Re: [Drip] Comment on -arch-22

[Jens Finkhaeuser <[e-mail]>]

Hi,

I am (recently) subscribed to the list, unfortunately under a different email address than I selected previously.

Yes, NPA-2021-14 is a good starting point. It refers to the U-SPACE regulation (EU) 2021/664 which concerns itself in more detail with identification. I don't think that offhand there is much conflict here with the draft in principle.

I am actually a little more concerned with the implications of the last paragraph on page 5 referring to C2 links and the first on the following page. The AMC on C2/C3 links always require mission appropriate link performance; in this they provide some parameters, but also refer back to ICAO regulations.

At any rate, given current state of the art, it is unlikely for a multi-purpose drone to carry a single link technology, but hand over C2/C3 connectivity between several. This, and how this relates to control hand over between different ground control stations is our current research focus.

Link technology and control handover tend to coincide with critical phases of flight (i.e. takeoff and landing), as altitude changes often trigger the need to switch links, and proximity to ground control stations often require control handover. A particular challenge here is posed by fixed-wing drones which can land at speeds in excess of 100km/h; range and latency of RF technology clearly influence the ability to switch over safely.

But also BVLOS scenarios to areas not covered by conventional 3GPP means (remote, offshore, in RF shadow) will require similar link and perhaps control handover as BVLOS here implies beyond RF LOS.

What this means is that the ASTM suggestion of e.g. Bluetooth 4 or WiFi for broadcast RIDs is likely only workable to comparatively slow drones. Conversely, the assumption that there is some Internet connectivity provided by the C2 link is not in line with beyond RF LOS scenarios - the draft acknowledges this, but seems to focus on situations where Internet connectivity is given after all.

Again, though, this doesn't invalidate any work done on this draft, or its contents. It just raises the spectre of future work in fulfilling regulatory requirements in such scenarios that are less ideal for communications.

I hope that clarifies my comment a little. It comes back to a question of intended scope; regional scope is only one aspect.

Unfortunately, I did not consider joining IETF mailing lists until very recently, or I would have been able to raise this much earlier.

Jens

------- Original Message -------

On Thursday, March 24th, 2022 at 11:31, <[e-mail]> wrote:

> Hi Jens,
> 

> Thank you for sharing these valuable comments.
> 

> The intent was not to be centric but we are working under the usual volunteer-based constraints. This point was discussed early in the WG (e.g., https://datatracker.ietf.org/doc/minutes-interim-2020-drip-01-202004221100/) and this limitation was called out, e.g. (from the write-up of RFC9153):
> 

>    Early versions of the document was largely based on the process
> 

>    of one region (US). The WG discussed that issue at the time and
> 

>    agreed to progress the work based on available inputs/volunteers
> 

>    as any other IETF effort. Also, the WG agreed to record this issue
> 

>    in an appendix. Since then, the document was enriched with inputs
> 

>    and relevant documents from the EU region.
> 

> For the first point, I guess you are referring to https://www.easa.europa.eu/document-library/notices-of-proposed-amendment/npa-2021-14. Right?
> 

> If you can share more specific comments, this will help the WG and authors assess them.
> 

> BTW, you may subscribe to the list because otherwise your messages will be delayed till a moderator validates them.
> 

> Cheers,
> 

> Med
> 

> De : Tm-rid <[e-mail]> De la part de Jens Finkhaeuser
> 

> Envoyé : jeudi 24 mars 2022 10:46
> 

> À : [e-mail]
> 

> Objet : [Drip] Comment on -arch-22
> 

> Hi all,
> 

> since I am active through my employer in European drone research (ADACORSA and COMP4DRONES projects to name just two), and our speciality here is communications which relates to identification, I read the draft with some interest. I fear a full analysis and review would require more effort than I have managed to put into it.
> 

> However, as a comment, it appears that the draft is very strongly related to ASTM F3411, and maybe more so than immediately apparent. I wonder how intentional that is?
> 

> I ask for two reasons:
> 

> 1.  The EASA regulation referenced is not the most relevant, and potentially a bit out of date; consequently, it is unclear how well this proposal will work as-is in European airspace.
> 2.  The assumptions made on communications technologies seem to exclude some drone categories and use cases (which admittedly are also a source of disagreement between some of our research partners).
> 

> I'd be happy to bring more perspectives to this, but I am not sure this is appropriate to the draft's intent.
> 

> Jens
> 

> _________________________________________________________________________________________________________________________
> 

> Ce message et ses pieces jointes peuvent contenir des informations confidentielles ou privilegiees et ne doivent donc
> pas etre diffuses, exploites ou copies sans autorisation. Si vous avez recu ce message par erreur, veuillez le signaler
> a l'expediteur et le detruire ainsi que les pieces jointes. Les messages electroniques etant susceptibles d'alteration,
> Orange decline toute responsabilite si ce message a ete altere, deforme ou falsifie. Merci.
> 

> This message and its attachments may contain confidential or privileged information that may be protected by law;
> they should not be distributed, used or copied without authorisation.
> If you have received this email in error, please notify the sender and delete this message and its attachments.
> As emails may be altered, Orange is not liable for messages that have been modified, changed or falsified.
> Thank you.