Category Archives: Drones

Drones, R/C aircraft, Radio-control, UAVs

FAA NPRM Summary of key points and recommendations, in my comments

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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 →
Drones, UAVs

#FAA #NPRM #REMOTEID: Proposal creates threat to national security

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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/

Drones

FAA NPRM: major purpose is to develop a nationwide aerial surveillance system

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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.

Drones

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.

Drones

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.

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