On Saturday, September 16, 2023, the world of uncrewed aircraft systems will change forever as the Federal Aviation Administration’s rules on remote identification come into effect. As a remote pilot, it’s not too soon to be asking, “What does this mean for me?”
In 2021, the Federal Aviation Administration (FAA) managed a feat that no one else has ever accomplished, before or since: it brought together the diverse factions of the small uncrewed aircraft system (sUAS) community. For one, glorious moment recreational pilots, commercial operators, aircraft manufacturers, industry advocates, educational institutions, first responders, trade associations and even crewed aviation groups were united in a common cause: criticizing the FAA.
What had the agency done to earn this universal opprobrium? Merely released its long-awaited proposal for the rules to govern Remote Identification, also known as Remote ID and RID. This raises two important questions:
• What is Remote Identification?
• What was wrong with the agency’s initial proposal?
As a concept, RID is not at all controversial within the sUAS community. In fact, most industry participants regard it as a necessary and inevitable step in the full integration of drones into the National Airspace System (NAS). At its most fundamental level, RID serves the same function for UAS that license plates serve on cars: it is a means of identifying the vehicle’s operator and providing accountability if that person breaks the rules.
However, unlike cars and crewed aircraft, external markings are not sufficient because small UAS are, well, so small. Unless you are physically holding the aircraft in your hand, you are unlikely to be able to read the registration number. Therefore, from the very start, RID was conceived of as some sort of signal or transmission that each UAS would send out including a unique identification code that could be traced back to its operator, and potentially other information, as well — such as aircraft telemetry.
To accomplish this, two fundamental concepts were developed: “Broadcast ID” and “Network ID.” Broadcast ID would equip each aircraft with a low-power radio transmitter, similar to the ones used in WiFi and Bluetooth accessories. Anyone in the vicinity of a UAS could use a smart phone with the right app installed to “read” this license plate.
Network ID, on the other hand, would require each aircraft to establish a connection to the cellular telephone network and share its unique identifier and other information with an online system in real time. Members of the public could access this data via the Internet to retrieve the “license plate” of an aircraft operating in their vicinity — accomplishing the same outcome as the broadcast variant.
In both cases, only this unique identifier would be visible to the general public, who could then share it with law enforcement if they observed suspicious or reckless operations. The authorities could then access the FAA database of remote pilots to retrieve the name and other personal information of the UAS operator to further investigate and take enforcement action, if necessary.
By 2019, industry consensus had coalesced around the Broadcast ID concept, formalized by the FAA’s own Aviation Rulemaking Committee (ARC). Comprised of 74 industry stakeholders, including numerous representatives of law enforcement, it recommended the agency move ahead with the Broadcast ID alternative.
Off the Rails
On December 31, 2019, the FAA shocked the industry by unveiling a proposed RID rule that called for a cumbersome Network ID system. Not only would the proposed system require UAS to access the cellular network, it would require operators to pay a monthly fee for this service. The agency estimated the cost would be $2.50 per month. A well-respected international consulting firm hired by DJI put the price at $10 per month.
Cost aside, the system would require a connection to the cellular network for the UAS to take off. This was a non-starter among users who operate drones in remote areas where cell service is spotty or non-existent, as well as emergency responders, who pointed out that cellular service can be knocked out by the very disasters—such as flooding and wildfires—that they need UAS to help manage. This approach also created the nightmare scenario that the entire U.S. drone fleet could be taken off-line by a cyber attack targeting the nation’s communications infrastructure.
Furthermore, since the required network connection would need to be embedded within the flight control system of every UAS, all aircraft built prior to the implementation of the proposed rule would have to be permanently grounded. For the model aviation community, the proposal represented an existential threat.
As has already been established, this proposal evoked a collective response from the industry that could best be characterized as, “Oh, hell no!” The FAA received more than 53,000 public comments on the rule, the vast majority of them stating their strong opposition to the Network ID approach. Stung by this swift and negative response, the FAA slinked back to its Washington, D.C., headquarters to reconsider its position.
Nearly a year later, on December 28, 2020, the agency released its final rule for RID, setting the standard that the remote pilots would be required to meet moving forward.
Back on Track
The FAA’s announcement was greeted with relief throughout the industry, as the agency opted for a system based exclusively on Broadcast ID. Furthermore, it created a basis for legacy UAS—such as older drones built prior to the introduction of RID, as well as model airplanes flown for recreation—to comply with the new rule.
Under the new system, UAS operators will have three options to comply with RID requirements:
• Fly a Standard RID Drone, that is: one with a Broadcast ID unit integrated into its flight control system;
• Fly a drone equipped with an RID Broadcast Module: a self-contained, external accessory that can be attached to an existing UAS; or
• Fly in an FAA-Recognized Identification Area (FRIA), where UAS are allowed to operate without any RID capabilities.
We’ll begin by taking a look at the “Standard RID Drone.” None of these exist yet, since the standards have just been released and aircraft manufacturers have yet to incorporate them into their designs. To comply with the new rule, every drone sold beginning on September 16, 2022 will need to include an RID system.
From takeoff to shut down, standard RID UAS will be required to broadcast a message on WiFi/Bluetooth frequencies that includes:
• An identification code unique to that individual aircraft;
• The aircraft’s current location, altitude and velocity;
• The current location of the aircraft’s ground control station (GCS);
• The current time; and,
• Whether or not the aircraft is experiencing an emergency.
An interesting consequence of this standard is that all UAS will now be required to incorporate GPS receivers into the GCS, so that this information can be shared via the RID transmission. Currently, most drones record their take-off location as a proxy for the location of the GCS, and this is a reasonable assumption in most cases.
However, if you have ever been operating from a boat and engaged your aircraft’s return-to-home function, you have likely come to the panicked realization that this isn’t always true. Furthermore, a bad actor intent on using a UAS to cause harm would be smart to change locations after launching their aircraft—an evasive maneuver much less likely to be effective when their drone is broadcasting their real-time whereabouts throughout the flight.
Keep on Flyin’
Along with abandoning the concept of Network ID, the FAA’s decision to permit the use of external RID modules is a crucial change from its earlier proposal — one that will allow all UAS sold prior to September 16, 2023 to continue operating in the NAS. Under the agency’s original draft, all of these aircraft would have been grounded, permanently.
With this concession, those aircraft can continue to be flown, provided that an active RID Broadcast Module is attached to it throughout the duration of the flight. These units will be required to transmit:
• A unique identification code;
• The aircraft’s current location, altitude and velocity;
• The location where the aircraft was launched; and,
• The current time.
There are a few details worth noting that distinguish drones using these external modules from the RID Standard UAS that fully integrate this capability. To begin with, because the RID Broadcast Module is completely separate from the aircraft, it will have its own serial number. That serial number must be listed on the aircraft registration certificate, which includes the aircraft’s own serial number — thereby establishing a connection within the FAA database between the module, the aircraft and the operator.
The FAA makes explicitly clear that recreational remote pilots will be able to move a single RID Broadcast Module between different aircraft, as all recreational aircraft owned by an individual share the same registration number. Commercial pilots can also move a single RID broadcast module between different aircraft. However, every time the module is moved, the operator will be required to update their aircraft registration in the FAA Drone Zone, making the process much more cumbersome.
In addition, because the RID Broadcast Module will transmit both the aircraft’s current location and its launch point — as a substitute for the GCS location — it will necessarily incorporate its own, internal GPS receiver, as it will not have access to the aircraft’s flight control system in order to obtain that information. This fact reveals something about the characteristics of these modules: specifically, their size and price.
At a minimum, these will necessarily incorporate a battery, a GPS receiver, WiFi/Bluetooth transmitter, a limited computer processor and memory. While we cannot know what some clever manufacturer will come up with to meet the demand for RID Broadcast Modules, there are some broadly similar products sold today: specifically, GPS-enabled pet trackers.
A quick Internet search reveals that these generally cost between $50 and $100 and weigh between 20 and 30 grams. This may be negligible on a Mavic Pro 2 that costs $1,600 and weighs nearly a kilogram, but it could have a significant impact if you’re flying a small recreational aircraft. There is some good news for recreational pilots: if your aircraft weighs less than 250 grams (a little more than a half pound), you will not be required to equip it with an RID module.
The final option to comply with the new RID rule requires no technology changes at all. Rather, it relies on limiting operations to geographically defined areas referred to as FAA-Recognized Identification Areas (FRIAs). Under the new regulations, only community-based organizations (CBOs) and educational institutions—to include primary and secondary schools, colleges, universities and trade schools—are eligible to establish a FRIA through a formal application process to the FAA.
As defined by the FAA Reauthorization Act of 2018, a CBO is a non-profit, tax-exempt organization with the goal of supporting the hobby of model aviation. It must provide a comprehensive set of safety guidelines for recreational UAS operations, support local clubs and affiliates and support the development of model aircraft flying sites.
If all of that sounds familiar, it’s because the Academy of Model Aeronautics (AMA)—which fulfills every one of those requirements—helped write the original definition of a CBO in the FAA Modernization and Reform Act of 2012. The FAA has resisted actually naming the AMA a CBO ever since, but it now appears inevitable with the release of the final RID rule.
The goal of creating FRIAs is to promote the continuation of the hobby of model aviation, as well as promoting aviation education and the study of science, technology, engineering and math (STEM) more generally—thus the addition of educational institutions as potential applicants for this designation.
The FAA declined to further expand the list of entities that are allowed to apply for FRIA status, specifically excluding units of state and local government as well as private land owners. The agency reasoned that if local governments could request FRIA designations, the number and size of these areas might begin to dilute the overall goal of having most UAS transmitting RID signals. Some land owners regarded their inability to create a FRIA over their own land as impinging on their property rights. Again, the FAA decided against this argument as part of its broader goal to achieve near universal compliance with the RID technology requirements, except when establishing a FRIA serves well-established recreational or educational activities.
One of the biggest controversies regarding the draft RID proposal is that it would have only allowed the creation of FRIAs during a 12-month window following the approval of the rule, and never again. This meant as RC flying clubs moved or shut down, those designated areas would be lost permanently and would not be replaced. The final rule allows new FRIAs to be created into the indefinite future. The FAA will begin accepting applications on September 16, 2023.
Who Wins? Who Loses?
There can be no doubt that the big winner out of the FAA’s final RID rule is the UAS industry itself. RID is a crucial step along the path to full integration of drones into the NAS. It’s a prerequisite for routine operations beyond visual line of sight (BVLOS), which is itself essential to applications such as package delivery, linear infrastructure inspection, large-scale surveying and countless other applications that will save money and lives in the years ahead.
Participants in the traditional hobby of model aviation likely won’t consider these regulations to be a win, except when compared with the waking nightmare that was the FAA’s original draft proposal. If small, civilian UAS technology had somehow never been invented, no doubt another generation of recreational remote pilots would still be enjoying flying their models unfettered by any FAA regulations at all, apart from a single page of guidance furnished the original Advisory Circular
Still, the hobby will largely continue as before—maybe with a little more paperwork—and that clearly isn’t a loss.
Perhaps the most remarkable aspect of this whole, years-long drama is that the government regulatory process worked, just like we learned it is supposed to in our high school civics class. Sure, it caused some frustrations and a few moments of blind panic and terror along the way, but the process yielded a workable compromise that not everyone will agree is perfect, but everyone can tolerate and respect moving forward.
The key to success, and peace of mind, as we move toward full integration of UAS into the NAS is to remember this lesson: at any given moment, it may appear that the whole enterprise is about to come crashing down. However, if we are patient and, more importantly, if we participate in the process, we can still reach a good outcome.
What About Recreational Operations?
Recreational flying will be treated like every other type of remotely piloted operation under the FAA’s new RID rule. This continues a trend over the past several years that has erased the distinction between “drones” and “model aircraft.” Both are recognized as UAS, with the only difference being the motivation of the pilot: for enjoyment or to earn money.
If you want to spend $50,000 on a DJI M300 RTK with a high-resolution electro-optical/infrared payload and fly it around your backyard for fun, it is perfectly legal to label it with your recreational registration number, just like a $150 foamie. However, if you want to fly a $150 foamie in a local park, it will need to comply with the RID rules by September 16, 2023.
The FAA clearly anticipates that many radio-controlled flying clubs and academic institutions will be able to avoid installing RID hardware by establishing their venues as FRIAs — FAA-Recognized Identification Areas. The agency will begin accepting applications to establish FRIAs from community-based organizations and schools on September 16, 2023.
What this means to the RC Hobby
The Academy of Model Aeronautics (AMA) has been working very closely with the FAA to make sure the effects of the new regulations with regard to traditional RC model aircraft models are minimal.
We reached out to the AMA’s Government Affairs Director, Tyler Dobbs, and discussed the situation and what it means to the future of our model airplane hobby. Here’s what we learned.
The Final Rule for Remote ID of Unmanned Aircraft was released on December 28, 2020 and the final rule grouped all drones, and model aircraft under the single designation of UAS or unmanned Aerial System. So whether you fly a quadcopter, an RC sport plane, or a scale P-51 Mustang, if you pilot it in U.S. airspace, you will have to follow the Remote ID rules.
In the beginning, these rules were very prohibitive for the recreational modeler but the AMA did a great job working with the FAA and paring back many of the requirements. Here’s a chart of the proposed and final standings for the rules.
Important changes to note from proposed rules to final rules
Here’s a simplified explanation.
THREE WAYS TO COMPLY:
1. Standard Remote ID
• Broadcast equipment built into UAS at a manufacturer’s level.
• Requires radio frequency spectrum to broadcast location, altitude, ID, emergency status, etc., for both UAS and its control station.
• UAS designed not to takeoff if not broadcasting signal.
• All UAS manufactured to fly in the National Airspace System need to meet standards and certification of the standard Remote ID requirements.
2. Broadcast Modules
• Module option allows for older (nonstandard) UAS.
• Sends same signal as standard, except no emergency status and no control information. The information will be UAS takeoff location and altitude instead. Module also needs to signal if not working properly.
• FAA anticipates modules to cost approximately $20 to $50.
• Visual-line-of-sight operations only.
3. FAA-Recognized Identification Areas (FRIAs)
• Valid for 48 months and renewal/changeable.
• Requires that the site be under the umbrella of a community-based organization or educational institute.
• Visual-line-of-sight operations only. The AMA interprets the use of a spotter for FPV to align with legislation (PL 115-254 sec. 349).
• Registration will remain $5 per individual every three years.
• Standard Remote ID registration must include serial numbers of all aircraft so equipped.
• Broadcast module registration must include serial number of broadcast module.
• Each effective date begins 60 days after publication in the Federal Register.
• Manufacturer producing a standard Remote ID UAS for operation–18 months.
• Manufacturer producing a Remote ID broadcast module– 60 days after publication date.
• Person operating in the national airspace–60 days and 30 months.
• Request FRIA status– 60 days and 18 months.
Note: Recreational UAS weighing below 250 grams will remain exempt from both Remote ID and FAA registration.
If you need to register with the FAA, go to faadronezone.faa.gov. Registration still needs to be renewed every 3 years and costs $5. Special events, such as RC airshows, fly ins, competitions or other temporary events, will have a path to receive authorization from the administrator to deviate from the Remote ID operation rules. Additionally, recreational and educational operators can “home build” UAS without meeting manufacturer certification standards. This allows homebuilt UAS (kit-built models, plans built and ARF airplanes etc.) to be operated at a FRIA or under option 2 (Broadcast Modules).
If you have any questions or concerns, contact the Government Affairs department at (765) 287-1256 or firstname.lastname@example.org.
Deadlines for RID Implementation
Government regulations go into effect when they are published in the Federal Register, a compendium of new and proposed rules, presidential documents and public notices. Established in 1936, the Federal Register is published at 6 a.m. every weekday, except for federal holidays. On average, this document expands by more than 70,000 pages each year—about 200 pages every day—and it is not exactly light reading.
Of course, the FAA and other federal agencies recognize that when they implement new technical requirements for an industry, such as RID, those industries need time to design, build and deploy the systems necessary to meet them. The clock starts ticking when the new rule is published in the Federal Register: January 15, 2021 in the case of RID.
UAS manufacturers have 18 months, until September 16, 2023, to have integrated RID modules installed on all of their new aircraft. Remote pilots will need to be in compliance with the new rules by September 16, 2023, either by flying an aircraft equipped with an integrated RID module, fitting an older aircraft with an external RID transmitter, or operating in an FAA-Recognized Identification Area (FRIA).