This report was issued in September 2017 as a set of “Recommendations Final Report” as to what the FAA ought to do about remote identification of drones, including model aircraft.

Source: UAS ID ARC Final Report with Appendices.pdf

Their report proposes that UAS be exempt from the remote ID requirement if the UAS is “operated within visual line of sight of the remote pilot and is not designed to have the capability of flying beyond 400′ of the remote pilot”.

However, any UAS that can autonomously navigate from one point to another without direct piloting from the operate, or which could be operated at greater than 400′ would require remote identification.

The 400′ limitation is problematic in that radio signals do just stop at a specific distance but gradually decrease in strength. In other to reliability operate a craft at 400 feet distance, the transmitter signals must be sufficiently strong through out the entire circle of the operator. This means that such a signal will, in fact, be usable at times beyond 400′. Consequently, this 400′ rule would likely mean that aircraft could be safely operated within a much smaller circle of as little as 200′ to 300′. To illustrate the difficulty of this, our model aircraft flying club has a paved runway that is 450′ long.

Most all of the popular quadcopters such as those made by Yuneec, DJI, and even some of the toy-class quadcopters made by MJX (Bugs 5W for example) have autonomous and return to home capabilities. Thus, to be legal in the FAA’s future world of remote ID, these devices would require a remote ID transponder. The report does also recommend that the FAA include a waiver mechanism, which might enable grandfathering of some existing UAS craft. The report also suggests that safety features like”return to home” be considered for an exemption to the remote ID requirement.

Products manufactured with built-in remote ID would be required to prohibit disabling the remote ID.

The remote ID would likely require transmission of identification, location and speed of movement evey one second during flight. This could have significant ramifications for battery life and payload of UAS.

The proposal for remote ID envisions two kinds of remote ID transmissions:

  • Direct broadcast to other local aircraft or law enforcement on the ground.
  • Network broadcast. In this form, the ID must be transmitted through a network, such as a cellular network, or from the aircraft to a cellular phone that links into the cellular network. (How this would work outside of cellular phone coverage is not explained.)

The above chart identifies their general concept.

Tier 0 – limited to 400′ craft not having autonomous capabilities

Tier 1 – Remote ID required, may require either Direct Broadcast or Network Broadcast. When conducted in controlled airspace, all flights would require filing of a flight plan and receiving authorization before flight. Note that most of the U.S. population living in cities and metro areas will be within the boundaries of Class B, C or D airspace where this would be required.

Tier 2 – Part 107 operations above 400′ (in other words, not hobbyist flights) or in controlled airspace or operating over people would require both Direct Broadcast and Network Broadcast capability.

Tier 3 – Advanced drones weighing more than 55 pounds, operating beyond line of sight would be treated as regular aircraft operations and all that implies.

The recommendation report suggests that all UAS users (including hobbyists and sport flyers) “may wish to voluntarily share the mission type by loading into the database that public officials could access during their response to an event. This information (along with route data…) would help public safety officials understand the nature of a UAS operation and assist in anticipating flight behavior”.

While filing a flight plan would be voluntary (and likely cost a fee), the alternative is that law enforcement, under the new law, can see any quadcopter as a “credible threat” and shoot it down. In other words, this is voluntary only if you don’t care if your quadcopter may be shot down because lack of a flight plan makes it a “credible threat”.

For flight in controlled airspace (which as noted, is where most everyone lives), remote ID, flight plans and tracking would be a requirement. In conjunction with this, the report foresees and integration of remote ID and tracking with a Universal Traffic Management (UTM) system – basically air traffic control on steroids. The report also foresees the Federal government creating a long term database of all UAS flights, based on their tracking data.

The FAA has not yet issued a Notice of Proposed Rulemaking. However, this preliminary “final report” specifies the starting point for the FAA’s NPRM.

Another aspect is cost:

  • Cost of devices
  • Cost of network access
  • Cost of network services (issuance of unique UAS ID, real-time tracking database, other services).

It seems likely that the potential costs of flying UAS, and model aircraft outside of approved flying fields, will likely be so high as to discourage most UAS flights but any one other than a commercial operation. This may, in fact, be the goal, as a way of clearing the airspace for commercial users.

Rupprecht Law summarizes the cost issue this way based on the 2018 FAA Reauthorization Act, which has been signed into law:

User fees for drones? Tells the Comptroller General of the United States to do a study on appropriate fee mechanisms to recover the costs of “the regulation and safety oversight of unmanned aircraft and unmanned aircraft systems” and “the provision of air navigation services to unmanned aircraft and unmanned aircraft systems.” Does this mean having unmanned aircraft flyers pay for UTM?

A sequence of FAA rule makings since 2001 largely eliminated the Part 103 ultralight aircraft scene by making it nearly impossible to obtain two-seater training in an ultralight aircraft. This was done because of Homeland Security’s fear that ultralights could be used for some sort of terror operations. Through clever rulemaking, the FAA basically snuck a series of rules into existence that de facto eliminated most ultralight training.

My suspicion is that Homeland Security, especially, would like to largely eliminate the operation of small model aircraft by the general public. Politically, they cannot quite do that. But they can, working with the FAA, push through a set of rules that will confine model aircraft to authorized flying fields, or requiring commercial licenses (Part 107) and pricey remote ID and network services for all other flights.

Hopefully they will continue to allow flights in mostly rural Class G airspace. However, the recent FAA Reauthorization Bill permits the FAA to regulate toy quadcopters even in Class G airspace.

And by the way, yes, the new law gives the FAA Reauthorization Act gives the FAA permission to regulate children’s kites with this very general definition of model aircraft:

5) MODEL AIRCRAFT.—the term ‘model aircraft’ means an unmanned aircraft that is—

“(A) capable of sustained flight in the atmosphere;

“(B) flown within visual line of sight of the person operating the aircraft; and

“(C) flown for hobby or recreational purposes.

Since the FAA may now regulate “model aircraft”, and kites fall within the definition, kites will now be regulated by the FAA. This also likely means you will not be allowed to fly a kite inside a national park – as all unmanned aerial systems craft are already banned inside all national parks and Congress has just declared kites as a form of unmanned aircraft. Good grief.

By EdwardM