The FAA published the long-anticipated Remote ID rulemaking on December 31 (Yay! Happy New Year!), and you have until March 02, 2020 to provide your feedback to the FAA. In the first few days, 1000s of comments were posted on the document from concerned or happy citizens.
If you want the FAA to hear your opinions, you need to submit your comments on specific sections using one of the following methods:
In-Person:
Hand Delivery or Courier:
Room W12-140 1200 New Jersey Avenue, SE, Washington, DC
Mail:
1200 New Jersey Avenue, SE, Room W12-140, West
Building Ground Floor, Washington, DC 20590-0001
Fax:
Comments to Docket Operations at 202-493-2251
Online:
http://www.regulations.gov
If you want to be laden by reading all 319 pages, it’s available at https://www.federalregister.gov/documents/2019/12/31/2019-28100/remote-identification-of-unmanned-aircraft-systems or you can check out my summary below.
The reason for this post is to help people that want to be heard but don't have the time to read and find the comments sections in the 319-page document. Then mail, fax, email, or hand-deliver comments to submit their feedback.
Airsight has created the form below to collect your feedback on questions asked by the FAA. All responses will be collected and sent to the FAA regardless of view.
We would love to see participation from the old school hobbyist, commercial 107 pilots, Law Enforcement, Airport officials, corporate security, educational institutions, UTM providers, LAANC providers, cUAS companies, and of course, manufacturers.
FAA Remote ID Rulemaking Summary:
Key Points:
- It’s going to be at least 3 years minimum before this goes into effect. I estimate it will take at least 4 years to implement fully.
- This is a big deal and pretty much universal. Unless you are flying a WiFi toy drone (which can't fly more than 400ft away from the controller), you have to comply.
- FAA says: Think of the big picture. The rulemaking will be the building blocks for UTM.
All Drones weighing more than 0.55lbs must comply with Standard or limited Remote ID.
Standard Remote ID will include most drones ( those that can fly beyond 400ft.) Drones will have to connect to the internet before take-off, whether by a SIM card on the drone or through a connected phone/tablet that is running the drone app, and transmit certain required information through a broker (USS provider) to the FAA. Also, the drone will need to be equipped with the ability to locally broadcast the required information as a backup to cellular.
Limited Remote ID will include drones that cannot fly beyond 400ft. All the standard remote ID requirements with one exception that no local broadcasting is needed.
FAA-Recognized Identification Area (FRIA): These are community-based organizations and areas recognized by the FAA. Drones that are not otherwise compliant with the first two Remote ID standards would be able to fly in these limited sites.
Other Takeaways:
- You have to register your drone with the FAA and provide personal information.
- Local broadcast will most likely be open to the public, but only law enforcement will have access to your personal information.
- Similar to LAANC, Private companies (they are looking to start with 9) will be USS service providers and will act as a broker to the FAA for a possible fee.
- There is a legal loophole that allows someone to purchase a drone kit that is 99.9% ready; the assembled drones will not comply with remote ID.
- The FAA completely scratched out the use of ADB-S due to congestion.
The FAA is seeking comments until March 02. 2020
Below are the questions that the FAA reached out to public and stakeholders for direction and feedback.
Minimum performance requirements for remote ID
What information should the drone transmit via network or broadcast?
Minimum performance requirements for remote ID are:
- Control station location
- Automatic connection to a Remote ID USS
- Time mark
- Self-testing and monitoring
- Tamper resistance
- Connectivity
- Error correction
- Interference considerations
- Message transmission
- Interoperability
- Message elements performance requirements
Features not proposed by the FAA but the FAA requests comments on whether and why any should be required.
- UAS operator contact information or other aircraft or control station information such as velocity, direction, route, or altitude above ground level Equipment interface requirements such as the appropriate connections between GPS receivers, altimeters, and the remote identification message compiler, the communication protocol between the aircraft and the control station through which remote identification message data is exchanged, or protocols and interfaces between UAS, internet providers, and Remote ID USS.
- Flight data recording features to store remote identification information within the UAS.
- Requirements for connection indications such as a separate indication of whether the UAS is connected to the internet and its connection to a specific Remote ID USS, an indication of the transmission latency, or a notification of the specific Remote ID USS to which the UAS is connected; or Transmission or broadcast requirements during a command and control lost-link event.
- The FAA requests comments on whether six months should be the period for retention of the remote identification message elements by Remote ID USS.
- The FAA requests comments regarding whether both barometric pressure altitude and geometric altitude of the control station should be part of the remote identification message elements.
Balance between Hobbyist, freedom and safety
- The FAA requests comments about whether persons should be allowed to produce kits for sale that contain 100 percent of the parts and the instructions for assembly necessary to build a fully functioning UAS without remote identification capability. Once assembled, such UAS without remote identification would be required to either have the unmanned aircraft weigh less than 0.55 pounds or operate only within an FAA-recognized identification area.
Questions Directed to UAS Manufacturers
- The FAA requests comments regarding appropriate time intervals for conducting independent audits, including any time intervals specified in industry standards related to independent audits of aviation systems.
- The FAA requests comment on whether manufacturers should be permitted to produce UAS that are only compatible with a particular Remote ID USS.
- The FAA requests comments on the capability of retrofits to meet the proposed remote identification requirements. Specifically, the FAA requests information and data from producers of affected UAS in response to the following questions that can be used to inform this analysis.
- At this time, the two-year producer compliance period appears reasonable and has a technical basis. The FAA has not identified or analyzed an alternative. The current proposal does not preclude earlier producer compliance (potential economic incentive to comply earlier). The FAA requests comments on alternative compliance periods that would minimize costs for small producers.
Assumptions & Cost:
The FAA estimates it will conduct 2,002 investigations of UAS incidents annually for each year of the analysis period and that each investigation will range between 1 and 40 hours. The FAA requests comments, with supporting documentation, on these assumptions.
- The annualized costs are about $16 million at a three percent and seven percent discount rate. The FAA provides a sensitivity analysis of these costs based on a range of trips per year in the Regulatory Impact Analysis report available in the docket. The FAA requests comments on the costs and frequency of additional travel to FAA Recognized identification areas for recreational flyers affected by this provision.
Technical:
- The FAA understands, however, that there are concerns about the impact that connecting to the internet directly from the unmanned aircraft (as opposed to the control station) could have on networks that use radio frequency spectrum, including interference, network stability, or other effects. The FAA seeks comments on these potential effects, recognizing that issues of interference or other impacts to communications networks are independently reviewed by the FCC. The FAA requests that comments indicate any drawbacks or impacts to users or license holders of either licensed or unlicensed spectrum.
- FAA seeks feedback regarding whether any existing UAS are capable of connecting to the internet from the unmanned aircraft, and if so, what methods are used for those connections
If these issues resonate with you, I hope you’ll take a minute to fill out our simple form and share your feedback with the FAA.