The Future of Advanced Air Mobility

UAS Groups Urge FAA Not to Delay New Remote Identification Requirements

Three UAS industry groups are urging the FAA to not delay the intended December release of rulemaking covering remote identification requirements (ID) for unmanned aerial systems. In a letter sent on September 29 to U.S. Transportation Secretary Elaine Chao, the Association for Unmanned Vehicle Systems International, the Consumer Technology Association, and the U.S. Chamber of Commerce’s Technology Engagement Center encouraged the Department of Transportation (DOT) and the FAA to proceed without delay and “support a final rule that sets performance requirements, rather than specifying particular solutions for remote ID compliance.”

The groups noted that they all had provided substantial input regarding “minor changes” sought to the prospective rule to DOT during the notice of proposed rulemaking public comment period and hoped “these changes have been considered.” They argued that remote ID standards will be “the linchpin needed for future rulemaking to pave the way for transformative uses of UAS with significant benefits for our economy and society.” They also pointed out other benefits of the technology, including real-time UAS identification, safer and more secure airspace, the role the technology is likely to have in developing UAS traffic management, and “driving public acceptance of UAS.”

FAA launched a consultation on the proposed remote ID rules on December 31, 2019, giving industry stakeholders until March 2 to comment on what is intended to provide a framework for integrating unmanned aircraft systems (UAS) into the U.S. National Airspace System. The proposals have important implications not only for how rapidly proliferating drone flights can be safely accommodated but also how autonomously-operated, passenger-carrying electric vertical takeoff and landing (eVTOL) aircraft might function in planned urban air mobility applications.

The final rule resulting from NPRM FAA-2019-100 is expected to require remote identification for the majority of UAS, with exceptions to be made for some amateur-built UAS, aircraft operated by the U.S. government, and UAS weighing less than 0.55 pounds. The core requirement is that UAS can provide “certain identification and location information that people on the ground and other airspace users can receive.”

Essentially, the FAA proposed three compliance methods: standard identification, limited identification, and operations without remote identification to be permitted within an “FAA-recognized identification zone.”

Under standard remote identification, aircraft would have to broadcast identification and location information and simultaneously transmit the same information to an approved UAS service supplier (USS). Identification can be based on the aircraft’s individual serial number or a “session identification number” that would be assigned by the USS and would allow the operator a greater level of privacy.

Remote ID USS service providers would be under contract to the FAA, under an operating model similar to that already applied by the agency for Low Altitude Authorization and Notification Capability (LAANC) which manages clearances for UAS operations at designated U.S. airports.

Under limited identification, operators would have to broadcast only the location of each UAS but would be permitted to operate only within 400 feet of a ground-based control station. Aircraft without remote identification capability that is not covered by the limited exceptions to the new rule, would be confined to FAA-recognized identification zones established within specific communities.

Significantly, the FAA indicated it would not permit either existing electronic surveillance technologies, including transponders and automatic dependent surveillance-broadcast (ADS-B), or radio communications with air traffic control services, to be used for UAS remote identification. The agency decided that these potential solutions were unsuitable, “due to the lack of infrastructure for these technologies at lower altitudes and the potential saturation of the available radio frequency spectrum.”

The FAA’s decision not to allow compliance through these existing technologies is a significant factor explaining the three-year transition period between the effective date of the final rule and full implementation. Earlier in 2019, the FAA indicated that the effective date for the new remote identification rules would likely be in late 2021.

Some industry observers have indicated that the relatively slow timeline for implementing the rule could slow the pace of service entry for some commercial UAS operations and autonomous eVTOL aircraft being prepared for urban air mobility services. 

In its January 2020 response to the NPRM, the Association for Unmanned Vehicle Systems International said that effective implementation of remote identification requirements will be critical to the anticipated growth of the UAS industry. “We have long called for the establishment and implementation of these standards, which will increase the safety and security of the airspace and advance the UAS industry beyond what is currently possible,” commented the group's president Brian Wynne. “The importance of remote ID regulations cannot be overstated, as they are necessary to enable advanced and expanded operations such as flights over people and beyond line of sight. They also serve as the linchpin needed for future rulemakings that will pave the way for transformative uses of UAS with significant benefits for our economy and society, including widespread UAS delivery. Finally, remote ID will also help law enforcement identify and distinguish authorized UAS from those that may pose a security threat.”

Several companies are well-positioned to take up the proposed USS role to support remote ID implementation. In many cases, they have relevant experience of providing similar support for the expanded implementation of the LAANC program.

One such company is Kittyhawk, which already offers its Air Control security and compliance system to UAS operators. “Overall, the [FAA] approach is sound. They have broken it out into three areas and the layered approach makes sense,” founder and CEO Jon Hegranes told FutureFlight in January. “More advanced aircraft will need both broadcast and remote ID functions. One important caveat that you can fly offline if you have broadcast capability. If you don’t have to have broadcast, you can use a network and be online. You can’t fly as far, but for short distances it is reasonable.”

According to Hegranes, UAS manufacturers and remote ID technology companies have “a lot more work to be done” to complete the “ecosystem” that is envisioned for safe integration of large numbers of unmanned aircraft into controlled airspace. “These rules will pave the way for much larger autonomous aircraft,” he said. “Having full visibility and situation awareness [for UAS] is a key facet of this and we need machinery that can use real-time data. The next step is connecting all these aircraft. We are already doing live telemetry [to track UAS’s positions] for some customers.”

AirMap, another prospective USS vendor, applauded FAA’s proposed remote ID rule and said that the LAANC program—for which it already provides service—is a proven model for how a public-private partnership can support growth in the UAS flights. “It validates a core belief we hold that the only way drones can operate at scale is if they all participate in a connected, internet-enabled unmanned aircraft traffic management [UTM] system,” company chairman and co-founder Ben Marcus told FutureFlight.

There are already established standards in place for remote ID and tracking technology, as defined by ASTM International through its WK65041 standard issued in July 2019. This document has been endorsed by 35 regulatory and industry organizations worldwide. According to AirMap, the standard provides, “a flexible and scalable way to remotely identify drones while protecting operator privacy.”

“The proposed Remote ID rule requires nearly all drone operators to share their position and identifying information,” Marcus explained. “That’s important as it will ultimately enable beyond-visual-line-of-sight flights and autonomous operations. When operators share their information in a UTM system, aircraft can safely fly in proximity to one another and dynamically reroute based on highly accurate airspace information including restrictions, traffic, weather, and emergency activity. We’re building these capabilities with drones now, but we know that in the future the low-altitude airspace is going to get busier with high-density drone and eVTOL operations.”