Fresh from the FAA is the Remote ID Proposal for Small UAS, Docket No.: FAA-2019-1100; Notice No. 20-01] RIN 2120–AL31
Remote ID was once called the linchpin regulation to allow the drone industry to truly take flight & allow for advanced drone operations like drone delivery, BVLOS. Remote ID was essentially the license plate system in the skies, except unlike drivers…pilots wouldn’t have any privacy. Albeit, RID is also way for law enforcement to identify and track drones from various operators. You have probably listened to our episode of Ask Drone U speaking about the license plate system in the sky and why pilot privacy is so important. While remote ID would surely increase the FAA’s abysmal enforcement rate, it was also supposed to allow for advanced operations and continue to open the skies.
With this proposed version of Remote ID, the industry will be impeded from any further growth, place a large burden on pilots and even cause deaths when SAR missions are limited in the Future. The version of the NPRM we’re seeing negated many of the recommendations from the ARC team, which shows the FAA isn’t listening as much as we would like We’re seeing the recommendations given in the ARC were not followed, the FAA
Anyone who knows me (Gene Robinson) knows that my passion is for the safe practical use of UA for Public Safety, specifically in the Search and Rescue (SAR) area. Having contended with the FAA, (Equisearch v. FAA) and their “clarifications” for 15 years I can sense when there is something significant that could impact Public Safety operations from a regulatory standpoint. Let’s breakdown how this Remote ID NPRM would affect our industry, public safety and Search and Rescue missions as a whole.
After spending an afternoon pouring over this proposal, it became very evident that changes are definitely in the wind for SUAS operators in the National Airspace (NAS).
As an industry we have seen that the “Sense and Avoid” ideology and subsequently, identification of small UA has risen to the forefront of conversation…and for very good reason. These two factors alone represent obstacles (or opportunities) to allow for a wider proliferation of small UA in the NAS. At first blush, it seems to be a straightforward “first swipe” at something for us as operators to consider and more importantly, to comment on.
The FAA identifies three ways to be in compliance, or at least operate in the NAS. They are called:
Standard Remote Identification (SRI)
The Standard Remote Identification (SRI) is the top of the line for commercial operations. It requires that you have aircraft and control stations that have good quality and persistent communications to the internet. This scenario allows the aircraft to send its “message” to a provider that will disseminate that message to all those concerned with your operation. With this you will be able to operate as normal under Part 107 or your Certificate of Authorization (COA).
Limited Remote Identification (LRI)
The Limited Remote Identification (LRI) is the category you would operate under if you do NOT have a good internet connection. This allows you to operate on a limited basis provided that your aircraft has the capability to at least transmit the information constantly. Doesn’t matter whether anyone receives the information, just that the aircraft is capable of, and is actively transmitting. The big key difference here is that under this mode of operation, you will be limited to operating within 400 feet (lateral) from the base station. If there is a malfunction that keeps your aircraft from sending the message, then your aircraft will not be allowed to take off.
FAA Recognized Identification Area (FRIA)
FAA Recognized Identification Area (FRIA) – This section is for the recreational fliers and will essentially be those fields that are recognized flying areas covered by a community based organization (CBO) like the Academy of Model Aeronautics (AMA). Interestingly enough they indicate that 90% of established fields will be approved for this designation, with 10% being denied due to being in a sensitive operating area. This process is also not automatic. The area wishing this designation must submit an application within 60 days of passage into law of this proposal. If approved, aircraft operating in that area are exempt from the hardware and transmitting requirement and may fly as long as they remain within 400’ from the control station.
Inability to Fly Beyond 400 Feet Lateral Distance Will Greatly Limit Drone Operations
In my view, the biggest change to our operations is the further definition of “Line of Sight.” This proposal puts a hard number of 400’ lateral distance from the control station as the limit to line of sight. I am sure there are more than a few operators that will take umbrage to this definition because it is easy to maintain an effective visual and provide deconfliction at 2, 3, or even 4 times that distance.
Unstable Internet Connection? You Might Be DENIED Permission to Takeoff
This statement appears on page 22 – Standard Remote Identification – 89.110. 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.
It is further clarified in the document that dependent upon whether the aircraft is even capable of sending the message determines whether it can even take off. Stated differently, if your aircraft reports a malfunction in the transmission of the message, it will NOT BE ALLOWED TO EVEN TAKE OFF. Most UAS will have to be retrofitted to include this monitoring/diagnostic system to report this condition. (As a side note, this element is significantly more onerous than manned GA requirements utilizing ADS-B. Even after the 2020 mandate, I can take off in my Cessna 172 without having to report my position as long as I stay out of controlled airspace.)
What Happens if You Lose Connectivity Mid-Flight?
So what happens if I just lose my internet in the middle of a mission? 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. This means that you could complete your mission but after you landed, you would either be denied take off or fall under the “Limited” plan and confined to 400’. This item alone could handicap Public Safety Agencies from effectively utilizing their aircraft on an emergency response basis. As we have stated time and time again, when we are responding to a life threatening situation, we just don’t have time to get an unlock code or call someone for permission.
Current Barometric Devices for Measuring Altitude are Totally Inaccurate
Just about everyone knows that the GPS altitude reported by any drone is pretty much useless in terms of accuracy. With swings of anywhere from 6 meters up to 50 meters or more in some cases it really cannot be used for controlling an aircraft or subsequently reporting that altitude. Most drones have some form of barometric measuring device so this barometric sensor could conceivably be used to provide that most important part of data (altitude) in “the message.”
The problem with tapping into that item is there is really no way to actively calibrate that piece of hardware. It would also need to correct for temperature variances or density altitude changes.
You Will Have To Upgrade Your Transmitter Too
Additionally the handheld control station (Transmitter) requires the same capability of measuring GPS AGL position so that it can record the take off altitude as well. I don’t know of too many hand held controllers that have a baro on board and that will most assuredly require a hardware upgrade to comply. In addition, it is clear that consumer based GPS solutions (like your phone) are only accurate to a 100′ or so.
Which Will Drastically Push Up Your Hardware Costs….
A big impact to the cost of such an addition to a UAS will be the minimum acceptable standard for error after calibration. In this document the FAA says that most off the shelf sensors that report an altitude +/- 20 feet will be sufficient. Historically these sorts of accuracy levels have been subject to change and without much notice. If the FAA demands a closer tolerance, say a couple of feet, then the cost of that particular sensor is going to be tested to a higher quality standard. Right now, most aircraft that have a baro sensor on board use it in conjunction with GPS data as a reference only. When it becomes a key portion of the equation the cost will most certainly go up.
Additionally, you will Have to Fork Out a Monthly Subscription to Use this New Remote ID Infrastructure
The FAA has been historically low when projecting costs for aviation based improvements or requirements that change the NAS and operations therein. Buyer beware in this category! Even the FAA in this document has indicated that costs are “estimated” and “while acknowledging significant uncertainty,” they quote from vendor surveys and interviews.
Monetization of the Remote ID UAS Services Supplier (RI USS) – The FAA further discusses some of its assumptions related to Remote ID USS business models in a Regulatory Impact Analysis, where it assumes (again while acknowledging significant uncertainty) the average available Remote ID USS will charge $2.50 as a monthly subscription ($30 annually) cost to users of its service. While this is most likely backed up to a certain degree by looking at some of the providers of the Low Altitude Authorization and Notification Capability (LAANC) models that are out there now, it must be stated that their success is still being determined.
Will Public Safety Agencies Be Exempt From These New Rules?
The FAA organizes a committee of industry wide participants to help them derive what rules or standards should be considered for codification. It is called an Aviation Rulemaking Committee or just ARC for short.
On page 64 – UAS ID ARC Recommendations (Exemptions) – It states that “Law enforcement and first responders MAY be exempted from UAS ID reporting requirements.” While this is only the ARC recommendation and the FAA is not bound to adhere to this, it is encouraging that consideration is being given so that local agencies may be exempted. While this is one key excited piece for Public Safety, if the ARC recommendations were followed as a whole, Public Safety wouldn’t have to apply for an exemption. In addition, how long will it take the FAA to figure out a system of exempting PS?
Will These New Rules Mean Stricter Enforcement For Illegal Drone Operations?
On this particular point it should be noted that the FAA is going to be relying heavily on local law enforcement to assist in the enforcement of some of these Federal rules. Indeed, they have even recommended that agencies, and the public, should be allowed to access a Public Safety Agency version of “the message” that will be sent to the Remote ID system so that the PSA can engage operators while the UAS is in the air.
There is no question that every public safety agency in the U.S. will want to have access to this data. It has already been shown that more and more calls concerning drone flights are coming into 911 dispatch centers. Responding officers are now getting training on what questions to ask an operator in determining if they are in compliance or not. While for now, the officer may only submit the information from that contact to the FAA so that they may determine what action to take, if any. It is not a far stretch to think that a citation could be issued in the near future. Albeit, enforcement actions will be severely limited due to resource constraints, can we really expect already busy officers to write federal drone reports?
This proposal is essentially the opening volley similar to what we have seen occur with the Part 107 release and the earlier 333 Exemption process as well. It will require some time for that process to complete. The FAA has determined that “the sooner the better” would be the best approach and has offered a “Phased integration” of Remote Identification. So what does that mean to your agency?
If it were to pass into law in its current state with no public safety exemption, you have three years from the effective date of this rule to become compliant.
It is NOW that all our public safety brothers and sisters utilizing unmanned aircraft should weigh in on the inclusion of that exemption. In terms of attrition and longevity of hardware, this is a very long time. The UA that sees a full three years of active duty and is still a viable up to date tool is the exception rather than the rule. After two years, no aircraft will be available commercially unless it is compliant with this rule.
In conclusion, the actual impact to any public safety agency will in the near term will be minimal. The benefits in having the ability to detect uncooperative aircraft or non-compliant aircraft by local authorities will be an enhancement to events as widely diverse as open air events to wild fires to wide area disasters, making us all safer in the process.
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