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portion of part 107 operators may be able to immediately perform
operations over people and
operations at night without a waiver once their UAS has remote
identification. As many as
68.4 million operations over people and at night could be enabled by
the proposed shortening the
of the operational compliance period. Assuming that the flight time
for each of these 68.4 million
operations lasts 30 minutes and the wage for a remote pilot is $12.09
per operation, the economic
benefit in terms of pilot wages alone is about $827 million
undiscounted (not present value).
170

169 As previously discussed, the proposal does not preclude early
compliance for producers or operators to realize
earlier expanded operations and commercial opportunities. The FAA
provides a sensitivity analysis of costs for
earlier developer and producer compliance by the effective date of the
final rule (60 days after publication). This
analysis shows that if Remote ID USS and UAS with remote
identification are available by the effective date of the
final rule (as proposed), then total net costs reduce by about 60-70%
and operations over people and at night would
be enabled beginning in the first year after publication.
170 https://www.payscale.com/research/US/Job=Drone_Pilot/Hourly_Rate
233
5. Alternatives Considered
The FAA considered both more and less costly alternatives as part of
the proposed rule.
The alternatives and the FAA’s reasons for rejecting those
alternatives are discussed below.
i. Alternative Compliance Periods - Producers
The chosen compliance period to estimate producer costs is two years
beyond the
effective date of the final rule. The FAA considered a producer
compliance period of one year,
especially considering potential retrofits, however this alternative
was determined to be
impractical since no FAA-accepted means of compliance currently
available for producers to
build to. Until an FAA-accepted means of compliance exists, producers
would not be able to
submit a declaration of compliance. Accordingly, the FAA believes it
is practical for an industry
consensus standard to be developed that could be submitted for
acceptance as a means of
compliance by the end of year 1 after the effective date of the final
rule, with an additional year
for producers to design, build, and test UAS that meet the standard.
The two-year compliance period for producers is consistent with
information on timelines
for available technology from the UAS-ID ARC Report and expected
availability of USS. The
ARC found technologies similar to planned Remote ID USS transmissions
have a “readiness for
implementation” of one year or less. This means products would be
available for original
equipment manufacturers within one year of the requirements being
known. This one-year period
would start after the availability of FAA-accepted means of compliance
and Remote ID USS—
the FAA expects means of compliance and Remote ID USS availability to
take up to one year
after the effective date of the final rule.
234
At this time, the two-year producer compliance period appears
reasonable and has a
technical basis. The FAA has not identified or analyzed an
alternative. The current proposal does
not preclude earlier producer compliance (in light of a potential
economic incentive to comply
earlier). Likewise, this proposal would not preclude producer
compliance through retrofits within
the two-year producer compliance period or earlier, as long as
retrofits use an FAA-accepted
means of compliance.
ii. Alternative Operational Compliance Period
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. 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 end of useful life.
However, the FAA
determined that the three-year compliance period was less preferable
since it prolonged safety
and security risks to air traffic and airports by delaying the ability
of law enforcement personnel
to identify unauthorized UAS operations. In addition, as previously
discussed, some producers
would be able to retrofit UAS in the existing fleet and comply early.
To reduce the delay in
implementing remote identification, the owner/operator compliance
period was reduced from
three years to one year.
The FAA analyzed the costs of allowing up to three years for
owners/operators to be in
compliance and found this alternative minimizes costs to
owners/operators of existing UAS that
could not be retrofit, since on average the affected existing fleet of
UAS could be replaced at the
end of useful life (three years). In addition, this alternative is
more likely to reduce uncertainty of
adverse impacts to producers with inventories of UAS produced before
the compliance date that
would likely not meet the remote identification provisions of this
proposal, including with
235
retrofits. Given the average three-year UAS lifespan, the three-year operational compliance
period would likely assist producers in depleting existing
non-compliant inventories with
reduced impact compared to the proposed one-year compliance period.
Under this alternative, present value costs at a three percent
discount rate total $494.2
million with annualized costs of $57.9 million. The present value
costs at a seven percent
discount rate total $394.4 million with annualized costs of $56.2
million. Present value cost
savings at a three percent discount rate total $2.45 million with
annualized cost savings of $0.29
million. At a seven percent discount rate, present value costs savings
total $1.82 million with
annualized cost savings of $0.26 million. As a result, present value
net costs at a three percent
discount rate are $491.7 million with annualized net costs of $57.7
million. At a seven percent
discount rate, present value net costs are $392.6 million with
annualized net cost of $55.9
million. The cost associated with this alternative are slightly less
than the proposal that assumes
producers would be capable of retrofits within one year of the
effective date of the final rule.
iii. Requiring ADS-B Out
The FAA could have proposed transponders or ADS-B Out for UAS as a
means to
remotely identify those aircraft. The FAA does not propose the use of transponders or ADS-B
Out for remote identification for three primary reasons. First, the
use of these technologies would
require significant additional infrastructure, including radars and
receivers, to cover the lower
altitudes where unmanned aircraft are expected to primarily operate.
Second, the FAA expects
that, due to the volume of unmanned aircraft operations projected, the additional radio frequency
signals would saturate the available spectrum and degrade the overall cooperative surveillance
system. Finally, transponders and ADS-B Out do not provide any
information about the location
of control stations, as these systems were designed for manned
aircraft. For these reasons, the
236
FAA has determined that existing cooperative surveillance systems are
incapable of supporting
UAS remote identification and is proposing a new cooperative
surveillance technology
specifically for UAS.
iv. FAA Provided Remote Identification Services
The proposed rule assumes that Remote ID USS would come forward to
offer remote
identification services to indiviRequireduals operating UAS in the
airspace of the United States.
The alternative would be for the FAA to provide these services
directly to operators of UAS
instead of providing them through a third-party provider. The FAA
chose the Remote ID
alternative for several reasons. First, the LAANC service model has
been effective due to the
success of public and private sector partnerships in implementing
LAANC and clear
Congressional approval of the model. Second, similar to LAANC USS, the
FAA will not provide
payment for the development or operation of Remote ID USS products or
services. The FAA
anticipates that the Remote ID USS would recoup the costs of providing
services either through
the sale of subscriptions for remote identification services, online advertising, or “value added”
services that can be purchased from the service provider.
v. Not Allowing FAA-Recognized Identification Areas
The FAA considered not allowing FAA-recognized identification areas.
If the proposed
rule did not allow for these areas, operators of UAS with no remote identification equipment
would not be allowed to operate unless the UAS were redesigned to have
remote identification.
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 for allowing FAA-recognized identification areas is to
minimize the regulatory burden
237
for operators of existing UAS used exclusively for limited
recreational operations that do not
have remote identification equipment, while still meeting the intent
of the rule.
Assumptions
? Individuals want to operate UAS without remote identification within FAA-recognized
identification areas
? Each individual owns two aircraft which are used for limited
recreational operations.
? These unmanned aircraft have a lifespan that extends beyond the
10-year analysis period
of the proposed rulemaking.
Should the FAA not allow FAA-recognized identification areas for the
operation of UAS
without remote identification, it is estimated that as many as 400,000
UAS that are used for
recreational flying would be grounded at the end of year 3.
vi. Requiring all UAS to be Standard Remote Identification UAS (Except
for UAS
without Remote Identification Operated at FAA-Recognized
Identification Areas)
The preferred alternative allows operators of limited remote
identification UAS to
operate at places other than FAA-recognized identification areas. The
FAA considered requiring
all UAS to be standard remote identification UAS. Under this
alternative, owners desiring to
operate any UAS that is not a standard remote identification UAS would
be required to travel to
an FAA-recognized identification area. The FAA analyzed the shortest
distance between zip
codes for each online hobbyist registration and the zip code closest
to one of over 2,000 AMA
flying fields.171 The zip code analysis indicates a person operating
UAS that are not standard

171 As of April 26, 2019, there are 1,013,893 individuals registered
as hobbyists.
238
remote identification UAS would be required to travel an average of 16
miles one-way to the
nearest FAA-recognized identification area.
Assumptions
? Operators of UAS that are not standard remote identification UAS are
willing to travel to
an FAA-recognized identification area.
? The average distance between an FAA-recognized identification area
and the homes for
operators of UAS used for limited recreational operations is 32 miles
round trip.
On average, operators of UAS that are not standard remote
identification UAS would
travel to an FAA-recognized identification area 52 times per year.
? The share of the UAS fleet operated by recreational flyers that is
not a standard remote
identification UAS is assumed to be 82 percent.
Based on these assumptions, the present value travel costs and
opportunity cost of time
accrued to recreational flyers is $2,276 million at a seven percent
discount rate. These costs
accrue during years 4-10 of the analysis period. Additionally, under
this alternative, affected
recreational flyers would no longer be required to subscribe to a
Remote ID USS since they
would only be flying at an FAA-recognized identification area. Thus
this affected group would
avert subscription costs. Averted present value subscription costs in
this alternative total
$72.7 million at a seven percent discount rate.
As discussed above, the costs of this alternative are calculated based
on individuals
traveling an average of 52 times per year to an FAA-recognized
identification area. Given that
there is uncertainty regarding the average number of trips that this
affected group would take on
an annual basis, the FAA conducted a sensitivity analysis by varying
the input for travel
239
frequency. Using 26 trips per year, the total cost becomes $1,138
million, and using 90 trips per
year the cost is $3,939.5 million.
172
vii. Grandfathering of Legacy UAS
The FAA considered allowing UAS that would not be able to retrofit to
continue
operating in the airspace of the United States using software-based
flight notification with
telemetry.173 This would be accomplished through software based
mission planning services. The
UAS operator would self-declare information pertaining to area their
drone would be flying in,
including altitude, duration and type of aircraft. This information
would be shared prior to flight
to enable authorities to clearly identify compliant operations.
Software apps are currently
available on the marketplace that would support this alternative.
The FAA did not pursue this option because it would not meet the
mission needs of the
proposed rule for security, performance, and information quality.
While this alternative would
allow for the rapid adoption of Remote ID and Tracking for nearly all
classes of UAS, it relies on
the individual operator to proactively report their location to a USS. Conversely, the proposed
rule requires remote identification UAS to automatically connect to a
USS. If the UAS cannot
connect to the USS, the unmanned aircraft will not take off.

172 These trip frequencies assume that an individual travels, on
average, every other weekend (26 trips/year), every
weekend (52 trips/year), or once every four days (90 trips/year) to an FAA-Recognized Identification Area. This is
used as a sensitivity analysis of the number of times an individual
would travel to an FAA-recognized identification
area in the period of one year. The lower bound of the sensitivity
analysis is based on the average number of rounds
a golfer plays in a year (Source: https://www.ngf.org/golf-industry-research/#golfers ). The upper bound
of the
sensitivity analysis is based on the number of times in a year a
person engages in a running/jogging/trail running
activity (Source: https://outdoorindustry.org/resource/2018-outdoor-participation-report/.
Page 23).
173 This option was discussed in the UAS Identification and Tracking
(UAS ID) Aviation Rulemaking Committee
(ARC) - ARC Recommendations Final Report, September 30, 2017.
240
B. Regulatory Flexibility Determination
The Regulatory Flexibility Act of 1980 (Pub. L. 96-354) (RFA)
establishes “as a
principle of regulatory issuance that agencies shall endeavor,
consistent with the objectives of the
rule and of applicable statutes, to fit regulatory and informational requirements to the scale of the
businesses, organizations, and governmental jurisdictions subject to regulation. To achieve this
principle, agencies are required to solicit and consider flexible
regulatory proposals and to
explain the rationale for their actions to assure that such proposals
are given serious
consideration.” The RFA covers a wide range of small entities,
including small businesses, notfor-profit organizations, and small
governmental jurisdictions.
Agencies must perform a review to determine whether a rule will have a significant
economic impact on a substantial number of small entities. If the
agency determines that it will,
the agency must prepare a regulatory flexibility analysis as described
in the RFA.
The FAA believes this proposed rule would have a significant economic
impact on a
substantial number of small entities. Therefore, under Section 603(b)
of the RFA, the initial
analysis must address:
? Description of reasons the agency is considering the action.
? Statement of the legal basis and objectives for the proposed rule.
? Description of the record-keeping and other compliance requirements
of the proposed rule.
? All Federal rules that may duplicate, overlap, or conflict with the
proposed rule.
? Description and estimated number of small entities to which the
proposed rule will apply.
? Description of Significant Regulatory Alternatives for Small
Entities.
241
1. Description of Reasons the Agency is Considering the Action
The remote identification of UAS is necessary to ensure public safety
and the safety and
efficiency of the airspace of the United States. The remote
identification framework would
provide UAS-specific data, which could be used in tandem with new
technologies and
infrastructure to facilitate more advanced operational capabilities
(such as detect-and-avoid and
aircraft-to-aircraft communications that support beyond visual line of
sight operations) and to
develop the necessary elements for UTM. Furthermore, remote
identification of UAS would
provide airspace awareness to the FAA, national security agencies, and
law enforcement entities,
which could be used to distinguish compliant airspace users from those potentially posing a
safety or security risk.
Current rules for registration and marking of unmanned aircraft
facilitate the
identification of the owners of unmanned aircraft, but normally only
upon physical examination
of the aircraft. Existing electronic surveillance technologies, like transponders and ADS-B, were
considered as potential solutions for the remote identification of UAS
but were determined to be
unsuitable due to the lack of infrastructure for these technologies at
lower altitudes and potential
saturation of available radio frequency spectrum. Currently, the lack
of real-time and historical
data regarding UAS operations affects the ability of the FAA to
oversee the safety and security
of the airspace of the United States, creates challenges for national
security agencies and law
enforcement entities in identifying threats, and impedes the further integration of UAS into the
airspace of the United States. The FAA proposes to address the
identification issues associated
with UAS by requiring the use of systems and technology to enable the
remote identification of
UAS.
242
The proposed requirement is consistent with the FAA’s safety mission
of overseeing and
promoting safety in air commerce and national security and promoting
the safe and efficient use
of the navigable airspace and would serve the public interest by
creating situational awareness of
all UAS flying in the airspace of the United States. It would also
strengthen the FAA’s oversight
of UAS operations and support efforts of law enforcement to address
and mitigate disruptive
behavior and hazards, which may threaten the safety and security of
the airspace of the United
States, other UAS, manned aviation, and persons and property on the
ground. The near real-time
access to remote identification information would also assist Federal
security partners in threat
discrimination—allowing them to identify an operator and make an
informed decision regarding
the need to take actions to mitigate a perceived security or safety
risk. The proposed rule would
enhance the FAA’s ability to monitor compliance with applicable
regulations; would contribute
to the FAA’s ability to undertake compliance, enforcement, and
educational actions required to
mitigate safety risks; and would advance the safe integration of UAS
into the airspace of the
United States.
2. Statement of the Legal Basis and Objectives for the Proposed Rule
Statement of the legal basis. The FAA promulgates this rulemaking
pursuant to various
authorities. First, under 49 U.S.C. 40103(b)(1) and (2), the FAA is
directed to issue regulations:
(1) to ensure the safety of aircraft and the efficient use of
airspace; and (2) to govern the flight of
aircraft for purposes of navigating, protecting and identifying
aircraft, and protecting individuals
and property on the ground.
Second, under 49 U.S.C. 44701(a)(5), the FAA must promote safe flight
of civil aircraft
by prescribing regulations the FAA finds necessary for safety in air
commerce and national
security.
243
Third, under section 2202 of Pub. L. 114-190, the Administrator must
convene industry
stakeholders to facilitate the development of consensus standards for
remotely identifying
operators and owners of UAS and associated unmanned aircraft and to
issue regulations or
guidance based on any standards developed.
Fourth, under 49 U.S.C. 44805, the Administrator must establish a
process for, among
other things, accepting risk-based consensus safety standards related
to the design and
production of small UAS.
Fifth, under 49 U.S.C. 44805(b)(7), the Administrator must take into
account any
consensus identification standard regarding remote identification of
unmanned aircraft developed
pursuant to section 2202 of Pub. L. 114-190.
Sixth, under 49 U.S.C. 44809(f), the Administrator is not prohibited
from promulgating
rules generally applicable to unmanned aircraft, including those
unmanned aircraft eligible for
the exception for limited recreational operations of unmanned
aircraft. Among other things, this
authority extends to rules relating to the registration and marking of
unmanned aircraft and the
standards for remotely identifying owners and operators of UAS and
associated unmanned
aircraft.
Seventh, the FAA has authority to regulate registration of aircraft
under
49 U.S.C. 44101–44106 and 44110–44113 which require aircraft to be
registered as a condition
of operation and establish the requirements for registration and
registration processes.
Lastly, this rulemaking is promulgated under the authority described
in 49 U.S.C. 106(f),
which establishes the authority of the Administrator to promulgate
regulations and rules, and
49 U.S.C. 40101(d), which authorizes the FAA to consider in the public interest, among other
244
things, the enhancement of safety and security as the highest
priorities in air commerce, the
regulation of civil and military operations in the interest of safety
and efficiency, and assistance
to law enforcement agencies in the enforcement of laws related to
regulation of controlled
substances, to the extent consistent with aviation safety.
Objectives for the proposed rule. The FAA is integrating UAS
operations into the
airspace of the United States through a phased, incremental, and
risk-based approach.
174
On June 28, 2016, the FAA achieved a major step towards UAS
integration when it
issued the final rule for Operation and Certification of Small
Unmanned Aircraft Systems.175
This was one of multiple UAS-related regulatory actions taken by the
FAA to enable the safe
integration of UAS into the airspace of the United States. As
technology progresses and the
utility of UAS increases, the FAA anticipates a need for further
rulemaking to continue to foster
the safe, secure, and efficient use of the airspace of the United
States. The FAA believes that the
next step in the regulatory process involves the enactment of
regulatory requirements to enable
the remote identification of UAS operating in the airspace of the
United States.
This action would implement requirements for the remote identification
of UAS. The
remote identification of UAS in the airspace of the United States
would address safety, security,
and law enforcement concerns regarding the further integration of
these aircraft into the airspace
while also enabling greater operational capabilities.

174 Consult http://www.faa.gov/uas for additional information
regarding UAS operations.
175 81 FR 42064.
245
3. Description of the Record-Keeping and other Compliance Requirements
of
the Proposed Rule
UAS owners, UAS operators (including pilots, remote pilots, and
persons manipulating
the flight controls of UAS), UAS manufacturers (i.e., persons
responsible for the production of
UAS), developers of remote identification means of compliance, and
Remote ID USS would
have important roles in the remote identification of UAS. Please see
section I.C of this preamble
for additional detail describing the roles and responsibilities of
each group within the scope of
the proposed rule.
This proposed rule imposes recordkeeping requirements. First, all
entities intending to
use the small unmanned aircraft for limited recreational operations
would be required to include
the manufacturer, model, and serial number of each small unmanned
aircraft in the registration of
that aircraft. Requiring the manufacturer, model, and serial number
would obligate registrants to
add this additional information to the registration for all their
aircraft used for limited
recreational operations.
Next, the FAA is proposing that persons who develop standards that the
FAA may accept
as a means of compliance submit those standards for review and
acceptance by the FAA. A
person who submits a means of compliance is proposed to be required to
retain the data for as
long as the means of compliance is accepted plus an additional 24
calendar months.
The FAA is proposing that persons who produce UAS with remote
identification must
meet the minimum performance requirements of the proposed rule using
an FAA-accepted
means of compliance. To demonstrate the UAS has been produced to meet
the minimum
performance requirements using an FAA-accepted means of compliance,
persons responsible for
the production of UAS would be required to submit to the FAA a
declaration of compliance. A
246
person who submits a declaration of compliance would be required to
retain the data submitted
for 24 calendar months after the cessation of production of the UAS
with remote identification.
The proposed rule would require a producer to label the UAS to show
that it was
produced with remote identification technology capable of meeting the
proposed rule. The
proposed labeling requirement would inform the operator that the UAS
is eligible to conduct
operations within the airspace of the United States.
The FAA proposes standard remote identification UAS and limited remote identification
UAS be designed and produced to connect to the internet and transmit
remote identification
message elements to Remote ID USS. The collection of this information
in the form of message
elements is necessary to comply with the statutory requirement to
develop standards for remotely
identifying operators and owners of UAS and associated unmanned
aircraft. The information
transmitted between the UAS and the Remote ID USS is collected
electronically without input
from the human operator, thus there is no burden on the person
manipulating the flight controls
of the unmanned aircraft to manually submit information to the Remote
ID USS. There would be
an exchange of information between the Remote ID USS and the FAA when identification of the
UAS is required. At this time, it is unknown how often exchanges
between the FAA and Remote
ID USS will occur.
To support the transmission of these message elements, the FAA
envisions that a Remote
ID USS (an FAA-qualified third party service provider) demonstrate
four primary capabilities:
(1) the ability to share the remote identification message elements in
near real-time with the FAA
upon request; (2) the ability to maintain remote identification
information; (3) the ability to meet
contractually-established technical parameters; and (4) the ability to
inform the FAA when their
services are active and inactive. Each Remote ID USS would be required
to establish a
247
contractual relationship with the FAA through a Memorandum of
Agreement (MOA), and to
comply with a series of terms, conditions, limitations, and technical requirements, and to outline
how the Remote ID USS must interpret and provide data to external
users, as well as store and
protect such data.
The FAA is proposing that representatives of CBOs submitting
applications for flying
sites to become FAA-recognized identification areas may apply for such designation in a form
and manner acceptable to the FAA. The application would collect
certain information regarding
the location and requirements of the flying site, and require the CBO representative to confirm
certain information regarding the site.
4. All Federal Rules that may Duplicate, Overlap, or Conflict with the
Proposed Rule
The FAA is unaware that the proposed rule will overlap, duplicate or
conflict with
existing Federal rules.
5. Description and an Estimated Number of Small Entities to which the
Proposed Rule Will Apply
This proposed rule would apply to four communities of small entities:
producers of UAS,
entities that either own or operate UAS, community based
organizations, and Remote ID USS.
The first affected group of small entities discussed will be
producers. For purposes of this
rulemaking, the FAA estimates that there are approximately 154 U.S.
entities that produce small
248
UAS as of January 2019.176 Out of these 154 U.S. entities, data on
entity size, as defined by
number of employees, was available for only 117. Out of the 117
entities for which data was
available, 87 of the entities are categorized as small, 12 of the
entities are categorized as
medium, and 18 are categorized as large.177 Data for the remaining 37
entities was not available
and thus the entity size could not be determined, however a majority
are believed to be small.
NAICS code 336411 is titled “Miscellaneous Aircraft Manufacturing.”
The manufacture of
unmanned and robotic aircraft are included in this code. The SBA
defines industries within this
code to be small if they employ 1,500 employees or less.
The next group of entities affected by the proposed rule are owners
and operators of UAS
that conduct operations under part 107 or part 91. Based on analysis
conducted by the
Association for Unmanned Vehicle Systems International (AUVSI), over
85 percent of part 107
waivers granted have been to small businesses.178 Using this finding
based on part 107 waiver
data as a proxy for the size of all entities operating UAS under part
107, the FAA assumes that
approximately 85 percent of the entities operating under part 107 are
small. The FAA requests
information on this assumption and the number of small entities
affected by the proposal.
Model aircraft organizations179 currently operating flying sites are
affected by this
rulemaking. These organizations would be required to submit a request
to the FAA to have an
established flying site approved as an FAA-recognized identification
area. Based on membership

176 AUVSI Air Platform Database. Accessed January 2019.
177 This is based on AUVSI criteria for number of employees. The AUVSI
criteria for a manufacturer of unmanned
aircraft to be identified as a small entity is 49 employees or fewer.
The criteria to be identified as a medium entity is
50-499 employees. Large entities are determined to have 500 or more
employees.
178 (AUVSI) Association of Unmanned Vehicle Systems International. As
of July 31, 2017, 1,074 waivers had been
issued of which 85 percent were granted to small entities (entities
with less than 10 employees).
179 Academy of Model Aeronautics (AMA), http://www.modelaircraft.org/aboutama/whatisama.aspx; more than
2,500 AMA fields.
249
of AMA (Academy of Model Aeronautics), it is estimated that each
flying club has, on average,
78 members.180 SBA standards for NAICS code 713990 “All Other
Amusement and Recreation
Activities” is $7.5 million in annual receipts, or less, to be
considered a small entity. Financial
records for these individual community based organizations are not
public information, but it is
believed that none have receipts totaling $7.5 million, and thus each
is considered a small entity.
The last group of entities affected by the proposed rule are Remote ID
USS. Because
Remote ID USS do not yet exist, the FAA is unable to classify the
entities as either small or
large.
The FAA determines that a majority of entities impacted by this
proposed rule are small.
Therefore, the FAA determines this proposed rule would have a
significant economic impact on
a substantial number of small entities.
6. Description of Significant Regulatory Alternatives Considered for
Small
Entities

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