Summary of FAA’s Proposal for Remote Identification of UAS
The notice of proposed rulemaking (NPRM) released on December 26, 2019 suggests three options for compliance with remote identification. The full 319-page rule can be downloaded and read here.
- Standard Remote ID: This is how many UAS that are not model aircraft would comply with remote ID. The proposed requirement is for UAS to broadcast identification and location information directly from the aircraft and simultaneously transmit that same information to a Remote ID UAS service provider through an internet connection. This would be done through equipage on the UAS.
- Limited Remote ID: This is another option to comply with remote ID for UAS flying no more than 400 feet from the control station and within visual line of sight. The proposed requirement is for UAS to transmit information through the internet only, with no broadcast requirements. This would be done through equipage on the UAS.
- FAA-Recognized Identification Areas: This is how many traditional model aircraft will comply with remote ID. This does not require any equipage on the model aircraft. Under the proposal, models (and other UAS manufactured before the compliance date) would be permitted to fly at certain specific geographic areas established under this rule specifically to accommodate them. These locations would need to be submitted to the FAA for approval and renewed every four years.
In addition, to these three remote ID compliance options, the FAA has proposed to revise the existing UAS registration requirements to require all owners of unmanned aircraft to register each unmanned aircraft individually. Furthermore, the owners of standard or limited remote identification unmanned aircraft would have to provide the serial number of all unmanned aircraft registered. The serial number would establish the unique identity of the unmanned aircraft.
Detailed Summary of Major Provisions
(page 21 of the NPRM)
| ISSUE | PROPOSED REQUIREMENT |
| Registration Requirements | |
| Individual registration of
unmanned aircraft and conforming changes |
Requires the individual registration of all unmanned aircraft registered
under part 48.
|
| Requires each unmanned aircraft to be registered under a unique registration number. Eliminates existing option to allow multiple recreational unmanned aircraft to register under a single registration number. | |
| Serial numbers for
unmanned aircraft |
The unmanned aircraft serial number provided as part of an application for aircraft registration for a standard remote identification or limited remote identification unmanned aircraft would be the serial number issued by the manufacturer in accordance with the requirements of part 89.
|
| The owner of a small unmanned aircraft would have to include the manufacturer and model name of the unmanned aircraft during the registration or registration renewal process, and for any standard or
limited remote identification unmanned aircraft, the serial number issued by the manufacturer.
|
|
| Adds clarifying language for existing registration requirements for part
107 operators.
|
|
| Telephone number(s) for
applicant for registration
|
Requires telephone number(s) of applicant at time of registration. |
| Operating Requirements | |
| Applicability of operating
requirements |
The remote identification operating requirements would apply to: (1)
persons operating unmanned aircraft registered or required to be registered under parts 47 or 48; and (2) persons operating foreign civil unmanned aircraft in the United States.
|
| Remote identification
requirements generally |
No person would be allowed to operate a UAS within the airspace of the United States unless the operation is conducted under one of the following: (1) the UAS is a standard remote identification UAS and that person complies with the requirements of § 89.110; (2) the UAS is a limited remote identification UAS and that person complies with the requirements of § 89.115; or (3) the UAS does not have remote identification equipment and that person complies with the requirements of § 89.120.
|
| Standard remote
identification UAS |
Remote identification:
If the internet is available at takeoff, the UAS would have to do the following from takeoff to landing: (1) connect to the internet and transmit the required remote identification message elements through that internet connection to a Remote ID USS; and (2) broadcast the message elements directly from the unmanned aircraft.
If the internet is unavailable at takeoff, or if during the flight, the unmanned aircraft can no longer transmit through an internet connection to a Remote ID USS, the UAS would have to broadcast the message elements directly from the unmanned aircraft from takeoff to landing.
|
| In-flight loss of broadcast capability:
A person manipulating the flight controls of a standard remote identification UAS that can no longer broadcast the message elements would have to land as soon as practicable.
|
|
| Operation of standard remote identification UAS:
A person would be allowed to operate a standard remote identification UAS only if it meets the following requirements: (1) its serial number is listed on an FAA-accepted declaration of compliance; (2) its remote identification equipment is functional and complies with the requirements of proposed part 89 from takeoff to landing; and (3) its remote dentification equipment and functionality have not been disabled.
|
|
| Limited remote
identification UAS |
Remote identification:
The UAS would have to do the following from takeoff to landing: (1) connect to the internet and transmit the required remote identification message elements through that internet connection to a Remote ID USS; and (2) be operated within visual line of sight.
|
| In-flight loss of remote identification:
A person manipulating the flight controls of a limited remote identification UAS would have to land as soon as practicable when it cannot transmit the message elements through an internet connection to a Remote ID USS.
|
|
| Operation of limited remote identification UAS:
A person would be allowed to operate a limited remote identification UAS only if it meets the following requirements: (1) its serial number is listed on an FAA-accepted declaration of compliance; (2) its remote identification equipment is functional and complies with the requirements of proposed part 89 from takeoff to landing; and (3) its remote identification equipment and functionality have not been disabled.
|
|
| UAS without remote
identification |
The limited number of UAS that do not have remote identification equipment would be allowed to operate within visual line of sight and within an FAA-recognized identification area.
With authorization from the Administrator, a person may operate a UAS that does not have remote identification for the purpose of aeronautical research or to show compliance with regulations.
|
| FAA-recognized identification areas | |
| Applicability | Prescribes procedural requirements to establish an FAA-recognized identification area.
|
| Eligibility | Only a community based organization (CBO) recognized by the Administrator would be allowed to apply for the establishment of an FAA-recognized identification area.
|
| Requests for establishment | Application:
A CBO requesting establishment of an FAA-recognized identification area would have to submit an application within 12 calendar months from the effective date of the final rule. The FAA will not consider any applications submitted after that date.
|
| Required documentation:
A request for establishment of an FAA-recognized identification area would have to contain the following information: · Name of the CBO making the request. · Declaration that the person making the request has the authority to act on behalf of the CBO. · Name and contact information, including telephone number(s), of the primary point of contact for communications with the FAA. · Physical address of the proposed FAA-recognized identification area. · Latitude and longitude coordinates delineating the geographic boundaries of the proposed FAA-recognized identification area. · If applicable, a copy of any existing letter of agreement regarding the flying site.
|
|
| Approval of an FAA-recognized identification area:
FAA would approve or deny applications for FAA-recognized identification areas, and may take into consideration matters including but not limited to: the effects on existing or contemplated airspace capacity, critical infrastructure, existing or proposed manmade objects, natural objects, or the existing use of the land, within or close to the proposed FAA-recognized identification area; the safe and efficient use of airspace by other aircraft; and the safety and security of persons or property on the ground.
|
|
| Amendment:
Any change to the information submitted in the application for establishment of an FAA-recognized identification area would have to be submitted to the FAA within ten calendar days of the change. Such information includes, but would not be limited to, a change to the point of contact for the FAA-recognized identification area, or a change to the community based organization’s affiliation with the FAA- recognized identification area.
If the community based organization wishes to change the geographic boundaries of the FAA-recognized identification area, the organization must submit the request to the FAA for review. The geographic boundaries of the FAA-recognized identification area will not change until they have been approved or denied in accordance with § 89.215.
|
|
| Duration of an FAA-recognized identification area:
An FAA-recognized identification area would be in effect for 48 calendar months after the date the FAA approves the request for establishment of an FAA-recognized identification area.
|
|
| Renewal:
A request for renewal would have to be submitted no later than 120 days prior to the expiration of the FAA-recognized identification area in a form and manner acceptable to the Administrator. The Administrator may deny requests submitted after that deadline or requests submitted after the expiration of the FAA-recognized identification area.
|
|
| Expiration and termination | Expiration:
Unless renewed, an FAA-recognized identification area would be automatically cancelled and have no further force or effect as of the day immediately after its expiration date.
|
| Termination prior to expiration (by request):
A CBO may submit a request to the Administrator to terminate an FAA-recognized identification area. Once an FAA-recognized identification area is terminated, that CBO may not reapply to have that flying site established as an FAA-recognized identification area.
|
|
| Termination by FAA:
FAA would be able to terminate an FAA-recognized identification area for cause or upon a finding that the FAA-recognized identification area could pose a risk to aviation safety, public safety, or national security or that the person who submitted a request for establishment of an FAA-recognized identification area provided false or misleading information during the submission process.
Once an FAA-recognized identification area is terminated, that CBO may not reapply to have that flying site reestablished as an FAA recognized identification area.
|
|
| Petition to reconsider the FAA’s decision to terminate an FAA recognized identification area:
A CBO whose FAA-recognized identification area has been terminated by the FAA would be able to petition for reconsideration by submitting a request for reconsideration and establishing the grounds for such reconsideration within 30 calendar days of the date of issuance of the termination. |
|