FAA finally sets rules for piloting small drones

All drones weighing over a quarter kilogram will need Remote ID transmitters.

Read the whole story

 

[dodexahedron]

My DJI Mavic Mini that I got a few weeks ago at Costco weighs 249 grams which is just a hair under the limit.

Under these new rules, if I were to apply a new paint job which pushes me over the 0.25 kg limit, would I suddenly have to attach this module?

And is the weight limit with or without the battery inserted?

Well obviously with the bettery otherwise you can't fly it and it can't be considered a hazard, unless you are using catapults to fly it. Which is funny as the batt us usually half a pound to begin with.

I'm going to assume they assume whatever is factory default on the device. There is no mention of post purchase modifications which could be a gray area if you upgrade its motor, etc.

That’s not a gray area with the FCC at all. As a pilot, I have to consider the weight of the freaking engine oil in my aircraft. Paint, decals, etc are part of the aircraft. The total weight, as flown, at the time the engine is started, is what matters.

The FARs are not ambiguous about pretty much anything, because the stakes are just too high. It’s one portion of the United States Code that is actually pretty easy to read and understand.

Edit to nitpick myself: It is takeoff weight that matters. For a drone, that’s the same as the time the engine starts, generally. For an airplane, the two may be several minutes apart and fuel weight changes over that time, which is explicitly accounted for, in flight-planning for weight/balance and fuel requirements.

 

[dodexahedron]

My DJI Mavic Mini that I got a few weeks ago at Costco weighs 249 grams which is just a hair under the limit.

Under these new rules, if I were to apply a new paint job which pushes me over the 0.25 kg limit, would I suddenly have to attach this module?

And is the weight limit with or without the battery inserted?

Well obviously with the bettery otherwise you can't fly it and it can't be considered a hazard, unless you are using catapults to fly it. Which is funny as the batt us usually half a pound to begin with.

I'm going to assume they assume whatever is factory default on the device. There is no mention of post purchase modifications which could be a gray area if you upgrade its motor, etc.

That’s not a gray area with the FCC at all. As a pilot, I have to consider the weight of the freaking engine oil in my aircraft. Paint, decals, etc are part of the aircraft. The total weight, as flown, at the time the engine is started, is what matters.

The FARs are not ambiguous about pretty much anything, because the stakes are just too high. It’s one portion of the United States Code that is actually pretty easy to read and understand.

Yeah. I'm pretty sure the code for proper human carrying aircraft is going to be way different then this. The PDF says

Category 1 eligible small unmanned aircraft must weigh less than 0.55, including everything on
board or otherwise attached, and contain no exposed rotating parts that would lacerate human
skin. No FAA-accepted Means of Compliance (MOC) or Declaration of Compliance (DOC)
required.

It does not say at time of flight or at time of purchase. Or that may be implied that its at time of flight.. But its doesn't say see FARs for further details or anything of the like.


The question I have is, what is: . Requires FAA-accepted means of compliance and FAA-accepted declaration of
compliance As cat 2 requires this. To google!

Actually, no. The term “aircraft” is firmly defined in the FARs. The FARs are not some special thing. They are just the titles under the United States Code that pertain to aviation.

And yes, weight at time of flight is what matters, period, by explicit definition in the rest of the FARs, and doesn’t need to be “implied,” anyway, as written. How can you possibly read that cited sentence any other way?

 

[dodexahedron]

3 miles of viability for nighttime flying on a drone that weighs a half pound seem excessive to me. That's just a gut reaction, hopefully someone can speak to that, but I'm just thinking about how bright any old flashlight I have is compared to how much it and its lithium battery weigh. It seems this could exclude a certain size drone from being able to fly at night at all.

You’d be surprised at how far away you can see a fairly low-powered LED.

Navigation lights aren’t flashlights or headlight equivalents. They’re the colored lights you see on the sides of aircraft or watercraft that let OTHER aircraft know your aircraft’s orientation, for collision avoidance purposes.


I do, however, question the utility of such lights on a tiny drone, where, from 3 miles away, they’re going to look like a single point of yellow light (red plus green equals yellow), to me, flying at several times the drone’s speed, with tons of other likely light noise near the ground making it further indistinguishable from or completely drowned out by said noise (traffic lights, cars, homes, etc).

On a larger drone? Sure. The nav light thing really should be based on size, not mass, IMO. Put a strobe on them, like any other plane, for basic collision avoidance. Nav lights are gonna be useless.


Edit to add:
I suppose, with proper reflector design, the lights would be directional enough to be discernable from each other, but that doesn't fix the problem of sighting them against ground light noise. Nor does it really help you in any meaningful way, anyway, unless the lights change color depending on the direction the drone is actually moving, since they can move in any direction at any time. You'd need a bunch of them around the perimeter of the drone or, otherwise, artificially restrict them to only be able to move up, down, and "forward," with respect to the orientation of the nav lights, for this to be a viable aid to anyone, anywhere. The more I think about it, the more useless nav lights on small drones sound, and the more useful a simple anti-collision strobe is about all that they should have required, under a certain size.

 

[dodexahedron]

My DJI Mavic Mini that I got a few weeks ago at Costco weighs 249 grams which is just a hair under the limit.

Under these new rules, if I were to apply a new paint job which pushes me over the 0.25 kg limit, would I suddenly have to attach this module?

And is the weight limit with or without the battery inserted?

Well obviously with the bettery otherwise you can't fly it and it can't be considered a hazard, unless you are using catapults to fly it. Which is funny as the batt us usually half a pound to begin with.

I'm going to assume they assume whatever is factory default on the device. There is no mention of post purchase modifications which could be a gray area if you upgrade its motor, etc.

That’s not a gray area with the FCC at all. As a pilot, I have to consider the weight of the freaking engine oil in my aircraft. Paint, decals, etc are part of the aircraft. The total weight, as flown, at the time the engine is started, is what matters.

The FARs are not ambiguous about pretty much anything, because the stakes are just too high. It’s one portion of the United States Code that is actually pretty easy to read and understand.

Weight and balance calculations are done very carefully for commercial aviation, but there are still a couple gray areas that the FAA would rather not get into despite some evidence they should. By far the best example is passenger weights. Under FAA rules, an adult male passenger weighs 200 pounds including carry-on baggage and clothing. The loadsheet uses ballpark average passenger weights, not actual weights.

This has become an issue in the past, particularly with small aircraft, like the overloaded Beechcraft that crashed on takeoff from Charlotte (Air Midwest 5481), but also with charter flights like Arrow Air 1285, which stalled on final approach in part because it was loaded with troops from the 101st Airborne Division and their gear, which weighs a lot more than 200 pounds per man. A charter flight for the NY Giants might be another example where the flight crew should really question the FAA average passenger weight.

I will of course admit to not having read plenty of parts of the FARs that apply to ATPs because I am not an ATP (yet...some day, maybe). BUT, at least in smaller planes, you bet your caboose I’m having as accurate as possible information before I, as pilot in command, decide if we’re even leaving the ramp, because it matters a whole lot more, the smaller the plane is, since each person or item is a bigger proportion of the overall weight.

But even that’s not gonna be perfect, either. I’m not gonna weigh each passenger, obviously. I will, instead, use the weight on their license plus or minus a decent estimate based on how they physically appear. Baggage is absolutely going on a scale if I’m flying you, though, especially if it goes in a more rearward compartment.

One thing the FARs do say, though, in all cases, is that it is the pilot in command’s ultimate authority (even though various operations are explicitly allowed to be offloaded). So, in that regard, it’s de jure unambiguous, but that really only helps when pointing the finger after the fact, rather than actually preventing the situations altogether.

 

[dodexahedron]

Would have been nice if the FAA just forced low powered ADS-B on drones. Then airplanes could pick it up on already established tech and not possibly need yet another expensive radio. Admittedly, in most cases we probably aren't going to pick up RemoteID before slamming into the drone (assuming it's being flown irresponsibly) but it'd be nice for when we're practicing slow flight at lower altitudes or in airport traffic pattern and someone is ignoring the law.

I wonder if they’ll combine this information with what’s already being fed through the ADS-B data.
If you’re equipped with ADS-B IN, like on a G1000 or something, that’d make it visible to you, anyway, since the ground station would be relaying that data.

 

[dodexahedron]

My DJI Mavic Mini that I got a few weeks ago at Costco weighs 249 grams which is just a hair under the limit.

Under these new rules, if I were to apply a new paint job which pushes me over the 0.25 kg limit, would I suddenly have to attach this module?

And is the weight limit with or without the battery inserted?

Ok the paint question is valid, but the battery question is stupid.

Obviously, the weight limit applies to a device as it weighs in-flight, or it’s not relevant. If you can fly it without a battery, then I guess it doesn’t apply.

Now the weight reference for planes refers to without fuel, so if you prefer a gas-powered drone...

If you prefer gas-powered, it’s still takeoff weight that matters. So you’d need to only fill it up to just under the limit. Filling it to over the limit would be a violation.

This is a viable strategy in a real airplane, too, when you’re slightly overweight, but don’t need full tanks to reach your destination plus required reserves. You can literally drain fuel from the tanks to remove weight to put you inside the envelope for the particular category you need the plane to fly in.

 

[dodexahedron]

Would have been nice if the FAA just forced low powered ADS-B on drones. Then airplanes could pick it up on already established tech and not possibly need yet another expensive radio. Admittedly, in most cases we probably aren't going to pick up RemoteID before slamming into the drone (assuming it's being flown irresponsibly) but it'd be nice for when we're practicing slow flight at lower altitudes or in airport traffic pattern and someone is ignoring the law.

I wonder if they’ll combine this information with what’s already being fed through the ADS-B data.
If you’re equipped with ADS-B IN, like on a G1000 or something, that’d make it visible to you, anyway, since the ground station would be relaying that data.

This final rule only requires local broadcast (it could end up being Wi-Fi Direct / 2.4GHz based, looking at some of the proposals submitted during the rulemaking process). It needs to have enough range for nearby law enforcement hunting a drone to pick up the signal on portable equipment, it doesn’t need the range to reach the nearest airport tower, and broadcasting above-ground at such high power could create interference for people on the ground anyway.

Drones are still expected to maintain spatial separation, drones subject to these rules aren’t going to be in your airspace (and if they violate your airspace, these rules will be used to hunt down the violators). Commercial drones that are equipped with ADS-B OUT will be exempt from having a Remote ID under this rule.

Well yeah. Per the FARs, I'm not permitted below 500 feet AGL in a sparse area, anyway, or 2000 feet AGL in most wilderness areas, so we should already be well-separated, out away from an airport.

But people fly drones into controlled airspace on a daily basis, and MAN I'd sure appreciate TCAS alerting me to some asshat's drone over the numbers that the tower hasn't spotted (situation I've been in before). Some of these things are small and light-colored, making them hard to spot til they buzz by your left wing.

 

[dodexahedron]

Would have been nice if the FAA just forced low powered ADS-B on drones. Then airplanes could pick it up on already established tech and not possibly need yet another expensive radio. Admittedly, in most cases we probably aren't going to pick up RemoteID before slamming into the drone (assuming it's being flown irresponsibly) but it'd be nice for when we're practicing slow flight at lower altitudes or in airport traffic pattern and someone is ignoring the law.

I wonder if they’ll combine this information with what’s already being fed through the ADS-B data.
If you’re equipped with ADS-B IN, like on a G1000 or something, that’d make it visible to you, anyway, since the ground station would be relaying that data.

This final rule only requires local broadcast (it could end up being Wi-Fi Direct / 2.4GHz based, looking at some of the proposals submitted during the rulemaking process). It needs to have enough range for nearby law enforcement hunting a drone to pick up the signal on portable equipment, it doesn’t need the range to reach the nearest airport tower, and broadcasting above-ground at such high power could create interference for people on the ground anyway.

Drones are still expected to maintain spatial separation, drones subject to these rules aren’t going to be in your airspace (and if they violate your airspace, these rules will be used to hunt down the violators). Commercial drones that are equipped with ADS-B OUT will be exempt from having a Remote ID under this rule.

Well yeah. Per the FARs, I'm not permitted below 500 feet AGL in a sparse area, anyway, or 2000 feet AGL in most wilderness areas, so we should already be well-separated, out away from an airport.

But people fly drones into controlled airspace on a daily basis, and MAN I'd sure appreciate TCAS alerting me to some asshat's drone over the numbers that the tower hasn't spotted (situation I've been in before). Some of these things are small and light-colored, making them hard to spot til they buzz by your left wing.

I’m not arguing with that, I get what you want, and it’s not a bad thing to want.

I’m just saying, the idea here isn’t to make something compatible with ADS-B or TCAS. It’s to make something that helps LEOs quickly identify and locate anyone who strays into the approach and landing area of your airport, and deal with them.

I get ya, for sure. Just wishing.

Seems like a missed opportunity, since anything operating within controlled airspace would surely be able to reach a tower, whether it be from the drone itself or relayed from the controller.

Edit to add:
And I'm sure, once drones are compliant with this regulation, a tower would likely monitor for them and alert pilots in their airspace anyway. I mean they alert you to birds, if they notice them. It's just that anything at all that reduces the workload on ATC and pilots is generally a good thing. There's already enough to think about when behind the yolk.

 

[dodexahedron]

The elimination of the network option is actually bad news for (some) existing drones.
That would just mean your cell phone needs to tell the FAA where your drone is when your drone is in the air. As an alternative to broadcast ID. Like I said, this would’ve been a cheap option to retrofit onto existing consumer drones, instead of having to get a “broadcast module” to put on them...

It is hard to imagine that there are areas without cellphone coverage... yet there are plenty, and they're right where drone operation is actually likely - mountainous wilderness and rural areas. So technically both approaches are pure nonsense.

I mean, the broadcast option in the final rule will work there. So I don’t get how it’s “pure nonsense.”

As a theoretical example: so I fly in a wilderness location, and have some device that is mandated, that broadcasts my drones location data. And I am in compliance with all other FAA regulations such as the drone pilots license etc.

But who is the broadcast data meant to be received by? Unless there is some mandated requirement for aircraft to have a receiver that can localize my broadcasts, then it doesn't do any nearby aircraft any good.

It was speculated in a reply to my previous question that the data could be used to localize the operator of a particular drone, if LE was close by. But that is more of an "after the fact" investigation.

So IMHO unless the location data can be fed into the ATC systems then I can't see anything in these proposed regs that are meant to actually increase safety of aircraft with regards to drones, aside from having a nice registry and requiring drone pilots to be licensed.

Yeah. This is where I'm coming from in my thinking on the subject. Sure, it's great for law enforcement and POSSIBLY catching someone AFTER the fact, unless they start actively monitoring for them and actively enforcing the regs. And, uh....WHO, exactly, is going to do that, and with WHAT funding?

The only reason I wouldn't want the data fed into ADS-B, though, on further thought, is that we're talking about something that is accessible to a huge portion of the public, and that system is super-vulnerable to someone spoofing data. It's not much of a leap to imagine that some bad actor might be able to inject ghosts or wreak other havoc on that system.

And, also, someone who intends to actively break the rules is probably going to do one of two things:
1) Disable the transmitter.
2) Modify it to emit a false ID, false position data, or any other spoof attack that would render it fairly useless for the intended purpose.

I feel like this will increase costs marginally, but do VERY little in the way of actually making the skies any safer.

 

[dodexahedron]

This is a viable strategy in a real airplane, too, when you’re slightly overweight, but don’t need full tanks to reach your destination plus required reserves. You can literally drain fuel from the tanks to remove weight to put you inside the envelope for the particular category you need the plane to fly in.

Been there. I once had a flight where a passenger and flight bag was added by dispatch literally at the last minute.

After I re-ran the numbers, balance was still good but as we sat we were 8 pounds over MTOW. Once I factored in the fuel required for engine start, taxi and run-up, we were scheduled to be right at MTOW as we took the runway, so it was all legal.

Certainly helped that it was a nice (i.e. not hot) day at sea level, with a 10k' runway and flat terrain as far as the eye could see.

I'm told some DPEs like to throw situations like this at you on check rides at all levels, even if only as thought exercises. Something like you do your precheck, get in the plane, and he suddenly says "hey, my buddy Frank, who weighs 300lbs, wants to ride along, too. Is that ok?" And then you have to recalculate your whole flight. And then, after you do that, he says "oh yeah, Frank has a 50lb suitcase. We good?"

Thankfully, I have not encountered a DPE that sadistic, yet.