[continued from previous message]

operating nearby. Facility operators could use remote identification information to know about
UAS operating near an airport, airfield, or heliport, regardless of
the airspace in which the
facility is located. This would provide a level of awareness that is
currently unavailable for those
facilities and the aircraft operating nearby. For example, an aircraft preparing to take off from an
49
airport in Class G airspace may have access to greater information
(e.g., number and location of
UAS, types of operations conducted in the airspace, etc.) than
currently available.
4. Compliance and Enforcement
The safety of the airspace of the United States largely depends on
aircraft operators
following the prescribed rules and being accountable for their
actions. The FAA needs the ability
to identify aircraft and their owners to ensure adequate oversight of
the operations (e.g., facilitate
the identification of noncompliant or unauthorized operations). When
unsafe operations are
discovered, the FAA is required to adequately address safety issues
that may adversely affect the
airspace of the United States as well as people and property on the
ground. To accomplish this,
the FAA needs a means to locate UAS operators – in near real-time, if
necessary – to take
immediate or subsequent action to mitigate safety issues or security
threats. Thus, the FAA
believes that the remote identification requirements in this proposed
rule are necessary to ensure
the safety of the airspace of the United States.
If an operator is unwilling or unable to comply with, or is
deliberately flouting
regulations, the FAA could employ legal enforcement action, including
civil penalties and
certificate actions, as appropriate, to address violations and help
deter future violations. Civil
penalties for violations of the federal aviation regulations range
from a maximum per violation
penalty of $1,466, for individual operators, to $33,333 for large
companies. In addition,
Congress granted the FAA authority to assess civil penalties of up to
$20,000 against an
individual who operates a UAS and in so doing knowingly or recklessly interferes with a law
enforcement, emergency response, or wildfire suppression activity. The
FAA may take
enforcement action against anyone who conducts an unauthorized UAS
operation or operates a
50
UAS in a way that endangers the safety of the airspace of the United
States. This authority is
designed to protect users of the airspace as well as people and
property on the ground.
B. Unmanned Aircraft Systems Traffic Management (UTM)
The FAA, in an effort to further integrate UAS into the airspace of
the United States, is
collaborating with other government agencies and industry stakeholders
to develop unmanned
aircraft systems traffic management (UTM) separate from, but
complementary to, the ATM
system. The term “UTM” refers to a set of third-party services and an all-encompassing
framework for managing multiple UAS operations. This vision for UTM
includes services for
flight planning, communications, separation, and weather, among
others. The FAA believes that
remote identification facilitates the long-term implementation of UTM
by providing greater
awareness of all aircraft, including unmanned aircraft, operating in a particular area. UTM would
help enable increased UAS operations in both controlled and
uncontrolled airspace, including
airspace where no air traffic separation services are currently
provided.
The vision for UTM18 relies on third parties’ ability to supply
services, under FAA’s
regulatory authority, where such services do not currently exist. The
FAA envisions communitybased traffic management, where UAS operators
have the responsibility for the coordination,
execution, and management of a safe operating environment. UTM would
be designed to support
the demand and expectations for a broad spectrum of UAS operations
with ever-increasing
complexity and risk.
The concept of UTM is predicated on layers of information sharing and
exchange, from
operator to operator, aircraft to aircraft, and operator to the FAA,
to achieve safe operations.

18 https://utm.arc.nasa.gov/docs/2018-UTM-ConOps-v1.0.pdf
51
Operators would share their flight intent with each other and
coordinate to de-conflict and safely
separate trajectories. Remote identification is a crucial first step
in the development of these
UTM services.
C. Facilitating Beyond Visual Line of Sight Operations
Providing a means to conduct routine BVLOS operations is a critical
step in the
integration of UAS operations in the airspace of the United States.
The technologies and
procedures necessary to enable BVLOS operations have been the focus of
past and current
research by the FAA and others.
19 The research indicated that for UAS to conduct safe, routine
BVLOS operation, UAS should be able to detect both cooperative and non-cooperative aircraft
(manned and unmanned) so they can maintain a safe distance from those
aircraft. Cooperative
aircraft are those that are providing information that identifies the
location of the aircraft,
typically through a standardized and receivable electronic radio
frequency broadcast or other
type of transmission. Non-cooperative aircraft are those that are not
providing any information
regarding their location.
A UAS that broadcasts or transmits remote identification information
would contribute to
a cooperative operating environment. Operators of UAS could use remote identification
information available from a Remote ID USS or broadcast directly from
other unmanned aircraft
to know the location of UAS operating nearby. Such data could be used
in UAS detect-and-avoid
and aircraft-to-aircraft communication systems to aid in unmanned
aircraft collision avoidance.

19
https://www.faa.gov/uas/programs_partnerships/integration_pilot_program/; https://www.faa.gov/uas/programs_partnerships/completed/; http://www.assureuas.org/projects/detectandavoid.php
52
Under UTM, when the locations of other unmanned aircraft become known,
the UAS operators
would be able to maintain a safe distance from those aircraft.
Although remote identification of UAS does not, in and of itself,
permit BVLOS
operations, it is a key stepping stone to the future ability to
conduct those operations. Without
remote identification of UAS, BVLOS operations on a large scale are
not feasible, and the
foundational building blocks of UTM – which is necessary to enable
routine BVLOS operations
– are not established.
D. National Security and Law Enforcement Efforts
This proposed rule would serve the public interest by assisting
government efforts to
address illegal activity and protect national security. The safety and
security benefits described in
this section are consistent with the FAA’s responsibilities to assist
law enforcement agencies in
their efforts to enforce laws related to regulation of controlled
substances, to the extent consistent
with aviation safety,
20 and to prescribe regulations necessary for safety in air commerce
and
national security.21
Federal, State, and local law enforcement and national security
agencies have expressed
their desire for new regulations to reduce and address the security
threats associated with illegal
or threatening UAS operations as well as the ability to discriminate
between compliant and noncompliant operations. The FAA recognizes the increasing availability and potential use of UAS
for illegal activities such as the carrying and smuggling of
controlled substances, illicit drugs,
and other dangerous or hazardous payloads; the unlawful invasion of
privacy; illegal surveillance

20 49 U.S.C. 40101(d).
21 49 U.S.C. 44701(a)(5).
53
and reconnaissance; the weaponization of UAS; sabotaging of critical infrastructure; property
theft; disruption; and harassment. The misuse of UAS for these
purposes presents a direct threat
to public safety. Such misuse also presents a hazard to safety in air
commerce. Such risks are
multiplied with the increasing sophistication of technology, the
availability of UAS equipment,
and the proliferation of UAS operations across the airspace of the
United States.
Unmanned aircraft operators who know they cannot easily be identified
are more likely
to engage in careless, reckless, or dangerous behavior because they
believe they will not be
caught. These operators could engage in evasive maneuvering to avoid
pursuit, violate airspace
restrictions, engage in unauthorized night or BVLOS operations, fly
too close to other aircraft, or
operate in weather conditions beyond the capability of the unmanned
aircraft or the person flying
it. Such behavior could create severe safety hazards not only to other
manned and unmanned
aircraft in the surrounding airspace, but also to persons and property
on the ground.
Additionally, UAS operators that do not comply with applicable law
create a unique
security challenge. On average, six sightings of UAS allegedly
conducting unauthorized
operations are reported to the FAA each day. Additionally, based on
information provided by
other U.S. Government agencies, there may be many additional UAS
sightings involving
unauthorized or illegal operations not reported to the FAA. Although
collisions with aircraft are
rare, there have been two confirmed unmanned aircraft collisions with
manned aircraft: an Army
Blackhawk helicopter in New York City in September 2017, and a small twin-engine passenger
aircraft approaching Quebec City’s Jean Lesage International Airport
in October 2017. In all of
these circumstances, remote identification could have enabled
immediate identification of the
UAS and enabled law enforcement to find the location of the control
station for near real-time
response and investigation.
54
Owners of critical infrastructure, airports, and venues for mass
gatherings have expressed
concern over the security of their facilities after sightings of UAS
of unknown identity and
intent. Many sightings are at night, when it may be more difficult to
see and identify the
unmanned aircraft or find the operator. Owners and facility managers
of sports stadiums and
other open-air venues are particularly concerned, given the
concentration of people present
during an event. Malicious UAS activities designed to disrupt and gain
media attention are a
distinct threat with the potential to inflict delays, fear, injuries,
and significant economic losses
across a variety of critical infrastructure sectors, including
airports, public facilities, and energy
production infrastructure.
On April 11, 2019, numerous spectators visually spotted a UAS
operating during a Major
League Baseball game.22 Although law enforcement were able to
eventually identify the operator
within 24 hours due to a municipally-owned detection system, remote identification would likely
have allowed them to find the operator and control station much more
quickly and address the
issue in real time. After law enforcement confiscated the UAS involved
in the April 2019
incident and were able to review its flight log, they learned that the
operator had flown over a
previous World Series game at the same stadium—violating an FAA
Temporary Flight
Restriction and numerous safety regulations.
A UAS that was not approved to operate over people was used to drop
pamphlets over
large crowds outside a concert venue and a university event in May,
2019, in Sacramento,

22 https://www.usatoday.com/story/sports/mlb/redsox/2019/04/13/drone-fenway-park-juvenile/3457190002/.
Accessed June 11, 2019.
55
California.23 This event was similar to two incidents in 2017 when a
UAS was used to drop
leaflets at two California National Football League games.24 Although
security and law
enforcement personnel at the stadium used rudimentary tactics to
eventually identify the accused
operator, the lack of remote identification made real-time location of
the operator impossible.
25
Security professionals have raised concerns that unmanned aircraft
that have not been
determined to be safe to fly over a large gathering of people may pose
a safety hazard, and a
UAS dropping objects could potentially pose a greater threat by
releasing hazardous substances
or creating a stampede of frightened spectators fleeing the area.
Although social media postings
helped identify the operator in some cases, such information rarely
helps law enforcement
officers address a potential threat in real time.
Multiple pilot reports of a UAS approximately 10 miles away from
Newark Airport led to
a disruption in arrivals in January 2019 that impacted other airports
on the East Coast for several
hours.26 The more than 30-hour disruption of flights at London’s
Gatwick Airport in December
2018,27 as well as brief disruptions at airports in Dubai,28 Dublin,
29 and Frankfurt30 within the
last year, further demonstrate the potential for significant
operational and financial impact from
the presence of an unauthorized UAS in and around an airport. UAS
operators have not been

23 https://www.newsweek.com/drone-used-drop-nazi-leaflets-ariana-grande-concert-sacramento-bites-bridge1414933.
Accessed June 11, 2019.
24 https://www.justice.gov/usao-ndca/pr/sacramento-area-resident-charged-flying-drone-over-nfl-games-violationnational-defense.
Accessed June 10, 2019.
25 Id.
26 https://www.washingtonpost.com/transportation/2019/01/22/drone-activity-halts-air-traffic-newark-libertyinternational-airport/?noredirect=on&utm_term=.c0e920a9e756.
Accessed June 11, 2019.
27 https://www.theguardian.com/uk-news/2018/dec/21/gatwick-airport-reopens-limited-number-of-flights-dronedisruption.
Accessed June 11, 2019.
28 http://www.digitaljournal.com/tech-and-science/technology/q-a-recent-airport-shutdowns-need-droneinterdiction-technology/article/543680.
Accessed June 11, 2019.
29 https://dronelife.com/2019/02/22/flights-were-grounded-at-dublin-airport-after-another-drone-sighting/.
Accessed
June 11, 2019.
30 https://www.ecnmag.com/news/2019/03/drone-sightings-interrupt-germanys-frankfurt-airport.
Accessed June 10,
2019.
56
identified in any of these airport events. Remote identification of
UAS would potentially prevent
disruptions such as these by enabling real time action by the FAA,
airport facilities, and law
enforcement.
Remote identification would also aid in preventing terrorist attacks.
Recent reports in the
news including the Islamic State of Iraq and Ash-Sham’s modifications
of commercial UAS,
31
the assassination attempt of Nicolás Maduro in Venezuela,
32 a foiled plot in the United Kingdom
to fly an unmanned aircraft into an airliner,
33 and a bomb-laden unmanned aircraft flown by
Huthi forces and detonated over a military parade in Yemen34
illustrate the ways in which UAS
may be used to threaten life, critical infrastructure, and national
security. Remote identification
of UAS would enable national security agencies and law enforcement to
quickly identify
potential threats and act to prevent such incidents.
The use of UAS to smuggle contraband into correctional facilities is
also increasingly
common.35 Even inexpensive consumer-grade UAS models have sufficient
payload and technical
capabilities to carry illicit and dangerous items over prison walls.
Recent efforts by law
enforcement, for example, have included the investigation and
prosecution of an individual who
illegally operated a consumer-grade UAS with the intent to deliver
contraband (marijuana) into a
Georgia state prison. The prosecution ultimately resulted in a guilty
plea in the Middle District of

31 https://ctc.usma.edu/app/uploads/2018/07/Islamic-State-and-Drones-Release-Version.pdf.
Accessed June 11,
2019.
32 https://www.bbc.com/news/world-latin-america-45073385. Accessed
June 9, 2019.
33 https://www.dailystar.co.uk/news/latest-news/724185/Terror-drone-plot-Britain-UK-spies-foil.
Accessed June 11,
2019.
34 https://www.reuters.com/article/us-yemen-security/houthi-drones-kill-several-at-yemeni-military-paradeidUSKCN1P40N9.
Accessed June 11, 2019.
35 https://www.washingtonpost.com/local/prisons-try-to-stop-drones-from-delivering-drugs-porn-and-cellphones-toinmates/2016/10/12/645fb102-800c-11e6-8d0c-fb6c00c90481_story.html?utm_term=.22b0427db4d0.
Accessed
June 11, 2019.
57
Georgia to a charge of operating an aircraft eligible for registration
knowing that the aircraft is
not registered to facilitate a controlled substance offense. The
defendant received a sentence of
48 months in prison.36 Remote identification will assist law
enforcement in their efforts to find
and stop operators who attempt to engage in similar conduct.
Four Federal departments37 have the authority to deploy counter-UAS
systems to detect
and mitigate credible threats posed by UAS.38 Remote identification of
UAS would provide these
departments with increased awareness of UAS operations conducted
across certain geographical
areas of interest. That information would aid the determination of
whether UAS represent a
threat that must be met with counter-UAS capabilities. In particular,
remote identification would
provide these departments with crucial information about the owner of
the UAS, and the control
station’s location in near real-time, supplementing and enriching
information obtained via UAS
detection capabilities. The FAA believes that the ability to identify
the owner and the location of
the control station would help these Federal agencies to more
accurately assess risk and take
action commensurate with that risk.
In addition, certain public safety activities have been hampered by
the inability to identify
UAS and their locations. While there are numerous examples, in one
case, a UAS interfered with
a police helicopter assisting with a cliff rescue;39 in another case,
a UAS interfered with a police
helicopter assisting a fire response.40 In 2017, a helicopter
performing security for the United

36 https://www.justice.gov/usao-mdga/pr/illegal-drone-operator-sentenced-attempting-drop-drugs-georgia-stateprison.
37 Department of Defense, Department of Energy, Department of Homeland Security, and the Department of Justice.
38 10 U.S.C. 130i; 50 U.S.C. 2661; 6 U.S.C. 124n.
39 https://www.mercurynews.com/2017/01/30/pacifica-drone-operator-arrested-for-interfering-with-helicopterrescue-mission/
40 https://www.nbcwashington.com/news/local/College-Park-Man-Arrested-For-Flying-Drone-Near-5-Alarm-FireMonday-420369903.html
58
Nations General Assembly struck an unmanned aircraft, causing more
than $100,000 worth of
damage to the helicopter.41 Remote identification would enable the
FAA, first responders, and
law enforcement officers to more easily determine who is operating in
the airspace, providing
important information to help determine appropriate responses to
ensure the safety and security
of the airspace of the United States and the people on the ground.
Although Federal, State, and local law enforcement agencies are
responsible for the
investigation and prosecution of illegal activities, the FAA retains
the regulatory and civil
enforcement authority and oversight over aviation activities that
create hazards and pose threats
to the safety of flight in air commerce. Both safety and security
enforcement are extremely
difficult absent a remote identification requirement that enables the
prompt and accurate
identification of UAS and operators.
V. Related International Activities
The International Civil Aviation Organization (ICAO) does not
prescribe any remote
identification equipage for UAS. However, as of the date of
publication of this proposed rule,
ICAO advisory groups are developing material addressing UTM and UAS
operations under
instrument flight rules (IFR). The European Union, the Direction
Générale de l’Aviation Civile
(France Civil Aviation Authority), and the Civil Aviation
Administration Denmark (Denmark
Civil Aviation Authority) have also proposed various actions and
advisory group activity for
remote identification.

41 https://www.reuters.com/article/us-usa-military-drone/u-s-probing-collision-between-civilian-drone-armyhelicopter-idUSKBN1CA1Z0
59
With the exception of Italy and Qatar, no individual ICAO-member Civil
Aviation
Authority has remote identification requirements for UAS. The Italian
Civil Aviation Authority
requires aircraft with a maximum takeoff weight of more than 55 pounds
(25kg) to have certain
equipage that transmits flight parameters and owner/operator data.
Aircraft compliant with these
requirements must also meet data storage standards. The Qatar Civil
Aviation Authority requires
that certain UAS operations be conducted with prescribed geo-fencing
and electronic
identification systems.
In May 2017, the European Commission published a notice of proposed
amendment
which included proposed rules for remote identification. That proposed amendment would
require UAS to broadcast a unique physical serial number of the
unmanned aircraft compliant
with standard ANSI/CTA-2063, the geographical position of the unmanned
aircraft and its height
above the takeoff point, the direction and speed of the unmanned
aircraft, and the geographical
position of the unmanned aircraft takeoff point. During the first half
of 2019, the European
Commission finalized and adopted the following rules for remote
identification: (1) the
Commission Delegated Regulation (EU) 2019/945 of 12 March 2019 on
unmanned aircraft
systems and on third-country operators of unmanned aircraft systems,
and (2) the Commission
Implementing Regulation (EU) 2019/947 of 24 May 2019 on the rules and procedures for the
operation of unmanned aircraft. The regulations address the design and operational requirements
for unmanned aircraft and include a requirement for unmanned aircraft
to be individually
identifiable, but do not impose a European standard for remote
identification.
As adopted, the regulations require the local broadcast of information
about an unmanned
aircraft in operation, including the marking of the unmanned aircraft
to demonstrate conformity
with the applicable requirements, so that the information may be
obtained without physical
60
access to the unmanned aircraft. The remote identification
requirements adopted by the European
Commission include the following:
(a) Allowing the upload of the UAS operator registration number in
accordance with
Article 14 of Implementing Regulation (EU) 2019/947 and exclusively
following the process
provided by the registration system;
(b) Ensuring, in real time during the whole duration of the flight,
the direct periodic
broadcast from the unmanned aircraft using an open and documented
transmission protocol, of
the following data, in a way that they can be received directly by
existing mobile devices within
the broadcasting range:
(1) the UAS operator registration number;
(2) the unique physical serial number of the unmanned aircraft
compliant with standard
ANSI/CTA-2063;
(3) the geographical position of the unmanned aircraft and its height
above the surface or
take-off point;
(4) the route course measured clockwise from true north and ground
speed of the
unmanned aircraft; and
(5) the geographical position of the remote pilot or, if not
available, the take-off point.
(c) Ensuring that the user cannot modify the data mentioned under
paragraph (b)(2)
through (5).
61
VI. Aviation Rulemaking Committee
On July 15, 2016, Congress passed the FAA Extension, Safety, and
Security Act of 2016
(Pub. L. 114-190). Pursuant to section 2202 of that Act, the
Administrator and the Secretary
were tasked with convening industry stakeholders to facilitate the
development of consensus
standards for remotely identifying operators and owners of UAS and
associated unmanned
aircraft. As part of the standards development, the Administrator was
directed to consider:
(1) requirements for remote identification of UAS; (2) requirements
for different classifications
of UAS; and (3) the feasibility of the development and operation of a
publicly accessible online
database of unmanned aircraft and operators, and criteria for
exclusion from the database.
To comply with the Congressional mandate, on May 4, 2017, the
Administrator chartered
the Unmanned Aircraft Systems (UAS) Identification (ID) and Tracking
Aviation Rulemaking
Committee (ARC) (UAS-ID ARC) to inform the FAA on technologies
available for remote
identification and tracking of UAS and to make recommendations for how
remote identification
and tracking could be implemented.42 The FAA charged the UAS-ID ARC
with the following
three objectives:
? Identify, categorize, and recommend available and emerging
technology for the
remote identification and tracking of UAS.
? Identify the requirements for meeting the security and public safety
needs of the law
enforcement, homeland defense, and national security communities for
the remote
identification and tracking of UAS.

42 The UAS-ID ARC was composed of 74 members representing aviation
community and industry member
organizations, law enforcement agencies and public safety
organizations, manufacturers, researchers, and standards
bodies that are involved in the promotion and production of UAS and in addressing security issues surrounding the
operation of UAS.
62
? Evaluate the feasibility and affordability of available technical
solutions, and
determine how well those technologies address the needs of the law
enforcement and
air traffic control communities. Develop evaluation criteria and characteristics for
making decisions, and rate the available technical solutions provided.
The Administrator was also tasked with submitting a report to Congress regarding any
standards developed and issuing regulations based on the standards
developed. On
June 30, 2017, the Administrator sent a letter to the Chairman of the
Commerce, Science, and
Transportation Committee detailing the FAA’s considerations and
efforts in supporting the
development and implementation of Remote ID standards.
A. ARC Recommendations Final Report
The members of the UAS-ID ARC were organized into working groups.
Working Group
One (WG1) was tasked with identifying, categorizing, and recommending
available and
emerging technologies for the remote identification and tracking of
UAS. WG1 identified and
analyzed eight viable technology solutions, falling into two broad
categories: (1) direct broadcast
solutions; and (2) network publishing solutions.
43 A detailed discussion of the eight viable
technology solutions, as well as tables summarizing WG1’s analysis of
those solutions can be
found in the ARC Recommendations Final Report (Recommendations
Report), available in the
docket for this rulemaking.
Working Group Two (WG2) was tasked with identifying the requirements
for meeting
the security and public safety needs of the law enforcement, homeland
defense, and national

43 The eight viable technology solutions WG1 identified are: (1)
Automatic Dependent Surveillance Broadcast
(ADS-B); (2) Low Power Direct RF; (3) Networked Cellular; (4)
Satellite; (5) SW-based Flight Notification with
Telemetry; (6) Unlicensed Integrated C2; (7) Physical Indicator; and
(8) Visual Light Encoding.
63
security communities for the remote identification and tracking of
UAS. WG2 identified two
general categories of UAS ID and tracking needs: (1) incident
investigation; and (2) active
monitoring of heightened awareness areas. To achieve the goals of both categories, WG2
determined that all UAS meeting certain threshold requirements would
need to be tracked,
whether passively or actively, from commencement to termination of
each operation.44 WG2
further concluded that information regarding the position of the
aircraft, the location of the
control station, and the identity of the remote pilot would help
maintain a safe and secure
environment for the general public and public safety officials.
The working groups presented their findings and conclusions to the
full UAS-ID ARC for
consideration in making its recommendations. The UAS-ID ARC submitted
its
Recommendations Report to the FAA on September 30, 2017. Although some decisions were
not unanimous, the ARC reached general agreement on many of its recommendations.
45
1. Applicability of Remote ID and Tracking Requirements
In its Recommendations Report, the ARC presented two options for an applicability
threshold for the ID and tracking requirements and recommended the FAA
give due
consideration to both of those options.
Option 1: All UAS are required to comply with remote identification
and tracking
requirements except under any of the following circumstances:

44 WG2 determined that UAS with either of the following
characteristics should be required to comply with remote
identification and tracking requirements: (1) those that have the
ability to navigate between more than one point
without direct and active control of the pilot; or (2) those that have
a range from control station greater than 400 feet
and real-time remotely viewable sensor.
45 Appendix D of the ARC’s Recommendations Report contains dissenting
opinions submitted by ARC members, as
well as a chart showing a breakdown of how ARC members voted on the
final report. The Recommendations Report
is available in the docket for this rulemaking.
64
? The unmanned aircraft is operated within visual line of sight of the
remote pilot and is
designed to not be capable of flying beyond 400 feet of the remote
pilot.46
? The unmanned aircraft is operated in compliance with 14 CFR part
101, unless the
unmanned aircraft:
o Is equipped with advanced flight systems technologies that enable
the aircraft
to navigate from one point to another without continuous input and
direction
from the remote pilot.
o Is equipped with a real-time downlinked remote sensor that provides
the
remote pilot the capability of navigating the aircraft beyond visual
line of
sight of the remote pilot.
? The UAS is operated under ATC and contains the equipment associated
with such
operations (including ADS-B, transponder, and communication with ATC).
? The UAS operation is exempt from ID and tracking requirements by the
FAA (e.g.,
for the purposes of law enforcement, security or defense, or under an
FAA waiver).
Option 2: UAS with either of the following characteristics are
required to comply with
remote identification and tracking requirements:
? Ability of the aircraft to navigate between more than one point
without direct and
active control of the pilot.
? Range from control station greater than 400 feet and real-time
remotely viewable
sensor.

46 The ARC noted that it is not intending to encompass drone racing at
very low altitudes on a closed course that
may be authorized by operation, by location, or some other mechanism.
65
The ARC also recommended that, regardless of which option for
applicability the FAA
chooses, UAS operating under the following circumstances be exempt
from the remote
identification and tracking requirement:
? The UAS is operated under ATC and contains the equipment associated
with such
operations (including ADS-B, transponder, and communication with ATC).
? The UAS operation is exempt from ID and tracking requirements by the
FAA (e.g.,
for the purposes of law enforcement, security or defense, or under an
FAA waiver).
The ARC further recommended the FAA do the following regarding the applicability of
remote identification and tracking requirements:
? Include a waiver mechanism in the remote identification and tracking
rule.
? Apply the remote identification and tracking requirements to the
remote pilot, not to
the manufacturer of the UAS.
? Require manufacturers to label their products to indicate whether
they are capable of
meeting applicable remote identification and tracking requirements.
? Consider whether unmanned aircraft equipped with advanced flight
system
technologies that are strictly for safety purposes and that keep the
aircraft within
visual line of sight of the remote pilot, such as a “return to home”
feature, should be
exempt from remote identification and tracking requirements, provided
the safety
features cannot be readily altered or reprogrammed.
Some ARC members objected to both of the applicability options

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