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- Aug 16, 2019
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I've been poring over the NRPM since its release and trying to formulate a response that conforms to their suggested "Commenter's Checklist" to maximize effective input. To do that, I need input from knowledgeable forum members on specifics of how our drones work and how the FAA's proposal may have a negative impact. I will recite from the NPRM published in the Federal Register and reference page number(s). My first question for you pertains to drone operation under the Standard Remote I.D. method, is specific and limited to how the drone communicates with the controller. Let me know your thoughts and how I can strengthen my response.
XIX. Regulatory Notice and Analyses - 3. Cost and Savings Summary -.iii. UAS Producers (Pg 62 para. 1)
Operators of limited remote identification UAS must transmit message elements to the Remote ID USS from the control station, which could be an electronic device such as a smart phone or tablet. For purposes of this analysis, the FAA determines that operators of limited remote identification UAS would already have a cell phone or electronic device capable of transmitting the message elements through an internet connection to the Remote ID USS and thus incur no additional costs for the purchase of a device to transmit messages to a Remote ID USS.
Response: Many drones communicate over 2.4 GHz and 5.8 GHz frequency bands via Wi-Fi. The 2.4 GHz band is particularly congested in urban areas and can experience interference potentially causing loss of command communication. While the 5.8 GHz band is less congested, the potential for interference exists. Most users have found that reducing the Wi-Fi interference by using a direct cable connection between the "control station" (remote control) and their electronic device (i.e., cell phone or tablet) and putting the electronic device in Airplane mode enhances control connection and reduces the likelihood of loss of control communication to the drone. The electronic device does not require a connection to the internet or cell provider service. Moreover, such connections invite unreliable control issues.
XIX. Regulatory Notice and Analyses - 3. Cost and Savings Summary -.iii. UAS Producers (Pg 62 para. 1)
Operators of limited remote identification UAS must transmit message elements to the Remote ID USS from the control station, which could be an electronic device such as a smart phone or tablet. For purposes of this analysis, the FAA determines that operators of limited remote identification UAS would already have a cell phone or electronic device capable of transmitting the message elements through an internet connection to the Remote ID USS and thus incur no additional costs for the purchase of a device to transmit messages to a Remote ID USS.
Response: Many drones communicate over 2.4 GHz and 5.8 GHz frequency bands via Wi-Fi. The 2.4 GHz band is particularly congested in urban areas and can experience interference potentially causing loss of command communication. While the 5.8 GHz band is less congested, the potential for interference exists. Most users have found that reducing the Wi-Fi interference by using a direct cable connection between the "control station" (remote control) and their electronic device (i.e., cell phone or tablet) and putting the electronic device in Airplane mode enhances control connection and reduces the likelihood of loss of control communication to the drone. The electronic device does not require a connection to the internet or cell provider service. Moreover, such connections invite unreliable control issues.