[continued from previous message]

identification standards being developed. The FAA estimates the cost
to each producer to obtain
a copy of a standard that could be an FAA-accepted means of compliance
for remote
identification to be $313.151 It is anticipated that a standard for
means of compliance for remote
identification may not be available until year 2 of the analysis
period152, and during this year, the
FAA estimates 157 U.S. producers and 324 foreign producers would
purchase the standard to be
used as an FAA-accepted means of compliance.153 For the remaining
years of the analysis
period, the FAA estimates three additional U.S. producers and six
additional foreign producers
would enter the market annually and would also incur the cost to
purchase a means of
compliance.
The proposed rule would require a person responsible for the
production of standard
remote identification UAS or limited remote identification UAS to
label the UAS to show that it
was produced with remote identification technology capable of meeting
the proposed rule. The
label must be in English and be legible, prominent, and permanently
affixed to the unmanned
aircraft. The proposed labeling requirement would assist the person manipulating the flight
controls of the UAS to know that his or her UAS is eligible to conduct operations within the
airspace of the United States. The proposed labeling requirement would
also assist the FAA in its

151 https://my.rtca.org/nc__store?category=a0L36000003g7jDEAQ.
Accessed November 13, 2018. Average price
for the 11 unmanned aircraft standards available at the RTCA website.
The 11 standards range in price from $140 to
$675 for an average of $313.
152 Noting the potential for earlier compliance and retrofits, the FAA
may adjust its analysis of costs associated with
available means of compliance for the final rule based on information
received during the comment period.
153 Based on AUVSI Unmanned Systems & Robotics Database for Air
Platforms (Association for Unmanned
Vehicle Systems International).
218
oversight role because it provides an efficient means for an inspector
to determine whether a
UAS meets the requirements of the proposed rule.
The FAA estimates that it would take twenty hours to design a label
for each model of
aircraft produced. The costs would begin in year 2 of the analysis
period at which time the FAA
estimates 313 U.S. models of aircraft and 787 models of foreign
aircraft would require
labeling.
154 For the remainder of the analysis period, an additional eighteen
models of U.S. and
foreign produced aircraft would require labeling design on an annual
basis.
Over the 10-year period of analysis, the present value costs to
producers for labeling is
about $2.0 million at a three percent discount rate and $1.7 million
at a seven percent discount
rate.
The proposed rule would require the producers of UAS to submit a DOC
to the FAA
identifying the means of compliance used to determine that the UAS
meets the applicable
performance requirements. The FAA would rely on a producer’s DOC to
ensure that the make
and model of UAS is compliant with the proposed requirements at the
time of manufacture.
The FAA estimates that the test report and/or substantiating data for
the DOC would
average 50 pages and would take five hours per page to generate. The
five hours consists of one
hour for documenting results and four hours for performing tests that demonstrate compliance
with the remote identification equipage requirements.155 For this
analysis, the FAA assumes that
five percent of DOCs would not be accepted and have to be resubmitted,
possibly with updated

154 Based on AUVSI Unmanned Systems & Robotics Database for Air
Platforms. (Association for Unmanned
Vehicle Systems International.
155 The report length is equivalent to the report generated in NOS for
the DOC. It is used as a proxy for the report
that producers will generate to substantiate compliance with remote ID requirements.
219
analysis, for acceptance. The FAA also assumes that after a producer
rewrites and resubmits a
DOC, the FAA would accept the revised DOC. The proposed rule requires manufacturers to
retain a test report or any other substantiating data that supports
their DOC.
In total, estimated costs over the ten-year period of analysis for
producers to perform tests
and generate substantiating data to support their DOC is approximately
$25.2 million at a present
value discount rate of three percent and $22.9 million at a present
value discount rate of seven
percent. Annualized costs at a three percent discount rate and a seven
percent discount rate are
approximately $3 million.
Any producer of a UAS with remote identification will be required to
submit a one-page
DOC form to the FAA to affirm that the UAS meets the performance
requirements and was
designed and produced using an FAA-accepted means of compliance for
UAS with remote
identification.156 The time required to complete the form and submit
it through an FAA web
portal is estimated to be 15 minutes at a cost of $20.73 per model.
157 In addition to the 15
minutes for submitting the DOC form, there is an additional 19.75
hours expended by multiple
levels of a producer’s organization for the purpose of review and
quality checking. The cost to
submit a declaration of compliance occurs largely in year 2 of the
analysis period so that UAS
producers are able to manufacture inventory with remote identification
for availability to
operators beginning with year 3 of the analysis period. Producers
would incur additional costs

156 The time allotted in the FAA information collection related to the registration of small unmanned aircraft is used
as a proxy to estimate the cost to producers for submitting a
declaration of compliance for remote identification. In
the Registration of Small Unmanned Aircraft information collection, it
was estimated that seven minutes was
required for an individual to complete a small unmanned aircraft
registration. Since the DoC requires approximately
twice as much information as a registration for unmanned aircraft, the
FAA estimates the DoC form will take
approximately 15 minutes to complete.
157 In this calculation, the FAA assumes the fully burdened wage
(compensation + benefits) to be similar to that of
the wage of FAA technical subject matter expert, which is increased by
a factor of 1.466 to become a fully burdened
wage of $82.93 per hour, or $20.73 for 15 minutes.
220
for submitting a declaration of compliance during years 3 through 10
of the proposed rule as they
design new models of UAS. The FAA assumes that five percent of the
submissions will not be
accepted initially, but will then be resubmitted and accepted by the
FAA.
Over the 10-year period of analysis, the present value costs to
producers for submitting
the declaration of compliance form is about $27.2 million at a three
percent discount rate or
$24.8 million at a seven percent discount rate for annualized costs of approximately $3.5 million
and 3.2 million, respectively.
Beginning in year 3 of the analysis period, producers would be
required to provide UAS
with remote identification.158 Standard remote identification UAS
would be required to transmit
message elements through the internet to a Remote ID USS and to
broadcast the same message
elements directly from the unmanned aircraft. Limited remote
identification UAS would be
required to be designed and produced such that the aircraft can
operate no more than 400 feet
from the control station and cannot broadcast remote identification
message elements.
The FAA estimates the incremental cost to a producer of standard
remote identification
UAS would include the cost of a computer chip for broadcasting the
remote identification
message elements ($5) and a cost to make the remote identification
equipment tamper resistant
($15). For limited remote identification UAS, the incremental cost to
a producer would include a
software update that prevents the aircraft from flying beyond 400 feet
from the operator ($5) and
a cost to make the remote identification equipment tamper resistant
($15).

158 Note the exceptions to this rule (military, law enforcement,
government not conducting operations as civil
aircraft). Additionally, the FAA determines that members of a
community based organization choose not to integrate
remote identification into existing aircraft.
221
Operators of limited remote identification UAS must transmit message
elements to the
Remote ID USS from the control station, which could be an electronic
device such as a smart
phone or tablet.159 For purposes of this analysis, the FAA determines
that operators of limited
remote identification UAS would already have a cell phone or
electronic device capable of
transmitting the message elements through an internet connection to
the Remote ID USS and
thus incur no additional costs for the purchase of a device to
transmit messages to a Remote ID
USS.
160
The present value costs to U.S. producers to build UAS with remote identification totals
$105 million at a three percent discount rate and $85 million at a
seven percent discount rate.
The annualized costs are about $12 million at either a three percent
or seven percent discount
rate.
iv. Developers of Remote Identification Means of Compliance
Under the proposed rule, a means of compliance would have to be
accepted by the FAA
before it is used in the design and production of UAS with remote identification. Means of
compliance are developed by persons or organizations to describe
methods by which a person
responsible for the production of standard remote identification UAS
or limited remote
identification UAS may comply with the minimum performance
requirements of this proposed
rule. The FAA would review the means of compliance to determine if it
meets the minimum
performance requirements, and testing and validation procedures of the
proposed rule.

159 Based on research of publicly available UAS information, the FAA
found that operators of limited remote
identification UAS already typically own a smartphone or other
electronic device which is capable of transmitting
the location of the control station to the internet.
160 In 2018, 77 percent of the adults in the United States owned a
smart phone (https://www.statista.com/statistics/219865/percentage-of-us-adults-who-own-a-smartphone/).
222
Specifically, the person or entity would have to submit a detailed
description of the means of
compliance, a justification for how the means of compliance meets the
minimum performance
requirements of the proposed rule, and any substantiating material the
person or entity wishes the
FAA to consider as part of the application. The FAA would indicate
acceptance of a means of
compliance by placing a notice in the Federal Register identifying the
means of compliance as
accepted and by notifying the submitter of the acceptance of the
proposed means of compliance.
A UAS remote identification standard that could be one potential means
of compliance to
the proposed rule is currently being developed by ASTM International,
and, for purposes of this
analysis, the FAA anticipates it would be available by the beginning
of year 2 of the analysis
period. Total present value costs incurred by industry consensus standard-setting entities to
develop and maintain a remote identification means of compliance is
$1.23 million at a three
percent discount rate and $1.08 million at seven percent discount rate
over the ten-year period of
analysis. The annualized costs are about $0.15 million at either a
three percent or seven percent
discount rate.
For purposes of this rulemaking, it is assumed that one additional
individual or entity,
would submit a means of compliance to the FAA for remote
identification on an annual basis for
years 2 through 10 of the analysis period. The costs would include
time to initially submit the
means of compliance and recurring time to accommodate changes in
broadcast technology and
evolution in the UTM/network requirements. Total present value costs
incurred by entities to
develop and maintain a remote identification means of compliance is
$1.6 million at a three
percent discount rate and $1.3 million at seven percent discount rate
over the ten-year period of
223
analysis. 161 The annualized costs are about $0.2 million at either a
three percent or seven percent
discount rate.
v. Remote ID USS MOA
The proposed rule would require persons operating UAS to transmit the
message
elements to a Remote ID USS over the internet. Remote ID USS will be FAA-qualified third
party service providers. Each Remote ID USS would be required to
establish a contractual
relationship with the FAA through a MOA and to comply with a series of
terms, conditions,
limitations, and technical requirements, and outline how the Remote ID
USS must interpret and
provide data to external users, as well as store and protect such
data. To implement remote
identification, the FAA anticipates establishing a cooperative data
exchange mechanism between
the FAA and Remote ID USS.
The FAA estimates ten entities would apply to the FAA to become a
Remote ID USS
during year 1 of the analysis period, and nine entities would be
approved.162 Over the remaining
years of the analysis period, the FAA estimates one additional entity
per year would submit an
application to become a Remote ID USS, and that entity would be
approved by the FAA. Each of
the entities would address technical requirements in the application
to become a Remote ID USS
that results in a 40-page document, which is then submitted to the
FAA. Each of the documents
would take 25 hours per page to prepare at full compensation wage of
$92.72 per hour.163 Total
costs to Remote ID USS applicants during years 1 through 10 of the
analysis period is about $1.6

161 See the Regulatory Impact Analysis for this proposed rulemaking
for the derivation of these estimates.
162 Based on the number of LAANC USS.
163 The full compensation wage (salary and benefits) is based on a
2019 FAA “Technical” Pay Band.
224
million at a three percent discount rate and $1.4 million at a seven
percent discount rate. The
annualized costs are about $0.19 million at either a three percent or
seven percent discount rate.
vi. FAA-Recognized Identification Areas
The FAA is proposing to allow UAS to operate without remote
identification if they do
so within visual line of sight within FAA-recognized identification
areas. By identifying a
defined location where operations of UAS without remote identification
would be occurring, the
FAA-recognized identification area itself becomes the form of
identification. The intent is to
minimize the regulatory burden for operators of UAS without remote identification, while still
meeting the intent of the rule. This proposal would not preclude UAS
with remote identification
from operating in or transiting the airspace over FAA-recognized
identification areas; it would
simply limit UAS without remote identification from operating anywhere
else.
Certain flying sites established within the programming of a community
based
organization (CBO) recognized by the Administrator would be eligible
to become FAArecognized identification areas to enable operations of
UAS without remote identification within
those areas, if they meet certain criteria and application deadlines.
CBOs can request that an
existing flying site be established as an FAA-recognized
identification areas, where UAS may
operate without remote identification equipment. The application would
have to be submitted
within 12 calendar months from the effective date of a final rule.
After that date, the number of
FAA-recognized identification areas could therefore only remain the
same or decrease. The FAA
also expects that as compliance with remote identification
requirements becomes cheaper and
easier, the need to operate only at FAA-recognized identification
areas would likely decrease.
The establishment of an FAA-recognized identification area is approved
by the FAA until 48
calendar months after the date on which the request for establishment
was approved. A person
225
wishing to renew the establishment of the FAA-recognized
identification area would have to
submit a request for renewal.
The FAA estimates it would receive approximately 2,500 requests for a
flying site to
become an FAA-recognized identification area, and that as many as 10
percent could be
disapproved due to the flying site being in a sensitive area.164 The
FAA estimates that in year 1,
each request would require two hours to complete at a total
compensation wage of $58.12 per
hour.165 The FAA anticipates that renewals would require less time to
submit since the process is
expected to be electronic, thus in years five and nine, the time
estimated to complete a renewal is
30 minutes. Over the 10-year period of analysis, costs incurred by
CBOs for submitting requests
for FAA-recognized identification areas total $0.39 million at a three
percent discount rate and
$0.35 million at a seven percent discount rate. The annualized costs
are about $0.05 million at
either a three percent or seven percent discount rate.
Individuals that are unable to use a flying site due to FAA
disapproval of the application
for establishment of an FAA-recognized identification area would have
the option to fly UAS
with remote identification or to drive to an alternate FAA-recognized identification area. For
purposes of this preliminary analysis, the FAA assumes this affected
group would choose to
drive to the next closest FAA-recognized identification area near
their home, which would
increase their driving distance to an FAA-recognized identification
area an additional 32 miles
per round trip, on average.166 The FAA estimates that ten percent of
the members belonging to a

164 https://www.modelaircraft.org/about-ama
165 U.S. Bureau of Labor Statistics, Aerospace Engineering or
Operations Technician Data
166 Source: FAA analysis of travel distance to current flying sites
based on zip codes of addresses on record for
unmanned aircraft registrations for limited recreational operators
show that over 94% of registered owners are
within 16 miles (32 miles round trip) of a flying site that may be
considered for application as an FAA-recognized
identification area.
226
CBO would be travelling an additional 32 miles per outing, and that
this group would travel 52
times per year to an FAA-recognized identification area for a total
present value expense of $136
million at a three percent discount rate and $109 million at a seven
percent discount rate over the
ten-year period of analysis.167 The annualized costs are about $16
million at a three percent and
seven percent discount rate. The FAA provides a sensitivity analysis
of these costs based on a
range of trips per year in the Regulatory Impact Analysis report
available in the docket.
The FAA requests comments on the costs and frequency of additional
travel to FAArecognized identification areas for recreational flyers
affected by this provision.
vii. FAA
The FAA will incur costs to support the implementation of the proposed
remote
identification rule. These costs include updating the website portal
for the part 48 unmanned
aircraft registry to aid recreational flyers to register each unmanned
aircraft individually and to
facilitate foreign operators of unmanned aircraft to provide
notification of identification;
establishing MOAs with entities seeking to become Remote ID USS;
accepting or not accepting
submissions of means of compliance; accepting or not accepting
submissions of declarations of
compliance; approving or denying requests from CBOs for FAA-recognized identification areas;
developing a website for identifying FAA-accepted means of compliance
and declarations of
compliance; updating the aircraft registry website; and finally,
establishing a network for the data
exchange between Remote ID USS and the FAA. The present value costs of
this proposed rule to
FAA total $56.9 million at a three percent discount rate and $50.3
million at a seven percent

167 Estimated using United States Department of Transportation
guidance on the hourly value of travel time savings
for personal purposes, the IRS mileage rate of 20 cents per mile, and
the additional 32 miles are traveled at a rate of
50 miles per hour.
227
discount rate. The annualized costs are approximately $7.0 million at
either a three percent or
seven percent discount rate.
The FAA also receives cost savings from this proposed rule resulting
from a reduction in
hours expended on UAS investigations by aviation safety inspectors.
This analysis includes
quantified savings to the FAA only. A variety of other entities
involved with airport operations,
facility and infrastructure security, and law enforcement would also
save time and resources
involved with UAS identification and incident reporting, response and investigation. The FAA
plans to update its estimates of savings for additional information
and data identified during the
comment period and development of the final rule. The present value
cost savings to FAA total
$2.4 million at a three percent discount rate and $1.8 million at a
seven percent discount rate.
The annualized costs savings are almost $0.3 million at either a three
percent or seven percent
discount rate.
Additionally, part 107 allows individuals to request waivers from
certain provisions,
including those prohibiting operations over people and at night. This
proposed rule, in concert
with the proposed rule for operations over people would create a cost
savings for the FAA
resulting from a reduction of time expended by FAA personnel
processing waivers for these
activities. 168
4. Total Costs and Cost Savings
The total costs of the proposed remote identification rule include
costs incurred by UAS
owners, CBOs, UAS operators, UAS producers, developers of remote
identification means of

168 See the appendix of the Remote Identification of Unmanned Aircraft
Systems Preliminary Regulatory Impact
Analysis for a quantification of these cost savings.
228
compliance, candidates to be Remote ID USS, and the FAA. In addition
to the costs incurred by
the various entities impacted by the proposed rule, the FAA has a cost
savings from avoided
aviation safety inspector costs due to a reduction in hours expended
on UAS investigations.
Over the 10-year period of analysis, using the primary estimate this
proposed rule would
result in present value costs of $584 million at a three percent
discount rate and $475 million at a
seven percent discount rate. These costs are partially offset by
present value cost savings of $2.5
million and $1.8 million at a three percent and seven percent discount
rate, respectively. As a
result, the net present value costs are $582 million at a three
percent discount rate with
annualized net costs of $68 million. At a seven percent discount rate,
the net present value costs
are $474 million with annualized net costs of $67 million.
The following table presents a summary of the primary, low and high
estimates of the net
costs of the proposed rule.
Table 8a: Preliminary Estimates of Net Costs of Proposed Rule
($Millions)*
Base Scenario – Primary Estimate
Affected Entity/Category
10-Year
Present Value
(at 3%)
Annualized
(at 3%)
10-Year
Present Value
(at 7%)
Annualized
(at 7%)
UAS Owners/Operators $145.87 $17.10 $117.48 $16.73
Remote ID USS Subscription $241.72 $28.34 $191.74 $27.30
UAS Producers (US and Foreign) $134.58 $15.78 $111.58 $15.89
Developers of Remote ID Means of Compliance $2.85 $0.33 $2.36 $0.34
Remote ID USS Memoranda of Agreement $1.60 $0.188 $1.43 $0.2038
Community Based Organizations $0.39 $0.05 $0.35 $0.05
FAA Costs $56.96 $6.68 $50.33 $7.17
Total Costs $583.98 $68.46 $475.27 $67.67
Cost Savings ($2.45) ($0.29) ($1.82) ($0.26)
Net Costs $581.52 $68.17 $473.46 $67.41
*Table notes: column totals may not sum due to rounding and
parenthesis, “( )”, around numbers to indicate savings.
229
Table 8b: Preliminary Estimates of Net Costs of Proposed Rule
($Millions)*
Low Scenario
Affected Entity/Category
10-Year
Present Value
(at 3%)
Annualized
(at 3%)
10-Year
Present Value
(at 7%)
Annualized
(at 7%)
UAS Owners/Operators $140.99 $16.53 $113.64 $16.18
Remote ID USS Subscription $206.58 $24.22 $164.24 $23.38
UAS Producers (US and Foreign) $116.53 $13.66 $97.25 $13.85
Developers of Remote ID Means of Compliance $2.85 $0.33 $2.36 $0.34
Remote ID USS Memoranda of Agreement $1.60 $0.188 $1.43 $0.2038
Community Based Organizations $0.39 $0.05 $0.35 $0.05
FAA Costs $56.96 $6.68 $50.33 $7.17
Total Costs $525.91 $61.65 $429.61 $61.17
Cost Savings ($2.45) ($0.29) ($1.82) ($0.26)
Net Costs $523.46 $61.36 $427.80 $60.91
*Table notes: (i) Column totals may not sum due to rounding and
parenthesis, “( )”, around numbers to indicate
savings. (ii) The low and high forecast scenarios are not symmetric
around the base—please see the forecast report
for more information. The FAA Aerospace Forecast Fiscal Years
2019-2039, available at https://www.faa.gov/data_research/aviation/aerospace_forecasts/media/FY2019-39_FAA_Aerospace_Forecast.pdf.
The forecast provides a base (i.e., likely) with high (or optimistic)
and low (or pessimistic) scenarios.
Table 8c: Preliminary Estimates of Net Costs of Proposed Rule
($Millions)*
High Scenario
Affected Entity/Category
10-Year
Present Value
(at 3%)
Annualized
(at 3%)
10-Year
Present Value
(at 7%)
Annualized
(at 7%)
UAS Owners/Operators $159.32 $18.68 $127.87 $18.21
Remote ID USS Subscription $336.14 $39.41 $264.22 $37.62
UAS Producers (US and Foreign) $181.51 $21.28 $148.26 $21.11
Developers of Remote ID Means of Compliance $2.85 $0.33 $2.36 $0.34
Remote ID USS Memoranda of Agreement $1.60 $0.188 $1.43 $0.2038
Community Based Organizations $0.39 $0.05 $0.35 $0.05
FAA Costs $56.96 $6.68 $50.33 $7.17
Total Costs $738.78 $86.61 $594.81 $84.69
Cost Savings ($2.45) ($0.29) ($1.82) ($0.26)
Net Costs $736.33 $86.32 $593.00 $84.43
*Table notes: column totals may not sum due to rounding and
parenthesis, “( )”, around numbers to indicate savings.
The following table presents an itemized list of preliminary estimates
of costs and cost
savings from this proposed rule.
Table 9: Remote Identification Costs and Cost Savings ($Millions)
Affected Entity 3% PV 7% PV
UAS Owners/Operators
Registration - Recreational Flyers $1.070 $0.887
Travel Expense* - Recreational Flyers $135.911 $108.960
230
Affected Entity 3% PV 7% PV
Registration - Part 107 $0.025 $0.021
Loss of UAS Use - Recreational Flyers $4.625 $3.972
Loss of UAS Use - Pt 107 Operators $4.238 $3.639
Community Based Organizations
Letters of Agreement Submission $0.389 $0.354
USS Subscription Fee
Part 107 $93.752 $73.787
Limited Recreational Flyers $147.969 $117.954
UAS Producers
Equipage Cost $105.325 $84.891
Declaration of Compliance $27.178 $24.795
Industry Consensus Standard - Remote ID $0.160 $0.146
Industry Consensus Standard - Serial # $0.000 $0.000
Labeling Requirement $1.917 $1.749
Developers of Remote Identification MoC
Industry Consensus Standard $1.230 $1.083
Developers of Remote ID MoC (Others) $1.620 $1.276
Remote Identification USS
Cost to submit MoA with FAA $1.601 $1.431
FAA Costs
Onboard USS Service Suppliers $2.179 $1.913
Accept/Not Accept MoC $0.144 $0.115
Accept/Not Accept Mfr DoC* $0.000 $0.000
Web Portal Update – Registration/Notification of Identification $0.728
$0.701
Approve/Disapprove Flying Field as an FAA-Recognized Identification
Areas $4.669 $3.966
Website for Means of Compliance/Declarations of Compliance $2.294
$2.000
Remote Identification USS Data Exchange $46.950 $41.631
Total Costs $583.975 $475.271
Cost Savings: Reduced Hours FAA UAS Investigations ($2.453) ($1.815)
Total Cost Savings ($2.453) ($1.815)
Net Costs $581.522 $473.456
Annualized Net Costs $68.172 $67.409
* Automated approval through FAA drone zone portal.
Note: Column totals may not sum due to rounding.
The estimated costs are presented on an annual basis in the table
below.
Table 10: Remote Identification Costs and Cost Savings – Years 1-10
($Millions)
Costs by Affected Entity Year 1 Year 2 Year 3 Year 4 Year 5 Year 6
Year 7 Year 8 Year 9 Year 10 Total
Costs
UAS Owners (3% PV) $0.167 $15.818 $15.714 $24.420 $15.394 $15.247
$15.070 $14.867 $14.688 $14.483 $145.87
231
UAS Owners (7% PV) $0.161 $14.656 $14.018 $20.968 $12.724 $12.130
$11.541 $10.961 $10.424 $9.894 $117.48
Community Based Org. (3% PV) $0.282 $0.056 $0.050 $0.39
Community Based Org. (7% PV) $0.272 $0.047 $0.036 $0.35
USS Subscription Fee (3% PV) $13.058 $29.430 $29.681 $29.384 $28.962
$28.491 $28.031 $27.572 $27.112 $241.72
USS Subscription Fee (7% PV) $12.099 $26.252 $25.485 $24.288 $23.042
$21.819 $20.667 $19.568 $18.520 $191.74
UAS Manufacturer (3% PV) $0.000 $39.446 $16.244 $8.366 $12.709 $14.362
$9.066 $11.955 $13.038 $9.396 $134.58
UAS Manufacturer (7% PV) $0.000 $36.550 $14.489 $7.182 $10.505 $11.426
$6.943 $8.814 $9.253 $6.418 $111.58
Developers of Remote ID MoC (3%
PV) $0.589 $0.215 $0.226 $0.236 $0.245 $0.253 $0.261 $0.268 $0.275
$0.280 $2.85
Developers of Remote ID MoC (7%
PV) $0.567 $0.200 $0.202 $0.203 $0.203 $0.202 $0.200 $0.198 $0.195
$0.192 $2.36
Remote ID USS (3% PV) $0.900 $0.087 $0.085 $0.082 $0.080 $0.078 $0.075
$0.073 $0.071 $0.069 $1.60
Remote ID USS (7% PV) $0.867 $0.081 $0.076 $0.071 $0.066 $0.062 $0.058
$0.054 $0.050 $0.047 $1.43
FAA (3% PV) $28.694 $3.298 $3.202 $3.109 $3.990 $2.930 $2.845 $2.762
$3.545 $2.590 $56.96
FAA (7% PV) $27.619 $3.055 $2.856 $2.669 $3.297 $2.331 $2.178 $2.036
$2.515 $1.769 $50.33
Total Costs - 3% PV $30.632 $71.922 $64.901 $65.894 $61.858 $61.832
$55.809 $57.957 $59.239 $53.930 $583.98
Total Costs-7% PV $29.485 $66.641 $57.892 $56.578 $51.130 $49.193
$42.740 $42.730 $42.041 $36.840 $475.27
Costs Savings - 3% PV ($0.520) ($0.505) ($0.490) ($0.476) ($0.462)
($2.453)
Costs Savings - 7% PV ($0.414) ($0.387) ($0.361) ($0.338) ($0.316)
($1.815)
Net Costs - 3% PV $30.632 $71.922 $64.901 $65.894 $61.858 $61.312
$55.304 $57.467 $58.763 $53.468 $581.52
Net Costs - 7% PV $29.485 $66.641 $57.892 $56.578 $51.130 $48.779
$42.354 $42.368 $41.703 $36.524 $473.46
Table notes: *PV = Present Value and “()”= denotes savings.
The key cost driver of the proposed rule is the USS subscription fee,
followed by travel
expenses for a select group of recreational flyers, and the cost of
compliance for UAS producers.
The present value cost of USS subscription fees is $241.7 million at a
three percent discount rate
and $191.7 million at a seven percent discount rate. The annualized
cost of USS subscription
fees is $28.3 million at a three percent and $27.3 million at a seven
percent discount rate. This
impact represents over 41.4 percent of the total costs of the proposed
rule. The travel expense for
a select group of recreational users represents 23.3 percent of the
proposed rule’s total costs, and
costs to UAS producers are 23.0 percent of the total costs.
232
The FAA believes this cost impact is justified in order to reduce the
delay (by two years)
in implementing for law enforcement, security partners, the FAA, and
airports to use remote ID
information. The FAA alternatively 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
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.169
A potential offsetting benefit of the one-year operational compliance
period is that a

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