[continued from previous message]

70 Although this exception applies to UAS produced for the use of the
United States Government, U.S. government
entities would still be bound by the operating provisions of part 89,
subpart B. Only the aircraft of the national
defense forces of the United States are excepted from the aircraft
registration requirements and not required to
comply with subpart B. All other United States government entities who
wish to use UAS without remote
identification at a location other than an FAA-recognized
identification area would be required to seek authorization
from the Administrator to deviate from the operating provisions of
subpart B.
152
? Under § 89.520, submit a declaration of compliance for acceptance by
the FAA
declaring that the UAS complies with the design and production
requirements of the
proposed rule.
The FAA anticipates that most UAS produced will be consumer or
professional grade, fullyassembled UAS from a commercial manufacturer.
Under those circumstances, the manufacturer
is subject to all of the design and production requirements of subpart
F. There are certain
circumstances, however, where the responsibility for the production requirements may be less
obvious.
? UAS Kits. The FAA anticipates that some UAS producers will wish to
sell kits that
would allow a person to assemble a fully functional UAS. If the kit
contains all the parts
and instructions necessary to build a UAS, the producer of the kit,
not the person
assembling the UAS from the kit, is considered the manufacturer of the
UAS and is
subject to all of the design and production requirements of proposed
subpart F. For
purposes of the proposed rule, the FAA does not consider any package
containing less
than 100% of the parts and instructions necessary to assemble a
complete, functional
UAS to be a UAS kit.
? Amateur-built UAS. As discussed later in this section, the FAA
considers a UAS to be
amateur built when the person building it fabricates and assembles
more than 50 percent
of the UAS. Under these circumstances, the person building the UAS
would be the
producer and may, but is not required to, comply with the design and
production
requirements of proposed subpart F.
153
? UAS assembled completely from pre-fabricated parts. The FAA
anticipates that some
model aircraft enthusiasts may assemble UAS entirely from
pre-fabricated parts and that
commercial vendors may wish to sell UAS parts, including packages that
contain more
than 50 but less than 100 percent of the parts necessary to build a
UAS. The resulting
UAS would not qualify as amateur-built because the person building it
would be
fabricating and assembling 50 percent or less of the UAS. The UAS
would not qualify as
built from a kit because it did not include 100 percent of the
necessary parts. Under these
circumstances, the person assembling the UAS would be considered the
producer and
would be required to comply with the design and production
requirements of proposed
subpart F.
In § 89.1 of this proposed rule, the FAA proposes defining an
amateur-built unmanned
aircraft system as a UAS, the major portion of which has been
fabricated and assembled by a
person who undertook the construction project solely for his or her
own education or recreation.
The FAA would consider a UAS to be amateur built if the person
building it fabricates and
assembles at least 50 percent of the UAS.
The FAA is proposing, in § 89.501(c)(1) to exclude amateur-built UAS
from the
requirements of subpart F. Specifically, amateur-built UAS would not
be required to meet the
performance requirements for a standard remote identification UAS or
limited remote
identification UAS. However, irrespective of the applicability of
subpart F, all UAS operated in
the airspace of the United States would be subject to the operating requirements of the proposed
rule. Accordingly, an amateur-built UAS that is fabricated and
assembled without remote
identification would be restricted to operating within an
FAA-recognized identification area in
accordance with §§ 89.105(c) and 89.120. The FAA has chosen to exclude
this category from the
154
design and production requirements of this rule because builders of amateur-built UAS may not
have the necessary technical knowledge, ability, or financial
resources to design and produce a
UAS that meets the minimum performance requirements proposed in this
rule. Requiring
amateur-built UAS to comply with the performance requirements proposed
in this rule would
place an undue burden on the builders of these UAS. The FAA expects
that amateur-built UAS
will represent a very small portion of the total number of UAS
operating in the airspace of the
United States.
Nothing in this proposal would prevent a person from building a UAS
with remote
identification for educational or recreational purposes. However, a
person doing so would be
subject to all of the requirements of subpart F, even if the UAS would otherwise be considered
an amateur-built UAS. For example, an individual may wish to design
and produce their own
standard remote identification UAS for educational or other purposes,
procuring parts and
components from multiple vendors. Under the proposed § 89.501(c), this
person would be
required to meet the requirements of subpart F including using a means
of compliance that meets
the requirements of proposed § 89.310.
The FAA is not proposing any restrictions on the sale, transfer of
ownership, or lending
of amateur-built UAS with or without remote identification to someone
other than the person
who originally built the UAS. For example, a person could lend his or
her amateur-built UAS to
another person on a temporary basis or sell it after he or she no
longer intends to use it for
personal operation. However, the new operators of such UAS would be
required to comply with
the applicable operating rules at all times, including the limitation
to fly within an FAArecognized identification area if the
amateur-built UAS does not have remote identification.
155
The FAA anticipates that some UAS producers will wish to sell complete
kits including
all parts and instructions that would allow a person to assemble a
fully functional UAS with
remote identification. If the kit contains all the parts and
instructions necessary to build a
standard remote identification UAS or limited remote identification
UAS, and the fully
assembled UAS would meet the requirements of an FAA-accepted means of compliance, then
the producer of the kit, not the person assembling the UAS from the
kit, is considered the
producer of the UAS and is subject to all of the design and production requirements of subpart F.
A requirement for the owner to assemble some or all of the parts of a
UAS fabricated by a
particular company prior to flight would not turn that owner into a
producer for purposes of
subpart F when all the parts and instructions for assembly have been
included for sale.
The FAA requests comments about whether persons should be allowed to
produce kits
for sale that contain 100 percent of the parts and the instructions
for assembly necessary to build
a fully functioning UAS without remote identification capability. Once assembled, such UAS
without remote identification would be required to either have the
unmanned aircraft weigh less
than 0.55 pounds or operate only within an FAA-recognized
identification area.
UAS that are designed and produced for the purpose of aeronautical
research or showing
compliance with regulations would not be required to meet the
production requirements of the
rule. The FAA intends this exception to allow for testing of prototype
UAS not intended for sale
without the requirement that the producer meet all of the production requirements of the
proposed rule. Any person operating a UAS under this exception would
still need to receive
authorization from the Administrator to operate the UAS in accordance
with § 89.120.
156
B. Requirement to Issue Serial Numbers
The FAA is proposing in § 89.505 to require the person responsible for
the production of
standard remote identification UAS or limited remote identification
UAS to issue a serial number
to each unmanned aircraft that complies with the ANSI/CTA-2063-A
serial number standard.
The FAA is proposing to adopt ANSI/CTA-2063-A as the serial number
standard to be used by
producers of UAS, and seeks comments on this approach. The FAA
believes the standard is
appropriate because it enables the issuance of unique serial numbers
to UAS and promotes
worldwide standardization of UAS remote identification requirements:
the European
Commission recently issued rules adopting this standard.
71
The FAA seeks specific comment regarding whether this standard can be effectively used
as a serial number standard for unmanned aircraft other than small
unmanned aircraft.
1. American National Standards Institute/Consumer Technology
Association
Standard 2063-A
For the serial number, the FAA is proposing the use of American
National Standards
Institute/Consumer Technology Association standard 2063-A
(ANSI/CTA-2063-A) – Small
Unmanned Aerial Systems Serial Numbers (September 2019) for the format
of the serial number.
ANSI/CTA-2063-A outlines the elements and characteristics of a serial
number to be used by
small UAS.72 The FAA is proposing the use of ANSI/CTA-2063-A as it has
been specifically
developed to provide a format for small UAS serial numbers. It is the
only widely available

71 Commission Delegated Regulation (EU) 2019/945 of 12 March 2019 on
unmanned aircraft systems and on thirdcountry operators of unmanned
aircraft systems.
72 ANSI/CTA-2063-A – Small Unmanned Aerial Systems Serial Numbers
(September, 2019) available at
https://www.cta.tech.
157
standard for these serial numbers. Use of ANSI/CTA-2063-A would
provide a single accepted
format for serial numbers, helping to ensure consistency in
transmission of this message element.
The FAA seeks feedback from UAS manufacturers who are assigning serial
numbers in
accordance with ANSI/CTA-2063-A, including the type and number of UAS
that the serial
numbers are being assigned to.
2. Incorporation by Reference
The FAA is proposing to incorporate ANSI/CTA-2063-A by reference. The
Office of the
Federal Register has regulations concerning incorporation by
reference. These regulations
require that, for a final rule, agencies must discuss in the preamble
to the rule the way in which
materials that the agency incorporates by reference are reasonably
available to interested
persons, and how interested persons can obtain the materials.
Additionally, the preamble to the
rule must summarize the material.
Interested persons can view ANSI/CTA-2063-A at https://www.cta.tech by
creating a
free account and searching under “Research and Standards”. At the time
of publication of this
notice of proposed rulemaking, the ANSI/CTA-2063-A standard is
available for viewing and
download free of charge. ANSI/CTA-2063-A is summarized in the
immediately preceding
section, 1. American National Standards Institute/Consumer Technology Association Standard
2063-A.
C. Requirement to Label UAS
The FAA proposes in § 89.515 that persons responsible for the
production of standard
remote identification UAS and limited remote identification UAS label
each UAS with an
indication of its remote identification capability and whether it is a
standard remote identification
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UAS or a limited remote identification UAS. The FAA envisions such
labels would be useful to
UAS operators, FAA inspectors, investigators, and law enforcement
agencies by communicating
the capabilities and restrictions of a particular unmanned aircraft
with respect to remote
identification. The label would be affixed to the unmanned aircraft
and would provide a simple
and efficient way to determine the UAS capabilities. The FAA is not
proposing a prescriptive
labeling requirement that specifies exactly how a producer would label
an aircraft, what size font
to use, where the label would have to be located, and so on. Due to
the variety of UAS models
that exist, such a prescriptive requirement would be unnecessarily
limiting for UAS producers.
Instead, a producer could label the aircraft by any means as long as
the label is in English,
legible, prominent, and permanently affixed to the unmanned aircraft.
D. Requirement for a UAS to Be Designed and Produced Using an
FAA-Accepted Means of
Compliance
According to proposed § 89.510(a)(1) and (3), no person would be
allowed to produce a
standard remote identification UAS or a limited remote identification
UAS unless the person
obtains FAA acceptance of the declaration of compliance. The
declaration of compliance would
establish that the UAS meets the minimum performance requirements for
standard remote
identification UAS or limited remote identification UAS because it was
produced in accordance
with an FAA-accepted means of compliance (see § 89.405) that meets the
minimum performance
requirements for standard remote identification UAS or limited remote identification UAS.
Further, § 89.510(a)(2) would require persons responsible for the
production of UAS to meet all
requirements of subpart F.
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E. Requirement to Submit a Declaration of Compliance
The FAA is proposing in § 89.520 that a person responsible for the
production of
standard remote identification UAS and limited remote identification
UAS be required to submit
a declaration of compliance for acceptance by the FAA. The declaration
of compliance would
affirm that the UAS meets the minimum performance requirements for
remote identification by
meeting all aspects of an FAA-accepted means of compliance (e.g., a
consensus standard) for
UAS with remote identification equipment. The FAA would rely on the
declaration of
compliance to show that the UAS complied with the applicable remote identification
requirements at the time the UAS was produced.
The FAA would not consider a declaration of compliance under this
proposed rule to be
an airworthiness certification. UAS that are certified under the 14
CFR part 21 Airworthiness
Certification processes may have other identification requirements in
addition to those being
proposed in this rule.
1. Information Required for a Declaration of Compliance
Proposed § 89.520(b) lists the information that would be required to
be included in a
declaration of compliance submitted by a person responsible for the
design or production of a
standard remote identification UAS or limited remote identification
UAS. This information
would make clear to the FAA if the producer has demonstrated
compliance with the remote
identification equipage requirements.
The following information would be required in the declaration of
compliance:
1) The name, physical address, telephone number, and email address of
the person
responsible for production of the UAS.
160
2) The UAS make and model name.
3) The UAS serial number, or the range of serial numbers for which the
person
responsible for production is declaring compliance.
4) The means of compliance used in the design and production of the
UAS and whether
the UAS is a standard remote identification UAS or a limited remote identification UAS.
5) Whether the declaration of compliance is an initial declaration or
an amended
declaration, and if the declaration of compliance is an amended
declaration, the reason for the
amendment.
6) A declaration that the person responsible for the production of the
unmanned aircraft
system can demonstrate that the UAS was designed and produced to meet
the minimum
performance requirements of § 89.310 or § 89.320 by using an
FAA-accepted means of
compliance.
7) A declaration that the producer complies with the inspection,
audit, and notification
requirements of § 89.510(b).
8) A declaration that the producer will perform independent audits on
a recurring basis to
demonstrate compliance with the requirements of subpart F of proposed
part 89 and will provide
the results of those audits to the FAA upon request.
9) A declaration that the producer will maintain product support and notification
procedures to notify the public and the FAA of any defect or condition
that causes the UAS to no
longer meet the requirements of subpart F, within 15 calendar days of
the date the person
becomes aware of the defect or condition.
161
The FAA invites comments on whether the previously discussed 15
calendar day notice
period is appropriate for the public to gain awareness of any defect
or condition that causes the
UAS to no longer meet the requirements of subpart F.
2. Acceptance of a Declaration of Compliance
As proposed in § 89.525, after a person submits a declaration of
compliance to the FAA,
the Administrator would evaluate the declaration of compliance
submitted and may request
additional information (e.g., test results) or documentation, as
needed, to supplement the
declaration of compliance. The FAA would evaluate the declaration of
compliance to ensure
completeness and compliance with the requirements of § 89.520(b).
After the FAA has finished
its evaluation, the FAA would notify the submitter whether the
declaration of compliance has
been accepted or not accepted. The FAA would also notify the submitter
if it determines the
submitter has not provided sufficient evidence to demonstrate
compliance. The FAA would also
provide a list of accepted declarations of compliance at
https://www.faa.gov.
3. Rescission of FAA Acceptance of a Declaration of Compliance
Pursuant to proposed § 89.530, a declaration of compliance would be
subject to ongoing
review by the Administrator. The FAA would notify a person responsible
for the production of
standard remote identification UAS or limited remote identification
UAS if a non-compliance
issue has been identified prior to initiating a proceeding to rescind
its acceptance of a declaration
of compliance. If the Administrator determines that it is in the
public interest, prior to rescinding
acceptance of a declaration of compliance, the Administrator could
provide a reasonable period
of time for the person holding the declaration of compliance to
remediate the noncompliance. A
162
failure to remediate the noncompliance would result in the rescission
of FAA’s acceptance of the
declaration of compliance.
As part of the rescission process, the FAA would notify the person who submitted the
declaration of compliance of its decision to rescind its acceptance by
sending a letter of
rescission to the email address on file for such person or entity. The
FAA would also send a
notice of rescission to the registered owners of unmanned aircraft
listed under a declaration of
compliance that is no longer accepted by the FAA. Additionally, the
FAA would publish a notice
of rescission in the Federal Register to provide notice of the
rescission to all interested or
affected parties, which include: (a) the person holding the
FAA-accepted declaration of
compliance and (b) the owners and operators of unmanned aircraft
listed in the no longer
accepted declaration of compliance. Lastly, the FAA would publish at https://www.faa.gov a list
of declarations of compliance that are no longer accepted.
The FAA could rescind its acceptance of a declaration of compliance
under
circumstances including, but not limited to:
1) A standard remote identification UAS or a limited remote
identification UAS listed
under an accepted declaration of compliance does not meet the minimum performance
requirements of § 89.310 for standard remote identification UAS or of
§ 89.320 for limited
remote identification UAS.
2) A previously FAA-accepted declaration of compliance does not meet
the requirements
of subpart F of proposed part 89.
3) The FAA rescinds its acceptance of a means of compliance listed in
a declaration of
compliance.
163
4. Petition to Reconsider the Rescission of FAA acceptance of a
Declaration of
Compliance
The FAA proposes in § 89.530(b) to allow a person who submitted a
declaration of
compliance that is no longer accepted or any person adversely affected
by the rescission of the
Administrator’s acceptance of that declaration of compliance to
petition for a reconsideration of
the decision to rescind its acceptance by submitting a request to the
FAA. For purposes of the
reconsideration, those adversely affected by the rescission of the Administrator’s acceptance of a
declaration of compliance includes the owners and operators of
unmanned aircraft listed in the
no longer accepted declaration of compliance.
A request for reconsideration would be required to be submitted to the
FAA within 60
calendar days of publication in the Federal Register of a notice of
rescission. A petition to
reconsider the rescission of the Administrator’s acceptance of a
declaration of compliance would
be required to show that the petitioner is an interested party and has
been adversely affected by
the decision of the FAA.
The petition for reconsideration would be required to demonstrate at
least one of the
following:
? The petitioner has a significant additional fact not previously
presented to the FAA.
? The Administrator made a material error of fact in the decision to
rescind its
acceptance of the declaration of compliance.
? The Administrator did not correctly interpret a law, regulation, or precedent.
If the FAA chooses to reinstate its acceptance of a declaration of
compliance, it would
indicate so by notifying the petitioner, and the person who submitted
the FAA-accepted
164
declaration of compliance (if different). The FAA would also publish
at https://www.faa.gov a
list of declarations of compliance that have been reinstated.
5. Record Retention
The FAA is proposing in § 89.535 to require any person who submits a declaration of
compliance to retain all of the following information for as long as
the UAS listed on that
declaration of compliance are produced plus an additional 24 calendar
months:
? The means of compliance, all documentation, and substantiating data
related to the
means of compliance used.
? Records of all test results.
? Any other information necessary to demonstrate compliance with the
means of
compliance so that the UAS meets the remote identification
requirements and the
design and production requirements of this part.
The person submitting the declaration of compliance would be required
to make the
information available for inspection by the Administrator.
F. Accountability
After obtaining FAA acceptance of their declaration of compliance, the
FAA expects
persons responsible for the production of UAS to monitor all UAS
produced under that
declaration of compliance to ensure they comply with the remote
identification requirements of
the proposed rule. The FAA expects persons responsible for the
production of UAS with remote
identification to take remedial action whenever they become aware of a
lack of compliance with
the proposed design and production regulations.
165
If the FAA suspects, or becomes aware of, a lack of compliance with
any of the
requirements of the proposed rule, the person responsible for the
production of the standard
remote identification UAS or limited remote identification UAS would
be required to allow the
Administrator to inspect any associated facilities, technical data, or
any UAS produced, and to
witness any tests necessary to determine compliance with part 89. In
addition to any inspection
that may be required by the Administrator from time to time, the
person responsible for the
production of UAS with remote identification would be responsible for performing independent
audits on a recurring basis to ensure that the standard remote
identification UAS or limited
remote identification UAS continue to comply with the remote
identification requirements of
proposed part 89. The FAA is not proposing a specific timeframe for
the independent audits. It
expects that the person responsible for the production of the UAS
would apply industry best
practices to determine when and how often independent audits are
needed. However, the FAA
believes these audits would have to occur on a regular basis and as
many times as necessary to
ensure continuous compliance with the technical requirements of the
proposed rule.
Additionally, all audit reports would have to be retained and would
have to be provided to the
FAA upon request. The FAA requests comments regarding appropriate time intervals for
conducting independent audits, including any time intervals specified
in industry standards
related to independent audits of aviation systems.
As part of the independent audits, a person responsible for the
production of UAS would
be responsible for maintaining a product support and notification
system and procedures to
notify the public and the FAA of any defect or condition that may
cause a standard remote
identification UAS or limited remote identification UAS to no longer
comply with the remote
identification requirements of proposed part 89. To satisfy these
obligations, persons responsible
166
for the production of UAS would have to monitor their manufacturing
processes, UAS
operational usage to the extent the manufacturer has access to such information, and collection of
accident and incident data. The FAA expects that as part of the
monitoring process, producers
would collect, analyze, and provide to the FAA any information that is furnished by the owners
and operators of the UAS with remote identification. If the FAA
identifies a safety issue that
warrants review of a producer’s data, records, or facilities, the
producers would have to grant the
FAA access to such data, records, or facilities, and would have to
provide all data and reports
from the independent audits and investigations.
XIV. Remote Identification UAS Service Suppliers
The operating rules in subpart B of part 89 would require persons
operating a standard
remote identification UAS or limited remote identification UAS to
transmit the remote
identification message elements through an internet connection to an FAA-qualified Remote ID
USS. The FAA intends to provide oversight of the Remote ID USS through contractual
agreements and is therefore not proposing specific rules related to
how the Remote ID USS offer
services. This section provides background information so that persons operating standard
remote identification UAS or limited remote identification UAS may
understand what the FAA
expects a Remote ID USS would be and how it would be required to
provide services to be FAAqualified.
A. UAS Service Suppliers (USS)
As the FAA looks to innovative solutions to develop UAS traffic
management (UTM),
the FAA is partnering with third parties referred to as UAS Service
Suppliers (USS). This
proposal defines a USS as any person (e.g., governmental or
non-governmental entity) that is
167
qualified by the Administrator to provide aviation related services to
UAS. The FAA anticipates
that some USS may choose to offer a suite of different services, while
others may choose to
specialize in one service.
The FAA already has leveraged the USS concept successfully in the implementation of
the Low Altitude Authorization and Notification Capability (LAANC).73
In qualifying a USS to
be a LAANC service provider, the FAA uses its acquisition authority to
enter into a
Memorandum of Agreement (MOA) with the USS. All prospective USS go
through an
onboarding process to become qualified and agree to abide by a set of documented terms and
conditions regarding the technical administration of the service and
how it is administered to the
public.74 See 49 U.S.C. 106(l) and (m). The LAANC USS are fully
responsible for the
development and operation of the software applications; the FAA does
not provide payment for
the development or operation of LAANC USS products or services.
Congress affirmed the USS
model for future UTM-related services in the FAA Reauthorization Act
of 2018. Section 376 of
Pub. L. 115-254 recommended that the FAA use the LAANC model of
private sector
participation in implementing future expanded UTM services. The FAA is proposing to use a
similar strategy for remote identification.
B. Remote ID USS
A Remote ID USS would be a person or entity qualified by the FAA to
provide remote
identification services to UAS. A Remote ID USS would perform four
primary functions: (1)
collect and store the remote identification message elements; (2)
provide identification services

73 LAANC automates significant portions of the application and
approval process for airspace authorizations
through an electronic data exchange with third party USS.
74 The terms and conditions the LAANC USS agree to be bound by are
available at: https://www.faa.gov/uas/programs_partnerships/uas_data_exchange/industry/media/uss_operating_rules.pdf.
168
on behalf of the UAS operator and act as the UAS operator’s access
point to identification
services; (3) provide the FAA access to the remote identification
information collected and
stored upon request through a data connection that may be on-demand or
a continuous
connection depending on safety and security needs; and (4) inform the
FAA when its services are
active and inactive.
Although a USS may be qualified as both a Remote ID USS and a LAANC
USS, the
services provided and the terms for providing each service would be
independent from one
another. Although the FAA anticipates that most Remote ID USS would
offer their services to
the general public, a Remote ID USS, such as an operator of multiple
routine unmanned aircraft
flights, may choose to provide remote identification services only for
its own fleet. Additionally,
the FAA expects that the majority of Remote ID USS would likely come
from private industry;
however, the FAA anticipates other Federal agencies may consider
creating a Remote ID USS to
manage their own flights. Although some Remote ID USS may choose to
offer their services for
free, Remote ID USS may have a variety of business models and may
choose to require a
subscription, payment, or personal information to access that Remote
ID USS.
The FAA does not propose to require a Remote ID USS be universally
compatible with
all UAS. That said, the FAA anticipates that some UAS manufacturers
will also be Remote ID
USS. In those cases, the Remote ID USS may choose to only connect to
UAS made by the same
manufacturer. This model is similar to how mobile telephone networks
sell devices that can only
be used on their networks. The FAA requests comment on whether
manufacturers should be
permitted to produce UAS that are only compatible with a particular
Remote ID USS.
Persons operating UAS with remote identification would be required to
interact with a
Remote ID USS. The FAA envisions that a UAS operator would connect to
the Remote ID USS
169
through the internet using a variety of different technologies, such
as cellular phone applications,
web-based interfaces, or other tools. The FAA expects some Remote ID
USS may provide UAS
operators with a session ID that would be used in place of the
unmanned aircraft serial number to
satisfy the UAS Identification message element requirement. Such
Remote ID USS would be
responsible for generating (and maintaining) the session IDs.
To ensure safety in the airspace of the United States, the FAA may
require access to the
remote identification message elements transmitted by UAS with remote identification to
Remote ID USS. This request may take the form of an individual query
or a continuous
connection to the Remote ID USS. In addition, the FAA anticipates
providing that information,
to other airspace users, authorized Federal Government partners, and
law enforcement entities as
discussed in section XI of this preamble. Upon request, a Remote ID
USS would be required to
provide the FAA: (1) the near real-time remote identification message
elements that meet the
minimum message element performance requirements discussed in sections
XII.C and XII.D.11
of this preamble; and (2) stored remote identification data.
Under proposed § 89.135, the Administrator would contractually require
that Remote ID

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