Hi - Here's what I plan to post to the FAA website.  I welcome all constructive comments, before the fact.

Suggestions & Conclusion

Automatic Dependent Surveillance – Broadcast (ADS-B)

I believe that ADS-B would be the best solution for UAS remote identification.  ADS-B transmissions need to be modified to carry 2 pieces of additional information.  For UAS flights, ADS-B needs to report the GPS coordinates of the UAS pilot (from the controller).  Emergency aircraft (MAS & UAS) need a special designator to report their presence in the air.

      Some points in favor of ADS-B:

• With ADS-B installed on most UAS aircraft, both MAS and UAS pilots would know the positions of all aircraft in their immediate vicinity.  MAS pilots would not need to install additional equipment.  As of January 1, 2020, most (but, strangely not all) MAS were required to have ADS-B installed.  The FAA even provided $500 rebates to help MAS owners meet this deadline.  
• Public safety personnel could have access to UAS information with simple and inexpensive, existing computer/phone applications (e.g. https://global.adsbexchange.com/VirtualRadar/desktop.html )  ADS-B message elements could be modified to provide UAS controller location, while pilot identification is a part of the registration number data.
• ADS-B and UAS controller software could be modified to initiate an automatic Return To Home (RTH) whenever an emergency aircraft is in the vicinity.  Further, temporary geofencing could keep UAS away from emergency operations such as rescue and firefighting.
  
  

      FAA arguments against ADS-B:

• ADS–B does not provide information regarding the location of a UAS control station. Thus, it would not advance the FAA’s need to associate a control station with the actual unmanned aircraft it controls.
  
  

Counter argument

I find it difficult to believe that the ADS-B message elements could not be modified to include both the registration number of the UAS (giving access to the owner’s name and contact information), and the GPS location of the controller.  Since this information would be needed only by law enforcement personnel, ADS-B receivers would not need to be modified and would still provide the UAS location information needed for aircraft safety.

• Further, because ADS–B receivers do not provide sufficient low altitude coverage, ADS–B Out would not align well with the FAA’s vision for the development of Unmanned Aircraft Systems Traffic Management (UTM).  
  
  

Counter argument

This argument seems to have the most sway over the solutions proposed in this NPRM.  In short, these rules are proposed to protect UPS, Amazon, and Pizza Hut autonomous delivery services.  While at first it might seem that autonomous UAS flight would be trivial compared to autonomous surface vehicle operation, autonomous UAS operation has many difficult problems to solve.  The rules in the NPRM seek to help autonomous UAS identify other UAS in their flight areas, which is a worthy goal.  However, some of the most restrictive rules are proposed to solve this problem, which does not yet even exist and may never exist in most of the US.

While these companies have money to pay to influence the regulation process, most current UAS pilots believe that drone delivery will not be economically feasible outside of a few densely populated areas. Those areas could be served by making a change to the airspace rules to prohibit MAS below 1000 feet (instead of 500 feet), and granting the space between 500-900 to autonomous UAS operation.

• Finally, the FAA determined that the use of ADS–B Out by UAS would generate undue signal saturation and would create an overall safety hazard for manned aircraft due to the potentially high numbers of UAS which may be operating in the airspace at any given time.
  
  

Counter argument

I find this argument the least persuasive of all.  As an Advanced Class Ham Radio operator (FCC callsign WW9JD), I’m well aware of the effects of multiple radio signals in small geographic areas, and I believe that the FAA fears of congestion are largely unfounded.  In fact, the FAA itself argues that the placement of ADS-B equipment on all of the various airport ground support vehicles will provide increased airport safety (“ADS-B reduces the risk of runway incursions with cockpit and controller displays that show the location of aircraft and equipped ground vehicles on airport surfaces – even at night or during heavy rainfall. ADS-B applications being developed now will give pilots indications or alerts of potential collisions.”  https://www.faa.gov/nextgen/programs/adsb/faq/ ).  I can’t imagine the situations that the FAA consider likely where there will be more UAS flying in as close proximity as the number of ground vehicles in an airport.  If ADS-B can be effective there, then why can’t it be used by a relatively few UAS in the air?

Pilot Certification

I suggest that every pilot needs to be certified to fly in the National Airspace, even children.  Without certification, the software controlling a UAS should prohibit flight beyond 200 feet from the controller (however, older equipment should be grandfathered).  Two hundred feet is recommended because the FAA/FCC permit the installation of radio towers up to 200 feet without hazard warning lights, so MAS pilots are flying very dangerously if they fly below 200 feet.  Consider the airspace below 200 feet as similar to sidewalks.  While the highest levels of UAS pilot certification might require the security of computerized testing at a testing center, the entry levels could be adequately administered by approved groups (e.g. the AMA) in a fashion similar to that used by the FCC for Amateur Radio (where ALL license tests  are administered by volunteers).

Different UAS

The FAA has chosen to include all UAS in this NPRM, even though there are substantial differences between different types of UAS.  For example, traditional model airplane (CTOL - Conventional Take Off & Landing) pilots have a completely different set of needs from drone (VTOL - Vertical Take Off & Landing) pilots.  It would be unreasonable for the FAA to treat different MAS (Manned Aircraft Systems - e.g. commercial passenger jets, private propeller planes, gliders, untralights, hang gliders, balloons) the same as each other, but the FAA is attempting to do that with UAS.

From my perspective, the CTOL segment mostly seems to want to just be left alone.  The FAA has worked with these pilots over time, and developed rules that have allowed that segment to grow to what it is today.  I understand that the potential is there for a CTOL UAS pilot to disrupt others using the National Airspace, but the risk is so minimal that further regulation seems pointless.

Current VTOL UAS identification & safety needs would be adequately met with ADS-B, and explained above.  MAS pilots were given $500 rebates for installing ADS-B systems on their aircraft, perhaps UAS pilots sould be granted additional privileges when similarly equipped.  ADS-B UAS should be allowed to fly Beyond Visual Line Of Sight (BVLOS) when equipped with ADS-B and camera equipment to permit the pilot to see.

Those VTOL UAS pilots that fly indoors or exclusively below 200 feet should not be required to have any remote identification.

Autonomous UAS will likely weigh more than 50 pounds, and not fall in the sUAS category at all.  They will need a set of rules all their own.

Conclusion

I find it extremely hypocritical that the NPRM contains language that would prevent a UAS from even taking off if it does not have identification, while manned aerial systems (MAS) only “requires ADS-B Out equipment by January 1, 2020, to operate in designated airspace. If you never fly into ADS-B-designated airspace, then there is no requirement to equip.” (https://www.faa.gov/nextgen/programs/adsb/faq/)  On our National Roadways, there is one set of rules (e.g. which side of the road to travel on, stopping at intersections, identifying turns, pulling over for emergency vehicles) for all vehicles - motorized & non-motorized.  

The courts have ruled that the National Airspace is equivalent to the  Public Highways.  What I want is to be a co-equal pilot in the National Airspace when I fly my camera drone, just like I’m a co-equal vehicle on the road when I ride my bicycle.  There is one set of rules for roadway use, and I believe that the National Airspace can be safe with rules, including identification rules, that apply to all Manned Aircraft Systems (MAS) and Unmanned Aircraft System (UAS) pilots.

People who want to harm others will find a way no matter what rules you write.  Please help the 99+% enjoy the benefits of flying UAS without undue regulation or expense.

Looking forward to see how this ends up, since I have a feeling the rest of the world will follow.
Thanks to inputs like you, this might end up not so badly as it looks right now.

InspektorGadjet Posted at 2-10 10:41
Looking forward to see how this ends up, since I have a feeling the rest of the world will follow.
Thanks to inputs like you, this might end up not so badly as it looks right now.

Thanks.  I also plan to send this as part of a letter to one of my state's Senators (Todd Young).  He's on the Senate Transportation Committee which has FAA oversight.

IndyRick Posted at 2-10 11:03
Thanks.  I also plan to send this as part of a letter to one of my state's Senators (Todd Young).  He's on the Senate Transportation Committee which has FAA oversight.

That´s good, the more "influential" people can say something, the better.
Fingers crossed!

Hello and good day IndyRick. Thank you for reaching out and for sharing these suggestions and conclusion with regards to this topic. Again thank you for your support and great arguments.

DJI Stephen Posted at 2-10 12:04
Hello and good day IndyRick. Thank you for reaching out and for sharing these suggestions and conclusion with regards to this topic. Again thank you for your support and great arguments.

You're welcome.  I also appreciate DJI's stand on this topic.

I wish you luck and your right about djis stand, it’s a pity FAA didn’t give dji or Arcs proposal a better hearing .

hallmark007 Posted at 2-10 12:24
I wish you luck and your right about djis stand, it’s a pity FAA didn’t give dji or Arcs proposal a better hearing .

https://youtu.be/fKJ5QisZsq4

IMHO I think that FAA Management was somewhat in agreement with both ARC and DJIs proposals.  However, I have a feeling that other federal agencies (who shall remain unnamed but I'm sure you know their 3 initials) desired more privacy information and data manipulation and overrode the FAA's initial chop of the proposed NPRM.  

Certain federal agencies maintain all the clout and are almost never told no or they figure a way to skirt the gray areas when it comes to carry out their agency's missions and taskings.  

The other side of who could be pushing certain aspects of the NPRM are the advocacy groups for the likes of Amazon, etc in order to clear up the national air space of recreational droner flyers so they can maximize drone deliveries of their products, etc.

My grandfather, rest his soul, always said to me that money talks and "you know what" walks.  I'm just hoping that at least some common sense prevails and that recreational drone flying is not limited to some space the size of a sports arena.  

Anyway, rant over.  Have a great day all.

Thanks hallmark007 & DowntownRDB.  While I'm new to working with the FAA, I've watched the progress of countless NPRMs through the FCC.   It's been my experience that the final result is usually a compromise.   I'm both hoping that the final rules look good for us, and doing what I can to help that along.

Give you Kudos for taking time to write comment to FAA.  

One coment: I believe at this time, it is a mistake to offer FAA the appeasement of adding any information past FAA's originally proposed need of Remote ID.  Localized broadcasting of Remote ID** is all FAA and Federal Law Enforcement need - to find out who owns or is piloting drone.  Flight of which, may or may not be violating flight regulations.

** Remote ID data broadcast needs to be secured / encrypted to where only a small number of authorized FAA staff and Federal Law Enforcement agents  having received Remote ID can find out personal information of drone owner or pilot.  


Again, Kudos for taking time to write comment to FAA.

Thanks for your comments, HedgeTrimmer.  I see this issue as having two parts.  ID broadcast, and retention of the broadcast data.  It's similar to photography in as much as it's legal to take photographs of anything that can be seen, when you're standing on public property.  However, depending on the use, you can't necessarily sell or publish without a release.  Like manned aircraft, we fly in the National Airspace.   The Web site https://global.adsbexchange.com/VirtualRadar/desktop.html will show you the ADS-B equipped aircraft anywhere in the world.  Storing that data on private individuals would likely be considered improper.  Right now, UAS registration information is considered a public record.  In the future, I would hope that UAS registration would be treated much the same way as automobile registration.  I think that the capability to identify a UAS registration number, in the same way that you could record someone's license plate, might be used as an argument against those who are worried that "drones are constantly spying on them."  Just like the license plate number of a car that often drives by a house could be given to the police for investigation,  so could a drones registration number.   Roadways are public spaces as is the National Airspace.

did you really mean to say this?  "I suggest that every pilot needs to be certified to fly in the National Airspace, even children."

That section was drafted rather early, and I'm not I'm wedded to it.  I've been a Ham Radio operator (WW9JD - You can find some personal information from that) since 1977.  No one can operate Ham Radio without a license, and I've taught Novice & Technician classes with folks of all ages.  That's what I was thinking of when I wrote that.  I'm not suggesting a child would need to pass the 107 test, but, perhaps, an entry UAS pilot certification would be useful for anyone flying above 200'.  It could be given by individuals that are already certified.   I just may drop that before I submit.

IndyRick Posted at 2-10 16:45
That section was drafted rather early, and I'm not I'm wedded to it.  I've been a Ham Radio operator (WW9JD - You can find some personal information from that) since 1977.  No one can operate Ham Radio without a license, and I've taught Novice & Technician classes with folks of all ages.  That's what I was thinking of when I wrote that.  I'm not suggesting a child would need to pass the 107 test, but, perhaps, an entry UAS pilot certification would be useful for anyone flying above 200'.  It could be given by individuals that are already certified.   I just may drop that before I submit.

nobody should be allowed to operate a cellular mobile telephone without a government license and certification as well, correct?

just so you know, I thought you meant 200 feet distance from your remote, I didn't read it as 200 AGL.

Right.  Or a walkie-talkie, WiFi, or an RF remote.  Those are all Part 15 devices.  I chose 200 AGL because the FAA permits radio towers up to 200' without marker lights.  Any MAS pilot is crazy  to fly at that level, other than to land a helicopter.  I thought, maybe, that UAS controller software could query a credential server and grant flight privileges in accordance to your certification.   

BTW - I think the 400' bubble in the NPRM shows a real lack of understanding of flight and FAA airspace.  Perhaps a further example of the NPRM beong eritten by a 3Rd party.  If you were at the 400' horizontal li,it, and the drone performed a typical RTH, you'd be in immediate non-conpliance.  All FAA airspace is defined by cylindets, not hemispheres.

IndyRick Posted at 2-10 12:19
You're welcome.  I also appreciate DJI's stand on this topic.

It is always my pleasure IndyRick. Please keep us updated and keep on flying.

Well thought out.

Thanks for sharing.

Cheers!
=C=

DJI Stephan & Cal Evans - Thanks for your support.

I appreciate what you are putting together as a comment to the NPRM. I do have a couple of suggestions though:

1. Don't get why you chose 200' AGL. Here in WA state we have trees, cliffs, hills and mountains. In many cases I would hate to be limited to 200' as I could only fly as high as just above tree tops. I would like to have a little more room and 400' AGL makes a lot of sense to me as I can escape problems with obstacles

2. The NPRM proposes NOT to use ADS-B. I think that is a good idea as the current crop of DJI drones and I suspect other drones could be made compliant with a software upgrade. ADS-B would require an expensive retro fit to most drones. Why not use what we currently have, with software mods, to make a drone compliant and thus ensure that our drones are not made obsolete?
In addition, I have proposed in my comment to the FAA register to drop the internet connectivity. The proposed internet connectivity is complicated. Too many points of failure and a serious invasion of privacy. Use the KISS principle instead. Without the requirement for the internet things are a LOT easier. So easy in that it would be possible to roll out RID for most drones in months instead of the years it will take to implement RID as currently proposed.

Hi NightThunder - Thanks for your comments, and thanks for making your comments to the FAA.  I'm taking all comments into account before I submit my comment to the FAA.

It's my, otherwise unsupported, belief that the FAA has ceded airspace below 200 AGL by the fact that they do not require marker lights on antenna structures shorter than 200 feet.  

While I may drop it from my comments entirely, I've suggested a graduated certification requirement for all UAS pilots.  Without certification, you'd be limited to 200 AGL.  I see that as working fine for kids, and FPV racers that never intend to be part of the National Airspace anyway.  I think that the cartification test to have the privileges we have right now should be basic, and administered by volunteer UAS pilots.  While that is imposing a requirement that does not currently exist, telling someone that you have FAA certification to fly your drone would likely go a long way to legitimizing your already ligitimate activity to them.   But, I'm not certain.  I may drop it entirely.

I agree with you about the FAA's Internet proposal.  It's just plain silly.  I do believe that ADS-B (with modifications that the FAA apparently doesn't want to make) actually solves the problems that the TLA government agencies are trying to solve, where existing manufacturer's solutions fall short AFAIK.
- Manned aircraft nearly all (as of January 1, 2020) have ADS-B capability and would then be able to locate UAS while flying.
- With message element modification, folks on the ground could identify UAS & pilot location inexpensively.  Personally, this doesn't bother me any more than having a license plate on my car.  I understand that folks can't identify my car with an app, but both commercial and private aircraft are so identified right now.
- With transmitter power requirement modification, I'm sure that ADS-B can be included in future designs at relatively low cost (money & battery power).
- I suggest grandfathering existing UAS.

"While that is imposing a requirement that does not currently exist, telling someone that you have FAA certification to fly your drone would likely go a long way to legitimizing your already ligitimate activity to them."

Agreed, I would drop this.  Such thinking is inconsistent and incompatible with the rights and freedoms we enjoy here in America.

The certification section was drafted rather early, and I'm not I'm wedded to it.   I just may drop that before I submit.

Where did FAA come up with 400-feet Max altitude limit?  

Was it safety gap of 100-feet between minimum flight altitude of 500-feet for aircraft, flying in large open areas, over bodies of water?

Why not change aircraft minumum flight altitude to be 1000-feet?  1000-feet minimum is already in place for cities and congested areas.  Simply, eliminate exemption for large open areas, over bodies of water.  Make space for all!


Doing so would allow "Commericial Delivery" UAVs to fly between 750-feet and 500-feet.  Leaving hobbist restricted to flying below 400-feet.

With aircraft exceptions for takeoff and landing at airfields, emergency landings, and search & rescue.  

"Commericial Delivery" UAVs would have similar exceptions during delivery takeoff and landings.

Related to FAA and maximum Drone flight altitude, Why was 250 grams picked for drones?  
While "Commercial Delivery" drones (UAVs) will be allowed to be far heavier and carry heavy payloads.

How is Mavic 2 weighing less than 1 Kilogram anywhere as dangerous as "Commercial Delivery" drone weighing up to 25 Kilograms?  
Ignoring extra weight of "Commercial Delivery" drone's payload.

I agree, HedgeTrimmer.   When I copied my comment into this message utility, it renumbered all of the FAA points against ADS-B as "1".  I suggest nearly the same altitude changes as you do in the 2nd paragraph of my counter argument of the 2nd of the FAA's points.  Let's hope that something that's obvious to the both of us makes sense to the FAA, too.

I also agree with what others have said about autonomous UAS delivery, in that it will be unlikely to prove cost effective.  I'd like to have a flying car, too, but it ain't gonna happen in my lifetime.

Nothing against your comment.  The following is an example of what is likely to get tossed:

"Here is a copy/paste statement the AMA has written for people to send to the FAA via the comment section of the new proposal-"
Followed by lengthy paste.  


Quick scan of most recent 50 comments is a mixed bag.  Some comments have good points and are well written.  Some not so much.
Believe any comments that essentially come down to "I disagree", without providing solid argument as to why will be ignored.

Think comments which point out issues or flaws with FAA's Proposed Remote ID, show FAA's process was done incorrectly or mistakes were made getting to this point, or show FAA's Proposal to be counter to U.S.'s prinicples on Freedoms and Rights has best chance of being taken seriously.

One thing is for sure:  We need more Comments!