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operations. While the FAA acknowledges remote identification of UAS
does not, in and of itself,
permit BVLOS operations, without remote identification of UAS, BVLOS
operations on a large
scale are not feasible. BVLOS operations are expected to replace
riskier manned activities and to
also create new economic opportunities. When UAS are transmitting and broadcasting, as
202
appropriate, remote identification information, they are contributing
to a cooperative operating
environment which supports detect-and-avoid and aircraft-to-aircraft communication systems
that could aid in unmanned aircraft collision avoidance. Remote
identification would help enable
these operations to occur on a routine basis, rather than through the
waiver process.
BVLOS operations enable entities to conduct activity which may
otherwise be too
expensive, too dangerous, or too impractical to carry out.117 For
example, BVLOS operations
allow unmanned aircraft to collect data at costs less than those
incurred using the more
traditional methods of manned aircraft or satellites.118 Cost savings
from the use of unmanned
aircraft for BVLOS operations is validated in a Precision Hawk case
study. In this study, the
costs of power line inspections using unmanned aircraft versus a
manned helicopter were
compared.
119 In the electric utilities industry, high tension power lines must
be inspected on a
regular basis, and these inspections are typically performed with
manned helicopters. While
requirements and methodologies vary, helicopter inspection costs could
range from $40 to $700
per mile.120 Conversely, utility companies operating UAS BVLOS could
spend $10 to $25 per
mile of inspection. Based on these costs, the Precision Hawk Study
estimates a potential savings
of approximately $9 million over a five-year period for a company that
must inspect 10,000
miles of power lines per year.121
UAS remote identification and BVLOS operations would enable entities
to conduct
dangerous activities with unmanned aircraft. While UAS remote
identification itself does not

117 https://www.precisionhawk.com/beyond-visual-line-of-sight-bvlos-drone-operations/.
Accessed December 19,
2018.
118 Ibid.
119 Ibid.
120 Ibid.
121 Ibid.
203
prevent accidents, accidents involving unmanned aircraft typically
have a much lower threat to
human life than do accidents involving manned aircraft. One example of
an accident where
injury could possibly have been prevented if a UAS was substituted for
a manned aircraft was for
a power line inspection near BWI Marshall Airport, MD Amtrak Rail
Station. The helicopter
used to perform the inspection crashed, resulting in injuries to the helicopter’s three occupants,
and subsequently started a brush fire that resulted in a service
interruption for Amtrak passengers
travelling between Washington, DC, 122 and Baltimore, Maryland. In May
of 2018, a helicopter
performing a routine transmission line inspection crashed in Louisiana
when its landing gear
became entangled in transmission lines. Of the three people on board
the helicopter, one was
killed, and the other two were injured.123 This loss of life could
possibly have been prevented if
the inspection had been conducted with a UAS instead of a manned
helicopter. In addition to
replacing manned aircraft for utility inspections, UAS can also
eliminate the need for workers to
climb to dangerous heights for inspection of power lines, cellular
towers, and wind turbines. 124
This proposed rule would assist government efforts to address illegal
activity and protect
national security. Criminal operations create a direct threat to
national security and public safety
and also pose severe hazards to safety in air commerce. Such risks are multiplied with the
increasing sophistication of technology, the availability of UAS
equipment, and the enabling of
additional types of operations across the airspace of the United
States. The FAA recognizes the
increasing availability and potential use of UAS for illegal
activities such as the carrying and
smuggling of controlled substances, illicit drugs, and other payloads;
the unlawful invasion of

122 https://baltimore.cbslocal.com/2016/04/16/helicopter-crash-reported-near-bwi-airport/.
Accessed December 19,
2018.
123 https://www.nola.com/traffic/index.ssf/2018/05/victims_in_fatal_boutte_helico.html
124 https://www.powermag.com/using-drones-to-increase-net-safety-in-the-utility-sector/?pagenum=1.
There are
approximately 52,000 utility-scale wind turbines in the United States.
204
privacy; illegal surveillance and reconnaissance; the weaponization of
UAS; sabotaging of
critical infrastructure; property theft; disruption; and harassment.
With this proposed rule, the
FAA, first responders, and law enforcement officers would be able to
more easily determine who
is operating in the airspace and assist in identifying anomalies or
dubious operations to determine
whether action is warranted to ensure the safety and security of the
airspace of the United States
and the people on the ground.
Safety and security enforcement can be extremely difficult absent a
remote identification
requirement that enables the prompt and accurate identification of UAS
and their operators.
Recently, there have been several instances of unmanned aircraft
operating illegally in the areas
of wildfires where the FAA typically implements temporary flight
restrictions to support U.S.
Forest Service activities. Aerial firefighting aircraft typically fly
in smoky, windy, turbulent
conditions, and unauthorized unmanned aircraft flights near a wildfire
could cause injury or
death to firefighters and pilots because firefighting aircraft
typically fly at very low altitudes,
which creates an environment for mid-air collisions. 125 If unmanned
aircraft are detected in an
unauthorized area, firefighting aircraft could be grounded. The
effects of lost aircraft flying time
can be compounded by flames moving into untreated terrain, potentially threatening lives and
property.126
The U.S. Department of Interior tracks private unauthorized unmanned
aircraft incursions
over wildland fires. In their first year of reporting (2014), there
were two incursions of
unauthorized unmanned aircraft over wildland fires. In 2015, the
number of unauthorized

125 https://www.usda.gov/media/blog/2016/08/10/unauthorized-drones-near-wildfire-can-cost-and-kill.
Accessed
December 21, 2018.
126 https://www.usda.gov/media/blog/2016/08/10/unauthorized-drones-near-wildfire-can-cost-and-kill.
Accessed
December 21, 2018.
205
unmanned aircraft incursions increased six-fold from the prior year to
total 12 incursions.127 By
2016, there were 42 unauthorized unmanned aircraft incursions over
wildland fires.
128 Of these
42 incursions, 12 resulted in delays of aerial support to
firefighters, and several incursions
resulted in fire suppression aviators taking evasive action to avoid
collisions with unmanned
aircraft. During 2017, aerial wildland firefighting efforts ceased 25
times due to unauthorized
unmanned aircraft incursions.129 The most recent report published by
the U.S. Department of
Interior (August of 2018) shows that firefighting efforts were
impacted 15 times due to
unauthorized unmanned aircraft incursions over wildland fires.
130
Delaying firefighting missions creates significant costs and can also
delay transportation
of firefighters to different locations.131 During the Lake Fire in
California’s San Bernardino
County in 2015, three planes carrying flame retardant were prevented
from dropping their cargo
due to interference from a private unmanned aircraft operating in the
vicinity and contrary to
rules.132 One aircraft was able to drop its retardant on a different
fire, but the other two aircraft
had to jettison retardant because they would not be able to land
otherwise due to aircraft weight.
Officials stated that the failed mission cost between $10,000 and
$15,000.
Similarly, a State senator from Utah stated that costs for fighting a
fire 300 miles south of
Salt Lake City would have been lower instead of actual costs of over
$10 million if five

127 https://www.doi.gov/pressreleases/interior-expands-information-sharing-initiative-prevent-drone-incursions
128 Ibid.
129 https://www.firehouse.com/tech-comm/drones/article/12396869/the-lovehate-relationship-between-droneswildland-firefighters.
Accessed December 18, 2018.
130 https://www.doi.gov/sites/doi.gov/files/uploads/2018_wildland_fire_incursion_events_of_unauthorized_uas.pdf
131 https://www.doi.gov/sites/doi.gov/files/uploads/2018_wildland_fire_incursion_events_of_unauthorized_uas.pdf
132 https://arstechnica.com/tech-policy/2015/06/drone-flying-over-forest-fire-diverts-planes-costs-us-forest-service10k/.
Accessed December 21, 2018.
206
unmanned aircraft flights had not interfered with firefighting
efforts.133 Likewise, in the Pinal
Fire (Arizona) that occurred during May of 2017, at least four
separate incidents involving
unauthorized unmanned aircraft hindered firefighting operations. 134
Each of the four incidents
involved recreational users. In one of the incidents, an air tanker
flying over the fire was forced
to release its retardant at a higher altitude for safety reasons,
which reduced the retardant’s
effectiveness for smothering fire. Likewise, unmanned aircraft
disrupting fire-fighting efforts at
the Lightner Creek Fire (Colorado) in 2017 resulted in two air tankers jettisoning 1,600 gallons
of retardant at a cost of approximately $8,000 to $10,000.135 Lastly,
during the Pole Creek Fire
(Utah) during October of 2018, all firefighting aircraft in the area
were grounded, as well as three
helicopters that had been supporting ground crews, due to unmanned
aircraft flying in airspace
with a temporary flight restriction.136
In addition to the remote ID requirements of this proposed rule, this rulemaking proposes
that recreational flyers have a single Certificate of Aircraft
Registration for each unmanned
aircraft operated. Currently, the FAA does not have aircraft-specific
data for aircraft operated by
recreational flyers. This means that the FAA does not have a data set
that includes the serial
numbers of all unmanned aircraft registered under part 48, and thus
cannot correlate the
registration data to the remote identification data which would be
transmitted and broadcast, as
appropriate, by unmanned aircraft under the proposed rule. Similarly,
the FAA is proposing 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.
These registration and

133 https://apnews.com/0e8053dc251f4efbacbd249f3aa8573c. Accessed
December 21, 2018.
134 https://wildfiretoday.com/2017/05/26/drones-interfere-with-aviation-operations-on-pinal-fire/.
135 https://durangoherald.com/articles/169962
136 https://universe.byu.edu/2018/09/21/firefighters-make-headway-fighting-pole-creek-bald-mountain-fires-1/
207
notification requirements are the foundation for both identifying
aircraft and for promoting
accountability and the safe and efficient use of the airspace of the
United States. The lack of
aircraft-specific data inhibits the FAA and law enforcement agencies
from correlating the remote
identification data proposed in this rule with operators of unmanned
aircraft.
Conclusion
The FAA expects this proposed rule will result in several important
benefits and
enhancements to support the safe integration of expanded UAS
operations in the airspace of the
United States. The proposal would provide situational awareness of UAS operations to other
aircraft and airport operators. The proposed rule would provide
information to distinguish
compliant UAS users from those potentially posing a safety or security
risk. The following table
summarizes the benefits of the proposed rule.
Table 6: Summary of Benefits of Proposed Rule
Safety and Security ? Provides situational awareness of UAS flying in
the airspace of
the United States to other aircraft in the vicinity of those
operations and airport operators.
? Provides information to distinguish compliant UAS users from
those potentially posing a safety or security risk.
? Enables the FAA, national security agencies, and law
enforcement entities to obtain situational awareness of UAS in
the airspace of the United States in near real-time.
? Provides additional registration and notification requirements
for identifying aircraft and promoting accountability and the
safe and efficient use of the airspace of the United States.
Enables Expanded
Operations and
UAS Integration
? Assists in the implementation of operations of small UAS over
people and at night. A final rule for operation of small UAS
over people and at night is contingent upon a final action for
UAS with remote identification being effective.
137

137 “Because these operations have a potential impact on public safety
and national security, the FAA does not
intend to promulgate a final rule to allow these operations until a
regulation finalizes the requirements regarding
208
? Provides UAS-specific data to facilitate future, more advanced
operational capabilities, such as detect-and-avoid and
aircraftto-aircraft communications that support beyond visual line of
sight (BVLOS) operations.
? Provides UAS-specific data contributing to a comprehensive
UAS traffic management (UTM) system that would facilitate
the safe expansion of operations.
In addition, the proposed rule provides flexibility through minimum
performance
requirements that would accommodate future innovation and improve the efficiency of UAS
operations. The proposal also does not preclude early compliance for
producers or operators to
realize earlier expanded operations and commercial opportunities.
3. Cost and Savings Summary
UAS owners, operators, and producers, as well as Remote ID USS and
developers of
remote identification means of compliance, would play important roles
in the remote
identification of UAS. The following subsections summarize costs and
cost savings by affected
groups within the scope of the proposed rule.
i. UAS Owners and Operators
Registration Provisions
The FAA is proposing to require the owners of UAS to register under
part 47 or part 48
and to provide the serial number of the unmanned aircraft, unless the
aircraft is specifically
excepted from registration. If an unmanned aircraft is currently
registered, its owner would be
required to update the aircraft’s registration to include the serial
number by the compliance date

remote identification of small UAS.” Safe and Secure Operations of
Small Unmanned Aircraft Systems, Advance
Notice of Proposed Rulemaking, February 13, 2019 (84 FR 3732).
209
of the final rule or the first registration renewal after a rule
becomes effective, whichever is
earlier.
Part 48 currently requires that registration of aircraft operated
under part 107 include the
make, model, and serial number, if available, of the aircraft as part
of the aircraft registration.
Since regulations require these registrations to be renewed every
three years, and the compliance
date for the requirement to include the make, model, and serial number
is 36 months after the
effective date of the final rule, some owners of registered aircraft
operated under part 107 would
not incur additional costs. Likewise, unmanned aircraft registering
under part 47 are currently
required to include make, model, and serial number, so some owners of
these aircraft would not
incur additional costs as well.
However, a portion of the part 107 fleet will be replaced early as a
result of the proposed
one-year operational compliance period, which will trigger the
requirement to register the new
aircraft at a time earlier than would otherwise have been. The 10-year
present value incremental
cost incurred for registering new aircraft is about $0.03 million at a
three percent discount rate
and $0.02 million at a seven percent discount rate. The incremental
annualized costs are about
$0.003 million at either a three percent or seven percent discount
rate.
The FAA also proposes to revise the registration requirements in part
48 to remove the
provisions that allow small unmanned aircraft to register as model
aircraft under a single
Certificate of Aircraft Registration and to require the individual
registration of each aircraft,
210
regardless of its intended use.
138 This means that every small unmanned aircraft registered under
part 48 would need to have its own Certificate of Aircraft
Registration.
The FAA estimates additional costs for recreational flyers to amend
the part 48 aircraft
registry to register each unmanned aircraft owned and update each
individual registration to
include make, model, and serial number. The FAA estimates the 10-year
present value costs to
affected recreational flyers is about $1.1 million at a three percent
discount rate and about $0.89
million at a seven percent discount rate. The incremental annualized
costs are about $0.13
million at either a three percent or seven percent discount rate.
Recreational flyers will also be required to pay a $5 registration fee
to the FAA for each
additional aircraft registered. Government fees and taxes are
considered transfer payments per
OMB Circular A-4 and are not considered a societal cost. These
transfers are reported separately
from the costs of this proposed rule.139 Over the 10-year period of
analysis, the present value of
incremental fees paid by recreational flyers for registration of
additional aircraft totals $8.1
million at a three percent discount rate and $6.6 million at a seven
percent discount rate. The
annualized fees are about $1 million at either a three percent or
seven percent discount rate.
Effects of Retrofits and One Year Operational Compliance
The proposed rule would require persons responsible for the production
of standard
remote identification UAS or limited remote identification UAS to
provide UAS with remote

138 This proposal uses the term “limited recreational operations” when discussing registration requirements under
part 48. Part 48 uses the term “model aircraft” to describe
recreational UAS operations. The FAA considers that
model aircraft under part 48 are consistent with the “limited
recreational operations” described in 49 U.S.C. 44809,
therefore “limited recreational operations” has been used throughout
to ensure consistency of terminology with
current statutory requirements.
139 See the “Separate Reporting of Transfers” per OMB Circular A-4 (https://www.whitehouse.gov/sites/whitehouse.gov/files/omb/circulars/A4/a-4.pdf).
211
identification two years after the effective date of the final rule.
Operators of UAS would have
one additional year beyond the production compliance date to begin
using UAS with remote
identification.
140 The exception is for operators of UAS without remote
identification. The FAA
determined this affected group could fly UAS without remote
identification at FAA-recognized
identification areas. Under the proposed construct, any person (e.g.,
a limited recreational flyer)
who flies exclusively at FAA-recognized identification areas could use
a UAS without remote
identification.
As previously discussed in the “Key Assumptions and Data Sources”
section, during the
development of this rulemaking the FAA received information from
industry suggesting part of
the existing fleet of UAS can be retrofit to comply with remote
identification requirements (e.g.,
by a software update or “push” through the internet) and this could be
achieved within the first
year after the effective date of the final rule given the availability
of FAA-accepted means of
compliance. The FAA estimates at least 93% of the current part 107
fleet and at least 20% of the
current recreational fleet would be eligible for retrofits. Besides
reducing costs, retrofits would
enable early compliance with remote identification for persons
operating a portion of the existing
UAS fleet and those UAS purchased during the proposal’s 24-month
period before compliance
with proposed production requirements. For example, retrofits of UAS
purchased in year 1 of the
analysis period would enable them to be operated for their entire
lifespan (i.e., one year after the
three year full compliance date of the proposal).141

140 After the proposed full compliance date of 36-months past the
effective date of the final rule, UAS without
remote identification that weigh more than 0.55 pounds may only be
operated at FAA-recognized identification
areas.
141 This analysis uses an average three year lifespan for affected UAS
(not including those UAS operated by
members of community based organizations that fly exclusively within FAA-recognized identification areas, see the
“Key Assumptions and Data Sources” section above). Based on the three
year lifespan and the proposed 36-month
212
Therefore, the group of retrofit UAS used in this analysis are based
on the following
assumptions: 1) these UAS are purchased during year 1 of the analysis
period and have a lifespan
of three years; 2) the producers of these UAS have identified an
FAA-accepted means of
compliance for remote identification that can be used for retrofits
during year 1 of the analysis
period; and, 3) these UAS are capable of being retrofit with relative
ease, little downtime from
operations, and at minimal costs for at least 93% of the UAS in the
part 107 fleet and at least
20% of the UAS in the recreational fleet purchased in year 1. Without
the availability of retrofits,
UAS purchased during year 1 would not be equipped with Remote Id and
therefore grounded in
year 4.
As a result of the proposed compliance period for UAS operators and
the potential for
retrofits, a portion of about 7% of the UAS in the part 107 fleet and
80% of the UAS in the
recreational fleet purchased in year 1 of the analysis would not be
compliant with the proposal in
year 4 of the analysis (after the full compliance date) and would
effectively become obsolete
prior to the end of useful life.142 The FAA uses a straight line
depreciation method to estimate a
measure of expense or cost to part 107 operators and recreational
flyers for early replacement of
UAS as a result of the proposed compliance period.
143 In the case of the part 107 operators, this
measure of depreciation represents the cost to entities for an early
outlay of funds for replacing

full compliance period, affected UAS purchased in year 1 of the
analysis period, or 12 months after the effective
date of the final rule, would be effectively grounded in year 4 of the
analysis unless retrofit.
142 This equates to eighteen percent of the overall affected UAS fleet
in year 4 would likely be replaced prior to the
end of useful life. This excludes UAS that are flown by members of
CBO, since the FAA assumes this affected
group would fly UAS at FAA-recognized identification areas.
143 The straight line depreciation method is a common default method
of depreciation that is calculated by dividing
the difference between an asset's cost and its expected salvage value
by the number of years it is expected to be used (https://corporatefinanceinstitute.com/resources/knowledge/accounting/straight-line-depreciation/
or
https://www.investopedia.com/terms/s/straightlinebasis.asp).
213
UAS with remaining useful life.144 For the recreational flyers, the
estimate is used as a proxy for
the opportunity cost for loss of use of UAS with remaining useful
life.
The estimated straight-line depreciation is based on average UAS
purchase prices of
$2,500 for the part 107 consumer fleet and about $114 for the fleet of
UAS flown by recreational
flyers. For each of these categories, the purchase price is spread
equally across 36 months to
estimate the monthly depreciation expense (36 months is the lifespan
of a small UAS).
145,146 The
early depreciation expense is only applicable to the portion of the
UAS fleet purchased in year 1
of the analysis period, as this group of UAS will be grounded due to
the proposed rule’s
requirement that all UAS have remote identification by the end of year
3 of the analysis period.
Therefore, some of the UAS purchased in year 1 will lose up to one
year of useful life (and
correspondingly up to one year of depreciation expense).
147 The following table presents loss of
use quantified as depreciation loss for year 4.148
Table 7: Cost Impact of Proposed Operational Compliance Period,
Loss of Use quantified as Depreciation Expense ($ Millions)
Affected UAS Fleet
Number of UAS Sold in
Year 1
Depreciation Expense
(Units Sold in Year 1)*

144 The FAA uses this depreciation analysis as a means to measure lost
utility or useful life of UAS due to the
proposed compliance period. However, these estimates may be offset
through tax savings. Companies and other
entities may use depreciation expenses to generate tax savings, which
is a transfer effect that might reduce the
impact on companies, but not reduce the social costs of the rule. U.S.
tax rules allow depreciation expenses to be
used as tax deductions against revenue in arriving at taxable income.
The higher the depreciation expense, the lower
the taxable income and the greater the tax savings.
145 Page 47 of The FAA Aerospace Fleet Forecast FY 2019-2039
identifies cost for consumer UAS. The estimated
average purchase price for UAS used by limited recreational operators
is based on research of UAS used by
hobbyists. The monthly depreciation expense for consumer UAS and
limited recreational UAS is $69.44 and $3.16,
respectively.
146 Annual UAS sales are spread evenly over a 12-month period to
estimate monthly sales.
147 For ease of calculation, sales of UAS are presumed to occur on the
first day of the month. Therefore, units sold in
January of year 1 of the analysis period are fully depreciated by
December of year 3 and thus there is no loss of
useful life; units sold in February of year 1 lose one month of useful
life (which is January of year 4); units sold in
March of year 1 lose two months of useful life (which are Jan-Feb of
Year 4); units sold in April of year 1 lose three
months of useful life (which are Jan-Mar of year 4); etc.
148 See the Regulatory Impact Analysis for this proposed rulemaking
for the derivation of these estimates.
214
Pt 107 – Consumer 12,489 $4.8
Recreational 299,252 $5.2
Undiscounted Total $10.0
3% PV $ 8.9
7% PV $ 7.6
Table notes: (i) Row and column totals may not sum due to rounding.
(ii) Affected UAS will be depreciated for a
period of one to eleven months, depending on the month of purchase.
The present value cost impact of the loss of UAS use for operators is
$8.9 million at a
three percent discount rate and $7.6 million at a seven percent
discount rate. The annualized cost
impact of loss of use is about $1 million at either a three percent or
seven percent discount rate.
If the estimated level of retrofits are possible, then this impact
represents only about two percent
of the total costs of the proposed rule. If fewer retrofits are
possible, then costs related to the loss
of UAS use for operators would increase proportional to the number of
retrofits available by
model and share of the model in the fleet.
The FAA believes this cost impact is justified in order to reduce the
delay for law
enforcement, security partners, the FAA, and airports to use remote ID information. The FAA
considered allowing three years beyond the producer compliance date
for owners and operators
to comply with the remote identification requirements of this proposed
rule in the “Alternatives
Considered” section. This period of time coincides with the three-year
lifespan of a small UAS
and would have prevented costly grounding or replacement of UAS prior
to the end of useful
life. However, the FAA determined that the three-year compliance
period was less preferable,
because it prolonged safety and security risks to air traffic and
airports by delaying the ability of
law enforcement personnel to identify unauthorized UAS operations. To
reduce the delay in
implementing remote identification, the operational compliance period
was reduced from three
years to one year.
215
ii. Remote ID USS Subscription Fee
The FAA is proposing that three years following the effective date of
a final rule,
standard remote identification UAS and limited remote identification
UAS would be required to
transmit remote identification messages through the internet to a
Remote ID USS. In addition,
standard remote identification UAS would also be required to broadcast
the same message
elements directly from the unmanned aircraft. UAS that are unable to
comply with the
requirements for standard remote identification UAS or limited remote identification UAS would
be required to operate exclusively within an FAA-recognized
identification area.
The FAA does not intend to provide remote identification services to
UAS operators, but
instead would enter into MOAs with Remote ID USS in a manner similar
to LAANC USS. The
FAA anticipates that UAS operators would subscribe to a Remote ID USS
and then connect to
the internet using their existing internet service provider. Based on
the LAANC USS business
model,
149 the subscription to a Remote ID USS may range in cost from $0 to
$5 per month, per
operator, for a midpoint of $2.50 per month.
150 For purposes of this regulatory evaluation, the
FAA determines that each operator of a standard remote identification
UAS or limited remote
identification UAS would be required to subscribe to a Remote ID USS
at a fee of $2.50 per
month.
Based on the compliance dates for this rulemaking, the FAA determines
that an app to
connect standard remote identification UAS and limited remote
identification UAS to a Remote
ID USS would be available at the start of year 2 of the analysis
period. The number of new and

149 The selection process for LAANC providers is approximately 10
months. https://www.faa.gov/news/updates/?newsId=93047&omniRss=news_updatesAoc&cid=101_N_U
150 The cost of $0 to $5 is based on an internet search of LAANC USS
providers. LAANC USS also provide
services through apps, such as AirMap and Kittyhawk.
216
renewed Remote ID USS subscriptions is approximately 3.1 million for
part 107 operators and
5.7 million for recreational flyers. The present value cost of
subscriptions to affected UAS
operators totals $242 million at a three percent discount rate and
$192 million at a seven percent
discount rate. The annualized costs of the subscriptions is about $28
million at either a three
percent or seven percent discount rate.
The FAA notes that the $2.50 subscription fee could be considered a
transfer payment
that is representative of the cost for Remote ID USS to provide remote identification services.
iii. UAS Producers
For each UAS designed and produced for operation in the United States,
the producer
(with limited exceptions included in the proposal) would be required
to:
? Produce the UAS in accordance with the minimum performance
requirements of the
proposed rule using an FAA-accepted means of compliance;
? Issue each unmanned aircraft a serial number that complies with the ANSI/CTA2063-A serial number standard;
? Label the unmanned aircraft to indicate that it is remote identification-compliant and
indicate whether the UAS is a standard remote identification UAS or
limited remote
identification UAS; and,
? Submit a declaration of compliance for acceptance by the FAA,
declaring that the
UAS complies with the minimum performance requirements of the proposed
rule.
As discussed in this preamble, the FAA would require persons
responsible for the
production of standard remote identification UAS and limited remote identification UAS to
comply with the minimum performance requirements of the proposed rule
using an FAA-
217
accepted means of compliance and would require the person to issue
serial numbers that comply
with the ANSI/CTA-2063-A serial number standard. Presently, an
FAA-accepted means of
compliance for UAS remote identification does not exist, but the FAA
is aware of UAS remote

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