• FAA Proposes Rule To Require Remote Identification Of Drones (6/19)

    From Larry Dighera@21:1/5 to All on Fri Dec 27 05:53:15 2019
    [continued from previous message]

    To register under part 47, the unmanned aircraft must not be
    registered under the laws of
    a foreign country, and must be:
    (1) owned by a citizen of the United States;
    (2) owned by an individual citizen of a foreign country lawfully
    admitted for permanent
    residence in the United States;
    (3) owned by a corporation not a citizen of the U.S. when the
    corporation is organized
    and doing business under U.S. Federal or State laws, and the aircraft
    is based and primarily used
    in the United States; or
    (4) owned by the U.S. Government, or a State, or local governmental
    entity.
    The registration process under part 47 is paper-based and commences
    with the filing of
    an Aircraft Registration Application (AC Form 8050-1) with the FAA
    Aircraft Registry. At a
    minimum, applicants must provide evidence of ownership (e.g., a
    traditional bill of sale, a
    contract of conditional sale, a lease with purchase option, or an
    heir-at-law affidavit), provide a
    certification of eligibility for registration, and pay a registration
    fee. Additional documentation
    may be required, particularly for amateur-built aircraft and aircraft
    imported from foreign
    jurisdictions. Additional information required may include a builder certificate describing the
    type of aircraft and a comprehensive description of the aircraft
    (e.g., make, model, serial number,
    engine manufacturer, type of engine, number of engines, maximum
    takeoff weight, and number
    of seats). Persons such as corporate registrants, trustees, and
    non-citizen corporations must file
    additional documentation evidencing their legal structures,
    authorities, and related data that
    supports registration. Aircraft previously recorded in foreign
    registries must file proof of
    84
    deregistration. In the case of amateur-built aircraft, either the
    owner or builder must designate the
    aircraft model name and serial number.
    Once an unmanned aircraft is registered, the FAA issues a Certificate
    of Aircraft
    Registration (AC Form 8050-3) to the aircraft owner. The FAA has
    clarified that, in the case of
    unmanned aircraft, the Certificate of Aircraft Registration may be
    maintained at the pilot’s
    control station rather than on the unmanned aircraft and must be made
    available for inspection
    upon request.
    56 The certificate expires three years after date of issuance.57 A
    Certificate of
    Aircraft Registration may be renewed by submitting a renewal
    application and paying a renewal
    fee.
    Unmanned aircraft registered under part 47 must comply with the
    identification and
    registration marking requirements in subparts A and C of 14 CFR part
    45. Under part 45, the
    aircraft must display certain marks consisting of the Roman capital
    letter “N” (denoting U.S.
    registration) followed by the registration number of the aircraft. The
    N-number must be: (1)
    painted on the aircraft or affixed to the aircraft by some other
    permanent means; (2) have no
    ornamentation; (3) contrast in color with the background; and (4) be
    legible.58
    B. Registration under Part 48
    Part 48 provides a web-based aircraft registration process for small
    unmanned aircraft to
    facilitate compliance with the statutory requirement that all aircraft
    register prior to operation.59

    56 See Memorandum to John Duncan, from Mark W. Bury, Assistant Chief
    Counsel for International Law,
    Legislation, and Regulations (August 8, 2014).
    57 Section 556 of the FAA Reauthorization Act of 2018 requires the Administrator to initiate a rulemaking to
    increase the duration of aircraft registrations for noncommercial
    general aviation aircraft to 7 years.
    58 See 14 CFR 45.21(c).
    59 See 80 FR 78593 (December 16, 2015).
    85
    A small unmanned aircraft weighing less than 55 pounds on takeoff,
    including everything that is
    on board or otherwise attached to the aircraft, may be registered
    under either part 47 or part 48.
    Owners of small unmanned aircraft used in civil operations (including commercial
    operations), limited recreational operations,
    60 or public aircraft operations, among others, are
    eligible to register under part 48. Currently, unmanned aircraft may
    be registered in one of two
    ways: (1) under an individual registration number issued to each
    aircraft; or (2) under a single
    registration number issued to an owner of multiple unmanned aircraft
    used exclusively for
    limited recreational operations.
    If the owner of a small unmanned aircraft intends to use it at any
    point for a purpose other
    than exclusively for limited recreational operations as defined in 49
    U.S.C. 44809, the owner
    must register that aircraft individually and obtain a unique
    registration number for the aircraft.
    The aircraft registration must include the: (1) name of the applicant;
    (2) applicant's physical
    address; (3) applicant's email address; (4) aircraft manufacturer and
    model name; (5) aircraft
    serial number, if available; and (6) any other information required by
    the Administrator.
    If the owner of multiple small unmanned aircraft intends to use the
    aircraft exclusively
    for limited recreational operations, part 48 currently allows the
    owner to register once and to
    obtain a single registration number that constitutes the registration
    number for all of the owner’s
    small unmanned aircraft. This means that multiple aircraft may display
    the same registration
    number when the unmanned aircraft are used exclusively for limited
    recreational operations.

    60 This proposal uses the term “limited recreational operations” when discussing registration requirements under part
    48. Part 48 uses the term “model aircraft” to describe recreational
    UAS operations. The FAA considers that model
    aircraft under part 48 are consistent with the “limited recreational operations” described in 49 U.S.C. 44809,
    therefore “limited recreational operations” has been used throughout
    to ensure consistency of terminology with
    current statutory requirements.
    86
    Applicants for a single Certificate of Aircraft Registration for
    multiple unmanned aircraft must
    provide: (1) the applicant’s name; (2) the applicant's physical
    address; (3) the applicant's email
    address; and (4) any other information required by the Administrator.
    This option does not
    require the applicant to provide the unmanned aircraft manufacturer,
    model, or serial number.
    Once an unmanned aircraft is registered, the FAA issues a Certificate
    of Aircraft
    Registration, which contains a registration number composed of
    multiple alphanumeric
    characters. A part 48 registration number is not the traditional
    N-number issued under part 47.
    Small unmanned aircraft registered under part 48 may not operate
    unless they display a
    unique identifier in a way that is readily accessible and visible upon inspection of the aircraft.
    The unique identifier must be either: (1) the registration number
    issued to an individual or the
    registration number issued to the aircraft by the Registry upon
    completion of the registration
    process; or (2) the small unmanned aircraft serial number, if
    authorized by the Administrator and
    provided with the application for Certificate of Aircraft
    Registration. Most commonly, the
    unique identifier displayed is the FAA registration number.
    C. Issues with the Current Registration Requirements and Proposed
    Changes
    The current registration requirements do not provide for
    aircraft-specific data of all
    aircraft, information fundamentally necessary for remote
    identification, due to the differing
    requirements of parts 47 and 48.
    Part 47 requires the individual registration of aircraft and the
    submission of an aircraft’s
    serial number as part of the application for a Certificate of Aircraft Registration. These
    requirements are consistent with the remote identification framework
    proposed in this NPRM
    because the FAA would be able to correlate the aircraft-specific
    registration data (i.e., serial
    87
    number) obtained under part 47 to the remote identification data which
    would have to be
    broadcast or transmitted by unmanned aircraft under the current
    proposal. This is not the case
    with the current registration requirements of part 48.
    Currently, part 48 allows for registration of multiple unmanned
    aircraft used exclusively
    for limited recreational operations under a single Certificate of
    Aircraft Registration without
    requiring the applicant to submit the aircrafts’ serial numbers.
    61 This means that the FAA has no
    aircraft-specific data for aircraft operated under a single
    Certificate of Aircraft Registration.
    Second, part 48 requires the provision of an unmanned aircraft’s
    serial number, only if available,
    and only if the aircraft is registered individually. This means that
    the FAA does not have a data
    set that includes the serial numbers of all unmanned aircraft
    registered under part 48 and cannot
    correlate the registration data to the remote identification data
    which would be broadcast or
    transmitted by unmanned aircraft under the proposed rule. Thus, the
    FAA believes that the
    current registration requirements of part 48 are not sufficient to
    support the remote identification
    framework proposed in this NPRM.
    A change to the registration requirements of part 48 is therefore
    necessary to enable the
    FAA to gather all of the necessary data to support the unique
    identification of unmanned aircraft
    registered under part 48. The lack of aircraft-specific data for
    aircraft registered under part 48
    inhibits the FAA and law enforcement agencies from correlating the
    remote identification data
    proposed in this rule with data stored in the Aircraft Registry. Thus,
    the FAA proposes to revise
    part 48 to require the individual registration of all small unmanned
    aircraft and the provision of

    61 As of November 25, 2019, are currently 1,081,329 recreational
    flyers registered under part 48 – but because these
    registrants do not currently register each individual UA the FAA does
    not have administrative data on the number or
    type of recreational UAs being flown. As a point of comparison, as of
    November 25, 2019, under part 48 there are
    also 417,663 UAs registered individually as non-model unmanned
    aircraft (largely part 107 operations).
    88
    additional aircraft-specific data. Owners of small unmanned aircraft
    would have to complete the
    registration application by providing aircraft-specific information in
    addition to basic contact
    information. This means that every small unmanned aircraft registered
    under part 48 would need
    to have its own Certificate of Aircraft Registration. To ease the
    financial burden on operators
    who previously registered multiple model aircraft under a single
    registration number, the FAA
    would explore ways to minimize the registration fee when multiple
    aircraft are registered at the
    same time.
    Specifically, the proposed changes would include the removal of §§
    48.100(b) and
    48.115, which currently allow small unmanned aircraft used exclusively
    as a model aircraft to be
    registered under a single Certificate of Aircraft Registration without
    unique identifying
    information. Sections 48.100(a) and 48.110, which require unique
    identifying information,
    would become the sole means for registration under part 48 and would
    be revised to reflect all of
    the requirements that apply to the individual registration of small
    unmanned aircraft under part
    48. Conforming changes would be made throughout part 48 to reflect the
    removal of
    §§ 48.100(b) and 48.115 and the transition to a single form of
    registration under part 48.
    The FAA believes the proposed revisions are necessary to implement the
    remote
    identification framework because individual aircraft registration
    under part 48 would allow the
    FAA to gather aircraft-specific data that is essential for remote identification. Furthermore, the
    proposed transition to an individual aircraft registration system
    under part 48 would harmonize
    these requirements with the individual aircraft registration
    requirements of part 47.
    89
    D. Proposed Changes to the Registration Requirements to Require a
    Serial Number and
    Telephone Number as Part of the Registration Process
    As discussed in section XII.C.1 of this preamble, this proposed rule
    would require a
    unique identifier as part of the message elements used to remotely
    identify UAS. A serial number
    is a unique number assigned to an aircraft – typically at the time of production – and does not
    change in case of a sale or transfer of ownership. The proposed
    revision of part 48 would require
    the provision of an unmanned aircraft’s serial number at the time of registration. This proposed
    requirement is essential for the remote identification framework
    proposed in this NPRM. The
    serial number requirement would enable the FAA to correlate the data
    broadcast or transmitted
    by the UAS with the registration data in the Aircraft Registry to
    associate an unmanned aircraft
    with its registered owner. The requirement would also allow the FAA to distinguish one
    unmanned aircraft from another operating in the airspace of the United
    States and would
    facilitate the identification of non-registered unmanned aircraft
    flying in the airspace of the
    United States, which may warrant additional oversight or action by the
    FAA, national security
    agencies, or law enforcement agencies.
    There has been little to no standardization regarding the issuance or
    use of serial numbers
    by UAS. The FAA believes that standardizing the issuance and use of
    serial numbers is
    necessary to successfully implement the remote identification
    requirements of the proposed rule.
    The standardization of the issuance and use of serial numbers would
    prevent a situation where
    two or more UAS are issued the same serial number. Thus, the FAA is
    proposing to add a new
    § 47.14 to require the owners of standard remote identification
    unmanned aircraft and limited
    remote identification unmanned aircraft registered under part 47 to
    list in the Certificate of
    Aircraft Registration the serial number issued by the manufacturer of
    the unmanned aircraft in
    90
    accordance with the requirements of proposed part 89. According to the manufacturing
    requirements in proposed § 89.505, the serial number would have to
    comply with the
    ANSI/CTA-2063-A serial number standard.
    The FAA is also proposing to revise § 48.100(a) to require a serial
    number for every
    small unmanned aircraft. Consistent with the proposed changes in part
    47, § 48.100(a)(5) would
    require the owner of any standard remote identification unmanned
    aircraft or limited
    identification unmanned aircraft to list in the Certificate of
    Aircraft Registration the serial
    number issued by the manufacturer of the unmanned aircraft in
    accordance with the production
    requirements of part 89. Per the production requirements in proposed §
    89.505, such serial
    number would have to comply with the ANSI/CTA-2063-A serial number
    standard.
    Owners of amateur-built unmanned aircraft would have to comply with
    the serial number
    requirement in proposed § 48.100(a)(5) if the unmanned aircraft are
    designed and produced as
    standard remote identification unmanned aircraft or limited
    identification unmanned aircraft. The
    proposed revisions to § 48.100(a) would also require the owners of amateur-built unmanned
    aircraft to list in the Certificate of Aircraft Registration a
    manufacturer and model name of their
    choice.
    Additionally, the FAA is proposing to update the registration
    information requirements to
    include one or more telephone number(s) for the applicant. Although registration data
    corresponds to the owner of the unmanned aircraft rather than the
    operator, the FAA believes
    that due to the nature and scope of most small UAS operations, it is
    reasonable to expect a
    significant number of unmanned aircraft owners to also be the
    operators of the aircraft or in close
    contact with the operators of the aircraft. Requiring owners of
    unmanned aircraft to provide their
    telephone number(s) as part of the registration process would assist
    FAA and law enforcement to
    91
    disseminate safety and security-related information to the registrant
    in near real-time. This
    additional information would be retained by the FAA and only disclosed
    as needed to authorized
    law enforcement or Federal agencies.
    E. Request for Comments Regarding Serial Number Requirements
    The FAA acknowledges that some unmanned aircraft may not have serial
    numbers that
    comply with the ANSI/CTA-2063-A serial number standard. Some examples
    include unmanned
    aircraft manufactured prior to the compliance date of the final rule
    that follows this notice of
    proposed rulemaking (assuming the producer of the unmanned aircraft is
    unable to modify the
    aircraft or push an upgrade to assign an ANSI/CTA-2063-A compliant
    serial number), some
    amateur-built unmanned aircraft, and foreign-built unmanned aircraft
    with no serial numbers or
    with serial numbers that do not comply with ANSI/CTA-2063-A. Since
    these unmanned aircraft
    do not comply with the remote identification requirements for standard
    remote identification
    UAS or limited remote identification UAS, the proposed rule requires
    their operation be
    restricted to FAA-recognized identification areas. Accordingly, the
    FAA has not imposed a
    requirement for the owners of such unmanned aircraft to obtain an ANSI/CTA-2063-A
    compliant serial number and to list it in the Certificate of Aircraft Registration or the Certificate
    of Identification. The FAA welcomes detailed comments on whether and
    why it should require
    the owners of UAS without remote identification to have to obtain an ANSI/CTA-2063-A
    compliant serial number and to list it in the Certificate of Aircraft Registration or the Certificate
    of Identification and whether there would be any costs associated with obtaining a compliant
    serial number. The FAA also welcomes comments on whether the Agency
    should issue
    ANSI/CTA-2063-A compliant serial numbers to such aircraft when
    registered or re-registered by
    their owners.
    92
    F. Serial Number Marking
    The FAA emphasizes that small unmanned aircraft owners are not
    required to affix the
    serial number to the exterior of the aircraft. However, nothing in the
    proposed regulation would
    preclude the owners from choosing to do so. The FAA envisions that
    producers may mark the
    exterior of unmanned aircraft with serial numbers that comply with the ANSI/CTA-2063-A
    serial number standard, and that such serial numbers could be used to
    meet the marking
    requirements of part 48, subpart C. This could alleviate the need to
    mark each UAS with the
    registration number. The FAA seeks specific comments on whether UAS
    producers should be
    required to affix the serial number to the exterior of all standard
    remote identification UAS and
    limited remote identification UAS. Please explain why or why not and
    provide data to support
    your response.
    X. Operating Requirements for Remote Identification
    A. Requirement to Broadcast or Transmit
    Under the proposed rule, no person would be able to operate a UAS in
    the airspace of the
    United States unless the UAS has remote identification capability
    meeting the requirements of
    this proposed rule (i.e., a standard remote identification UAS or
    limited remote identification
    UAS) or if the UAS has no remote identification equipment but is
    otherwise identified by
    operating exclusively within visual line of sight and within an
    FAA-recognized identification
    area.
    The FAA is proposing to require all UAS with remote identification to
    broadcast or
    transmit the appropriate remote identification message elements from
    takeoff to landing. The
    agency is also proposing that no person would be able to operate a UAS
    with remote
    93
    identification unless the UAS is transmitting (for limited remote identification UAS) or
    transmitting and broadcasting (for standard remote identification UAS)
    the appropriate message
    elements. The remote identification message elements are described in
    greater detail in section
    XII.C of this preamble. Furthermore, the FAA proposes to prohibit the
    operation of UAS with
    remote identification if the remote identification equipment and
    functionality have been disabled
    without the authorization of the Administrator.
    UAS would have to comply with the remote identification requirements
    in one of three
    ways, depending on the capabilities of the UAS. To help operators
    determine whether a
    particular UAS has remote identification, the FAA is proposing to
    require that all persons
    responsible for the production of standard remote identification UAS
    and limited remote
    identification UAS label the unmanned aircraft to indicate whether the
    UAS complies with the
    remote identification requirements of this proposed rule and whether
    the UAS is standard remote
    identification or limited remote identification. A person would
    therefore be able to determine
    what type of UAS they have and if it has remote identification
    capability simply by visual
    inspection of the unmanned aircraft.
    1. Standard Remote Identification UAS
    Standard remote identification UAS would be required to transmit
    certain message
    elements through the internet to a Remote ID USS (an FAA-qualified
    third party discussed in
    section XIV of this preamble) and to broadcast the same message
    elements directly from the
    unmanned aircraft using radio frequency spectrum in accordance with 47
    CFR part 15, where
    operations may occur without an Federal Communications Commission
    (FCC) individual
    94
    license. These message elements would include: the UAS Identification
    (either the unmanned
    aircraft’s serial number or session ID); latitude, longitude, and
    barometric pressure altitude of
    both the control station and the unmanned aircraft; a time mark; and
    an emergency status code
    that would broadcast and transmit only when applicable.
    A standard remote identification UAS would be required to broadcast
    and transmit the
    remote identification message elements from takeoff to landing. If the
    internet is available at
    takeoff, the standard remote identification UAS would have to connect
    to the internet and
    transmit the message elements through that internet connection to a
    Remote ID USS and would
    also be required to broadcast the message elements directly from the
    unmanned aircraft. If the
    internet is unavailable at takeoff, the standard remote identification
    UAS would only be required
    to broadcast the message elements directly from the unmanned aircraft.
    If the Internet is
    available, but the UAS cannot connect to a Remote ID USS, the UAS
    would be designed such
    that it could not take off. This is discussed in more detail in
    section XII.D.6 of this preamble.
    The FAA is proposing to define “broadcast” as sending information from
    an unmanned
    aircraft using radio frequency spectrum. Under the proposed rule, only
    standard remote
    identification UAS would be able to broadcast remote identification
    message elements. The
    reasons for prohibiting limited remote identification UAS from
    broadcasting message elements is
    explained in section XII.D.14 of this preamble.
    A standard remote identification UAS that loses connection to the
    internet or that can no
    longer transmit to a Remote ID USS after takeoff would be able to
    continue its flight, as long as
    it continues broadcasting the message elements. If a standard remote identification UAS
    experiences an in-flight loss of broadcast capability, regardless of
    whether it is connected to a
    Remote ID USS, the operator would have to land the unmanned aircraft
    as soon as practicable.
    95
    This is necessary because a loss of the broadcast capability is an
    indication of a remote
    identification equipment failure, whereas loss of connectivity to the
    internet or a Remote ID USS
    could be attributed to unavailability of a service outside the control
    of the UAS operator. In
    addition, a functioning broadcast capability is necessary in order for
    remote identification
    information to be available in areas that do not have wireless
    internet connectivity. For example,
    during a BVLOS operation, the unmanned aircraft could be operating
    over a rural area that does
    not have wireless internet connectivity, but, through the command and
    control link, the
    unmanned aircraft has connectivity with a control station that is in
    turn connected to the internet
    and transmitting to a Remote ID USS. If the unmanned aircraft is in a
    location that does not have
    wireless internet connectivity, then for any local third-party
    observers attempting to identify the
    unmanned aircraft the only accessible source of remote identification information would be the
    broadcast. To support compliance with this requirement, the FAA is
    proposing that standard
    remote identification UAS have a monitoring feature that would notify
    the person manipulating
    the flight controls of the UAS if the broadcast capability was lost.
    The FAA expects that the proposed design and production requirements
    of this rule
    would facilitate a person’s compliance with the proposed operating
    requirements (e.g.,
    transmission requirement). The FAA intends for compliance with the
    remote identification
    requirements to be simple and straightforward for individuals
    operating UAS produced in
    accordance with a current FAA-accepted means of compliance. For
    example, a standard remote
    identification UAS would automatically transmit and broadcast the
    message elements and its
    design would prevent it from taking off when the remote identification capability is not
    functioning. Under this rule, the remote identification capability
    would be considered not
    functioning when the equipment does not work or is unable to perform
    its intended function or
    96
    when the remote identification message elements are not transmitted or broadcast in accordance
    with the requirements of the proposed rule. Under this proposed rule,
    all UAS with remote
    identification would be designed and produced such that the remote identification functionality is
    always enabled and cannot be disabled except as otherwise authorized
    by the Administrator.
    UAS with remote identification would be designed and produced to
    notify the person
    manipulating the flight controls of the UAS of any remote
    identification malfunctions, failures,
    or anomalies.
    2. Limited Remote Identification UAS
    Limited remote identification UAS are UAS that are designed and
    produced such that the
    aircraft is not capable of operating more than 400 feet from the
    control station and cannot
    broadcast the remote identification message elements identified in
    proposed § 89.305 or §
    89.315. Under the proposed rule, persons operating limited remote identification UAS would be
    required to fly within visual line of sight at all times. Limited
    remote identification UAS would
    be required to connect to the internet and transmit the appropriate
    message elements through that
    internet connection to a Remote ID USS. Unlike standard remote
    identification UAS, if a limited
    remote identification UAS cannot connect to the internet or transmit
    through an internet
    connection to a Remote ID USS, the UAS would not be able to take off.
    Again, unlike with
    standard remote identification UAS, if a limited remote identification
    UAS loses connectivity to
    the Remote ID USS in flight, the person manipulating the flight
    controls of the UAS would be
    required to land as soon as practicable. The limited remote
    identification UAS would not be able
    to continue its flight because it cannot broadcast remote
    identification message elements.
    A limited remote identification UAS is not permitted to broadcast
    remote identification
    message elements using radio frequency spectrum because the broadcast
    function is only
    97
    applicable to standard remote identification UAS. If remote
    identification broadcast capability is
    added to a limited remote identification UAS, it would not have been
    subject to the design and
    production requirements of this rule and could result in erroneous, non-compliant, or incorrectly
    formatted messages being broadcast, undermining the fundamental
    purposes of this rule.
    However, the proposal does not prohibit designers, producers, or
    operators from including a
    capability for limited remote identification UAS to broadcast
    information or data unrelated to
    remote identification, such as a camera feed or telemetry data.
    The message elements for limited remote identification UAS would
    include: the UAS
    Identification (either the unmanned aircraft’s serial number or
    session ID); latitude, longitude,
    and barometric pressure altitude of the control station; a time mark;
    and an emergency status
    code that would transmit only when applicable.
    Table 4 provides a summary of the differences between standard remote identification
    UAS and limited remote identification UAS.
    Table 4: Summary of Differences between Standard Remote Identification
    UAS and
    Limited Remote Identification UAS
    Standard Remote
    Identification UAS
    Limited Remote
    Identification UAS
    Message elements:
    UAS Identification (serial number or session ID) YES YES
    Unmanned aircraft:
    Latitude and longitude, barometric pressure altitude
    YES NO
    Control station:
    Latitude and longitude, barometric pressure altitude
    YES YES
    98
    A time mark identifying the Coordinated Universal
    Time (UTC) time of applicability of a position
    source output
    YES YES
    An indication of the emergency status of the UAS YES YES
    Connectivity prior to takeoff:
    Internet and Remote ID USS YES YES
    Broadcast YES NO
    If, at takeoff, the UAS cannot connect to the internet Broadcast Do
    not take off
    If, at takeoff, the UAS is connected to the internet,
    but is not transmitting to a Remote ID USS
    Do not take off Do not take off
    In-flight loss of remote identification:
    If, during flight, the UAS loses the connection to the
    internet or stops transmitting to the Remote ID USS
    Broadcast Land as soon as practicable
    If, during flight, the UAS loses its ability to
    broadcast the message elements
    Land as soon as practicable N/A
    Range limitation:
    Range limitation from control station None; operation would have
    to comply with all other
    operating requirements
    Limited to operations
    within 400 feet of control
    station
    Broadcasting from the unmanned aircraft at any point:
    Broadcast limitation Standard remote identification
    unmanned aircraft must
    broadcast remote
    identification message
    elements
    Limited remote
    identification unmanned
    aircraft cannot broadcast
    remote identification
    message elements
    3. UAS without Remote Identification
    Under the proposed rule, the vast majority of UAS would be required to
    remotely
    identify. The FAA understands, however, that not all UAS would be able
    to meet this
    requirement. For example, some UAS manufacturers may be able to bring
    UAS produced before
    the compliance date of this rule into compliance, but others might
    not. In addition, certain
    99
    amateur-built UAS might not be equipped with remote identification
    equipment. The FAA is
    proposing operating rules in § 89.120 to allow these aircraft to
    continue to operate without
    remote identification equipment. A UAS that would not qualify as
    either a standard remote
    identification UAS or a limited remote identification UAS would only
    be allowed to operate
    under two circumstances. The first circumstance is where the UAS
    operates within visual line of
    sight and within the boundaries of an FAA-recognized identification
    area. An FAA-recognized
    identification area is a defined geographic area where UAS without
    remote identification can
    operate. In the proposed § 89.120(a), the phrase “operated within an FAA-recognized
    identification area” means that both the unmanned aircraft and the
    person manipulating the flight
    controls of the UAS would be required to be located within the
    FAA-recognized identification
    area from takeoff to landing. FAA-recognized identification areas are
    described in section XV of
    this preamble. Note that this operating exception from remotely
    identifying only applies to those
    UAS that do not have remote identification; anyone operating a
    standard or limited remote
    identification UAS would continue to be bound by the operating rules
    applicable to their UAS,
    even if he or she is located inside an FAA-recognized identification
    area during the flight.
    The second circumstance in which a UAS that is not a standard remote identification
    UAS or limited remote identification UAS could be operated without

    [continued in next message]

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