That headline might sound like clickbait. An outrageous lie designed to scare people.
It is not.
The FAA Remote ID proposal was published on 12/31/2019 and, as written today, would make almost all sUAS on the market today (Commercial and Non-Commercial) obsolete in just a few years.
I will focus on the commercial aspects here. But don’t assume that hobbyists or people that fly model aircraft will be exempt. If you have a model plane that you built with your father years ago – that too will be grounded or so limited as to be useless. For more information on that click here.
But, before we get there I want to start out by saying that I am pro-remote ID. It is a necessary step we need to take before the industry can reach its true potential.
But the FAA has obviously been misled by some powerful groups in writing this proposal. And I believe that, as written, it will stifle innovation, hand the technology lead over to other countries, and result in more people flouting the regulations and flying illegally.
The proposal is long at over 300 pages and, honestly, I’m still digging my way through it. But I wanted to put this out there to get people thinking and becoming active.
In due course, I will be commenting on the proposal on the FAA site, and I will publish my exact comments here for those that may wish to use my notes for their own comments. If you would like to receive a notification when that happens, please subscribe using the box on the right.
So, let’s get to it. What items in the proposal are causing such concern? I will list a few of them here, but I am sure there will be more in due course.
1. All existing drones become obsolete.
Under the proposal, there are three ways that you can legally fly. Standard, Limited and “UAS without remote ID”.
Limited limits flights to just 400ft – in all directions – from the operator.
Upgrading your existing drones to this standard may be possible using software, but 400ft isn’t even far enough to perform a basic realtor shoot on a medium-sized house. For me, this is a non-starter.
UAS without remote ID is also limited to 400ft, but can only fly at pre-designated locations. One assumes these will be AMA fields, but that is still TBD. But, obviously, from a commercial standpoint, this is also not workable.
That leaves us with only one option available for any sort of commercial work. Standard Remote ID
Standard Remote ID requires a number of things that simply do not exist on the vast majority of drones out there today. Namely, that the drone (not the tablet) must be able to continuously broadcast information including the ID, the location of the drone, and the location of the operator. The ground station must also have a GPS location and a means of recording barometric pressure.
This means that each drone will need broadcast capability built into it that complies with the ANSI/CTA-2063-A serial number standard. None of my existing drones have that and, I will wager, yours don’t either. And upgrading that will not be a cheap fix.
It also states that you should be broadcasting the location of the drone and the operator, including the operator altitude. And that this needs to simultaneously be transmitted to the Internet for data collection, meaning a data plan is required.
The tablets I use do not have the necessary capabilities for the operator location. When working I use either a Wifi-only iPad or a Crystal Sky monitor. Neither of those has a barometer nor GPS capability. Do not get confused with the approximate location that is generated using cell/wifi data. That is not the same.
Once this change goes into effect I won’t just have to buy new drones, I will have to buy new tablets, plus a data plan for each drone.
2. Publishing the location of the operator will lead to conflict.
As written the location of the operator will be continuously published and, crucially, made available to the public via an app.
I don’t hide when I am flying. In fact, I often wear a Day-Glo vest.
But publicizing this information is a huge problem given that the general public has a very poor, and often badly misguided, understanding of FAA regulations.
Most people (for example) believe that they own the airspace over their house, and will challenge you if you are hovering trying to get a good angle for the realtor shot. Others will simply assume you are spying or doing some other nefarious activity.
I can see this as an open invitation for pilots to be repeatedly disturbed while flying at best and attacked by angry neighbors or muggers at worst.
I don’t mind the police having access to my details. I don’t mind the public having access to my ID and calling the police. But broadcasting my location is recipe for disaster IMHO and will lead to bad things. Several pilots I know are saying if this goes into effect they will have start carrying items for self-defense. Some already do.
And I can’t even imagine how worried out female pilots must feel knowing that their location is being broadcast via the internet in real-time.
3. Increased cost
Once the FAA Remote ID requirement goes into effect, a number of new costs will be added.
- An unlimited data plan drone will be the first requirement to continuously transmit the location information. And there is a rumor that the FAA is being pushed to specify 5G as a requirement, possibly even directly from the drone. Given that 5G isn’t really a thing yet, there is zero chance this will have the necessary coverage by the time this goes into effect.
- The new hardware needed will require extra features including drone broadcast capabilities, ground station GPS and barometers, which will drive up costs over time.
- This new system requires a network of Remote ID UAS Service Suppliers (Remote ID USS) that would collect the identification and location in real-time from in-flight UAS under contract with the FAA. Each USS is expected to require a subscription to their service, which will almost certainly be charged for.
4. Loss of innovation in the global drone industry.
The proposal requires that each “UAS producer” produce a significant amount of documentation and have increased security requirements in the hardware for any drone they build.
The FAA estimates that the test report and/or substantiating data would average 50 pages and would take five hours per page to generate.
This means, if I want to build a drone in my basement (something I have done many times in the past with my children) I will need to produce a 50-page legal document at 5 hours per page (FAA estimates) if I want to fly it further than 400 ft away.
Assuming a very conservative cost of a lawyer being $150 per hour, that equates to $37,500 in legal fees and filings before I can take off. And that is on the low end!
The FAA’s own analysis estimates costs over the ten-year period of analysis for producers to perform tests and generate substantiating data to support their DOC is approximately $25.2 million
This will, in a stroke, kill the hobby and small businesses that are the innovation leaders and the pipeline of future engineers. The USA is already far behind in terms of drone technology (DJI is, by far, the leader in all but some specialist areas).
By putting this in without an acceptable means for individuals or small producers to avoid this exorbitant cost, we might as well admit that we have ceded air superiority in drone capability other countries.
How do I get involved?
All is not lost! We are in the period where the FAA is accepting comments on these proposals. One thing that we learned from the Part 107 rulemaking was that if enough people spoke up we could get things changed. And that is what we need to do now!
To get involved, visit the FAA site here and submit a formal comment. Just remember that all comments are public, so keep your comments PG-rated.
And we have a little time. As of today, we have about 60 days, so take your time and make sure your comment is helpful.
Point out where they have gone wrong, why the costs are problematic, why the range limitations are not sensible etc. Just saying “It’s not fair”, “This is stupid”, or “This is just more government overreach” isn’t going to do anything. If you are taking the time to comment, make sure the comment counts!!
And stay tuned for future updates.