[continued from previous message]

investigating UAS incidents.
7 Additionally, part 107 allows individuals to request waivers from
certain provisions, including those prohibiting operations at night
and over people. This proposed
rule, in concert with the FAA’s proposed rule for operations over
people would create cost

7 This analysis includes quantified savings to the FAA only. A variety
of other entities involved with airport
operations, facility and infrastructure security, and law enforcement
would also save time and resources involved
with UAS identification and incident reporting, response and
investigation. The FAA plans to update its estimates of
savings for additional information and data identified during the
comment period and development of the final rule.
32
savings for the FAA and part 107 operators by avoiding the time
expended processing waivers
for these activities.8
The analysis of this proposed rule is based on the fleet forecast for
small unmanned
aircraft as published in the FAA Aerospace Forecast.9
The forecast includes base, low, and high
scenarios. This analysis provides a range of net impacts from low to
high based on these forecast
scenarios. The FAA considers the primary estimate of net impacts of
the proposed rule to be the
base scenario. For the primary estimate, over a 10-year period of
analysis this proposed rule
would result in net present value costs of about $582 million at a
three percent discount rate with
annualized net costs of about $68 million. At a seven percent discount
rate, the net present value
costs are about $474 million with annualized net costs of $67 million.
The following table
presents a summary of the primary estimates of the quantified costs
and cost savings of this
proposed rule. Additional details, including low and high estimates of quantified net costs, are
provided in the Regulatory Evaluation section of this proposal and in
the Preliminary Regulatory
Impact Analysis available in the docket for this rulemaking.
Table 2: Preliminary Estimates of Costs and Cost Savings of Proposed
Rule ($Millions)*
Base Scenario—Primary Estimate
Affected Entity/Category
10-Year
Present
Value
(at 3%)
Annualized
(at 3%)
10-Year
Present
Value
(at 7%)
Annualized
(at 7%)
UAS Owners/Operators $145.87 $17.10 $117.48 $16.73
Remote ID USS Subscription $241.72 $28.34 $191.74 $27.30

8 On February 13, 2019, the FAA published a notice of proposed
rulemaking titled “Operation of Small Unmanned
Aircraft Systems over People,” (84 FR 3856) in which the FAA proposed
to allow operations of small unmanned
aircraft over people in certain conditions and operations of small UAS
at night without obtaining a waiver.
9
FAA Aerospace Forecast Fiscal Years 2019-2039, available at https://www.faa.gov/data_research/aviation/aerospace_forecasts/media/FY2019-39_FAA_Aerospace_Forecast.pdf.
The forecast provides a base (i.e., likely) with high (or optimistic)
and low (or pessimistic) scenarios. The low and
high forecast scenarios are not symmetric around the base—please see
the forecast report for more information.
33
Affected Entity/Category
10-Year
Present
Value
(at 3%)
Annualized
(at 3%)
10-Year
Present
Value
(at 7%)
Annualized
(at 7%)
UAS Producers (US and Foreign) $134.58 $15.78 $111.58 $15.89
Developers of Remote ID Means of Compliance $2.85 $0.33 $2.36 $0.34
Remote ID USS Memoranda of Agreement $1.60 $0.19 $1.43 $0.20
Community Based Organizations $0.39 $0.05 $0.35 $0.05
FAA Costs $56.96 $6.68 $50.33 $7.17
Total Costs $583.98 $68.46 $475.27 $67.67
Cost Savings (reduced hours for FAA investigations) ($2.45) ($0.29)
($1.82) ($0.26)
Net Costs $581.52 $68.17 $473.46 $67.41
*Table notes: Column totals may not sum due to rounding and
parenthesis, “( )”, around numbers to indicate savings.
The FAA expects this proposed rule will result in several important
benefits and
enhancements to support the safe integration of expanded UAS
operations in the airspace of the
United States. The proposal would provide situational awareness of UAS operations to other
aircraft and airport operators. The proposed rule would provide
information to distinguish
compliant UAS users from those potentially posing a safety or security
risk. The following table
summarizes the benefits of the proposed rule.
Table 3: Summary of Benefits of Proposed Rule
Safety and Security ? Provides situational awareness of UAS flying in
the airspace of
the United States to other aircraft in the vicinity of those
operations and airport operators.
? Provides information to distinguish compliant UAS users from
those potentially posing a safety or security risk.
? Enables the FAA, national security agencies, and law
enforcement entities to obtain situational awareness of UAS in
the airspace of the United States in near real-time.
? Provides additional registration and notification requirements
for identifying aircraft and promoting accountability and the
safe and efficient use of the airspace of the United States.
Enables Expanded
Operations and
UAS Integration
? Assists in the implementation of operations of small UAS over
people and at night. A final rule for operation of small UAS
over people and at night is contingent upon a final action for
UAS with remote identification being in effect.
34
? Provides UAS-specific data to facilitate future, more advanced
operational capabilities, such as detect-and-avoid and
aircraftto-aircraft communications that support beyond visual line of
sight (BVLOS) operations.
? Provides UAS-specific data to develop a comprehensive UAS
traffic management (UTM) system that would facilitate the
safe expansion of operations.
In addition, the proposed rule provides flexibility through minimum
performance
requirements that would accommodate future innovation and improve the efficiency of UAS
operations. The proposal also does not preclude early compliance for
UAS producers or
operators to realize earlier expanded operations and commercial
opportunities.
E. Structure of this Proposed Rule
This proposed rule addresses remote identification of UAS from a
number of
perspectives: UAS owners, UAS operators, UAS designers and producers, developers of remote
identification means of compliance, and Remote ID USS. The FAA
recognizes that certain
persons may only be interested in certain topics. Therefore, the
following provides the structure
of this proposed rule.
Section II of this preamble discusses the FAA’s legal authority for promulgating this
proposed rule.
Section III of this preamble discusses the integration of UAS into the
airspace of the
United States. The complexities surrounding the full integration of
UAS into the airspace of the
United States has led the FAA to engage in a phased, incremental, and risk-based approach to
rulemaking based on the statutory authorities delegated to the agency.
35
Section IV of this preamble discusses the need for remote
identification of UAS
operating in the airspace of the United States. The section addresses
the role of the FAA as the
United States civil aviation authority and air navigation service
provider, current registration
requirements and how those requirements do not provide information
responsive to remote
identification, current cooperative surveillance for manned aircraft,
and the need for situational
awareness. The section further explains how remote identification of
UAS fits within the FAA’s
compliance and enforcement programs. The section describes how the FAA envisions remote
identification may facilitate beyond visual line of sight (BVLOS)
operations in the future. The
potential benefits of remote identification of UAS to national
security and law enforcement
agencies are noted.
Section V of this preamble discusses related international activities.
Section VI of this preamble provides a summary of the Unmanned
Aircraft Systems
(UAS) Identification (ID) and Tracking Aviation Rulemaking Committee
(ARC) (UAS-ID ARC)
report and the FAA’s response to that report.
Section VII of this preamble discusses the new terms to be defined as
part of this
proposed rule.
Section VIII of this preamble describes the applicability of the
proposed rule. It also
discusses the framework of the following sections: operating
requirements for UAS with remote
identification, means of compliance, and design and production
requirements.
Section IX of this preamble discusses the current registration
requirements for unmanned
aircraft under part 47 and part 48 and the issues with the current
registration requirements in light
of the need for remote identification of UAS. The section also
discusses the FAA’s proposed
36
revision of the registration requirements of part 48 to require the
individual registration of
unmanned aircraft and the proposed use of unmanned aircraft serial
numbers as unique
identifiers for remote identification purposes.
Section X of this preamble explains the operating requirements related
to remote
identification of UAS. It describes the requirements for standard
remote identification UAS and
limited remote identification UAS. It also discusses the proposed
requirements for UAS without
remote identification. The section provides the proposed requirements
to transmit and broadcast,
as appropriate, message elements. It discusses the FAA’s proposal to
prohibit the use of ADS-B
Out to satisfy remote identification of UAS. Finally, it discusses UAS operators’ requirement to
operate a UAS with remote identification only if that UAS is listed on
a valid FAA-accepted
declaration of compliance.
Section XI of this preamble discusses law enforcement access to remote identification
information.
Section XII of this preamble discusses the FAA’s proposed requirements
for what an
FAA-accepted means of compliance for remote identification would
contain. The FAA is
proposing that any FAA-accepted means of compliance contain
requirements regarding the
message elements to be transmitted and the minimum performance
requirements for the
transmission and broadcast, as appropriate, of those elements. The
section discusses the process
to submit and have the FAA accept a means of compliance, and data
retention requirements for
submitters of means of compliance. The section also discusses other requirements the FAA
considered in the development of this proposed rule.
Section XIII of this preamble provides the proposed design and
production requirements.
It discusses the proposed requirement that producers of standard
remote identification UAS and
37
limited remote identification UAS issue serial numbers for UAS and
that persons producing
UAS with remote identification would be required to do so in
accordance with the minimum
performance requirements of the proposed rule using an FAA-accepted
means of compliance.
The section also describes the requirement for producers to submit a declaration of compliance,
followed by a description of the process for FAA acceptance of
declarations of compliance,
rescission of those declarations, and the right of a person who
submitted the FAA-accepted
declaration of compliance or any person adversely affected by the
rescission of the
Administrator’s acceptance of a declaration of compliance to petition
for reconsideration of a
rescission. Finally, the section discusses data retention requirements
for producers submitting
FAA-accepted declarations of compliance.
Section XIV of this preamble discusses the role of Remote ID USS. The
section describes
the FAA’s vision regarding the role of Remote ID USS in providing
remote identification
services as well as how they will be established and what data
provided to them will be publicly
available. The section also describes the FAA’s vision for data
privacy and information security.
Section XV of this preamble provides the overarching requirements for FAA-recognized
identification areas to be used by UAS that cannot, or do not, comply
with the proposed remote
identification requirements.
Section XVI of this preamble discusses the circumstances under which
the use of ADS-B
Out and transponders for UAS would be prohibited.
Section XVII of this preamble provides the proposed effective dates
and compliance
dates.
Section XVIII of this preamble discusses the proposed guidance
documents.
38
Sections XIX and XX of this preamble address the FAA’s requirements to
comply with
various statutes and Executive Orders pertaining to all regulations.
Section XXI of this preamble discusses the tribal considerations
related to this proposed
rule.
Section XXII of this preamble discusses the privacy impact analysis
the FAA conducted
as part of this proposed rule.
Section XXIII of this preamble provides additional information to
persons wishing to
provide comments to this proposed rule.
II. Authority for this Rulemaking
The FAA’s authority to issue rules on aviation safety is found in
Title 49 of the United
States Code (49 U.S.C.). Subtitle I, section 106 describes the
authority of the FAA
Administrator. Subtitle VII, Aviation Programs, describes in more
detail the scope of the
Agency’s authority.
This rulemaking is promulgated pursuant to 49 U.S.C. 40103(b)(1) and
(2), which direct
the FAA to issue regulations: (1) to ensure the safety of aircraft and
the efficient use of airspace;
and (2) to govern the flight of aircraft for purposes of navigating,
protecting and identifying
aircraft, and protecting individuals and property on the ground. In
addition,
49 U.S.C. 44701(a)(5) charges the FAA with promoting safe flight of
civil aircraft by prescribing
regulations the FAA finds necessary for safety in air commerce and
national security.
Section 2202 of Pub. L. 114-190 requires the Administrator to convene
industry
stakeholders to facilitate the development of consensus standards for
remotely identifying
39
operators and owners of UAS and associated unmanned aircraft and to
issue regulations or
guidance based on any standards developed.
The Administrator is granted the authority under 49 U.S.C. 44805 to
establish a process
for, among other things, accepting risk-based consensus safety
standards related to the design
and production of small UAS. Under 49 U.S.C. 44805(b)(7), one of the considerations the
Administrator must take into account prior to accepting such standards
is any consensus
identification standard regarding remote identification of unmanned
aircraft developed pursuant
to section 2202 of Pub. L. 114-190.
Additionally, section 44809(f) of 49 U.S.C. provides that the
Administrator is not
prohibited from promulgating rules generally applicable to unmanned
aircraft, including those
unmanned aircraft eligible for the exception for limited recreational operations of unmanned
aircraft. Among other things, this authority extends to rules relating
to the registration and
marking of unmanned aircraft and the standards for remotely
identifying owners and operators of
UAS and associated unmanned aircraft.
The FAA has authority to regulate registration of aircraft under 49
U.S.C. 44101–44106
and 44110–44113, which require aircraft to be registered as a
condition of operation and
establish the requirements for registration and registration
processes.
Finally, this rulemaking is promulgated under the authority described
in 49 U.S.C. 106(f),
which establishes the authority of the Administrator to promulgate
regulations and rules, and
49 U.S.C. 40101(d), which authorizes the FAA to consider in the public interest, among other
things, the enhancement of safety and security as the highest
priorities in air commerce, the
regulation of civil and military operations in the interest of safety
and efficiency, and assistance
40
to law enforcement agencies in the enforcement of laws related to
regulation of controlled
substances, to the extent consistent with aviation safety.
III. Integration of UAS into the Airspace of the United States
The rapid proliferation of UAS has created significant opportunities
and challenges for
their integration into the airspace of the United States. The
relatively low cost of highly capable
UAS technology has allowed for hundreds of thousands of new operators
to enter the aviation
community.
The complexities surrounding the full integration of UAS into the
airspace of the United
States have led the FAA to engage in a phased, incremental, and
risk-based approach to
rulemaking based on the statutory authorities delegated to the agency.
On December 16, 2015,
the FAA and DOT jointly published an interim final rule in the Federal
Register titled
Registration and Marking Requirements for Small Unmanned Aircraft (“Registration Rule”),10
which provided for a web-based aircraft registration process for small
unmanned aircraft in
14 CFR part 48, to serve as an alternative to the registration
requirements for aircraft established
in 14 CFR part 47. The Registration Rule imposed marking requirements
on small unmanned
aircraft registered under part 48 to display a unique identifier in a
manner that is visible upon
inspection. This unique identifier could be the registration number
issued to an individual or to
the aircraft by the FAA Registry or the small unmanned aircraft’s
serial number if authorized by
the Administrator and provided with the application for the
certificate of aircraft registration.

10 80 FR 78594.
41
On June 28, 2016, the FAA and DOT jointly published the final rule for Operation and
Certification of Small Unmanned Aircraft Systems (“The 2016 Rule”) in
the Federal Register.
11
This was an important step towards the integration of civil small UAS operations (for aircraft
weighing less than 55 pounds) into the airspace of the United States.
The 2016 Rule set the initial
operational structure and certain restrictions to allow routine civil operations of small UAS in the
airspace of the United States in a safe manner. Prior to the 2016
Rule, the FAA authorized
commercial UAS operations, including real estate photography,
precision agriculture, and
infrastructure inspection, under section 333 of Pub. L. 112-95. Over
5,500 operators received this
authorization. The FAA also issued over 900 Certificates of Waiver or Authorization (COA),
allowing Federal, State, and local governments, law enforcement
agencies, and public
universities to perform numerous tasks with UAS, including
search-and-rescue, border patrol,
and research. The 2016 Rule allows for certain operations of small UAS
in the airspace of the
United States without the need for airworthiness certification,
exemptions, or certificates of
waiver or authorization.
The 2016 Rule also imposed certain restrictions on small UAS
operations. The
restrictions include a prohibition on nighttime operations,
limitations on operations conducted
during civil twilight, restrictions on operations over people, a
requirement for all operations to be
conducted within visual line of sight, and other operational,
airspace, and pilot certification
requirements. Since the rule took effect on August 29, 2016, most
low-risk small UAS
operations that were previously authorized on a case-by-case basis
under Pub. L. 112-95
section 333 are now considered routine operations. These operations
are now permitted within

11 81 FR 42064.
42
the requirements of part 107 without further interaction with the FAA. Publishing Part 107 was
the first significant regulatory step to enable lower risk, less
complex UAS operations.
Part 107 opened the airspace of the United States to the vast majority
of routine small
UAS operations, allowing flight within visual line of sight while
maintaining flexibility to
accommodate future technological innovations. Part 107 allows
individuals to request waivers
from certain provisions, including those prohibiting operations over
people and beyond visual
line of sight. Petitions for waivers from the provisions of part 107
must demonstrate that the
petitioner has provided sufficient mitigations to safely conduct the
requested operation.
On October 5, 2018, Congress enacted Pub. L. 115-254, also known as
the FAA
Reauthorization Act of 2018. The FAA Reauthorization Act of 2018
amended Part A of
subtitle VII of title 49, United States Code by inserting a new
chapter 448 titled Unmanned
Aircraft Systems and incorporating additional authorities and mandates
to support the further
integration of UAS into the airspace of the United States, including
several provisions that
specifically deal with the need for remote identification of UAS.
Section 376 of the FAA
Reauthorization Act of 2018 requires the FAA to perform testing of
remote identification
technology and to assess the use of remote identification for the
development of UTM.
Additionally, congressional action supports the implementation of
remote identification
requirements for most UAS. Section 349 of the FAA Reauthorization Act
of 2018 included a
provision indicating that the Administrator is not prohibited from
promulgating rules relating to
the standards for remotely identifying owners and operators of UAS and associated unmanned
43
aircraft.
12 The provision denotes Congress’s acknowledgment that remote
identification is an
essential part of the UAS regulatory framework. Section 349 also does
not prohibit the
Administrator from promulgating rules generally applicable to unmanned
aircraft related to
updates to the operational parameters for unmanned aircraft used for
limited recreational
operations, the registration and marking of unmanned aircraft, and
other standards consistent
with maintaining the safety and security of the airspace of the United
States.
13
Lastly, on February 13, 2019, the FAA published three rulemaking
documents in the
Federal Register as part of the next phase for integrating small UAS
into the airspace of the
United States. The first of such documents was an interim final rule
titled “External Marking
Requirement for Small Unmanned Aircraft,”14 in which the FAA required
small unmanned
aircraft owners to display the registration number assigned by the FAA
on an external surface of
the aircraft. The second rulemaking document was a notice of proposed rulemaking titled
“Operation of Small Unmanned Aircraft Systems Over People,”15 in which
the FAA proposed to
allow operations of small unmanned aircraft over people in certain
conditions and operations of
small UAS at night without obtaining a waiver. The third rulemaking
document was an advance
notice of proposed rulemaking titled “Safe and Secure Operations of
Small Unmanned Aircraft
Systems,”16 in which the FAA sought information from the public on
whether and under which
circumstances the FAA should promulgate new rules to require stand-off distances, additional
operating and performance restrictions, the use of UAS Traffic
Management (UTM), additional

12 See 49 U.S.C. 44809.
13 Id.
14 84 FR 3669.
15 84 FR 3856.
16 84 FR 3732.
44
payload restrictions, and whether the agency should prescribe design requirements and require
that unmanned aircraft be equipped with critical safety systems.
IV. Need for Remote Identification of UAS Operating in the Airspace of
the United States
A. Maintaining the Safety and Efficiency of the Airspace of the United
States
The FAA is both the civil aviation authority and the air navigation
service provider
(ANSP) for the United States. The FAA has statutory responsibilities
to set standards and certify
aircraft, airmen, and facilities. In addition, the FAA is responsible
for ensuring the safe and
efficient use of navigable airspace. The FAA carries out its
responsibilities by developing air
traffic rules, assigning the use of airspace, and controlling air
traffic through a complex network
of airport towers, air route traffic control centers, and flight
service stations.
The FAA is responsible for serving tens of thousands of commercial and
private aircraft
operating in 29 million square miles of airspace each day. Through its
air traffic management
(ATM) system, the FAA coordinates the movements of these aircraft to
ensure they operate at
safe distances from each other and manages disruptions to normal air
traffic flow. The FAA’s
ability to manage air traffic in the airspace of the United States is predicated on the agency
knowing who is operating in the airspace and, if necessary, on being
able to communicate with
those airspace users.
1. Existing Cooperative Surveillance System
The ATM system relies on appropriately equipped aircraft to provide
the surveillance
services necessary to ensure the safety and efficiency of the airspace
of the United States. In
addition to ground-based equipment such as primary and secondary
radar, participating aircraft
45
use ATC transponders and ADS-B Out to participate in the ATM’s
cooperative surveillance
environment. Transponders emit a radio frequency response when they
are interrogated by
ground-based secondary radar systems. Part of the response is the Mode
3/A code which is a four
digit number ranging from 0000 to 7777 that allows ATC to identify
aircraft under radar
surveillance and correlate the target to a flight plan. Other
information provides ATC with the
location of the aircraft, which is shown on ATC radar displays. After
January 1, 2020, aircraft
will be required to equip with ADS-B Out to operate in certain
airspace.
Some UAS, such as those operating in Class A airspace, are already
equipped with
transponders and ADS-B Out and operate in accordance with existing
rules. But for the
majority of UAS, especially those operating at low altitudes, the
existing cooperative
surveillance system is not capable of providing the necessary
services.
Currently, there is no regulatory requirement mandating the remote identification of
unmanned aircraft other than the existing equipment rules in part 91
for transponders that are
applicable to aircraft in certain airspace and ADS-B Out, which will
be required for aircraft in
certain airspace after January 1, 2020. Because the majority of UAS
operations occur at low
altitudes, the existing rules do not adequately provide for awareness
of who is operating in the
airspace. The FAA is therefore proposing to require the remote
identification of UAS to enable
the agency to identify unmanned aircraft flying in the airspace of the
United States and locate the
operators of those aircraft. Remote identification equipment would
provide identifying
information for UAS similar to how ADS-B and transponders provide
identifying information
for manned aircraft. This information would also be essential for the management of the flow of
air traffic as more UAS integrate into the airspace of the United
States.
46
The FAA does not propose the use of transponders or ADS-B Out for
remote
identification for three primary reasons. First, the use of these
technologies would require
significant additional infrastructure, including radars and receivers,
to cover the lower altitudes
of the airspace of the United States where unmanned aircraft are
expected to primarily operate.
Second, the FAA expects that, due to the volume of unmanned aircraft
operations projected, the
additional radio frequency signals would saturate the available
spectrum and degrade the overall
cooperative surveillance system. Finally, transponders and ADS-B Out
do not provide any
information about the location of control stations, as these systems
were designed for manned
aircraft. For these reasons, the FAA has determined that existing
cooperative surveillance
systems are incapable of supporting UAS remote identification and is
proposing a new
cooperative surveillance technology specifically for UAS. However, the
proposal does not
prohibit the use of ADS-B In, if the ADS-B In equipment is
manufactured and installed in
accordance with FAA requirements and guidance.
17
2. Current Challenges with Associating UAS with Their Owners and
Operators
All manned aircraft, unmanned aircraft weighing over 0.55 pounds, and
any unmanned
aircraft operated pursuant to 14 CFR part 107 or part 91 (irrespective
of weight) are subject to
FAA’s aircraft registration and marking requirements. These
requirements are the fundamental
means for the FAA to physically identify manned and unmanned aircraft
operating in the
airspace of the United States and to associate them with their owners.
The FAA recognizes that
current registration and marking requirements are most useful when the
aircraft is static or when
information regarding the aircraft and its owner is needed without a
direct link to the aircraft

17 See Advisory Circulars 20-172B and 90-114A.
47
itself. In the case of unmanned aircraft in flight, however,
registration and marking alone are
insufficient to identify the aircraft and to locate the person
manipulating the flight controls of a
UAS. This is due to both the small size of most unmanned aircraft and
to the fact that the person
manipulating the flight controls of the UAS is not co-located with the aircraft. The Registration
Rule acknowledged that the registration of small unmanned aircraft
would provide a means by
which to quickly identify the aircraft in the event of an incident or
accident involving a small
UAS. The Registration Rule also acknowledged that registration of
small unmanned aircraft
would provide an immediate and direct opportunity for the FAA to
educate small UAS owners
on safety requirements before they begin operating. The Registration
Rule did not, however,
envision the use of registration numbers as a means to identify or
locate the small UAS owner or
the person manipulating the flight controls of the UAS during
real-time flight operations.
The small size of most unmanned aircraft makes it difficult – if not
impossible – to read
their registration numbers from the ground, preventing proper
identification of the unmanned
aircraft while it is in flight. Although it is true that manned
aviation faces similar identification
issues (since aircraft registration marks may be impossible to read
from the ground when the
aircraft is flying at certain altitudes or speeds), there is an
important distinction between manned
and unmanned aviation that makes the inability to read a registration
number from the ground
less problematic in manned aviation. In manned aviation, the
pilot-in-command is co-located
with the aircraft and is therefore more easily identifiable, even if
such identification occurs after
landing.
In addition, pilots of manned aircraft are often required to, or
choose to, maintain
two-way communications with air traffic control (ATC) for purposes of
receiving air traffic
services. This communication helps ascertain the identity and intent
of the pilot in command.
48
Furthermore, transponders and ADS-B Out systems transmit unique codes
that allow ATC to
identify and distinguish aircraft from others flying in the airspace
of the United States, as
discussed in the preceding section. These means of identification are
not currently required or
feasible for UAS. The challenge of identifying UAS would only increase
with the proliferation
of BVLOS operations – when pilots will likely be located far away from
the unmanned aircraft
location.
3. Situational Awareness
The ability to know the location of unmanned aircraft operating in the
airspace of the
United States and to identify and locate their operators creates
situational awareness of
operations conducted in the airspace of the United States, fosters accountability of the operators
and owners of UAS, and improves the capabilities of the FAA and law
enforcement to
investigate and mitigate careless, hazardous, and noncompliant
operations. This contributes to
safety in air commerce and the efficient use of the airspace of the
United States.
Remote identification would provide greater situational awareness of
UAS operating in
the airspace of the United States to other aircraft in the vicinity of
those operations and also
provide information to airport operators. Manned aircraft, especially
those operating at low
altitudes where UAS operations are anticipated to be the most
prevalent, such as helicopters and
agricultural aircraft, could carry the necessary equipment to display
the location of UAS

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