Not sure what other possible conditions or circumstances you are wanting to have covered, but these are the only three referenced by the FAA, justifying relief, and intended to be covered in their discretionary enforcement of the deadline, and also referenced by Pilot Institute here. There are no others. I agree that the published rule doesn't have the same specificity, but expecting relief from enforcement for some other unspecified reason, independent and unrelated to the three, is highly unlikely. However, it does state that the totality of all the circumstances will be examined on a case by case basis. Whatever your excuse is, one would be advise to at least try to make it fit into some form of one of those three. Those are the three safe harbor excuses.
Remote ID Requirements starting Sept 2023
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Why is it so easy to show the three "excuses" in a video or typed in someone post but you cannot point it out in the law? I'll tell you why. It's because it *isn't* in the law. Can you at least admit that these three "excuses" are not exactly in the law but when you read the law, these are the best three *excuses* that you and others can come up with? That way we are all working from the same base and if for some reason I want to make up my own three excuses instead of using yours....I have that option?
Autel promised to provide broadcast modules to Autel Evo 2 owners and they have not yet said "never mind, we change our mind and won't be providing broadcast modules." So I'm not buying one and I'm waiting. Is that a valid "excuse?" DJI said they are providing software updates later and Autel said they are providing broadcast modules later, why do you think the recent FAA announcement covers one but not the other?
Here's what I think? You and others have come up with the big 3 excuses because you have to find a way to justify the date which went ahead into effect from yesterday. Instead of deferred enforcement for everybody, you change it to deferred enforcement for just the 3 excuses only but the problem is the law doesn't say that. What you are doing is simply trying to get RC plane owners and drone owners who plan to never comply to attach a broadcast module to their aircraft today. Generally it is that person who cannot "articulate" the situation and FAA wants to option to take action against them now instead of March when this whole process implodes.
I'm just explaining what the FAA is doing and why.
Please don't shoot the messenger.
You can do anything you want, but if you are expecting relief from enforcement for any other reason, other than one that reasonably falls within the ONLY three safe harbor excuses that the FAA has clearly articulated, your noncompliance does not qualify for any FAA delay in enforcement.
As I very clearly stated above,
"expecting relief from enforcement for some other unspecified reason, independent and unrelated to the three, is highly unlikely. However, it does state that the totality of all the circumstances will be examined on a case by case basis. Whatever your excuse is, one would be advise to at least try to make it fit into some form of one of those three."
The hypothetical that you have posed clearly falls into the "unavailability of the broadcast module" safe harbor exemption. You can reasonably argue that you are waiting for the promised broadcast module from Autel, which Autel now has until March 16, 2024 to supply, unless Autel clearly states they won't be providing them at any time before then, which would shift the burden to you to obtain one independently. I'd certainly take that position, were I you, and it is defensible, if you can prove that broadcast module promise from Autel.
I have no dog in this fight. Not a fan of RID as presently implemented, and I wish it were truly cancelled instead of now enacted with enforcement merely selectively delayed. Unfortunately, the FAA has no legal authority to cancel RID which was actually enacted by Congress. Only Congress can cancel it. The FAA is only responsible for enforcement, so enforcement is what they are now selectively delaying.
Realistically, anyone that now needs a broadcast module to be in compliance as of September 16th, whether an RC plane or drone owner without built in RID and no FW update promised by the manufacturer, has 6 more months to get one, before any FAA enforcement against them for lack of RID compliance can no longer be defended as excusable noncompliance.
However, if their true intent is to never comply, they should certainly not state that to the FAA at any time. Instead they should still maintain to the FAA that they are at least "trying to get a module" to comply.
Enforcement is based upon the totality of the circumstances, on a case by case basis. Just because the FAA chooses not to enforce against another RC plane flyer under the exact same circumstances does not mean they can't choose to enforce against you, if they don't like your answers. Open defiance won't help your case.
Given the FAA history of delay and unpreparedness, even the March 16, 2024 date could slide, but as of now, most of those that are now technically noncompliant still have 6 more months to enjoy flying their aircraft, without repercussions from the FAA over lack of RID. Smoke 'em if you got 'em!
However, the real issue is those needing or relying upon some form of drone liability insurance, requiring compliance with all FAA Rules, who may now have a problem. Drone business liability insurance policies may be voided for noncompliance with all FAA Rules, even if the FAA isn't enforcing the rule one is in violation of!
Even AMA member liability insurance can be voided if your AMA Flying Field's FRIA application has not yet been approved by the FAA, and only 26% of the applications received have been reviewed! 74% still have not! That's 1206 AMA Flying Fields that are currently still in violation!
Carefully check with your drone liability insurer to find out if you are now flying bare!
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What no one is addressing is the wanton idiocy of a 'Module per Drone', every drone must have it's own module registered to ONLY that drone!
I can only fly one drone at a time, the point of RID is to identify a drone to it's owner so why can't one RID module be used on each 'flying' drone?
This is just more FAA "Good Old Boys" support crap, like the testing, designed to keep an existing blotted out-dated system 'in the money' and growing so to speak.
I can only fly one drone at a time, the point of RID is to identify a drone to it's owner so why can't one RID module be used on each 'flying' drone?
This is just more FAA "Good Old Boys" support crap, like the testing, designed to keep an existing blotted out-dated system 'in the money' and growing so to speak.
One External attached RID module is good for all your faa drone zone registered recreational drones, Part 107 registered drones-one external rid module is associated with one Part 107 drone. Check it out on FAA Drone zone its plainly written in each drone inventory section on the top of the page !
In case you all missed it Forum - General Discussions- Holy Stone RID Module is Available- FAA Certified-
Cheers
3Fees
In case you all missed it Forum - General Discussions- Holy Stone RID Module is Available- FAA Certified-
Cheers
3Fees
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Agreed and to be more clear, it is one RID module per FAA registration ID. A recreational flyer only has one FAA registration ID so that means only one module is needed. Different recreational flyers cannot share the same RID module. Since the part 107 drone pilot needs to have one unique registration ID per each of his drones and the RID module cannot change it's broadcast details then that leaves you with one RID module per each unique registration ID.....with one exception:
As a part 107 pilot, when you go into the FAA database to register your RID module, you tie the module to your FAA registration ID which means you are basically tying it to one drone only. However, if you "unregister" the RID module, you are free to re-register it to a different drone/registration ID. Probably will cost you another $5.
CactusJackSlade
Well-Known Member
What has alrwady been clarified: For recreational use, one module for all your drones. Velcro is your friend
Exactly. From FAA Drone Zone on the recreational inventory side of the dashboard:
"Recreational flyers must add manufacturer and model information for all UAS over 0.55 pounds that they own and operate. For standard remote identification UAS or broadcast modules, you’ll also be required to provide the serial number. Each broadcast module serial number may only be entered once to your inventory, even if shared with more than one recreational UAS."
Cheers
3Fees
"Recreational flyers must add manufacturer and model information for all UAS over 0.55 pounds that they own and operate. For standard remote identification UAS or broadcast modules, you’ll also be required to provide the serial number. Each broadcast module serial number may only be entered once to your inventory, even if shared with more than one recreational UAS."
Cheers
3Fees
Agree - purchased the Holystone version. Registered it and with Velcro it works fine. All good here...thanks
