As you may have heard, the FAA released an NPRM on Remote ID in late December. This rulemaking for Remote ID is probably the most important drone-related rulemaking the FAA has ever done – even more important than the Part 107 rules released in 2016.
The NPRM has generated a lot of discussion and analysis amongst stakeholders across the drone and broader aviation community, and it is encouraging to see so many people take an active role in the rulemaking process to ensure their voice is heard. There is some excellent commentary and analysis out there by a variety of industry stakeholders, but some of it is under-informed.
If the industry is going to have a robust debate with thoughtful comments, then everyone should agree on some basic facts. If you want to get caught up on the NPRM, last week Kittyhawk wrote a summary of its key points.
Misconception 1: “If I am in an area where I don’t have access to the internet, I can’t fly.”
NPRM, page 94: “A standard remote identification UAS that loses connection to the internet or that can no longer transmit to a Remote ID USS after takeoff would be able to continue its flight, as long as it continues broadcasting the message elements.”
You can operate a Standard Remote ID UAS in an area where you don’t have access to the internet. If the internet is available, you have to transmit via network too. If the internet is not available, you are allowed to take off using only broadcast.
Misconception 2: I have to go out and buy a data plan for my drone because my drone has to connect directly to the internet.
NPRM page 95: “For example, during a BVLOS operation, the uncrewed aircraft could be operating over a rural area that does not have wireless internet connectivity, but, through the command and control link, the uncrewed aircraft has connectivity with a control station that is in turn connected to the internet and transmitting to a Remote ID USS.”
The NPRM does not say that each uncrewed aircraft has to have a data plan or even that each uncrewed aircraft has to be able to connect directly to the internet. If you have a smartphone, you can comply. You just need to connect your smartphone to any Remote ID compliant UAS and whichever Remote ID USS you want to use.
Misconception 3: I will be required to pay a Remote ID USS a monthly subscription.
NPRM pg. 168: “Although some Remote ID USS may choose to offer their services for free, Remote ID USS may have a variety of business models and may choose to require a subscription, payment, or personal information to access that Remote ID USS.”
The NPRM language shows that the FAA is open to having Remote ID USSs use a variety of different business models to deliver Remote ID services, and Remote ID USSs can offer services for free.
The FAA’s successful LAANC program has proven that USSs will choose a variety of different business models and many of those are free, with some paid and some private. The vast majority of drone operators do not pay for LAANC authorizations being granted today because they use a LAANC USS that has made a business model decision to offer that service for free to the public. For example, Kittyhawk offers all auto-approval LAANC capabilities for recreational and commercial authorizations for free.
Remote ID USS can differentiate themselves by offering complimentary features or services that people value enough to pay for, or they can offer Remote ID services for free. In some instances, people clearly value some features and services enough to pay a subscription for them, such as better user experiences, great design, work flows, or data security.
Misconception 4: Remote ID requirements will make my drone obsolete or require an expensive fix.
NPRM pg 189: “The FAA reviewed UAS registered to part 107 operators and found 93% of the existing part 107 UAS fleet may have technical capabilities to be retrofit based on information received by industry (i.e., could support software updates through the internet).”
The NPRM assumes that 93% of the current part 107 fleet could likely be retrofit with software updates because they have internet and WiFi connectivity, ability to transmit data, receive software uploads, and have radio frequency transceivers, among other technology such as advanced microprocessors.
If 93% of the current part 107 fleet can be retrofit with only software updates, it seems likely that there will be very cheap or free fixes available with minimal disruption to drone programs. It looks like those who have invested in drone hardware already or who have to invest in additional hardware before the compliance deadline have reason to be optimistic that their drones can be made compliant with the proposed rules.
Misconception 5: Broadcast-only is good enough by itself, so we don’t need a network solution.
NPRM pg 95: “The FAA believes an internet-based solution is appropriate, when the internet is available, because the internet is the largest, most multifaceted, and prevalent platform for data submission.”
Broadcast solutions are an important part of achieving near-universal compliance with Remote ID. There is a reason the NPRM proposes requiring Standard Remote ID UAS to broadcast its position at all times – because using broadcast provides an important safety redundancy when internet connection is not available or in case of a weak network connection.
Network Remote ID utilizing the internet can be additive to broadcast, because connectivity to the internet enables the kind of innovation and benefits we’ve seen in the world of mobile devices and smartphones. Kittyhawk has previously explained how network Remote ID can be a more nimble platform for future development: Network solutions can be more effective in performing advanced or complex operations like those beyond visual line of sight and can enable data-sharing that powers innovation like the InterUSS project, where Kittyhawk and other industry leaders showcased a network Remote ID solution that is both hardware and software agnostic.
It makes sense that we would take advantage of technology available to us and build the future of drone operations using network solutions. For example, the FAA in previous NPRMs have discussed allowing advanced operations currently only allowed under a waiver to occur as long as Remote ID is being used. Connected devices are only going to become more common, and widespread 5G could make network-based Remote ID solutions even more powerful, seamless, and secure.
All of this development will provide essential pieces of technology and capabilities for the true goal of the industry: a safer, more efficient, low-altitude, automated traffic management system for UAS called UTM (UAS Traffic Management). UTM requires persistent communication, navigation, and surveillance (CNS) coverage to track, ensure, and monitor conformance. Achieving that will require overlapping and redundant connectivity. Even though it may seem like the FAA is requiring more than is necessary for today’s operations and fleet, tomorrow’s operations with an exponentially larger fleet will need duplicative, redundant capabilities in order to make that system run smoothly.
Misconception 6: Remote ID will require my Personally Identifiable Information (PII) to be publicly available.
NPRM page 171: “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. The FAA would provide registration data associated with a particular serial number or session ID only to law enforcement or the Federal Government.”
While the NPRM contemplates that some information will be publicly available, such as the message elements the UAS will have to broadcast and/or transmit, the information that will be publicly available is not by itself PII and there are privacy protections in place. It is important to note that no operator registration information will be required to be available to the general public or even to Remote ID USS – only to the FAA and law enforcement.
There are two other privacy issues that should be addressed:
First, operators have the option to add another layer of privacy when they transmit the required message elements which are available to the public. The NPRM supports the idea that instead of the serial number of the aircraft, a randomly generated “Session ID” will be used, making the UAS serial number inaccessible to the general public. The ability to correlate a Session ID to a specific UAS serial number will only be available to the FAA and law enforcement.
Second, there is real concern about the general public being able to determine the precise location of the controller / control station of the UAS. This information is necessary for law enforcement and the FAA, but it is understandable that UAS operators don’t want that information publicly available. The safety of those operating drones in the field is important. The most reasonable compromise is probably to limit the general public’s ability to see the operator’s precise location while still allowing law enforcement and the FAA to access it.
Later this week, look out for our blog post recapping our upcoming comments to the NPRM and results from our Remote ID NPRM survey!
It’s not too late to take our survey and add your voice. It should only take 2-3 minutes.
