Regulators do a bad job of head faking, so they don’t. But, they do telegraph their moves with startling clarity. The audience saw this in action during FAA’s 2018 UAS Symposium in Baltimore on the subject of UAS remote identification. That four senior FAA executives championed the basic premise that drones should be identified and tracked should come as a surprise to no one. But what audience members heard suggests that this potential requirement will apply to nearly every registered user who flies a drone or model airplane. Currently, one million drone users reside in the FAA registry. To compound matters, the FAA expressed broad policy objectives for the integration of remote ID and tracking information into airspace operations and how this occurs without an equipage mandate on manufacturers is not understandable.
By way of background, 74 members of the FAA Unmanned Aircraft Systems (UAS) Identification and Tracking Aviation Rulemaking Committee (ARC) provided a series of recommendations to the Agency in December of 2017. The work of the ARC was based on the FAA provided premise that remote identification and tracking could be implemented. The ARC recommended two methods to the FAA for consideration (p.3). Of note, the ARC did not reach consensus on the threshold to govern which users would be subject to remote ID and tracking and provided for certain exemptions. (p.2.) The ARC also recommended that the remote ID and tracking requirement was the responsibility of the remote pilot and not the manufacturer.
Regarding the basic premise, FAA Deputy Associate Administrator, Angela Stubblefield summarized it best during her remarks when she said, “ID and registration are two important parts to [UAS] NAS integration.” This was seconded by FAA Deputy Chief Operating Officer, Tim Arel, who remarked, “to achieve true integration we need both.” FAA Associate Administrator, Ali Bahrami, completed the trifecta by affirming, “we definitely must have both.” When leaders in safety, ATC, and security use identical language on the same topic you can be assured this is set in stone policy of the Agency and not just opinions.
Clues to how broad a swath of registered drone operators may be impacted by remote ID and tracking was found in the ensuing policy discussion focused on the benefits to the NAS provided by such a system. Again, FAA comments provided valuable insights. In discussing key benefits, FAA representatives noted that UAS remote ID provides safety, air traffic control, security, and “post-incident education.” When referring to who needs education, FAA specifically pointed out "careless and inexperienced users." In agency talk this is everybody who is not flying under part 107. More precisely, RC model aircraft users and drone hobbyists. The same group that makes up the bulk of the 1M+ registered users.
Still not convinced of a broad mandate? Mike Reynolds, a top staffer at the Senate Commerce Committee, said in a following panel in response to a question on traditional model aircraft users, “a model exception will not apply to drone ID requirements.” While acknowledging the difference between a drone and a RC airplane he made it clear that the Senate was focusing on changes to small RC aircraft laws so as to include them in remote ID legislation.
The train has left the station on the remote ID debate. Both the agency and law makers have telegraphed in the most unmistakable way that if you have to register, you will have to comply with remote ID equipage.
The big question is: what UTM system will be able to enroll a million or more small aircraft and receive remote ID signals for tracking purposes? Don’t look at ADS-B. These frequencies are already congested to the point where serious discussion continues on altering TCAS software and other bandwidth intensive systems. Cellular maybe, but at a great cost. The practical effect of this policy decision is that manufacturers of all sizes of drone systems need to start thinking about engineering a transponder for their vehicles. But not only that, the transponder needs to be associated with a registration on the registry and provide a way for authorities to contact the operator of the vehicle in real time. That’s a big lift.