Thanks Dan,

I appreciate you taking the time to provide the links.

So, what is FPVFC doing right now to fight this action by the FAA?  Since this action has been in the works for awhile now, what has been done by the FPVFC to this point?  What avenues of attack does FPVFC have to combat this?  Are there any legislators that are on the side of FPVFC?  Any conversations by FPVFC with the FAA prior to now?  If so, what is the mood of the FAA on things from the FPV community's position?

(29-Dec-2019, 05:10 PM)Krohsis Wrote: Thanks Dan,

I appreciate you taking the time to provide the links.

So, what is FPVFC doing right now to fight this action by the FAA?  Since this action has been in the works for awhile now, what has been done by the FPVFC to this point?  What avenues of attack does FPVFC have to combat this?  Are there any legislators that are on the side of FPVFC?  Any conversations by FPVFC with the FAA prior to now?  If so, what is the mood of the FAA on things from the FPV community's position?

Good questions.  Right now the FPVFC has done our best to read the 300+ pages and attempt to understand them, distill it down to 6 pages and plan to make a 1 page summary soon.  We also created a FAQ.  We are trying to spread the word, answer questions, and inform everyone that this is indeed a very bad situation for the hobby.  In the near future we plan to post more information about how to respond to the FAA, create an official FPVFC response, and pass along suggestions to everyone on what they might want to say or include in their own response to the FAA.  I believe we are also going to encourage people to contact their state representatives and provide information on how to do that.

The FPVFC plans to communicate with manufacturers, vendors, and everyone we can who has a stake in this to help spread the word.  From our work in the various Drone Advisory Committe sub-groups, we have made some contacts with the FAA and others like DJI.  From my understanding, DJI is also not particularly happy with this proposal and was not what they were expecting either.  So imagine if our goals for FPV align with DJI and other compnies, and we all tell the FAA some of the same things, we have a better chance of making a difference.

This facebook comment by FPVFC president Dave Messina does a good job of describing some of the things the FPVFC has been up to thus far. 

"We have been working with the FAA through 2019 in DAC Tasking Group on Remote ID, Spectrum/C2 and UAS Facility Maps. We also had a very minor assist with the ASTM which the DAC used as a reference standard in recommending Remote ID standards to the FAA. In this FAA Remote ID NPRM, the FAA has ignored its Aviation Rule Committee, the DAC, the ASTM standards as well a Congressional Mandate relating to section 374 (spectrum). Many other organizations and companies are as surprised as we are that the FAA ignored all this input. We are doing a number of things to respond. First, we're hoping to educate the FPV community with a distillation of the 319 pages plus the FAQ. The comments here are helping us refine the Guideline doc and the FAQ. Next there are many requests in the document for comments. We will work on those and share our proposed responses prior to the end of the 60 day comment period. We will also provide suggested comments and how to comment to the FAA. Then, depending on the sentiment of the community we may draft suggested memos to Congressional Representatives and Senators. Are there other tasks you can recommend that would help us persuade the FAA to alter this NPRM? Also, please note, the FPVFC is a not-for-profit, non-stock corporation and is currently all volunteer."

Personally, I have only met with one FAA official.  Kevin "the drone guy" Morris.  In person he seemed very positive about FPV.  But that was a couple months ago and when I recently sent him an email the auto reply said he was on vacation until December 31.

Honestly, I think the best way to go at this isn't so much mobilizing the FPV community - rather to mobilize the media instead.  They love their sound bites.  If you guys (FPVFC) and others can somehow get the media to hook onto this thing from our perspective and not the FAA's ... I dunno, call it the big bad government agency manipulated by corporate greed and money going after the innocent defenseless nerds that just want to fly their little drones kind of angle ... MAYBE we have a chance to shift the FAA's thinking?

Personally, I spammed the New York Times, 60 Minutes, and The Economist with my elevator pitch to this effect and referencing Xjet's video (posted below).

I used to think so, but now, I'm not so sure even a deluge of comment letters just from the FPV community will make much difference.  There is WAYYY too much money on the line this time around (read:  this is good for Amazon, et al and they have been wanting this for years now - and they have WAYYY more money than you or I).  I do hope I am wrong.

(29-Dec-2019, 05:26 PM)5zero7rc Wrote: Good questions.  Right now the FPVFC has done our best to read the 300+ pages and attempt to understand them, distill it down to 6 pages and plan to make a 1 page summary soon.  We also created a FAQ.  We are trying to spread the word, answer questions, and inform everyone that this is indeed a very bad situation for the hobby.  In the near future we plan to post more information about how to respond to the FAA, create an official FPVFC response, and pass along suggestions to everyone on what they might want to say or include in their own response to the FAA.  I believe we are also going to encourage people to contact their state representatives and provide information on how to do that.

The FPVFC plans to communicate with manufacturers, vendors, and everyone we can who has a stake in this to help spread the word.  From our work in the various Drone Advisory Committe sub-groups, we have made some contacts with the FAA and others like DJI.  From my understanding, DJI is also not particularly happy with this proposal and was not what they were expecting either.  So imagine if our goals for FPV align with DJI and other compnies, and we all tell the FAA some of the same things, we have a better chance of making a difference.

This facebook comment by FPVFC president Dave Messina does a good job of describing some of the things the FPVFC has been up to thus far. 

"We have been working with the FAA through 2019 in DAC Tasking Group on Remote ID, Spectrum/C2 and UAS Facility Maps. We also had a very minor assist with the ASTM which the DAC used as a reference standard in recommending Remote ID standards to the FAA. In this FAA Remote ID NPRM, the FAA has ignored its Aviation Rule Committee, the DAC, the ASTM standards as well a Congressional Mandate relating to section 374 (spectrum). Many other organizations and companies are as surprised as we are that the FAA ignored all this input. We are doing a number of things to respond. First, we're hoping to educate the FPV community with a distillation of the 319 pages plus the FAQ. The comments here are helping us refine the Guideline doc and the FAQ. Next there are many requests in the document for comments. We will work on those and share our proposed responses prior to the end of the 60 day comment period. We will also provide suggested comments and how to comment to the FAA. Then, depending on the sentiment of the community we may draft suggested memos to Congressional Representatives and Senators. Are there other tasks you can recommend that would help us persuade the FAA to alter this NPRM? Also, please note, the FPVFC is a not-for-profit, non-stock corporation and is currently all volunteer."

Personally, I have only met with one FAA official.  Kevin "the drone guy" Morris.  In person he seemed very positive about FPV.  But that was a couple months ago and when I recently sent him an email the auto reply said he was on vacation until December 31.

Thanks Dan,

Given what you have posted and some of the other pages that I've digested on how this is going, it looks pretty dire.  Further, given the FAA is ignoring input from groups they should listen to or have listened to in the past, seems rather futile to mobilize any ground swell of people to voice their concerns.  But with that said, it can't hurt to contact representatives to share our concerns and suggestions.  I doubt much of that will happen though, because most of the hobbyists affected by this are apathetic.

I will send off letters to my representatives next week.  And I will send a letter in during the comment period.  

This whole thing is like deja vu after the closing of public lands in the USA in the mid to late 70s to motorcycles and off-road vehicles.  It didn't go well then, even though some of the land use has been recovered after 30+ years, it's still a fraction of the original area.  And those groups were a lot more powerful than anything with FPV. 

I will reach out to my buddy who is the lead investigator for the FAA in the Southwestern USA.  He is also a drone fan with numerous drones and a CFI for both fixed wings and helicopters.  I will see what he might know from the inside on the topic.

So I talked to my FAA buddy.  

He said that he finds the decision process to go this route odd and is it in conflict from what the investigators gave to the administration of the FAA when their input was solicited.

As to the issue of how this might affect the home built FPV world there is a quote below from him.  Based on his quote it seems like one or more manufacturers of FCs may be working on a fix to comply with the new law.  We will see.

The FAA really needs to take a page from the FCC's playbook and how they handle federal radiofrequency spectrums. The AARL which is basically a humungous version of intoFPV (read: bunch of amature radio operators not different to us being non-pro drone operators) self regulates the amature side of radio. They have their own band plans (who can talk where) and they so far have evidently done a good enough job of self-regulation that they are the ones in charge of conducting license examinations.

And if the argument is, well radios aren't that dangerous ... I can use my $20 Amazon China made (FCC part 15 no doubt LOL) transceiver to blast police and first responder signals not to mention Canadian military signals (don't ask lol) not to mention the International Friggin Space Station (I know, so cool lol) so they can't communicate - any time I want. Dangerous enough for you?

(29-Dec-2019, 08:10 PM)the.ronin Wrote: The FAA really needs to take a page from the FCC's playbook and how they handle federal radiofrequency spectrums.  The AARL which is basically a humungous version of intoFPV (read:  bunch of amature radio operators not different to us being non-pro drone operators) self regulates the amature side of radio.  They have their own band plans (who can talk where) and they so far have evidently done a good enough job of self-regulation that they are the ones in charge of conducting license examinations.  

And if the argument is, well radios aren't that dangerous ... I can use my $20 Amazon China made (FCC part 15 no doubt LOL) transceiver to blast police and first responder signals not to mention Canadian military signals (don't ask lol) not to mention the International Friggin Space Station (I know, so cool lol) so they can't communicate - any time I want.  Dangerous enough for you?

I agree with you, mostly.  What I have seen in the last 5 years or so is a huge degree of apathy move into the Ham hobby.  It used to be that if you had transmission violation the community worked together to bring it to an end.  Now days, the younger crowd just doesn't care much.  

About a year ago I posted on several of the Ham forums about what was going on with FPV and the huge number of violations in that regard.  No one cared.  Also, I shared that many people in FPV and other outdoor sports and activities were buying Ham radios, usually handhelds without a license and transmitting freely with no license.  Again the majority of the individuals were completely apathetic about it.  

So, self policing works as long as the community takes it to heart.  If they don't, then it becomes lawless and unsafe.  When you have the idiots on RR and other places posting video of unsafe and highly illegal flying, and you don't publicly call them out on their behavior, I believe you are as guilty as them for their activity.  If they get more negative responses than positive responses they may be less likely to continue doing stupid    .  

Given the high percentage of morons in the FPV and drone hobby that are unsafe and do things that bring discredit to the hobby, there needs to be reasonable regulation.  But what is happening with the most recent proposal has the ability to destroy this hobby.   

I'm not 100% legal in my FPV activities.  I fly out further than LOS.  And I have flown in areas that are prohibited, like National Parks.  But I'm always safe, never endangering persons or property.  And when I have flown in NPs, there has never been another person in the area I was flying, so their experience wasn't negatively impacted.

(29-Dec-2019, 08:40 PM)Krohsis Wrote: ... So, self policing works as long as the community takes it to heart.  If they don't, then it becomes lawless and unsafe.  When you have the idiots on RR and other places posting video of unsafe and highly illegal flying, and you don't publicly call them out on their behavior, I believe you are as guilty as them for their activity.  If they get more negative responses than positive responses they may be less likely to continue doing stupid    .  ...

This is a really good point that I had not thought of when making my comparison to the FCC and ARRL. Last time I checked, there was no "CQ CQ CQ Riot" youtube channel with a bunch of millenials prank calling frequencies or something. And unfortunately, in the same manner that sex sells, stupidity sells. Like it or not, RR would not be nearly as popular without their law defying shenanigans.

5zero7rc, I know I've called this out before and I know it bothers you but this is one of the reasons why I am a little suspect of the FPV Coalition with Kapper leading that ship. His ownership of RR and financial ties to DJI just makes me too suspect of that organizations motivations. Frankly, I've read the team's bios and all of you, particularly you, are clearly sincere in your efforts. Just that one guy man ... sorry, I just can't get past it. He just strikes me as someone willing to dip his fingers into absolutely anything that can generate that extra income stream ... regardless of how conflicting - perceived or actual, it really doesn't make a difference - that it may be.

(29-Dec-2019, 08:05 PM)Krohsis Wrote:

"As to home grown drones, I know for a fact that there are companies already working on mods to flight controllers that will provide the remote ID capability."

I am really wondering how that could possibly work.  If the FC's run betaflight, you have open source software anyone can modify and change the remote ID code.  That is against these regulations as they have to be tamper resistant.
Second, in order to comply with remote ID, the drone has to come from the manufacturer with remote ID baked in, serial # listed on the FAA website, and meet all the other rules placed on drone manufacturers.  At the very least the smaller manufacturers will have a hard time with that.
If you purchase anything less than a kit of 100% of the parts you need, it qualifies as amateur built, and thus only allowed to fly in FRIA sites.

So, I had one more thought on this today that gives me a tiny bit of hope.

Imagine you are the FAA and you want to cover your A$$.  Create regulations in the name of "safety" and "security" that you know will not fly with the community.  Ask for the moon if you will.  After all the criticism and public comments, the FAA relents and backs off a little bit with the regulations.  Years down the road some rogue drone takes out a manned aircraft and it does not fully comply with remote ID.  Now the FAA gets to say, "See, we told you guys this was dangerous and you didn't listen, we tried to prevent this".   A$$ covered.

Dunno, just a random though that gave me a little hope on how the FAA could back down a little bit.

(29-Dec-2019, 10:01 PM)5zero7rc Wrote: I am really wondering how that could possibly work.  If the FC's run betaflight, you have open source software anyone can modify and change the remote ID code.  That is against these regulations as they have to be tamper resistant.
Second, in order to comply with remote ID, the drone has to come from the manufacturer with remote ID baked in, serial # listed on the FAA website, and meet all the other rules placed on drone manufacturers.  At the very least the smaller manufacturers will have a hard time with that.
If you purchase anything less than a kit of 100% of the parts you need, it qualifies as amateur built, and thus only allowed to fly in FRIA sites.

I guess we will see.  

I would agree that betaflight would be a problem, but maybe the transponder control program could be contained in a eeprom on the FC or something like that.  I'm not an electronics engineer.  And maybe even betaflight would cease to exist in its current form....I know that might be distasteful for some right now, but who knows. 

Dan, the doubting Thomas perspective is a little concerning coming from a main player in an organization that is supposed to be protecting the hobby.  What ideas do you have?  Even Bruce, (Xjet) had some good ideas like airspace separation that would fix the problem.  I seem to remember all the RF experts saying that HD video was impossible for years and if possible only for a few hundred feet, yet here we are killing it out over 5 miles.  So I'm reluctant to buy into there is nothing that can be done by current manufacturers.  

Since producing a system that meets the requirements is possible, because DJI and others will have it, and there is money to be made doing so, I'm fairly confident it will happen.  Entrepreneurship and capitalism is a beautiful thing.  Plus someone closer to the malignancy of the FAA than you or me has weighed in and sees it happening, I'll bet it does.

AND, if the transponder removes the BVLOS requirement, I'm ALL in!

The best part is, if in the future you choose to fly without a transponder it's highly likely the penalty will be a civil one only, not criminal, so only a fine (Rarely does the FAA make criminal investigations).  A big fine maybe, but no jail time, and none of the negatives that come with a felony conviction.

(30-Dec-2019, 01:05 AM)Krohsis Wrote: I guess we will see.  

I would agree that betaflight would be a problem, but maybe the transponder control program could be contained in a eeprom on the FC or something like that.  I'm not an electronics engineer.  And maybe even betaflight would cease to exist in its current form....I know that might be distasteful for some right now, but who knows. 

Dan, the doubting Thomas perspective is a little concerning coming from a main player in an organization that is supposed to be protecting the hobby.  What ideas do you have?  Even Bruce, (Xjet) had some good ideas like airspace separation that would fix the problem.  I seem to remember all the RF experts saying that HD video was impossible for years and if possible only for a few hundred feet, yet here we are killing it out over 5 miles.  So I'm reluctant to buy into there is nothing that can be done by current manufacturers.  

Since producing a system that meets the requirements is possible, because DJI and others will have it, and there is money to be made doing so, I'm fairly confident it will happen.  Entrepreneurship and capitalism is a beautiful thing.  Plus someone closer to the malignancy of the FAA than you or me has weighed in and sees it happening, I'll bet it does.

AND, if the transponder removes the BVLOS requirement, I'm ALL in!

The best part is, if in the future you choose to fly without a transponder it's highly likely the penalty will be a civil one only, not criminal, so only a fine (Rarely does the FAA make criminal investigations).  A big fine maybe, but no jail time, and none of the negatives that come with a felony conviction.

There has been a huge flurry of activity on our discord server tonight discussing all of this.  Xjet, Zoe, Ole Gravy Leg, and a dozen others all trying to find solutions.

I have been doing a little more research on aviation transponders since until a few days ago I knew zero about them.  I still know very little.  

There are several manufacturers that make them for UAVS.  They are pretty big, probably too big for anything less than a 10 inch quad.  Maybe smaller ones are out there, but I haven't found them yet.  Most of the transponders are for location of downed UAVs, but some also squawk on the beacon frequency we will be required to transmit on to meet FAA requirements.  Regardless, the equipment is out there now being used on UAVs in the commercial market. Below is one of the ones on the market for size reference.  This one is set up to transmit on the new freq we will have to abide by if the law goes through.  Pretty big to put on a 5-7 inch quad.  Maybe they can be made smaller.  And the transmit range is about 150 miles LOS, so maybe we won't have to transmit that far.  That could make it easier to make smaller as well.

Also, it appears that the frequency they will transmit on is in the 960-1164mhz range.  If so, that is likely a problem that will interfere with Crossfire that transmits on 915mhz.  Maybe there will be filters and/or enough distance on a bigger UAVs to minimize the problems, but maybe not.  I know guys flying with 1.3ghz video on extreme long range wings have to go to some lengths to get 1.3ghz to work with Crossfire.  At first blush, I see quads having to get bigger to carry the extra stuff, and maybe Dragon Link frequencies becoming the standard (433mhz) rather than at Crossfire frequencies.  Dragon link is much bigger than Crossfire and bigger antennas.   

So the problems continue to mount up.
[url=https://www.ntia.doc.gov/files/ntia/publications/compendium/0960.00-1164.00_01MAR14.pdf][/url]

(30-Dec-2019, 03:00 PM)Krohsis Wrote: I have been doing a little more research on aviation transponders since until a few days ago I knew zero about them.  I still know very little.  

There are several manufacturers that make them for UAVS.  They are pretty big, probably too big for anything less than a 10 inch quad.  Maybe smaller ones are out there, but I haven't found them yet.  Most of the transponders are for location of downed UAVs, but some also squawk on the beacon frequency we will be required to transmit on to meet FAA requirements.  Regardless, the equipment is out there now being used on UAVs in the commercial market. Below is one of the ones on the market for size reference.  This one is set up to transmit on the new freq we will have to abide by if the law goes through.  Pretty big to put on a 5-7 inch quad.  Maybe they can be made smaller.  And the transmit range is about 150 miles LOS, so maybe we won't have to transmit that far.  That could make it easier to make smaller as well.

I thought the proposal said we would have to broadcast on wifi or bluetooth frequencies so that the public can detect the broadcast on their mobile devices?  So 2.4ghz or 5.8ghz, both of which also have potential to mess up control or video signals.

If you can't connect to the internet you can still fly if you squawk via RF only, which will be the freq mentioned.  But yes if internet is available the UAV needs to connect to the internet.  That will only make the transponder bigger, and more antennas.  That would be FPVFC's responsibility to offer in compromise to do away with the internet requirement if it comes down to negotiating points if the change can't be trashed completely.