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
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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).
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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.
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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
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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).
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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.
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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
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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
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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
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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
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