On December 19, the FAA's Unmanned Aviation System Identification and Tracking (UAS-ID) Aviation Rulemaking Committee (ARC) released a Final Report detailing its recommendations to the agency.
Earlier this year, the FAA chartered the ARC to assist in developing standards for the remote identification and tracking of unmanned. The ARC was tasked with three objectives:
- Identify, categorize and recommend available and emerging technologies for remote identification and tracking.
- Identify requirements for meeting the security and public safety needs of law enforcement, homeland defense, and national security communities for remote identification and tracking.
- Evaluate the feasibility and affordability of the available technical solutions, and determine how well they address the needs of law enforcement and air traffic control communities.
The UAS-ID ARC's Final Report is the culmination of meetings and discussions between unmanned aircraft industry and aviation community stakeholders, as well as manufacturers, researchers and standards groups.
The ARC presented two methods for UAS to provide remote ID and tracking information: direct broadcast and network publishing. Direct broadcast allows for data transmissions that can be received by any receiving station within the broadcast range. This method is reliable around sensitive areas where network coverage may not be readily available, such as airports, defense installations, and remote locations. Alternatively, network publishing requires data be transmitted to an approved Internet-based database that allows clients to access the ID and tracking information. The ARC noted that existing infrastructure under development by third party providers and UAS service suppliers could assist the FAA in deploying such capabilities.
The report also recommended that the FAA require UAS to transmit certain data, while making other data optional to transmit. For example, mandatory information would include the unique identifier of the aircraft, tracking information for the UAS and identifying information of the UAS owner and remote pilot, while optional data may include the mission type, route data, and operating status of the aircraft.
The ARC recommended a tiered approach to these broadcast and publishing requirements. For example, Tier 0 UAS would require no ID or tracking mechanism, eliminating UAS that are less capable or pose less of a threat to either safety or airspace. Tier 1 UAS would have the option of broadcasting or publishing to a network, while Tier 2 systems would be required to both broadcast and network publish ID and tracking data. Finally, Tier 3 systems would be required to adhere to the FAA's part 91 rules for manned aircraft.
The chief area of disagreement among members was the applicability of remote ID and tracking requirements. Some members preferred a capabilities-based approach focused either on aircraft with the ability navigate to multiple points without control of the operator or on aircraft with greater ranges and remotely viewable sensors. This standard raised some concerns among a subset of members that expressed concern it would inadvertently include a significant number of low-risk, traditional model aircraft. Other members favored a weight-based approach, arguing that it would be straightforward and familiar, promote compliance, and be future-proof to encompass technological developments.
The ARC ultimately provided two non-consensus recommendations based on the capabilities of the aircraft. In both cases, the committee recommended exempting aircraft operated under air traffic control and aircraft exempt by the FAA for law enforcement, national security, or other purposes.
The ARC first recommended that all UAS comply with remote ID and tracking requirements, except 1) those operated within the visual line of sight and with a range of less than 400 feet, and 2) those in compliance with the FAA's model aircraft rules, as long as they cannot navigate from one point to another without continuous input from the remote pilot and are not equipped with a real-time viewable sensor. Alternatively, the ARC recommended that aircraft with 1) the ability to navigate from one point to another without continuous input from the remote pilot, or 2) ranges of greater than 400 feet and real-time viewable sensors, be subject to remote ID and tracking requirements.
Regardless of the recommendation chosen by the FAA, the ARC clarified that the requirements should be applied to remote pilots, not to manufacturers of UAS. The ARC recommended, however, that manufacturers be required to label their products to indicate whether they are capable of meeting applicable remote ID and tracking requirements. The ARC also deferred to the FAA on the question of whether to exempt UAS equipped with advanced flight system technologies that are strictly for safety purposes from the remote ID and tracking requirements.
Regarding implementation, the ARC made several recommendations to the FAA. Prior to enactment of any rule, the ARC suggested the FAA broaden UAS safety education efforts, continue UAS detection research with industry, and devise standards to enable direct broadcast and network publishing technologies on both new and existing equipment. After enactment of the ID and tracking rule, the ARC recommended that the FAA provide a reasonable grace period to retrofit UAS manufactured and sold within the United States. The ARC also offered suggestions on the potential role for air traffic control in UAS ID and tracking and urged the FAA to consider the implementation costs of ID and tracking for airports and other critical infrastructure facilities.
Though the ARC's report focused on furthering its three objectives, it also identified a number of related issues for the FAA to consider in its deliberations. Specifically, the ARC noted that issues such as the extent to which information transmitted by UAS would be publicly accessible, the interoperability of remote ID and tracking systems with current and future programs, First Amendment and public education considerations, and harmonization of local, state, and federal legislation and regulations also impact implementation of effective UAS ID and tracking solutions and should be considered.
The UAS-ID ARC's Final Report reflects collaboration and input from the various stakeholders involved in the process. The Final Report fulfills the ARC's objectives by presenting the FAA with important recommendations regarding the remote ID and tracking of UAS. Though the ARC did not reach a consensus recommendation on all topics, the process was a positive step forward and better frames the remote ID and tracking debate, providing the FAA with valuable information that will assist the agency in developing rules of the road moving forward.