Three Ways the FAA Can Fix The Remote ID NPRM Dumpster Fire

The FAA has been painfully behind the power curve with regards to Unmanned Aircraft. They have not only failed to effectively enforce current UAS related laws but now they have proposed a Remote ID (RID) law that would effectively cripple RC Hobbyists and severely impact Part 107 UAS Pilots as well. The Remote ID NPRM is broken, but we think the FAA can fix it.

With only a few days remaining to make a comment on the NPRM, we wanted to share a few ideas on how the FAA could fix the NPRM before it is made law.

Before we discuss how to extinguish the dumpster fire, let’s do a quick refresher of what the NPRM will do.

The Remote ID NPRM

The FAA believes that the only way to safely integrate UAS into the NAS at scale is to force all UAS to broadcast their location (a la ADS-B.) The Remote ID NPRM lays out 3 ways in which recreational and commercial UAS/RC Pilots can remain compliant, Standard RID, Limited RID, and FAA Approved UAS Flight Fields.

Standard RID

Standard Remote ID requires both pilot and UAS location to be broadcast by two methods; from the UAS directly and via the internet. In this case, the pilot would be required to subscribe (at a cost) to a Remote ID Unmanned aircraft system Service Supplier (USS) in order to broadcast their location via the internet. The FAA suggests USS would operate in a similar manner to current LAANC providers.

If the internet is not available, the UAS would only be required to broadcast the message elements directly from the unmanned aircraft. However, if internet is available but the system cannot connect to a USS, the AC would be restricted from taking off.

DJI, the largest manufacturer of recreational and commercial UAS, has stated that a majority of their recent drones are already capable of broadcasting some form of RID messages but that a firmware update would be required to be fully compliant. However, those drones that are more than a few years old would be forced to operate under the Limited RID or at a FAA Recognized Identification Area. This could place a burden on owners of those older drones who still use them for commercial activities.

Limited RID

The Limited Remote ID category drops the requirement of the UAS to broadcast its location but retains the requirement to transmit the controller location via the internet/USS. In addition, the Limited RID category restricts the aircraft to operate within 400ft of the controller. This would create challenges for many operations who inspect towers, buildings, or other infrastructure >400′ high. If the internet is not available, the UAS would not be allowed to take off and if internet connectivity is lost at any time, the UAS would have to be landed.

FAA Recognized Identification Areas

RC Aircraft/UAS without broadcast capabilities (which includes most modern FPV and RC aircraft) could still be flown at FAA Recognized Identification Areas (like AMA fields).

For 12 months after the effective date of the rule, the FAA would accept applications from FAA approved, Community Based Organizations (CBOs) like the AMA, to create fixed identification areas where UAS without RID capabilities could fly.

After that period, the FAA will create no new sites. While established sites can be renewed every 48 months, if they are not renewed within the allotted time, they will not be allowed to re-apply for Recognized Identification Area Status. In making this process arduous, the FAA has made it clear that its goal is to eliminate theses sites eventually. They even stated that they expect the number of active sites to decrease over time.

Is There Still Hope?

Well, it’s clear that Remote ID has to happen in some form (it was part of the FAA Reauthorization Act of 2018.) The FAA has stated that a functioning RID solution will be necessary before they can proceed with things like Flight Over People and BVLOS flights. In my opinion, these two things are critical to the future of the UAS industry so that means RID is going to happen. However, the NPRM we see today is clearly written to benefit the large, corporate UAS users (think Amazon, UPS, Uber, etc.) on the backs of SMB and Sole Proprieter UAS Service Providers. We think there are a few minor changes the FAA can make to the final rule that will ease the burden on the average drone pilot without disrupting the future of commercial operations within the NAS.

1. Respect the Privacy of UAS Pilots

This a big one for many of the drone pilots I have spoken with and rightfully so. The NPRM states, “The remote identification message elements that operators would be required to transmit to a Remote ID USS under this rule would be considered publicly accessible information.” While the location of the drone itself is of little consequence, I do take exception with the location of the ground station (RC Controller) being publicly available. Law enforcement, sure…First Responders, of course…but there is no reason for the general public to be aware of my location for any reason.

There have been too many cases of pilots being assaulted, harassed, and threatened by ill-informed members of the public who felt as though the drone pilot was infringing on their privacy. I have personally, witnessed people threaten to shoot or otherwise physically harm anyone flying a drone near their property.

Providing the pilot’s location to the general public is a gross infringement on the privacy of all drone pilots.

2. Cut the Cost

Flying drones commercially or as a hobbyist isn’t cheap. Paying for aircraft, extra batteries, insurance (liability and hull), and all the necessary accessories can quickly add up. The last thing we should be doing to drone enthusiasts is adding an additional cost.

Yet, that is exactly what the FAA intends to do with Remote ID NPRM. Forcing UAS pilots across the board to pay a monthly service fee for a subscription to a USS just to fly. While this could work in tandem with current LAANC operators, it isn’t guaranteed. Plus, drone pilots would be required to have an internet-connected device to fly. While this would impact the RC community hardest, it may also cause trouble for pilots flying in areas where mobile internet is not available with their carrier. I enjoy relatively low prices with T-Mobile’s Veteran Plan but recognize that sometimes Verizon or AT&T has better coverage in rural areas. Should I be forced to change to a more expensive service provider just to legally fly my drone?

The FAA has suggested that any aircraft not following one of these two methods be restricted (via software) from taking off outside of the Recognized Identification Areas. This would effectively brick any drone that is not compliant, placing an even higher burden on pilots.

Alternatively, a free USS funded by the FAA would begin to ease the cost burden placed on pilots.

2. Listen to the ARC

In 2016, Congress directed the FAA to convene a group of UAS experts from various segments of public and private industry. This group, the Aviation Rulemaking Committee (ARC) had one major goal, to identify the best possible way to implement Remote ID. Even though this group of 74 people was mainly made up of those parties (Telcom providers, police, airports, etc) who stood to benefit from RID they still came up with a solution that would minimize the impact of the rule on the average drone pilot. This was believed to increase compliance as well as future innovation.

The ARC determined that broadcast ID (coming from the drone itself) was sufficient to provide all stakeholders the necessary amount of information to ensure the safety of the airspace and those on the ground.

It’s unclear why the FAA chose to go with a far more aggressive RID proposal than was recommended by the ARC, it can only be assumed that this RID proposal is designed to make way for far more complex drone operations like delivery drones and air taxis at the cost of small drone operators.

So What Should I Do?

Make your voice heard, and do it fast! The comment period for the Remote ID NPRM ends March 2nd at 11:59PM, so head over and leave a comment. Don’t copy and paste and don’t be rude, just let the FAA know that you think they should follow the advice of the ARC and follow the lead of European Aviation Officials in supporting a broadcast only option for Remote ID.

Don’t let the FAA sell our National Airspace out from under us.