How FAA's New Remote ID Proposal Will Endanger the Drone Pilot's Safety and End Up Hurting the Drone Industry As a Whole

FAA Proposes Remote ID..By Vic Moss

I’m going to start this article with a qualifier: “I am pro UAS Remote ID”.

I was incredibly excited to have the ability to comment on the proposed NPRM, even if it was already 29 months late.

And oh, how I wanted this NPRM to be good. I wanted it to be something the industry can have tweaked and we can get pushed out post haste. I wanted to have the industry fall in line behind this NPRM and tell the FAA, “Let’s get this done and open up the skies!”

It’s not, it won’t be, and we won’t. Period.

As the NPRM is written, the FAA should just shoot this horse before the gate even opens. This race is over before the starter even fires his starting gun. We can’t even get past the first page of the Executive Summary without realizing that a key component to the success of Remote ID ain’t gonna happen.

The NPRM states that full implementation of Remote ID (RID) relies on “three interdependent parts”. First is the proposed rule itself. The second is a network or RID service suppliers (RID USS), similar to how LAANC works today. The third is the “collection of technical requirements that standards-setting organizations will develop to meet the performance-based design and production requirements in this proposed rule”.

They forgot about a fourth interdependent part, and one that is crucial to the success of the Remote Identification system. That fourth (and argumentatively the most important) aspect of RID is compliance. Low compliance, or even less than very high compliance, will destroy the concept and success of Remote ID.

How to Comply with FAA’s New Remote Identification Rule

The summary states there are three methods of being in compliance with RID.

Option 1 states the drone simultaneously transmits ID message via radio frequency (pretty much all ready to fly drones do this already), as well as via internet. The big issue here is that in order to transmit via internet we would require a data plan that would be very expensive for many operators. In addition, we would have to pay a subscription fee to use the Remote ID USS.

This creates additional monetary burdens to businesses, manufacturers, and imposes new burdens on hobbyists. Although it does allow for flight without RID method by using a “session”, as of now, I can’t see a method of maintaining and supplying that session info.

Option 2 allow drones to operate on a “limited remote ID UAS” basis. But that limits to flight to 400’ from operator (FAA uses the term ground station). 400’ is nothing. We can’t do our job if we can’t fly more than 400’. We ruin the operational efficiency that drones provide to other industries. And why 400’? Who came up with that number? Did someone just draw a column with a 400’ ceiling and radius and call it good? That’s a ridiculous limitation. If you have 20/20 vision, with a 400mm cross section, you can essentially see the drone until about 2200-2400 feet away.

Option 3 is for drones without RID equipment within the boundaries of an “FAA-recognized identification area” or (FRIA). While this is certainly a viable option for clubs like AMA fields (and undoubtedly this option’s targeted audience along with FPV racers), it’s completely unworkable for the commercial world, and/or hobbyists wanting to fly around a park or in their neighborhoods.

How FAA’s New Remote ID Proposal Could Seriously Threaten the Drone Pilot’s Safety

So, right off the bat, there are serious problems for many inside the commercial and recreational UAS communities.

The major issue that would create very limited compliance is that options 1 and 2 require “Latitude/longitude and altitude of the control station [operator] and UA” be transmitted at all times, and to the public.

I don’t know about other operators, but I DO NOT want my location transmitted over public airways.

Actually I do know about other operators too, this is not an option for many of us at all. The technical wording is “message”. That the “message” (as written) requires “UAS ID (serial number of UAS or session ID); Latitude/longitude and altitude of the control station; and Time stamp.”

There is no problem with people knowing where my VO and I are flying and for them to see aircraft location. We even wear our orange or green Hi-Vis vests. If there is a problem, I want people to find me and ask questions. These interactions almost always end in education for me, but that's not always the case in other location. The problem with being able to find my location via an RID system is that people who have no business needing to know where I am will be able to easily find me.

We all know of people who have been threatened, or we have been part of a thread where people threaten to shoot us down. We also know that the majority of the time we’re dealing with those who are just blowing smoke and being keyboard warriors. But we also all know that there are those out there that are just unstable or paranoid enough to have a system that will “sniff” for drones and take action. We see it daily in the drone groups. People fear the unknown.

If we must transmit our location, that information should only be made available to law enforcement. Period.

This sentence, on page 171 of the NPRM, scares the living daylights out of me as well: “Remote ID USS would be required to provide to the public, for no cost, the UAS Identification message element, either the UAS serial number or session ID.” Remember, as currently written, that includes operator location. Which means if you fly some areas at the same time every month, like we do occasionally, if someone doesn’t like the fact that you’re flying over their home every month, they can be waiting for you the next time you’re there. The sentence quoted above in the NPRM is followed by this one: “At this time, the FAA does not intend to make registration data held under 14 CFR part 48 available to Remote ID USS or the general public.”

“At this time” should put a chill down anyone’s spine. “At this time” means it may happen at a different time in the future. And what is part of our registration? Our addresses. Let that sink in.

And This is How Much It Will Cost The Drone Pilot To Access the New Remote ID Infrastructure

Let’s talk cost for a bit.

The FAA estimates that it would cost around $2.50 per month for a RID USS subscription. There will be the additional cost of data plans for Option 1 flights. Remember, unless you do not have internet available (Wi-Fi counts as internet), you must broadcast your “message” in real time during your flight.

So now drone companies paying private contracts to aggregate our data, then resell it. Absolutely not. The Government already made this mistake with Facebook.

That means a data plan. And a healthy one. Someone flying multiple times a week, and/or for hours per day, this would become financially burdensome. Someone flying large tracts for mapping or inspections will be racking up some serious data charges to AT&T, or Verizon, or any number of other carriers. And you’ll need to keep up with the latest technology to stay up to speed with your plan. While unlimited data is always an option, a quick check on my AT&T plan shows that would cost me an additional $60/month.

How Manufactured Perceptions are Hurting the Drone Industry

Where does the justification come from for some of this nonsense? Gatwick. No, really.

Page 197 talks about “Benefit Summary” of the Remote ID system. We can all come up with legitimate justifications for why we need RID in this country. That’s not really all that hard to come up with some benefits and cost savings that are obvious for RID. But the first thing talked about in the Benefit Summary is the disruptions at airports caused by drones. And the FAA uses the Gatwick incident at an example. One that is widely disputed by even airport authorities. They go on to mention numerous incidents, none of which are verifiable.

And further in that section the NPRM states: “over 200 unmanned aircraft were detected in the no-fly-zone of the 2018 Albuquerque International Balloon Fiesta”. A quick search shows DJI’s own numbers are much less than that. Less than 25% of that total. To DJI’s credit, they quickly posted their own numbers debunking the over inflated numbers published by Aerial Armor. DJI confirmed 40 flights. Aerial Armor had inflated those numbers to 458 in a now deleted tweet.

But obviously the damage to the industry was done and those numbers persist, even though they are false.

Why do the government agencies tasked with protecting our airspace (not just the FAA) purposely inflate numbers or use unconfirmed scare tactics in an NPRM for such an important piece of airspace safety like Remote ID? We’re not children, give us facts. Most of us agree with you on the necessity of Remote ID.

Conclusion

Let’s sum up this first article on the Remote ID NPRM. And remember, I’m Pro-RID, as are most responsible drone operators. We understand the need, but this is NOT THE SOLUTION.

But if this is the actual language of the NPRM (we have no reason to doubt it) being published on 12/31, then this is a train wreck in the making.

We as a UAS community, whether hobby or commercial, MUST come together and make sure this is drastically changed before it ever makes it to any rules making committee.

This is draconian (I don’t use that lightly) in depth and cost. It will obliterate the compliance numbers necessary to be useful. This NPRM is about identifying drone pilot location to thwart nefarious attacks, in the mean time.. .the entire industry losses.

Those of us paying attention for the last couple of years know that the FAA had Remote ID ready to go in 2017, but the security agencies got ahold of it and slammed on the brakes of this cornerstone necessary for the advancement of the UAS industry in the United States.

Anyone with the patience to sit down and read this 319 page NPRM (and digest it) can see other agency’s fingerprints all over it. But the FAA (technically the DOT) is the agency that has to put their name on it. So they’re the ones who will end up taking the blame for it. By all means, the glacial speed at which the FAA moves played a part in it. But the language and Orwellian requirements for us to simply fly a drone in the air, have the other federal security agencies to call their master.

I strongly encourage all of us within the industry to sit down, and read this 319 page document. This article will be one of many. Read them all, formulate a plan, and put together a professional, well thought out response for when the comments open. We must band together and protect the commercial and recreational aspects of flights outside Recreational Flight Fields (i.e. AMA fields).

We at Drone U will be putting out a more in depth article that will include a more positively targeted call to action. This sole reasoning for this article was a wakeup call, stating in no uncertain terms that the language and requirements of this NPRM are unacceptable to the UAS community.

This is what happens when federal security agencies sacrifice ingenuity and industry progress on the altar of safety.

Nothing in this proposal will stop any bad actor from committing exactly what those agencies are afraid of. It does nothing but burden the honest (and hardworking) people. This proposal is basically installing a deadbolt on a screen door. And they’re making honest people pay for the deadbolt.

We are disappointed.

~Vic Moss
[email protected]
Drone U Policy Director

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Vic Moss is a commercial photographer with over 30 years experience. He is also a national voice for drone safety and reasonable drone regulation. Vic has worked with numerous cities and states to help craft drone regulations that don’t inhibit safe and responsible drone use. Vic is also a FAASTeam member and one of three UAS specialists in the Denver FSDO Service Area. As a frequent contributor in many UAS forums, Vic keeps tabs on the pulse of all things UAS. Vic’s duties as a co-owner of Drone U include photography instruction, legislative liaison, and Elite pilot instructor. Vic was recently appointed to the FAA’s Drone Advisory Committee Waiver Task Group. You can get in touch with Vic by emailing him at [email protected]

More blog posts by Vic Moss

Comments (25)

V

What about the 4th amendment this is data that will be accessible without a warrant. And violation of our rights
“When law enforcement and a search or secure is deemed unlawful any evidence derived from that search or seizure will almost be kept out of any criminal case against the person who’s rights were violated “
The 4th amendment is important because gene framers of the constitution realized that governmental intrusions infringed on the the rights of the public
Today the 4th protects citizens from unreasonable governmental actions
VeteransAerialMedia
There is a lot to take in and digest. Being new to the Drone industry I am trying to learn as much as I can.
I have seen in Apps like Kitty Hawk other drones in the area flying. but it just shows where the drone is not the operator and who it is. It looks like just a S/N , I don’t mind seeing that. I guess that is someone else using that same app at the same time i am. I certainly don’t need to see the name and location of the operator.
I also really don’t want to pay for another data plan for my drone. I work for a Telecommunication company and I get why we would want to have them on our signal.
As a consumer, I have a family of 4 and don’t want another device added to my data plan that might be just 60.00 (example only) but that is in addition to the 200+ I pay every month just to fly my drone for fun or not. Will I then see drones manufacturers have specials with certain Telecommunication companies, will there be a AT&T version that is different then a VZW or T-Mobile version.
Laurence M
T

This is why I have to chuckle at the never-ceasing federal mantra, “Safety First.” If safety was indeed first, how much of what we know today would never have gotten done. Even NASA espouses safety first. If that was the case, a rocket would never be launched. It’s scary just how close to that we’ve gotten. Safety First = Stay in your house and don’t move.
Terry Stafford
J

Wow, a lot to take in. First I AM PRO RID. But only for law enforcement to be able to track down the idiots and bad guys. Just this month I was flying over a event when a local cop, and his departments drone pilot, made contact with me because he thought I was the pilot of the drone he had been trying to find because that pilot had been flying over people attending the event. After providing my part 107 certificate and telling him that I was not the guy he was looking for he was satisfied I was doing it the right way. If he had had a proper RID he would have been able to make contact with the idiot long before I even showed up, and would not have had to interrupt my pro operation. How ever the proposed rules from the FAA make so restrictive I may not be able to compete in a industry that I have already invested in very heavily. I would hate to have to abort my business now after all I have done to make it work over the past few years. We all know that the FAA has made this process a roller coaster ride of compliance for years now. They talk about how they are on our side, but their actions over the past few years scream that they are trying to shut us down. I for one am getting exhausted of jumping through hoops to stay in business. I have several stories of people interrupting my operations to harass me, and some of those people were very scary. it seems the FAA wants to help the crazies find and harass me. I agree with Vic when he says they are listening to all the wrong people!
Thanks for being here for us Drone U!!!
Jerry Freeman
D

Who is the editor? Hard to read in spots due to poor grammar and sentence structure. But thanks for the info!!
DM
A

One, you’re smoking crack if you think the FAA really wants you in the sky – they may say one thing but their actions speak an entirely different story – drone pilots are a nuisance to the FAA and until they can figure out how to monetize you in some way either through fees or criminalization of your hobby they will keep stringing you along. Two, if you think any data you hand over to the government will only ever be used for law enforcement purposes you need to see the crack pipe I referred to in “one” – the gov will lie cheat and steal to get you to say yes and once you do they’ll just start changing the rules because by then they already have the data in hand and you can’t take it back. The only data the government will ever protect is data about itself – you should be ten times as vigilant with your data as they are with theirs.
AB
D

Wow. So you think if people knew where you were going to fly, they would hurt you? Try not making them so angry. In the meantime, if you want to fly in my sky, you’ve got to broadcast ID. Delta Air Lines does it. Many apps show exactly where those planes are. Why should UAS be any different?
And no one shoots at Delta planes, or pilots. Don’t be paranoid.
DRT
D

The cost will be ridiculous, I have a limited data plan. Why should drones be tracked G airspace at all? Aircraft are not. So a farmer takes off from his G airfield and flies around with no tower contact or tracking but I can not? I am for RID and I follow all the laws but if they do this I done, it’s back to a life of crime. I think that you know Vic, that I have been an advocate for following the rules with UAV’s and an ambassador to the public, but this is too much. If they do this, the drone goes in the trash or I become a criminal. We have to change this pice of crap. I will be commenting. This stuff is really becoming tiring.
dangerd
M

First off, very well written Vic! I’m a relatively new start up in the drone service business, it’s been approximately 1.5. During this time I’ve operated my drones. Over 3 different continents and talking with an incredible number of bystanders. The two points I would like to mention are,; the public are terribly uneducated about drones & this leads to unnecessary fears and concerns. This leads to many problems for the average UAS operators. This problem has really never been addressed on a large scale and definitely not by the powers to be! It would seem this is the way it is being addressed by those powers. As Vic stated, why does identification have to extend past law enforcement? I think for myself, the answer might be as simple as money & enforcement, maybe even a little pandering. It doesn’t seem to make any sense they would make that personal and private information public.
I for one ,will be very vocal to my representative about how these restrictions will not only cause me to close my business but also devalue my equipment to the point a fear the inevitable huge financial loss of not even being able to sell my equipment because of industry collapse!
Mark Sheehan
S

DRT, I’ve been physically assaulted and my drone was destroyed by a “do-gooder” who thought I was invading someone else’s privacy, even though the property manager was 1) a client and 2) had specifically given me permission by email and 3) minutes before the assault a security guard confirmed via phone call.

I was calm and polite and professional leading up to being assaulted. When DJI heard the story they sent me a new drone free of charge, so that was nice.

The point is drones and airline pilots are not the same thing. The app that tells you where planes are, is not displayed real time, plus you can’t easily get on board an airplane flying overhead and assault the pilot.

Back to this remote ID proposal, another huge problem I see is that if you’re out filming scenery that’s so remote that there’s no cell phone coverage or towers within broadcast range of your drone, you’re out of luck.
Steve
V

This is directed to DRT. I am the author of this blog. And if you have a problem with what I’m about to say, both of my emails addresses are at the bottom of the article.

You have no idea what you are talking about. I am damn sick and tired of commercial airline pilots thinking they are hot stuff and know more about drones than we do. You say if we want to fly in your sky (an arrogant statement in and of itself) we need to broadcast. Here’s a newsflash Mr. Superior, it’s not your sky, and we wouldn’t be flying anywhere near where you fly 99.99% of the time.

And you have the audacity to tell us to not “Try not making them so angry”. Another news flash for you, we don’t make them angry. They’re already angry people. And we have the same right to the sky as you do, so it’s their fault if they get angry, not ours.

You can keep your arrogant, superiority complex driven comments to yourself. No one in this industry has any wish to hear you vomit nonsensical ramblings about something you are incredibly ignorant about.

Go fly your Delta airplanes and leave the lower 400′ section of the NAS to us. If we’re a problem to you, you better readjust your altimeter, because it’s reading very, very, very incorrectly. If it’s that far off, a drone is the least of your problems.
Vic Moss
S

Anyone who ever thought regulation would be a good thing is getting what they deserve. Government agencies always want more control, never less. Anyone who believes government makes anything better or more efficient is living in a dream world and is Naïve. Welcome to reality.
Scott
M

Spot on Vic. A consistent problem with the heads of these regulatory bodies is most are former or retired airline pilots. Many are absolutely clueless. The only one I’ve ever met that wasn’t clueless is the current Chairman of the NTSB. A solid gentleman who listens intently, and who actually gets it. Remember former FAA Chair Randy Babbit? He was the most clueless of them all. When ATC operators were falling asleep in control towers he initiated a sleep study. I was doing back flips over that one since during most of my flying career has been at night. Luckily that imbecile’s career came to a arresting end at the bottom of a bottle of Jack in the wrong lanes of a boulevard in Fairfax! So yes, when airline pilots start puffing their chests and professing their superior aviation knowledge, it flows in one ear and out the other!
Mark Colborn
A

The drone community only has until Feb. 29th, 2020 to address the proposal and provide comments that could influence the government over-reach crafted by big business. There is a solution that could benefit both hobbyists and small drone business operators. Can the experts at Drone U help craft a letter of concern and solutions that can be made available for the community to download and distribute for helping community to respond to the FAA before the deadline?
Addy Overbeeke
O

As designed and intended, this rule will decimate the hobby. And in no way will it make drones safer. Does registering a firearm make it less lethal? Of course not and that’s why neither the BATF or Congress mandate it. I have always followed the laws that matter but ignore the ones that don’t.
Ottomatic
D

The fact that maaany someones in power points across the land all said in unison “Yep this is an AWESOME idea ” just blows my wig back. I’m fast running out of the ability to count with fingers the safety issues their ridiculous adherence to a running web link has! Ran by sub contracted admins at Whothehellever Inc and Sellyerdata Ent. makes it better in no way! And I agree Vic, the time for witty hyperbole and being anecdotal is over man..the more I digest this, the more it disturbs me. Lastly, them using the BVLOS / overflights as allowable general flight and this proposal being the absolute only way we can get there, is laughable. I’m good with waivers and auths and last I checked LAANC works just fine so…yeah.
If this weren’t a big glaring example of when organization is needed, I’m affraid I just couldn’t give a better one. People..MANY people who are good at what they do and are a true asset to the drone industry will get trampled as a result of this, and I really cant get behind that in any way. Read this thing gang, read it all and closely..talk about it in your groups and whatever pages you visit. They let this dangle for too damned long, brought on by the fact that they got caught with their pants down after the dronesplosion earlier in the decade. Part 107 came around and it looked like they had their heads screwed on kind of strait..welp. Time to close ranks..to be continued
Daniel Sabrowski
B

Well written article, VIC! I know most of us in Ohio will be sending comments to the FAA, Doc# FAA-2019-1100. We are hoping for a lengthy letter to all sign and send in. Thanks again for your hard work explaining the good, bad and ugly to all of us!
Brannon Criner
D

I also read in the 319 pages that current AMA fields can apply to be a FRIA. There is a 12 month window to do so. After 12 months they will not take any more applications, ever. This is just more proof it’s not about safety, it’s about clearing the skies for commercial drones. It’s the big companies and their lobbyist that got section 336 repealed so they could squash the hobbyist and clear the skies for them. Remember, in America you are free to do many things, if you pay the government to let you.
Didier
R

They should include RC plane. RC wings, RC Gliders,RC Helicopters to… anything Flying RC all of this is not a robotic drone or smart drone that everyone can fly it like Phamtom.,Mavic and all other robotics Drone I agree for robotics smart drone Not the hobbyists FPV manual flying Quads drone what ever you call it…dumb ass lawmakers
Roscel Torres
M

So what will happen to people like me that fly ONLY at AMA(R/C club) fields. The field I fly at each week is in a rural area of the county I live in, no houses just cows, ferrell pigs, and snakes. There is no wifi at this park, would RID work with the wifi connection between my Mavic Air and my cell phone? Not sure what to expect.
Marc T
S

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Sajjad Ahmad
M

Nicely written, VIC. I just can’t believe that commercial businesses (other than the delivery businesses) are not speaking up! Do they not realize that this is going to literally kill their opportunity to utilize drones for their business?? Here’s a couple of examples: I just got into crop research for the Bayer corp. this past summer. 99% of my flying is done over crop fields, most of which I don’t even have a strong cell signal or sometimes none at all. And I’m sure that other industries like oil and gas, wind turbines, power companies etc have assets located miles from a cell tower. And even if they are close to a WiFi signal, there’s going to added costs to manufacturing new drones (to include RID), which will be passed down to the buyer, as well as the cost to retro-fit their current drones with RID capabilities, not to mention the cost of RID services, increased data with their cell provider. The list goes on and on. Those of us who have taken the time to comply with the current regulations (certification test, registering drone, LAANC compliance, etc) know that breaking these regulations could result in (at the least) loosing our legal right to fly drones (or recreational RCs). It’s the idiots that don’t care about rules or safety that screw it up for the rest of us. We don’t need more regulation, we need enforcement of current ones, and ways to (safely) remove them from the skies. Not sure how that can be done, but this proposed regulation push is only good for the delivery companies, no one else. I’m on board for a calibrated effort to write a well-written ‘comment’ to the FAA about all of this.
MD
P

Full disclosure: I use drones in my business and am a part 107 licensed PIC with a UAS rating.
I am also a proponent of RID as a safety measure, and have no problem sharing my drone’s telemetry or my location with law enforcement. I do not agree that there’s a benefit to sharing this infomration with the public at large.

Both Vic and a couple of posters touched on this- the Achilles heel of this and other drone-related legislation is compliance. The more difficult/expensive our friends in Washington make compliance, the greater the likelihood that people will simply ignore the regs and fly where / when they want. I’m a member of a couple of FB groups related to drones, and I’m continually surprised at the prevalence of the opinion that the existing rules are “stupid” and thus they don’t need to be followed. The evidence is obvious- on FB lots of shots taken at night, over people, and well over 400AGL of major cities with airports not far away. Some amateurs are unaware of the rules currently in place, but most of the posters proudly claim to simply ignore them.

So, if compliance is an issue, what’s the solution? As with any other regulation, the solution is enforcement. The FAA is completely unprepared to enforce rules that affect the public at large. Nowhere near enough inspectors, and the most draconian rules on earth will be ignored if they are not enforced. I didn’t see this addressed anywhere in the document, so unless there is a Federal Drone Police force being formed somewhere if fear that this legislation will counterproductive in that it will simply encourage more people to ignore the rules, to the detriment of all users of the NAS.

Summary –

1) Without enforcement, you have voluntary compliance at best, regardless of how the regulation is written.
2) The more difficult/expensive compliance becomes, the less likely the public will be to be in compliance.
Peter Hunt
M

The big thing people are forgetting here is hacking. They are asking for internet connections directly to our drones. Unless security is properly implemented people could take over control and do whatever they want with them. Given the track record of “internet connected devices” I am highly skeptical it will be done properly.
Matt
M

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