Originally Posted by
Shrrdavid
Makes one wonder if any RC planes will be up-gradable at all. The single manufacturer thing basically makes mine not up-gradable, depending one how you interrupt it.
They're all upgradable IF someone decides to make components that will make the upgrade possible. But there's a catch. If you do the upgrade, YOU become a "UAS Producer" in the eyes of the FAA. That's UAS - Unmanned Aerial System - not just the airplane. You'll have to prove, to the FAA's satisfaction, that your complete system (including the transmitter), meets all of the Remote ID requirements. Including things like preventing the aircraft from "taking off" (apparently they don't know some of us hand launch) without an Internet connection. You'll have to prove that it does this RELIABLY. And you'll have to prove it's "tamper-proof" -- that you can't just take it out and fly without it when you want to.
It's not at all clear HOW you will prove this, and the FAA makes it clear that this is intended to be beyond the reach of most individuals. You'll need to set up some kind of test lab, perform "system-level tests" and document the results. You'll need to let the AMA come and inspect your facility upon request. You'll need to perform "audits" of all UAS you produce to verify that they continue to meet requirements. You'll need to keep all the resulting paperwork on file for inspection.
And you'll need to issue your UAS a serial number, using a written standard you can't even look at until you pay the organization that issues it something like $313.
And finally -- it's not at all clear whether you can use one transmitter for more than one Remote ID compliant UAS. The transmitter is part of the system. Can it be used for multiple systems? The NPRM doesn't say. Does the act of "binding" a different model require you to repeat all your system-level testing before you can go fly it? The NPRM doesn't say -- but it's best to assume the worst.
Of course, you can ignore all this stuff as long as you build at least 51% of the "system" and fly your UAS at a FRIA, without Remote ID. ARFs don't qualify -- if you merely put pre-finished components together you'll HAVE to put Remote ID in the thing and act as "Producer". Since the 51% thing applies at the SYSTEM level it's also not clear if the FAA expects you to build 51% of your TRANSMITTER.
What can we do about it? Well, at least if we do everything we can to defend FRIAs, we'll have more to play with than if we don't.