The key takeaways from the FAA’s proposed USD582 million remote UAS ID regulation

The U.S. Department of Transportation’s Federal Aviation Administration (FAA) today announced a proposed rule that would continue the safe integration of Unmanned Aircraft Systems (UAS), commonly called drones, into the nation’s airspace by requiring them to be identifiable remotely. The FAA will seek input on the Notice of Proposed Rulemaking (NPRM) for Remote Identification (Remote ID) of UAS that today was placed on display at the Federal Register.  In the coming days, it will be accompanied by a 60-day comment period to receive public feedback and help the FAA develop a final rule to enhance safety in the skies over the U.S.

The long awaited 319 page report contains a number of key elements – some of which are surprising. These include the early identification of potentially nine UTM service suppliers in the first year of operation, the opportunity for non-industry standards groups to develop protocols for the communication and sharing of remote ID drone data and a firm “no” for using ADS-B as potential remote UAS communications technology. These are some of the highlights of the proposed legislation:

The general service

  • The FAA is proposing that three years following the effective date of a final rule, standard remote identification UAS and limited remote identification UAS would be required to transmit remote identification messages through the internet to a Remote ID USS. In addition, standard remote identification UAS would also be required to broadcast the same message elements directly from the unmanned aircraft.
  • The FAA is proposing to tie the remote identification requirements to the registration of unmanned aircraft because the FAA and law enforcement agencies need the ability to correlate remote identification information with registration data to obtain more complete information regarding the ownership of unmanned aircraft flying in the airspace of the United States

Costs and charges

  • The FAA anticipates that UAS operators would subscribe to a Remote ID USS and then connect to the internet using their existing internet service provider. Based on the LAANC USS business model, the subscription to a Remote ID USS may range in cost from $0 to $5 per month, per operator, for a midpoint of $2.50 per month.
  • This analysis provides a range of net impacts from low to high based on these forecast scenarios. For the primary estimate, over a 10-year period of analysis this proposed rule would result in net present value costs of about $582 million at a three percent discount rate with annualized net costs of about $68 million.
  • The present value cost of subscriptions to affected UAS operators totals $242 million at a three percent discount rate and $192 million at a seven percent discount rate.

Standards for sharing data

  • A UAS remote identification standard that could be one potential means of compliance to the proposed rule is currently being developed by ASTM International… The FAA recognizes that consensus standards are one way, but not the sole means, to show compliance with the performance requirements of the proposed part 89. The FAA emphasizes that, although a means of compliance developed by a consensus standards body (e.g., ASTM International (ASTM), Society of Automotive Engineers (SAE), Consumer Technology Association (CTA), etc.) may be available, any individual or organization would also be able to submit its own means of compliance to the Administrator for consideration and potential acceptance.

What’s in the remote ID communications?

  • The FAA is proposing to require all UAS with remote identification to broadcast or transmit the appropriate remote identification message elements from takeoff to landing…These message elements would include: the UAS Identification (either the unmanned aircraft’s serial number or session ID); latitude, longitude, and barometric pressure altitude of both the control station and the unmanned aircraft; a time mark; and an emergency status code that would broadcast and transmit only when applicable.
  • A standard remote identification UAS that loses connection to the internet or that can no longer transmit to a Remote ID USS after takeoff would be able to continue its flight, as long as it continues broadcasting the message elements

The UTM service suppliers

  • A network of Remote ID UAS Service Suppliers (Remote ID USS) that would collect the identification and location in real-time from in-flight UAS. The Remote ID USS would perform this service under contract with the FAA, based on the same model the FAA currently uses for the Low Altitude Authorization and Notification Capability (LAANC)…. The FAA estimates that ten entities will request to become Remote ID USS and nine of the entities will be approved by the FAA by the end of year 1 in the analysis period. For each of the nine remaining years of the analysis period, the FAA assumes one additional entity will request to become a Remote ID USS annually which will then be approved by the FAA.
  • Remote ID USS would be required to demonstrate four primary capabilities: (1) the ability to share the remote identification message elements in near real-time with the FAA upon request; (2) the ability to maintain remote identification information securely and to limit access to such information; (3) the ability to meet contractually-established technical parameters; and (4) the ability to inform the FAA when their services are active and inactive. Another capability of a Remote ID USS may be to generate and provide UAS operators with a UAS Identification known as a session ID. A session ID would be a randomly-generated alphanumeric code that is used only for one flight.

A “no” to ADS-B

  • The FAA is concerned that the potential proliferation of ADS-B Out transmitters on UAS may negatively affect the safe operation of manned aircraft in the airspace of the United States. The projected numbers of UAS operations have the potential to saturate available ADS-B frequencies, affecting ADS-B capabilities for manned aircraft and potentially blinding ADS-B ground receivers. The FAA is therefore proposing that UAS operators, with limited exceptions, be prohibited from using ADS-B Out or transponders.

The FAA has taken a number of divergent from the  Unmanned Aircraft Systems (UAS) Identification (ID) and Tracking Aviation Rulemaking Committee (ARC) (UAS-ID ARC) set up in 2017 to inform the FAA on technologies available for remote identification and tracking of UAS and to make recommendations for how remote identification and tracking could be implemented.

“After consideration, the FAA determined that the sensor capabilities of a particular UAS should not be a factor in determining whether the aircraft should have remote identification. UAS without sensor capabilities can still be operated in a manner that may pose a threat to public safety, national security, and the safety and efficiency of the airspace of the United States and therefore the FAA determined that this recommendation would not meet the objective of this proposed rule. Accordingly, the FAA is proposing that the majority of UAS should have remote identification, regardless of the sensors installed on the unmanned aircraft. However, the FAA acknowledges that remote identification is not necessary for certain UAS operations conducted in an FAA-recognized identification area.

“…The FAA does not agree with the recommendation that model aircraft, referred to throughout this proposal as limited recreational operations for consistency with 49 U.S.C. 44809, should be excluded from the remote identification requirements. Unmanned aircraft used in limited recreational operations required to register under part 47 or part 48 would be subject to the proposed remote identification requirement. The agency is, however, proposing a means for such aircraft to operate without remote identification equipment. Under the proposed rule, UAS would be permitted to operate without remote identification equipment if they are operated within visual line of sight and within an FAA-recognized identification area.”

The FAA will seek input on the Notice of Proposed Rulemaking (NPRM) for Remote Identification (Remote ID) of UAS that today was placed on display at the Federal Register.  In the coming days, it will be accompanied by a 60-day comment period to receive public feedback and help the FAA develop a final rule to enhance safety in the skies over the U.S.

(Image: FAA)

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