment Now" blue button in the middle-right of the page.

[@michaelsowden5892]

There is no situation so bad that Bureaucracy won’t exert great effort to make it worse.

[@jalpa9642]

AMA Cbo's charge $60.00+ per year to fly on their FRIA's..... B.S. !!! And the FAA stated rules, you can't fly within 5 miles of an Airport...! More B..S. !!! I can not even fly w/in my own areas because of all the Restricted Airspace's, Which means, I will have to drive my vehicle at least 45 miles from my current residence, probably more, to fly my S500 mm Quad-copter for about 20 minutes, if that, depending on the Battery mAhr capacity and how I fly...! I have two 5200 mAhr batteries, that;s approx. 40 minutes +/- I don't think it's even worth it...! The whole situation SUCKS..!

[@JohnSwitzer]

The only way things will change for the better is if we all comment on the NPRM

[@EmpReb]

Love what happened to model aircraft. Just about the same to flying on planes pre 9/11 vs post. Full loss of freedom for nothing gained

[@bhaskarg233]

COOL

[@ldcam21]

Recreational and RC started the whole thing then it went commercial now they want to take it away for recreational flyers I’m not paying a monthly fee recreational I’m not playing at the dam park I’ll stay below 200 feet I’ll be dam if I’m not gonna fly over my own house .

[@jimlindamorgan1]

You mean ama, not EAA.

[@PilotInstitute]

Oops, yes! EAA is something different...

[@BlizzardDelta]

One of the first things the 911 hijackers did was turn off the transponders. (This is going in my comment, so don't steal it…)

[@PilotInstitute]

Correct. And it's ok for people to mention this in their comment. The FAA just doesn't want to see a word-to-word comment or else it will be counted as one. Thanks for sharing.

[@BlizzardDelta]

I'm thinking of following it with, "And if you think you can make RID tamper-proof, you don't have a good handle on the nature of the people you imagine you can regulate." (The stealing thing was attempted reverse psychology…)

[@PilotInstitute]

@@BlizzardDelta haha. Yes, like I said in the video, bad people will do what is needed.

[@tzmanthropology]

Just keep the common sense laws in place already. I'm a criminal, ok. None of this will stop me from flying safely.