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compliance. Instead, the error correction capabilities incorporated
into a proposed means of
compliance would be reviewed and evaluated as a part of the acceptance
process.
8. Interference Considerations
As proposed in § 89.310(h) for standard remote identification UAS and
in § 89.320(h) for
limited remote identification UAS, and consistent with FCC
regulations, the FAA would prohibit
the remote identification equipment from causing harmful interference
to other systems or
equipment installed on the unmanned aircraft or control station. For
example, the remote
identification equipment could not cause harmful interference to the
UAS command and control
datalink and could not otherwise be in violation of FCC regulations.
In addition, the remote
identification equipment would not meet the requirements of this rule
if its operation would be
adversely affected by interference from other systems or equipment
installed on the unmanned
aircraft or control station, such as the UAS command and control
datalink or a camera feed from
the unmanned aircraft to a display at the control station.
135
A specific means of compliance may include requirements to use
specific radio frequency
emitters and receivers. The FAA envisions that a proposed means of
compliance could include
an analysis of frequency congestion and interference considerations.
For example, a proposed
means of compliance could require analysis and mitigation of
interference from equipment on
the ground as well as other similarly equipped unmanned aircraft in
the air. Additionally, the
means of compliance could also consider the impact those equipped
aircraft could have on
manned aircraft or equipment on the ground that use the same frequency
bands (e.g., personal
electronic devices). The FAA does not propose a particular method by
which interference
considerations are identified or mitigated by designers or producers.
Instead, the FAA would
consider proposed methods for dealing with interference considerations
and would verify that
they are appropriate for the types of equipment and operations
applicable to those means of
compliance and do not run counter to any applicable regulations,
including FCC regulations.
9. Message Transmission
The FAA is proposing in § 89.310(i)(1) that standard remote
identification UAS be
capable of transmitting the message elements in proposed § 89.305
through an internet
connection to a Remote ID USS. Additionally, the FAA is proposing in § 89.310(i)(2) to require
that standard remote identification UAS be capable of broadcasting the
message elements in
proposed § 89.305 using a non-proprietary broadcast specification and
radio frequency spectrum
in accordance with 47 CFR part 15 that is compatible with personal
wireless devices. The FAA
envisions that remote identification broadcast equipment would
broadcast using spectrum similar
to that used by Wi-Fi and Bluetooth devices. The FAA is not, however,
proposing a specific
frequency band. Rather, the FAA envisions industry stakeholders would
identify the appropriate
spectrum to use for this capability and would propose solutions
through the means of compliance
136
acceptance process. This requirement would ensure that the public has
the capability, using
existing commonly available and 47 CFR part 15 compliant devices, such
as cellular phones,
smart devices, tablet computers, or laptop computers, to receive these broadcast messages.
The FAA has considered the conditions of operation, the general
technical requirements,
and the performance limitations associated with the use of part 15
devices and has determined
that these conditions, requirements, and limitations would be
acceptable and compatible with the
proposed use and expected performance of the broadcast capability of
standard remote
identification UAS. The FAA acknowledges that, by rule, part 15
devices, including those used
for the remote identification broadcast, may not cause harmful
interference and must accept any
interference received.
To meet the proposed requirement of compatibility with personal
wireless devices, a
means of compliance may take into consideration whether the remote identification capability
would be compatible with current and older models of personal wireless
devices still in common
usage. The FAA intends the proposed requirement to ensure that the
broadcast message from
standard remote identification UAS would be accessible by most
personal wireless devices in
use.
Additionally, for standard remote identification UAS, § 89.310(i)(2)
proposes that the
broadcast device use radio frequency spectrum in accordance with 47
CFR part 15 that is
compatible with personal wireless devices and must be designed to
maximize the range at which
the broadcast can be received, while complying with the 47 CFR part 15 regulatory requirements
in effect at the time that the Declaration of Compliance is submitted
for FAA acceptance, and
must be integrated into the unmanned aircraft or control station
without modification to its
authorized radio frequency parameters. This proposed requirement would
ensure that producers
137
use a means of compliance that specifies a broadcast technology or
broadcast technology
characteristics that maximize the broadcast range while still meeting
the other minimum
performance requirements under this proposed rule. Maximizing the
broadcast range would
ensure that remote identification information would be available to
the largest number of
potential receiving devices within the limits permitted by law.
Maximized range would also
optimize future operational capabilities, such as detect-and-avoid and aircraft-to-aircraft
communications where range is a factor.
For limited remote identification UAS, the FAA is proposing in §
89.320(i) that the UAS
be capable of transmitting the message elements in proposed § 89.315
through an internet
connection to a Remote ID USS. Under the proposed rule, limited remote identification UAS
would be prohibited from broadcasting the remote identification
message elements.
For both standard and limited remote identification UAS, at this time
the FAA has not
proposed any requirements regarding how the UAS connects to the
internet to transmit the
message elements or whether that transmission is from the control
station or the unmanned
aircraft. The FAA understands, however, that there are concerns about
the impact that connecting
to the internet directly from the unmanned aircraft (as opposed to the
control station) could have
on networks that use radio frequency spectrum, including interference,
network stability, or other
effects. The FAA seeks comments on these potential effects,
recognizing that issues of
interference or other impacts to communications networks are
independently reviewed by the
FCC. The FAA requests that comments indicate any drawbacks or impacts
to users or license
holders of either licensed or unlicensed spectrum. Additionally, the
FAA seeks feedback
regarding whether any existing UAS are capable of connecting to the
internet from the
unmanned aircraft, and if so, what methods are used for those
connections.
138
10. Interoperability
To achieve interoperability among standard remote identification UAS
that may be
produced using different means of compliance, the FAA is also
proposing in § 89.310(i)(2) that
for standard remote identification UAS, a means of compliance would be
required to include the
requirement that the message elements be broadcast using a
non-proprietary specification for
remote identification. For the broadcast to be interoperable with
personal wireless devices, the
message elements for standard remote identification UAS would have to
be broadcast using a
message format available to the public. A known message format is
necessary for the receiving
personal wireless devices to decode the messages and make the message
elements available for
use by software applications on the receiving devices. For example,
where the UAS remote
identification broadcast message format is known to the public, an
entity would be able to
develop a mobile phone application that allows the user to view
unmanned aircraft operating
nearby on a map display.
11. Message Elements Performance Requirements
As proposed in § 89.310(j) for standard remote identification UAS and
§ 89.320(j) for
limited remote identification UAS, the FAA would require that all UAS
with remote
identification meet certain minimum requirements regarding the
transmission of the message
elements including the minimum performance requirements related to
positional accuracy,
barometric pressure, message latency, and message transmission rate.
The FAA invites
comments on whether the parameters for the message elements
performance requirements
proposed in § 89.310(j) and § 89.320(j) are appropriate and requests
commenters submit
specifics, supported by data, to sustain their position.
139
i. Transmission and Broadcast of Identical Message Elements
Under § 89.310(j)(1), the FAA is proposing that standard remote
identification UAS
transmit and broadcast identical message elements.
ii. Positional Accuracy
The FAA is proposing positional accuracy requirements that are
compatible with
commercial off the shelf position sources, such as GPS receivers
integrated into many existing
UAS, smart phones, or other smart devices. For an unmanned aircraft,
the position source is
considered to be equipment onboard the aircraft that computes a
geodetic position (latitude and
longitude). The position source can be a separate sensor or can be
integrated into other systems.
While the FAA anticipates that most unmanned aircraft would use a GPS
receiver as the position
source, other equipment could be used as long as it is capable of
producing the required message
elements and meets the proposed accuracy requirement. For a control
station, the position source
is considered to be equipment that is either integrated into the
control station or separate from but
in close proximity to the control station. For example, a commercially available smart phone
with a GPS receiver could be an acceptable control station position
source if it meets the
proposed accuracy requirement.
As proposed in § 89.310(j)(2) for standard remote identification UAS,
the reported
position of the unmanned aircraft and control station would have to be
accurate to within 100
feet of the true position, with 95 percent probability. For limited
remote identification UAS, the
same requirement is proposed in § 89.320(j)(1) except that it would
only apply to the control
station since the FAA is not proposing an unmanned aircraft location
message element
requirement for limited remote identification UAS. The proposed
100-foot accuracy requirement
140
is based on the 30-meter (98.4 feet) accuracy requirement for
commercial off the shelf GPS
position sources allowed for Traffic Awareness Beacon System (TABS)
equipment in TSOC19969
.
Based on information the FAA has reviewed from UAS producers and smart
device
technology developers, the FAA believes this accuracy requirement is
achievable by the majority
of GPS-enabled UAS and smart devices in use today, and indications are
that future GPS-based
technology will have improved accuracy compared to current systems.
The FAA expects that
future UAS will take advantage of technological advancements in
position source accuracy to
provide even greater accuracies as technologies evolve.
iii. Barometric Pressure Altitude Accuracy
The FAA is proposing an unmanned aircraft and control station
barometric pressure
altitude accuracy requirement that it believes is compatible with
barometers integrated into many
existing UAS, smart phones, and smart devices.
As proposed in § 89.310(j)(3) for standard remote identification UAS,
the reported
barometric pressure altitude for the unmanned aircraft and the control
station would be required
to be accurate to within 20 feet of the true barometric pressure
altitude for pressure altitudes
ranging from 0 to 10,000 feet. For limited remote identification UAS,
the same requirement is
proposed in § 89.320(j)(2) for the control station only, as there is
no unmanned aircraft pressure
altitude message element requirement for limited remote identification
UAS. Based on
information the FAA has reviewed from producers of UAS, the FAA
believes this requirement is

69 See http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgTSO.nsf/0/1600df588a6f53ae86257d710070d105/$FILE/TS
O-C199.pdf. Accessed July 31, 2019.
141
achievable by many UAS and smart devices in use today that are
equipped with a barometer. In
addition, there are indications that UAS and smart device barometer
technology is continually
improving in terms of accuracy, and the FAA expects the trend of
improving performance and
accuracy of these systems to continue. The FAA seeks comment from UAS
designers and
producers and other interested individuals on whether the proposed
barometric pressure altitude
accuracy requirement is consistent with current and anticipated future
UAS performance
capabilities.
iv. Remote Identification Message Latency
The FAA is proposing a remote identification system latency
requirement that it believes
is compatible with existing commercial off the shelf UAS systems,
including position sources,
and both transmit and broadcast technologies. The proposed latency
requirement would apply to
both the transmitted message set and the broadcast message set and is
the time between when a
position is measured by the unmanned aircraft or control station
position source and when it is
transmitted and broadcast by the remote identification equipment. The
latency requirement does
not apply to any systems external to the UAS, such as broadcast
receivers or information display
devices. Based on information the FAA has reviewed from manufacturers
of commercial off the
shelf position sources, broadcast equipment, and transmission
equipment, the FAA believes a
latency of no more than one second is achievable by existing systems.
The FAA therefore
proposes that this is the appropriate latency requirement for the
remote identification message set
in § 89.310(j)(4) for standard remote identification UAS and in §
89.320(j)(3) for limited remote
identification UAS.
142
v. Remote Identification Message Transmission Rate
The FAA is proposing a transmission rate for the remote identification
message elements
that it believes is compatible with existing commercial off the shelf
UAS systems, including both
internet connectivity and broadcast technologies. The proposed
transmission rate would apply to
both the message elements transmitted to a Remote ID USS and
broadcast, and is the minimum
rate at which the remote identification message would be either
broadcast or transmitted to a
Remote ID USS by the remote identification equipment. The FAA believes
a transmission rate of
at least 1 message per second (1 hertz) is achievable by existing
systems and is proposing this as
the minimum transmission rate for the remote identification message
elements in § 89.310(j)(5)
for standard remote identification UAS and § 89.320(j)(4) for limited
remote identification UAS.
12. Cybersecurity
As proposed in § 89.310(k) for standard remote identification UAS and
§ 89.320(k) for
limited remote identification UAS, the FAA is proposing to require all
UAS with remote
identification equipment to incorporate cybersecurity protections for
the transmission and
broadcast of the message elements, as appropriate. Cybersecurity
protections are necessary to
defend against cyber threats that could adversely affect the
authenticity or integrity of the remote
identification information being transmitted by the UAS to a Remote ID
USS or being broadcast
from the unmanned aircraft. The FAA is not proposing any specific
cybersecurity protection
methods that would be required to be incorporated into an FAA-accepted
means of compliance.
Instead, the cybersecurity protection methods incorporated into a
proposed means of compliance
would be reviewed and evaluated as a part of the acceptance process.
143
13. Range Limitation
The FAA is proposing in § 89.320(l) to require that a limited remote identification UAS
be designed to operate no more than 400 feet from its control station.
The FAA is proposing this
as a performance-based requirement so that persons submitting means of compliance can
innovate and develop their own means to meet the requirement. The FAA
envisions that this
requirement can be met through a range of solutions, such as
geo-fencing or command and
control link power limitations.
The FAA is not proposing to impose any range limitation on standard
remote
identification UAS.
14. Broadcast Limitation
The FAA is proposing in § 89.320(m) to prohibit limited remote
identification unmanned
aircraft from broadcasting remote identification message elements
identified in § 89.305 or
§ 89.315. A limited remote identification unmanned aircraft cannot
broadcast remote
identification message elements using radio frequency spectrum because
the broadcast function
is only applicable to standard remote identification UAS. Remote
identification broadcast
capability on a limited remote identification UAS would not have been
designed or produced to
meet the proposed requirements in this rule and could result in
erroneous, non-compliant, or
incorrectly formatted messages being broadcast, undermining the
principal purposes of this
proposed rule. An unmanned aircraft that is equipped to broadcast any
of the remote
identification message elements identified in § 89.305 or § 89.315
would have to comply with
the remote identification requirements for standard remote
identification UAS.
144
E. Other Performance Requirements Considered
The FAA considered imposing additional performance requirements as
part of an
acceptable means of compliance; however, the FAA believes that the
current proposal reflects
the minimum requirements necessary to achieve the intent of the
proposed rule. Regardless, the
FAA acknowledges that imposing additional requirements could add value
to the remote
identification of UAS and further integration into the National
Airspace System. The FAA
welcomes comments on whether the final rule should incorporate
additional performance
requirements, including but not limited to any of the ones addressed
in this section.
The FAA emphasizes that nothing in the proposed rule would preclude a
person or entity
from developing and submitting a means of compliance that covers the
topics discussed in this
section or any other topics that span beyond the minimum performance requirements of the
proposed rule. Although the FAA is proposing to require specific
minimum performance
requirements on certain message elements such as location and
altitude, the FAA envisions that
technology may progress such that improved performance may become
achievable and revised
minimum performance requirements may be appropriate at some point in
the future. For this
reason, the FAA would be willing to consider means of compliance that incorporate performance
requirements that are more stringent and that exceed the minimum
performance requirements of
the proposed rule. The FAA would not accept any means of compliance
that fails to meet any of
the minimum performance requirements of the proposed rule but would
consider accepting
means of compliance that exceed the minimum performance requirements.
Once a means of compliance is accepted by the FAA, it establishes the
actual required
performance and functionality for UAS with remote identification that
are designed and
produced using that particular means of compliance. A person
responsible for the design and
145
production of UAS using a particular means of compliance would be
required to adhere to that
means of compliance in its totality, even if certain elements exceed
the minimum performance
requirements. Developers of means of compliance should consider the implications of specifying
performance or functionality that exceeds the minimum regulatory
requirements.
The FAA considered several potential requirements that it ultimately
decided were not
necessary to include in the proposed minimum performance requirements.
The FAA considered
but chose not to propose the following:
? Other message elements such as certain UAS operator contact
information or other
aircraft or control station information such as velocity, direction,
route, or altitude above
ground level;
? Equipment interface requirements such as the appropriate connections
between GPS
receivers, altimeters, and the remote identification message compiler,
the communication
protocol between the aircraft and the control station through which
remote identification
message data is exchanged, or protocols and interfaces between UAS,
internet providers,
and Remote ID USS;
? Flight data recording features to store remote identification
information within the UAS;
? Requirements for connection indications such as a separate
indication of whether the
UAS is connected to the internet and its connection to a specific
Remote ID USS, an
indication of the transmission latency, or a notification of the
specific Remote ID USS to
which the UAS is connected; or
? Transmission or broadcast requirements during a command and control
lost-link event.
146
Although the FAA is not proposing these features in the minimum
performance
requirements, the FAA requests comments on whether and why any should
be required.
F. Submission and FAA Acceptance of Means of Compliance
Any person or entity would be able to submit a proposed means of
compliance to the
FAA for review and potential acceptance. To submit a means of
compliance for acceptance by
the FAA, a person or entity would be required to indicate how the
means of compliance meets
the minimum performance requirements in §§ 89.305 through 89.320, as applicable, by
submitting any information, analysis, or test results necessary for
the FAA to determine
acceptability. Specifically, under § 89.405(b), the person or entity
would be required to submit
all of the following information to the FAA: (1) the name of the
person or entity submitting the
means of compliance, the name of the main point of contact for
communications with the FAA,
the physical address, email address, and other contact information;
(2) a detailed description of
the means of compliance; (3) an explanation of how the means of
compliance addresses all of the
minimum performance requirements established in §§ 89.305 through
89.320, as applicable, so
that any standard remote identification UAS or limited remote
identification UAS designed and
produced using that means of compliance meets the remote
identification performance
requirements of proposed part 89; and (4) any substantiating material
the person or entity wishes
the FAA to consider as part of the application.
In § 89.405(c), the FAA is proposing to require the means of
compliance to include
testing and validation procedures for the person responsible for
production of the standard
remote identification UAS or limited remote identification UAS to
demonstrate through analysis,
ground test, or flight tests, as appropriate, how the UAS with remote identification would
perform its intended functions and how it meets the minimum
performance requirements
147
established in §§ 89.305 through 89.320, as applicable. The FAA makes
no finding on radio
transmitter technical compliance with 47 CFR regulations but expects technically compliant
transmitters to be integrated into the UAS without modification to
their authorized radio
frequency parameters.
The FAA would indicate acceptance of a means of compliance by
notifying the submitter
and publishing a notice in the Federal Register identifying the means
of compliance as accepted.
The FAA would also notify the public that it has accepted the means of compliance by including
it on a list of accepted means of compliance at https://www.faa.gov.
The FAA would not disclose
commercially valuable information in this document. It would only
provide general information
stating that FAA has accepted the means of compliance.
G. Rescission of a Means of Compliance
Pursuant to proposed § 89.415, a means of compliance is subject to
ongoing review by
the Administrator. The Administrator would be able to rescind
acceptance of a means of
compliance when the Administrator finds that a means of compliance
does not meet any or all of
the requirements of the proposed rule. The FAA would publish a notice
of rescission in the
Federal Register. If discussions with the person or entity that
submitted the means of compliance
are unable to resolve any noncompliance issues, the FAA would notify
the person or entity who
submitted the FAA-accepted means of compliance of its decision to
rescind its acceptance of the
means of compliance by sending a letter of rescission to the email
address on file for such person
or entity. The FAA would also provide notice of the rescission to any
person responsible for the
production of standard remote identification UAS or limited remote identification UAS who
submitted an FAA-accepted declaration of compliance as discussed in
section XIII.E of this
preamble that uses the means of compliance that is no longer accepted
as a basis for compliance
148
with the proposed requirements of this rule. Lastly, the FAA would
also choose to publish at
https://www.faa.gov a list of rescinded means of compliance.
The main consequence of the rescission of the FAA’s acceptance of a
means of
compliance is that the FAA’s acceptance of any declaration of
compliance that relies on the no
longer accepted means of compliance may be rescinded. Therefore, any
UAS with remote
identification produced and listed under a declaration of compliance
that relies on a no longer
accepted means of compliance would fail to comply with the proposed requirements of this rule
and would be restricted to flying within FAA-recognized identification
areas. The rescission of
the FAA’s acceptance of a declaration of compliance, as a result of
the rescission of the FAA’s
acceptance of a means of compliance, would follow the rescission and reconsideration provisions
of proposed § 89.530. In such case, prior to rescinding the FAA’s
acceptance of a declaration of
compliance, the FAA proposes to notify the submitters of the affected FAA-accepted
declaration(s) of compliance that their declaration(s) of compliance
may be rescinded by sending
a letter to the email address on file for such person or entity. Where
the proposed rescission is
due to the rescission of the FAA’s acceptance of a means of
compliance, the FAA may allow the
submitter of the FAA-accepted declaration of compliance to amend the declaration of
compliance to include another FAA-accepted means of compliance, as
long as the UAS
produced and listed under the declaration of compliance comply with
the newly-listed means of
compliance. The FAA proposes not to rescind its acceptance of a
declaration of compliance that
is promptly amended to list another FAA-accepted means of compliance.
Failure to amend the
declaration of compliance would result in the rescission of FAA
acceptance of the declaration of
compliance in accordance with the provisions of § 89.530.
149
The FAA does not expect the rescission of its acceptance of a means of compliance to
occur frequently. However, the FAA does contemplate potential
scenarios when FAAacceptance of a means of compliance might be
rescinded. For example, the FAA could rescind
its acceptance of a means of compliance if it is based on a technology
standard that becomes
obsolete, particularly if the old technology would interfere with the
newer technologies used on
UAS at that given time. The FAA believes that due to the rapid changes
in technology, new
means of compliance would likely be submitted for FAA acceptance
whenever a significant
technological change warrants a change in the design and production of
UAS with remote
identification. The FAA believes that due to the typical lifecycle of
UAS, very few UAS built in
accordance with older means of compliance would be in operation by the
time the FAA’s
acceptance of a means of compliance is rescinded due to a major shift
in technology. By that
time, the FAA expects most UAS would be designed and produced in
accordance with the latest
means of compliance available. Older, operational UAS built in
accordance with means of
compliance that are no longer accepted would still be eligible to
operate within FAA-recognized
identification areas.
H. Record Retention Requirements
In § 89.420, the FAA is proposing for persons or entities who submit FAA-accepted
means of compliance under part 89 to retain certain information for as
long as the means of
compliance is accepted plus an additional 24 calendar months. The
information would be
required to be made available to the FAA upon request. Specifically,
the person or entity would
be required to retain all documentation and substantiating data
submitted for the acceptance of
the means of compliance; records of all test procedures,
methodologies, and other procedures, if
150
applicable; and any other information necessary to justify and
substantiate how the means of
compliance enables compliance with the remote identification
requirements of part 89.
This requirement is being proposed so that, in the event of an FAA investigation or
analysis, the Administrator may obtain data necessary to re-assess the acceptability of the means
of compliance. The additional 24 calendar months is being proposed
because the FAA envisions
that, if a means of compliance is found to no longer be acceptable,
UAS produced using that
means of compliance might still be on the market or in the possession
of operators. The
additional time would ensure that the data is still readily available
while any FAA actions are
being taken such as possible rescissions of FAA acceptance of
declarations of compliance. If the
FAA requests the data and the submitter did not retain the data in
accordance with this
requirement, then the Administrator may choose to rescind acceptance
of the means of
compliance.
XIII. Design and Production Requirements
A. Applicability and Summary of Requirements
Subpart F of the proposed rule prescribes requirements for the design
and production of
UAS operated in the United States. It also proposes certain procedural requirements for the
submission of declarations of compliance for FAA acceptance and
certain rules governing
persons who have submitted FAA-accepted declarations of compliance.
According to proposed § 89.501(c), the requirements of subpart F would
not apply to the
following UAS, unless they are intentionally designed or produced as
standard remote
identification UAS or limited remote identification UAS:
151
? Amateur-built UAS.
? UAS of the United States Government.
70
? UAS where the unmanned aircraft weighs less than 0.55 pounds
including the weight
of anything attached to or carried by the aircraft.
? UAS designed or produced exclusively for the purpose of aeronautical
research or to
show compliance with regulations.
The FAA is proposing that persons responsible for the production of
standard remote
identification UAS or limited remote identification UAS would be
required to do the following:
? Under § 89.505, ensure each UAS produced has a serial number that
complies with
the ANSI/CTA-2063-A serial number standard.
? Under § 89.510(a)(1), ensure that the UAS are designed and produced
to meet the
minimum performance requirements for standard remote identification
UAS or
limited remote identification UAS by using an FAA-accepted means of
compliance.
? Under § 89.510(b), comply with certain inspection, audit, and
notification
requirements.
? Under § 89.515, label each unmanned aircraft to indicate that the
unmanned aircraft
system is remote identification compliant and indicate whether it is a
standard remote
identification UAS or a limited remote identification UAS.


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