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.
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.
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.
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.
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.
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.
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.
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.
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.
Drone U Policy Director
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]
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