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The FAA recently passed rulemaking for the remote identification of Unmanned Aircraft (UA).
I’ve seen so much written about the new rules. Some say it is no big deal. Others say not to worry about it since it won’t go into effect right away.
But I’m going to do the deep dive for you and go through the 470 pages and see what the release documentation says about Remote ID and how it applies to us lowly public safety professional pilots.
I will not report on information related to hobbyists or recreational flight operations since we are professional commercial pilots in the public safety space.
The biggest shocker is that if you have an existing drone and decide to retrofit it with a Remote ID broadcast module, you will be limited to visual line of sight operations only.
Given this significant limitation, it would make sense for all departments to not purchase any UA right now until the release of an aircraft with integrated Remote ID is available or one of the Part 21 Airworthiness Certified aircraft is released.
The focus of the FAA effort is to improve airspace safety. The FAA says, “The remote identification of unmanned aircraft in the airspace of the United States will address safety, national security, and law enforcement concerns regarding the further integration of these aircraft into the airspace of the United States, laying a foundation for enabling greater operational capabilities.”
The FAA has had a decade’s long focus and mandate to keep the skies safe. They are an airspace regulatory agency, so thinking about Remote ID from a pilot only point of view would be the wrong approach. It would help if you thought about Remote ID first from a safety position.
The FAA position is stated clearly, “Remote identification provides airspace awareness to the FAA, national security agencies, law enforcement entities, and other government officials.”
Drones are not targeted more than other aircraft in the National Airspace System (NAS). Manned aircraft already have a requirement to broadcast identification information and can be tracked by radar. The Remote ID effort is bringing UAS into the FAA tracking environment. UAS are aircraft. The FAA tracks aircraft. The FAA will want to track drones more in the future.
The FAA tips their hand when they say, “Remote identification will become increasingly important as the number of unmanned aircraft operations increases in all classes of airspace in the United States.”
Remote ID Integration
The FAA anticipates Remote ID will become a built-in component in UA moving forward. But in the soft introduction of this new approach, the FAA sees three ways the Remote ID will be implemented.
- Through a standard remote identification unmanned aircraft that broadcasts identification, location, and performance information of the unmanned aircraft and control station.
- By operating an unmanned aircraft with a remote identification broadcast module. The broadcast module, which broadcasts identification, location, and takeoff information, may be a separate device that is attached to an unmanned aircraft, or a feature built into the aircraft.
- In a restricted FAA approved flight test area.
So there are two ways Remote ID will be integrated into public safety UA operations. You either need to purchase a new drone with an integrated Remote ID or attach a module, but that might lead to safety compliance issues if the FAA requires you to file for and obtain a Declaration of Compliance (DOC) for safe operation for the modification. See this post for more on the DOC issue.
The FAA believes, “a declaration of compliance is an essential part of the remote identification framework. An FAA-accepted declaration of compliance allows a person to produce standard remote identification unmanned aircraft or remote identification broadcast modules. It serves as an assurance that producers are using an FAA-accepted means of compliance for the production of the unmanned aircraft or broadcast module to meet the minimum performance requirements of this rule and are complying with all other design and production requirements.”
According to the FAA, no unmanned aircraft can be produced for operation in the United States’ airspace after September 16, 2022, and no drone can be operated in the airspace of the United States after September 16, 2023, that does not comply with the Remote ID rule.
Remote ID Modules Added to Existing Aircraft Will Significantly Restricted
Buried deep in the rulemaking document is this statement, “the FAA has determined that persons manipulating the flight controls of UAS where the unmanned aircraft is equipped with remote identification broadcast modules must be able to see the unmanned aircraft at all times throughout the operation.”
It appears if you are counting on being able to add a broadcast aftermarket module to your existing aircraft, you will be limited to VLOS operation only. Only new aircraft manufactured with an integrated Remote ID capability or that have to obtain airworthiness certification under Part 21 will be eligible for flight operations beyond visual line of sight.
Standard Remote Identification Drones
To comply with the Remote ID requirements, the drone must send the following information data points directly from the drone and not through any control unit or other external method.
- a unique identifier to establish the identity of the unmanned aircraft;
- an indication of the unmanned aircraft latitude, longitude, geometric altitude, and velocity;
- an indication of the control station latitude, longitude, and geometric altitude;
- velocity was included as well;
- a time mark; and
- an emergency status indication.
The broadcast will be via a non-proprietary messaging format that will be received and read by all. Data will be sent at least once per second. The range of the broadcast will be dependent on “signal strength limitations for unlicensed devices.”
You can choose to use the serial number of the aircraft or an alternative ID to provide additional privacy. However, that alternative number must be registered with the FAA and matched to your aircraft serial number so authorized entities and law enforcement can identify you.
Before you can add a module or purchase an integrated Remote ID drone you must have an accepted DOC on file with the FAA that:
- Lists the actual serial number
- Complies with all of the broadcast requirements from takeoff to shutdown
- The Remote ID must not be disabled
- The Certificate of Aircraft Registration used in the operation must include the serial number of the aircraft.
Developers of Remote ID modules will have to make sure their product “meets the requirements of an FAA-accepted means of compliance. A means of compliance describes the methods by which the person complies with the performance-based requirements for remote identification.”
You might think that would make it easy to comply but the FAA says, “the FAA must accept that means of compliance before it can be used for the design or production of any standard remote identification unmanned aircraft or remote identification broadcast module. A person seeking acceptance by the FAA of a means of compliance for standard remote identification unmanned aircraft or remote identification broadcast modules is required to submit the means of compliance to the FAA. The FAA reviews the means of compliance to determine if it meets the minimum performance requirements and includes appropriate testing and validation procedures in accordance with the rule. Specifically, the person must submit a detailed description of the means of compliance, a justification for how the means of compliance meets the minimum performance requirements of the rule, and any substantiating material the person wishes the FAA to consider as part of the application. ”
Delays in compliance approval will occur. The FAA states, “A means of compliance is not considered to be “FAA-accepted” until the means of compliance has been evaluated by the FAA, the submitter has been notified of acceptance, and the means of compliance has been published at https://www.faa.gov as available for use in meeting the requirements of part 89.”
Manufacturers of Remote ID modules are required to:
- Issue each unmanned aircraft or remote identification broadcast module a serial number that complies with the ANSI/CTA-2063-A serial number standard.
- Label the unmanned aircraft or remote identification broadcast module to indicate that it is remote identification compliant.
- Submit a declaration of compliance for acceptance by the FAA, declaring that the standard remote identification unmanned aircraft or remote identification broadcast module complies with the requirements of the rule.
No Network Requirement In This Version
Some of the pushback from pilots surrounded the issue of having to transmit the required Remote ID broadcast information via cellular technology or the internet.
While the requirement was removed from this version of the Remote ID rule, you should anticipate that it will become a requirement in future updates.
The FAA says, “The complexities surrounding the full integration of UAS into the airspace of the United States have led the FAA to engage in a phased, incremental, and risk-based approach to rulemaking based on the statutory authorities delegated to the Agency.” Ultimately, the FAA works to achieve data domination of airspace movements. Or as the FAA says, “The requirements for the identification of manned and unmanned aircraft form an integral part of the FAA’s regulatory framework.”
This additional statement seems to be pretty clear to expect changes in the elimination of network transmission of Remote ID in the future.
The rulemaking says, “Though the FAA recognizes that there are potential benefits associated with establishing a network of Remote ID USS, the FAA believes that, for the time being and given the types of unmanned aircraft operations that are currently allowed, the broadcast remote identification solution fulfills agency and law enforcement needs to maintain the safety and security of the airspace of the United States.”
And this should convince you that network-based Remote ID is absolutely coming, “The FAA continues to work toward full integration of UAS into the airspace of the United States by partnering with industry to develop UTM and facilitate advanced unmanned aircraft operations, like BVLOS. However, the FAA has determined that a broadcast-based remote identification system that provides for immediate awareness of unmanned aircraft in the widest variety of settings will be adequate to support the phased, incremental approach, while allowing the UAS industry additional time to continue developing the network-based UTM ecosystem.”
The Remote ID requirements apply to both Part 107 and COA flight operations. Public aircraft operations are not automatically exempted from registration requirements. The FAA also says, “therefore, unmanned aircraft operations conducted by such government entities must comply with the operating requirements of this rule. Nevertheless, any covered government entity that wishes to use an unmanned aircraft without remote identification at a location other than FAA- recognized identification areas may request authorization from the Administrator under § 89.105 to deviate from the operating requirements or under § 89.120 to conduct aeronautical research or to show compliance with regulations.”
Failure of the Remote ID Capabilities
Unmanned aircraft with integrated broadcast Remote ID must be able to perform a self-test and prevent takeoff if the test fails.
For any aircraft retrofit with a broadcast module, takeoff will not be allowed if the module does not pass a satisfactory self-test.
After takeoff and up to the moment of the shutdown, both the integrated and modules solutions must “continuously monitor their performance while in use and provide an indication if the remote identification equipment is not functioning properly. If the remote identification equipment provides an indication of failure or malfunction during flight, the unmanned aircraft operator must land the unmanned aircraft as soon as practicable.”
“When determining how and when to land the unmanned aircraft as soon as practicable, the FAA expects the person manipulating the flight controls of the UAS to operate in a manner that minimizes risk to other users of the airspace and people and property on the ground, while using aeronautical decision making to quickly and safely land the unmanned aircraft at a suitable landing area. The FAA recommends including UAS remote identification contingency planning, including plans for landing as soon as practicable, as part of a pre-flight assessment.”
Public safety operations will not get a free pass from this requirement. The FAA says, “While there may be some operations, such as emergency or disaster response, where continued unmanned aircraft operations, even in the presence of a broadcast equipment failure, may provide significant societal benefit, the FAA does not find that any particular activity warrants a specifically stated exception in the regulation from the requirement to land as soon as practicable. Instead, authorizations may be granted on a case-by-case basis if there is sufficient justification and an acceptable level of safety.”
Feel free to refer to the rulemaking document for additional information.