The FAA is moving to drastically change the rights and responsibilities of model aircraft pilots by enacting new rules. This may be one of the most important changes in the history of the hobby.
On December 31, 2019, the FAA published its proposed rule for Remote Identification of Unmanned Aircraft Systems in the Federal Register. This proposal outlines a system for drones to broadcast their location, the location of the operator, and other related information. Most drones will be required to adopt this system, and non-compliant aircraft will be significantly limited in their capabilities.
FAA Press Release: https://www.faa.gov/news/press_releases/news_story.cfm?newsId=24534
Joshua Bardwell’s Interview: https://www.youtube.com/watch?v=4E1aEym-1cQ
Pilot Institute: Remote ID Response Guide – How to Submit Your Comment to the FAA
The point of this article is not to be alarmist; remember that this is a proposal and not yet a rule. It is open to comment and can be altered and amended. This is a call to action, we, as a community, need to mount a strong response to ensure the FAA hears our voices. The time to act is now, before the end of February 2020.
This article relates only to the proposal from Dec 31, 2019. Readers finding this article after April 2020 should not use this information as reference for the final implemented Remote ID system.
What’s Remote ID?
As proposed, the Remote ID system records the position and identity of a drone in flight and its operator. This data may be broadcast from the drone in real-time, and is saved to a remote server for six months.
Unmanned aircraft fall into three categories: “Standard”, “Limited”, and “without Remote ID”.
Standard Remote ID
Standard-equipped drones communicate their location and their operator’s location continuously in flight. The drone broadcasts this information locally over a radio frequency. If internet is available, the information is also sent to a server. These drones have the least restrictions on what they are allowed to do.
Limited Remote ID
Limited drones require that the control station communicate its location continuously in flight. These must always communicate this information over the internet. They are never allowed to fly more than 400ft from the operator. Drones with Limited Remote ID are designed to automatically enforce the 400ft distance restriction and prevent the drone from taking off if internet is not available.
Without Remote ID
Drones fabricated non-commercially by an individual may be flown without Remote ID. To qualify, the majority of the drone must be fabricated by that person, not simply assembled from separately purchased parts. Drones without remote ID must only be flown at FAA-approved flying sites and never beyond visual line-of-sight.
The proposal applies to all drones that are required to be registered. Currently, drones are exempt if they are under 250g (.55lbs) and flown only for recreation. However, the requirements for registration could change in the future to include sub-250g craft.
How will Remote ID be implemented?
Other aspects of the proposal include:
- Operating drones with Remote ID will require a subscription to a data server. The FAA suggest this may cost $30/yr, but the servers will be privately owned and operated—the FAA will have no control over the actual cost.
- Each aircraft will need to be registered individually for $5. Currently a recreational pilot applies one registration to multiple drones; this would no longer be valid.
- Fixed flying sites may only be operated by a community-based organization (CBO) such as the AMA. Private citizens will not be able to register flying sites on their own.
- Fixed flying sites may only be registered for a period of 12 months after the rule goes into effect. Fixed sites must be renewed every 4 years, and the FAA may revoke a site for any reason.
A lot of the proposal lacks specifics, including the method used for collecting the operator’s location and the broadcast frequency and protocol for the messages. The FAA has intentionally left out other information, such as the cost of the remote database service. The FAA intends for 3rd parties to administer this service, similar to what is done now for LAANC.
What are some of the potential impacts of Remote ID to FPV?
As written, this proposal removes rights to almost all airspace for many existing aircraft.
Some of the effects of this proposal would be:
- Many new costs will be associated with flying. All pilots will pay the FAA for each individual aircraft. Pilots who fly craft without Remote ID will pay dues to a CBO and pay dues to a local chapter that operates a flying site. Pilots who fly with Remote ID will pay a data supplier for Remote ID capabilities, even if they never fly in an internet-connected area.
- RTF/ARF drones will be heavier. 5″ freestyle and race drones, (all of which exceed the 250g threshold,) must be Remote ID compliant and therefore carry position sensors and broadcast equipment.
- If a location has poor internet connectivity, “limited” drones will not be able to fly there. Pilots may be required to subscribe to a mobile data service to fly in many locations.
- FPV freestyle without Remote ID will be illegal except at approved flying sites (which are likely to be flat, open, AMA fields)
- Pilots who wish to fly craft without Remote ID will be required to become members of a community-based organization (CBO) which operates a local flying site. They will not be able to choose the CBO that best serves their needs.
- Only CBO-registered sites will be allowed, negating any sites set up and coordinated directly with local airports and air traffic control.
- No new fixed sites would ever be added. Eventually, approved flying sites may no longer be available.
Why is Remote ID necessary?
The FAA states that “The remote identification of UAS is necessary to ensure public safety and the safety and efficiency of the airspace of the United States.” The system facilitates “future, more advanced operational capabilities” such as those that allow drones to communicate with each other and with manned aircraft. This could allow drones to operate beyond visual line of sight and provide better information to air traffic controllers.
The FAA believes that enhancing safety, efficiency, and security with this system would serve the public interest. This system would provide data to national security and law enforcement agencies. The FAA states that real-time use of the data could be used to facilitate compliance, enforcement, and educational actions.
Model flying is a safe activity which does not pose significant risk to people or property. Unfortunately, it appears that decades of history were not enough to persuade the authors of the proposal.
Is this all overblown?
Remote ID could actually improve our ability to fly, possibly opening the door to operations beyond visual line of sight—and there is some hope that the FAA wants to make adoption easy. The proposal includes the line “Nothing in this proposal would prevent a person from building a UAS with remote identification for educational or recreational purposes.” Remote ID might not be a great burden to operators if all of the following are true:
- Small, lightweight, and inexpensive Remote ID equipment becomes available
- Remote ID broadcasts do not interfere with model control and video signals
- Hobbyists are compliant after installing Remote ID equipment into existing models
- At least one Remote ID server is available for free for non-commercial use
It’s important to understand, though, that there are no guarantees and a great many unknowns.
- Remote ID equipment does not yet have defined parameters such as broadcast protocols and frequencies.
- The FAA may make compliance difficult since it requires “tamper-resistance” and “inability to disable”, and the process for compliance is not defined in the proposal.
- Private, for-profit companies will administer the Remote ID servers. While LAANC can be accessed for free, Remote ID services might not.
The FAA is pushing hard for all unmanned craft to be Remote ID compliant. Since a great deal of recreational aircraft are fabricated or assembled for non-commercial purposes, recreational users must have a reasonable means to add it to their systems.
Even if the above all work out in our favor, the proposal requires that each aircraft be individually registered with a certificate of compliance filed. For collectors, the registration costs will add up quickly.
While some blogs and vloggers are providing and reacting to incomplete or inaccurate information, this proposal definitely has the potential to destroy recreational aircraft flight as we know it. It’s critically important to respond to the FAA on these matters.
What can we do about it?
The FAA invites comments on this proposal, which can be easily submitted online. The best thing we can each do is submit a reasonable comment.
To make a convincing response, you must be informed on the details of the proposal. It’s best to read the full text of the proposal. If not, the FPV Freedom Coalition has a FAQ page on Remote ID that breaks it down to essentials, and a longer-form Guide to Remote ID.
As you develop your comment, consider (comments below do not represent GetFPV’s view):
- Adding onerous requirements for recreational users will be catastrophic for the hobby. Compliance with regulations will substantially decline, and many users will simply leave the hobby. This will diminish or eliminate the positive effect in education and innovation that recreational modeling has provided for decades.
- A great deal of recreational aircraft are assembled non-commercially, since parts are selected for many purposes and various control systems are not cross-compatible. The FAA should not underestimate the prevalence of this practice in the model aircraft hobby. The number of model aircraft sold with 100% of the parts needed to fly is extremely limited and confined to a small number of manufacturers.
- The FAA must make adding Remote ID capability to self-built drones easy and straightforward. It is in the FAA’s interest to have more craft using Remote ID. A modeler that voluntarily adds the equipment to a craft has no incentive to tamper or disable it. Complicated compliance requirements to install Remote ID will prevent adoption and should be eliminated for non-commercially produced aircraft.
- The FAA should not cease to consider new fixed flying sites. The proposed system unfairly penalizes recreational pilots and favors commercial usage by allowing political and financial matters to determine the secession of airspace instead of items which actually affect the safety, security, and efficiency, and utility of the airspace.
- A Limited Remote ID craft currently requires an internet connection. This requirement eliminates their ability to be used in many locations with poor coverage, or by operators without expensive cellular data plans. The FAA should consider how limited aircraft could be operated in these areas covering a great deal of airspace.
- The current proposal requires that anyone trying to retrieve Remote ID data must both access the internet and have equipment capable of receiving a local broadcast, because some craft are capable of operating with only one or the other. This is not always possible. For example, the operator of a Limited Remote ID craft may use private, protected WiFi for internet in an area where mobile data is not available.
- Registration and usage of Remote ID servers (USS) for commercial purposes should be held to a different standard than non-commerical users. Hobbyists are unlikely to disrupt airspace in the same way as commercial use, and hobbyists are generally under a greater financial burden than commercial users. Commercial users will benefit most from the system and should bear the cost of maintaining it. The FAA should ensure that non-commercial registrations and use of USS server are available without incurring a fee.
- The economic impact of onerous requirements for modelers will cause a collapse in the model aircraft industry. This will impact pilots, but also many domestic companies that manufacture, sell, and/or repair model aircraft.
- Other countries have successfully implemented “shielded operations” Shielded operations is a common-sense proposal which allows unrestricted drone flights in locations that are unlikely to interfere with commercial operations or manned flight. The FAA should consider how a similar provision would provide modelers with usable low-risk airspace. See https://www.aviation.govt.nz/drones/your-drone-questions-answered/what-is-shielded-flight/ .
If you’re looking for more guidance, the AMA has published a template response, and the FPVFC has a working document with talking points and policy suggestions.
Submitting your comment
Be sure to write your own comment rather than copy and pasting a response you find somewhere. Duplicated responses may not carry as much weight.
Once you’ve written your response, visit the comment page for remote ID to submit it. You have until March 2, 2020.
The FAA is about to write some of the most influential rules about model aircraft in the United States. In these 60 days, we have the opportunity to directly contribute to that conversation. We must remind the FAA that we are responsible users of the airspace, that the airspace can be used safely in the future, and that recreational use is at least as valid as any commercial interest. The more of us that respectfully respond, the more seriously we will be taken. On behalf of all racers, freestyle pilots, and all model aircraft enthusiasts: please submit a comment on this proposal!
Every comment helps.