• FAA Proposes Rule To Require Remote Identification Of Drones (7/19)

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

    remote identification is
    where the person operating the UAS has been authorized by the
    Administrator to operate the
    UAS for the purpose of aeronautical research or to show compliance
    with regulations. In this
    context, the FAA would consider aeronautical research to be limited to
    the research and testing
    of the unmanned aircraft, the control systems, equipment that is part
    of the unmanned aircraft
    (such as sensors), and flight profiles, or development of specific
    functions and capabilities for the
    UAS. Under this provision, producers and other persons authorized by
    the Administrator, would
    100
    have the ability to operate UAS prototypes without remote
    identification exclusively for
    researching and testing the UAS design, equipment, or capabilities.
    This provision does not
    extend to any other type of research using a UAS.
    Additionally, a person authorized by the Administrator would be
    permitted to conduct
    flight tests and other operations to show compliance with an
    FAA-accepted means of compliance
    for remote identification, or airworthiness regulations, including but
    not limited to flights to
    show compliance for issuance of type certificates and supplemental
    type certificates, flights to
    substantiate major design changes, and flights to show compliance with
    the function and
    reliability requirements of the regulations.
    B. Prohibition from Using ADS-B to Satisfy Remote Identification
    Requirements
    The FAA proposes to prohibit the use of ADS-B Out to meet remote
    identification
    requirements in this rule. The FAA determined that both the ADS-B
    message elements and the
    infrastructure required to receive the ADS-B message elements are
    incompatible with the current
    need for remote identification at lower altitudes. ADS-B does not
    provide information regarding
    the location of a UAS control station. Thus, it would not advance the
    FAA’s need to associate a
    control station with the actual unmanned aircraft it controls.
    Further, because ADS-B receivers
    do not provide sufficient low altitude coverage, ADS-B Out would not
    align well with the FAA’s
    vision for the development of UTM. Finally, the FAA determined that
    the use of ADS-B Out by
    UAS would generate undue signal saturation and would create an overall
    safety hazard for
    manned aircraft due to the potentially high numbers of UAS which may
    be operating in the
    airspace at any given time. For these reasons, the FAA is proposing in
    § 89.125 to prohibit ADSB Out equipment from being used to comply with
    the remote identification requirements of
    part 89.
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    C. Internet Availability and Transmission to a Remote ID USS
    The FAA is proposing to require standard remote identification UAS and
    limited remote
    identification UAS to connect automatically to the internet, when
    available, and transmit remote
    identification message elements through that internet connection to a
    Remote ID USS. The FAA
    is also proposing a related performance requirement for standard
    remote identification UAS and
    limited remote identification UAS to continuously monitor the
    connectivity to the internet and
    the transmission of remote identification message elements to a Remote
    ID USS and notify the
    person manipulating the flight controls of the UAS if that connection
    is lost or the UAS is no
    longer transmitting to the Remote ID USS. Because of this proposed
    performance requirement
    for the UAS, the person manipulating the flight controls of the UAS
    would be aware at all times
    of whether the UAS was connected to the internet and transmitting to a
    Remote ID USS.
    The FAA believes an internet-based solution is appropriate, when the
    internet is
    available, because the internet is the largest, most multifaceted, and prevalent platform for data
    transmission. Under the proposed rule, the internet would be
    considered available if cellular or
    other forms of wireless internet connectivity such as Wi-Fi are
    available in an operational area
    with sufficient signal strength to maintain a connection between the
    UAS and the internet. UAS
    with remote identification would automatically connect to the internet
    when it is available,
    similar to how wireless devices, such as smart phones, connect
    automatically to the internet
    when there is sufficient signal strength and coverage.
    If the internet is available but the operator’s Remote ID USS is not
    working, the operator
    would be required to either connect to another Remote ID USS or the
    UAS would be restricted
    from taking off. In the unlikely event that all Remote ID USS become unavailable at the same
    time but the internet remains available, no standard or limited remote identification UAS would
    102
    be able to take off. The FAA assumes this situation would be extremely unlikely. The FAA seeks
    public comment on whether there are ways to address this extremely
    unlikely situation within the
    framework of the rule as proposed.
    After connecting to the internet, a standard remote identification UAS
    or limited remote
    identification UAS must transmit the remote identification message
    elements to a Remote ID
    USS. The FAA anticipates that there will be some Remote ID USS
    available to the general
    public and that others will be private. Under the proposed rule, a
    Remote ID USS would be
    considered available as long as that Remote ID USS provides remote identification services to
    the general public at the time the standard remote identification UAS
    or limited remote
    identification UAS is being operated. A private or restricted access
    Remote ID USS would be
    considered available only to UAS operators who receive remote
    identification services from that
    Remote ID USS. For example, if Company ABC sets up a private Remote ID
    USS to provide
    remote identification services exclusively to its fleet of UAS, then
    the private Remote ID USS
    would only be available to the UAS operators of Company ABC. In
    comparison, if Company
    XYZ sets up a Remote ID USS that can be accessed by the general public
    for remote
    identification services, then Company XYZ’s Remote ID USS would be
    considered available to
    all operators of UAS flying in the airspace of the United States,
    irrespective of whether that
    access requires a monetary cost. The FAA is not proposing to establish
    specific requirements
    regarding Remote ID USS business models, (e.g., charging fees,
    requiring user agreements, and
    requiring information from Remote ID USS users). The FAA believes that operators will choose
    a Remote ID USS that best meets their operational needs. The FAA
    further discusses some of its
    assumptions related to Remote ID USS business models in the
    accompanying Regulatory Impact
    Analysis, where it assumes (while acknowledging significant
    uncertainty) the average publicly
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    available Remote ID USS will charge $2.50 as a monthly subscription
    ($30 annually) cost to
    users of its service.
    D. In-flight Loss of Connectivity with a Remote ID USS or Loss of
    Functionality
    The FAA foresees situations where the person manipulating the flight
    controls of a UAS
    would need to receive an indication that the connection to a Remote ID
    USS has been lost midflight. Under this proposal, standard remote identification UAS would be produced with the
    capability to both connect to the internet and, through that
    connection, transmit to a Remote ID
    USS and to broadcast. The broadcast capability provides continuous
    remote identification
    information and continues to provide remote identification when
    connectivity to the internet is
    lost or the unmanned aircraft is no longer transmitting to a Remote ID
    USS. If the connection to
    the internet or to a Remote ID USS is lost after takeoff, the person manipulating the flight
    controls would be allowed to continue operating the UAS as long as it
    is still broadcasting the
    remote identification message elements. If, however, a standard remote identification UAS loses
    its ability to broadcast the message elements, the person manipulating
    the flight controls of the
    UAS would be required to land the unmanned aircraft as soon as
    practicable. This is necessary
    because a loss of the broadcast capability is an indication of a
    remote identification equipment
    failure.
    Because limited remote identification UAS cannot broadcast remote identification
    message elements, if the UAS loses connection to the internet or to a
    Remote ID USS, then the
    person manipulating the flight controls would have to land the
    unmanned aircraft as soon as
    practicable. The FAA considers this to be the safest course of action
    given that these operations
    would be conducted within visual line of sight and no more than 400
    feet from the person
    manipulating the flight controls of the UAS.
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    Should the UAS remote identification equipment experience a loss of functionality or
    malfunction in flight, the FAA proposes in §§ 89.110(b) and 89.115(b)
    to require the person
    manipulating the flight controls of the UAS to land as soon as
    practicable. The FAA does not
    define the phrase “land as soon as practicable” and expects that the
    person manipulating the
    flight controls of the UAS will take steps to land in a safe manner.
    For instance, if the aircraft is
    still within visual line of sight, the safest option may be to keep
    the aircraft within sight to avoid
    other aircraft and return to the departure point. For a standard
    remote identification UAS
    operating BVLOS, the safest way to land may be to continue to the
    intended destination.
    E. Valid Declaration of Compliance
    The FAA is proposing to require persons responsible for the production
    of UAS with
    remote identification to declare that the UAS meet the minimum
    performance requirements of
    the proposed rule using an FAA-accepted means of compliance by
    submitting a declaration of
    compliance for acceptance by the FAA. A declaration of compliance is a
    document submitted to
    the FAA by the person responsible for the production of UAS with
    remote identification. It
    includes information required by the FAA to determine whether the
    person and the UAS comply
    with the remote identification requirements of the rule. The FAA is
    proposing in §§ 89.110(c)(1)
    and 89.115(c)(1) to prohibit a person from operating a UAS with remote identification unless its
    serial number is identified on an FAA-accepted declaration of
    compliance. The FAA would
    provide a list of all FAA-accepted declarations of compliance on its
    website to notify the public
    when its acceptance of a declaration of compliance is valid. The
    website would also identify
    declarations of compliance that have been rescinded. Section XIII.E.3
    of this preamble discusses
    the rescission of a declaration of compliance.
    105
    F. Foreign Registered Civil Unmanned Aircraft Operated in the United
    States
    In § 89.101(b), the FAA is proposing to apply the operational
    requirements of part 89 to
    persons operating foreign civil unmanned aircraft in the United
    States. These persons would have
    to comply with the remote identification requirements in § 89.105,
    which means that these
    persons would only be able to operate foreign civil unmanned aircraft
    in the United States that
    qualify as standard remote identification UAS, limited remote
    identification UAS, or that have
    no remote identification equipment but are operated within an
    FAA-recognized identification
    area.
    The FAA must be able to correlate the remote identification message
    elements
    transmitted or broadcast by foreign civil unmanned aircraft operated
    in the United States against
    information that helps FAA and law enforcement identify a person
    responsible for the foreign
    civil unmanned aircraft. Where unmanned aircraft are registered in a
    foreign jurisdiction, the
    FAA may not have access to information regarding the unmanned aircraft
    or its registered
    owner. Thus, the FAA is proposing in § 89.130(a) to allow a person to
    operate foreign-registered
    civil unmanned aircraft in the United States only if the person
    submits a notice of identification
    to the Administrator. The notice would include the following
    information to allow the FAA to
    associate an unmanned aircraft to a responsible person:
    (1) The name of the operator and, for an operator other than an
    individual, the name of
    the authorized representative providing the notice.
    (2) The physical address of the operator and, for an operator other
    than an individual, the
    physical address for the authorized representative. If the operator or authorized representative
    does not receive mail at a physical address, a mailing address must
    also be provided.
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    (3) The physical address of the operator in the United States (e.g.,
    hotel name and
    address).
    (4) One or more telephone number(s) where the operator can be reached
    while in the
    United States.
    (5) The email address of the operator or, for an operator other than
    an individual, the
    email address of the authorized representative.
    (6) The aircraft manufacturer and model name.
    (7) The serial number of the aircraft.
    (8) The country of registration of the aircraft.
    (9) The registration number of the aircraft.
    Once a person submits a notice of identification, the FAA would issue
    a confirmation of
    identification. Under § 89.130(c), a person operating a
    foreign-registered unmanned aircraft in
    the United States would have to maintain the confirmation of
    identification at the UAS’ control
    station and would have to produce it when requested by the FAA or a
    law enforcement officer.
    As specified in proposed § 89.130(b)(2), the filing of the notice of identification and the
    issuance of a confirmation of identification would not have the effect
    of U.S. aircraft registration.
    The issuance of a confirmation of identification would not exempt any
    person from
    having to obtain the appropriate safety authority issued by the FAA or
    economic authority issued
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    by the Department of Transportation62 prior to conducting unmanned
    aircraft operations in the
    airspace of the United States, if required for their particular
    operations.
    Lastly, under proposed § 89.130(d), the holder of a confirmation of identification would
    have to ensure that the information provided under proposed §
    89.130(a) remains accurate and is
    current prior to operating a foreign registered civil unmanned
    aircraft system in the United
    States.
    G. Example Operating Scenarios
    The FAA is providing these notional scenarios to provide examples of
    how the FAA
    envisions the proposed rule would apply to certain common situations.
    1. Subscribing to a USS
    Kim decides to give her daughter Emily a UAS for her birthday. Emily,
    excited to finally
    have her own UAS, eagerly unwraps the package so she can begin taking
    aerial selfies. Under
    FAA rules, Emily’s drone must be registered and therefore comes with
    remote identification.
    The UAS will not take off unless it is connected to a Remote ID USS.
    In order to comply with
    the remote identification requirement, Kim researches FAA-qualified
    Remote ID USS on the
    FAA’s website and decides to subscribe to Alpha USS, Inc. Emily’s UAS
    was designed to pair
    with her smartphone and connect to the Remote ID USS through her
    smartphone’s internet
    connection. After Emily’s UAS connects to Alpha USS, she is able to
    start using her drone to
    take selfies.

    62 https://www.faa.gov/uas/resources/foreign_operators/
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    2. Operating a Standard Remote Identification UAS
    Patty has a photography business and has decided to purchase a UAS to
    take aerial
    photos for weddings and other events. She researched different types
    of UAS and their
    capabilities and determined that she needs a UAS that can operate more
    than 400 feet from its
    control station. Patty decides to buy a standard remote identification
    UAS. Because the UAS has
    standard remote identification, it is designed to: (1) connect to the
    internet and transmit the
    remote identification message elements through that internet
    connection to a Remote ID USS;
    and (2) broadcast the same message elements directly from the unmanned aircraft.
    Patty sees that the UAS she wants to buy has a label that says it is a
    standard remote
    identification UAS. Regardless, Patty checked the FAA’s website to
    confirm that the UAS she is
    buying has a valid FAA-accepted declaration of compliance. Because the
    UAS was listed on the
    FAA website, the UAS meets the requirements of part 89. Patty intends
    to operate her UAS for
    business purposes, so the operations are subject to the operating
    rules in 14 CFR part 107, which
    require her to register the unmanned aircraft with the FAA. Patty goes
    online to the
    FAADroneZone63 website, applies for, and is issued a Certificate of
    Aircraft Registration under
    part 48. As part of the application process, Patty submits her
    unmanned aircraft’s serial number.
    Because Patty is required to register her unmanned aircraft under part
    48, she is subject to the
    remote identification operating requirements in part 89.
    Patty then subscribes online to Alpha, Inc., an FAA-qualified Remote
    ID USS. Her UAS
    is designed to connect to the internet by automatically pairing with
    her personal smart phone
    when the phone is running an application provided by Alpha USS. Each
    time Patty uses her

    63 https://faadronezone.faa.gov
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    UAS, it automatically transmits the standard remote identification
    UAS’ remote identification
    message elements through that internet connection to Alpha USS. Patty
    chooses to use her
    unmanned aircraft’s serial number for the UAS Identification message
    element, but in the future,
    she may instead choose to use a session ID assigned by Alpha USS.
    Sometimes, Patty’s UAS loses its internet connection while she is
    operating in rural
    areas; she can continue the operation as long as the unmanned aircraft
    is still broadcasting the
    remote identification message elements. During one operation, Patty’s
    UAS indicated that, due
    to a malfunction, the unmanned aircraft was no longer broadcasting the
    message elements, at
    which point she landed the unmanned aircraft as soon as practicable.
    During a different operation, Patty’s UAS attempts to connect to Alpha
    USS at the time
    of takeoff, but Alpha’s remote identification service is unavailable
    because Alpha’s server is
    down. Patty’s UAS can still connect to the internet through her smart
    phone and she discovers
    that an alternate FAA-qualified Remote ID USS, Bravo, Inc., is
    available. Patty’s UAS connects
    to Bravo, Inc. and is able to fly her UAS. Patty’s subscription with
    Alpha USS provides for a
    “roaming” feature that allows her to connect to other available USS
    free of charge so she can
    have uninterrupted service. If her subscription did not provide this
    roaming feature, Patty would
    have had to pay any associated fees directly to Bravo. This is because
    if any Remote ID USS is
    available, even if it is not the one she contracted with, her UAS is
    designed to connect to it
    through the internet. As long as she can connect to the Internet, it
    is incumbent on Patty to
    connect to a USS. Only when the UAS cannot connect to the internet
    would the unmanned
    aircraft be able to take off while only broadcasting.
    On another occasion, Patty is unable to connect to Alpha, Inc. at the
    time of takeoff due
    to a disruption in Alpha’s service, but Bravo is also experiencing
    problems. There are no other
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    publicly available Remote ID USS. Because Patty’s UAS is designed not
    to take off when it has
    access to the internet but is not connected to a Remote ID USS, her
    unmanned aircraft would not
    take off. Her service would be interrupted until Alpha, Bravo, or
    another publicly available USS
    became available.64
    3. Operating a Limited Remote Identification UAS
    Charlie purchases a used UAS that looks like a spaceship. The UAS
    weighs more than
    0.55 pounds and he intends to operate it outside his house for
    recreational purposes, such as
    filming his daughter’s soccer games and entertaining his sons who love
    science fiction movies.
    The person who sold Charlie the UAS assures him it is remote
    identification compliant. Because
    the company responsible for production of the UAS was required to
    label the unmanned aircraft
    to indicate that it is remote identification compliant, Charlie is
    able to confirm the seller’s
    assurance by reading the label affixed to the aircraft. Charlie’s UAS
    is a “limited remote
    identification UAS,” which means it is designed and produced to
    operate no more than 400 feet
    from its control station and cannot broadcast remote identification
    message elements. Under part
    89, he is only allowed to operate his limited remote identification
    unmanned aircraft within
    visual line of sight. Prior to his purchase, Charlie visits the FAA’s
    website and confirms that his
    UAS has an FAA-accepted declaration of compliance. After the previous
    UAS owner deregisters the unmanned aircraft as required by §
    48.105(b)(2), Charlie goes online to the
    FAADroneZone website, applies for, and is issued a Certificate of
    Aircraft Registration under

    64 Practically speaking, the FAA anticipates that there will be many
    more than two publicly available USS and this
    scenario under which all USS would be simultaneously unavailable
    should not occur except in the rarest of
    circumstances.
    111
    part 48. During the registration process, he provides the UAS
    manufacturer name, the model
    name, and the aircraft’s manufacturer-issued serial number.
    Because Charlie is required to register his unmanned aircraft, he is
    also subject to the
    remote identification operating rules in part 89. This means that
    before Charlie can start to use
    the UAS, he must subscribe to a USS. He subscribes to Bravo, Inc., an FAA-qualified Remote
    ID USS and opts to use the unmanned aircraft’s serial number for the
    UAS Identification
    message element. Charlie’s UAS is designed to pair with his smartphone
    to transmit the remote
    identification message elements through an internet connection to a
    USS. Because Charlie’s
    UAS cannot broadcast remote identification message elements, it does
    not function unless his
    smartphone is connected to the internet and transmitting through that
    internet connection to
    Bravo USS. If Charlie’s UAS loses its connection to either the
    internet or is unable to transmit to
    Bravo USS in the middle of an operation, he would be required to land
    the aircraft as soon as
    practicable. Charlie may take off again as soon as his UAS
    reestablishes its connection to the
    internet and can transmit to a Remote ID USS.
    4. Operating a UAS without Remote Identification
    Linus wants to fly a UAS without remote identification that he
    assembled at home from
    parts he bought at a hobby shop a few years ago. He uses his unmanned
    aircraft exclusively as a
    model aircraft. Since he registered his unmanned aircraft in 2018,
    before the effective date of the
    remote identification rule, he was not required to provide any
    specific information about the
    aircraft, such as the serial number. Linus’s aircraft registration
    expires in 2021, and he will renew
    the registration of his unmanned aircraft on the FAADroneZone website.
    At that time, he would
    have to submit the unmanned aircraft’s manufacturer and model name as
    part of the registration
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    process. Because Linus built his own UAS, he plans to use his own name
    as the manufacturer
    and use a model number of his choosing.
    Because his UAS does not have any remote identification capabilities,
    Linus knows he
    may only operate it within an FAA-recognized identification area.
    Linus is a member of the
    Arizona Amateur Modelers (AAM) organization, which has an
    FAA-recognized identification
    area near his home. He found information about AAM’s FAA-recognized identification area at
    the FAA website and has agreed to AAM’s terms and conditions for
    operating within the FAArecognized identification area. While
    operating there, Linus makes sure that both he and the
    unmanned aircraft physically stay within the boundaries of the
    FAA-recognized identification
    area. Linus operates the unmanned aircraft within visual line of sight
    and in accordance with any
    applicable operational rules and site-specific safety guidelines.
    5. Flying in an FAA-recognized Identification Area
    Scenario 1: Linus owns another UAS which is a standard remote
    identification UAS and
    wants to operate it at AAM’s FAA-recognized identification area. Since
    his second UAS is a
    standard remote identification UAS, even when operating within the
    boundaries of the FAArecognized identification area, he is still
    required to ensure that the standard remote identification
    UAS transmits the applicable remote identification message elements
    through an internet
    connection to a Remote ID USS and broadcasts directly from the
    unmanned aircraft. The remote
    identification requirements for Linus are no different inside or
    outside of the FAA-recognized
    identification area when he is operating a UAS with remote
    identification.
    Scenario 2: Linus owns a third UAS – this one a limited remote
    identification UAS –
    which was given to him as a birthday present. He decided he would try
    out his new limited
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    remote identification UAS after he finished posting on his blog. While
    working on his computer,
    there was a massive power outage that took out all communications in
    the city. Since Linus lost
    connection to the internet in both his computer and mobile phone, he
    decided he would go fly his
    limited remote identification UAS at the nearby FAA-recognized
    identification area until the
    internet came back and he could finish working on his blog. When Linus
    arrived at the FAArecognized identification area, he took out the
    limited remote identification UAS from its box,
    turned it on, and attempted to fly. The limited remote identification
    UAS did not lift off. Linus
    realized that he was going to have to go back home to get his standard
    remote identification UAS
    or his UAS with no remote identification capabilities. Even though he
    was at an FAA-recognized
    identification area, he would not be able to fly his limited remote identification UAS because the
    limited remote identification UAS cannot broadcast remote
    identification message elements and
    was produced to meet requirements that prevent it from taking off when
    it cannot connect to the
    internet and transmit to a Remote ID USS. Linus will be able to
    operate his limited remote
    identification UAS at the FAA-recognized identification area or
    elsewhere when the connection
    to the internet is reestablished and his limited remote identification
    UAS is able to transmit to a
    Remote ID USS.
    Scenario 3: Sam is cleaning out his closet and finds a UAS that he
    bought a number of
    years ago. The UAS was purchased before the remote identification rule
    went into effect and the
    unmanned aircraft weighs 1 pound. He remembers registering the
    unmanned aircraft, but knows
    it does not have remote identification. Sam is aware that some older
    UAS manufactured without
    remote identification could receive a software update that makes them
    remote identification
    compliant. He checks the UAS manufacturer’s website, but unfortunately
    his model of UAS is
    114
    not eligible for an update. Because Sam’s unmanned aircraft is
    required to be registered and does
    not have remote identification, Sam can only operate it at an
    FAA-recognized identification area.
    XI. Law Enforcement Access to Remote Identification and Registration Information
    In addition to aiding the FAA in its civil enforcement of FAA
    regulations, the FAA
    anticipates that with the implementation of the proposed remote
    identification requirements, law
    enforcement and national security agencies would find the remote
    identification information
    useful for criminal enforcement, public safety, and security purposes.
    There are over 18,000 law
    enforcement and security agencies across the United States, many of
    which would seek access to
    remote identification information to respond to emerging threats or as
    part of an investigation.
    The FAA envisions it would facilitate near real-time access to the
    remote identification
    message elements (paired with certain registration data, when
    necessary) for accredited and
    verified law enforcement and Federal security partners. The
    information could be used to
    identify and possibly contact the person manipulating the flight
    controls of a UAS in response to
    potentially unsafe or nefarious UAS activities. Potential scenarios
    include local law enforcement
    or Federal agencies seeking information in response to nuisance calls
    from private citizens or
    large crowd event managers; UAS at emergency scenes (e.g., fires,
    motor vehicle accident
    scenes); critical infrastructure protection; UAS around airports; and
    manned aircraft encounters
    with UAS. Law enforcement agencies would be able to access remote identification information
    in near real-time and also access remote identification information
    maintained by Remote ID
    USS.
    Remote identification would assist in providing law enforcement and
    security agencies
    with important information about the UAS in real time, including the
    location of the control
    115
    station and therefore the location of the person manipulating the
    flight controls of the UAS. This
    information would better enable law enforcement to immediately find
    the location of the person
    manipulating the flight controls of a UAS and help with preliminary
    threat discrimination. In
    addition, when correlated with registration information, remote
    identification of UAS also would
    enable law enforcement officers to determine some information about
    who the UAS’ owner is
    before engaging the person manipulating the flight controls of a UAS
    directly. Once located, a
    law enforcement officer can speak with the person manipulating the
    flight controls of a UAS to
    gain potential insight into his or her intentions and allow the
    officer to either educate the person
    manipulating the flight controls of a UAS or begin an investigation.
    Although remote
    identification of UAS may not deter nefarious actors, it would allow
    the swift interdiction of the
    clueless and careless persons manipulating the flight controls of UAS
    and shift law enforcement
    and security partners’ UAS protection efforts to the truly nefarious
    actors. This information
    would also aid in any subsequent criminal or civil enforcement action.
    Remote identification information, when correlated with UAS registry information,
    would inform law enforcement officers about two essential factors: who registered the UAS, and
    where the person manipulating the flight controls of a UAS is
    currently located. This is
    particularly relevant to a law enforcement officer’s decision on
    whether use of force would be
    appropriate. Law enforcement officials have made clear that it can be
    very difficult to make a
    decision about the potential intent of a person manipulating the
    flight controls of a UAS with the
    limited information available from visually observing a UAS. Remote identification information
    would enable better threat discrimination, an immediate and
    appropriate law enforcement
    response, and a more effective follow-on investigation.
    116
    As part of this NPRM, the FAA has conducted a Privacy Impact
    Assessment. The PIA
    found the NPRM requirements that affect privacy include, among others,
    the registration of the
    UAS with the FAA, the transmission of data from the UAS to Remote ID
    USS, and the broadcast
    of data from standard remote identification UAS to any person capable
    of receiving broadcasts.
    As noted elsewhere in this NPRM, the FAA anticipates that the message
    elements related to any
    standard remote identification UAS or limited remote identification
    UAS are publicly available
    information and may be accessed by any person able to receive a
    broadcast or who has access to
    a Remote ID USS. Currently, the FAA restricts access to information
    contained in its small
    unmanned aircraft registration system; the FAA is not proposing to
    change the restrictions
    regarding that information.
    The PIA discusses the information proposed to be collected and the
    uses of that
    information. The PIA points to several mitigation strategies
    including: limiting collection to only
    relevant and necessary personally identifiable information (PII),
    limiting the use of PII to the
    specific purpose for which it was collected, using security measures
    to protect PII collected,

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