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The FAA considered both more and less costly alternatives as part of
the proposed rule
because the RFA requires the agency to consider significant regulatory alternatives that meet the
agency’s statutory objectives and minimize the costs to small
entities. 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;

180 Ibid. Based on 2018 AMA membership of 195,000 and approximately
2,500 AMA fields, the average
membership per field is estimated to be 78 individuals.
250
however, this alternative was determined to be impractical. One reason
that the alternative was
not chosen is that there is 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 one 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 (producers) within one year of the
requirements being known. This
one-year period would start after the availability of FAA-accepted
means of compliance and
services from Remote ID USS—we expect means of compliance and Remote
ID USS
availability to take up to one year after the effective date of the
proposed rule.
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 (potential economic incentive
to comply earlier). The
FAA requests comments on alternative compliance periods that would
minimize costs for small
producers.
251
ii. Alternative Operational Compliance Periods
The FAA considered 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
costly grounding or replacement of UAS prior to end of useful life.
However, the FAA
determined that the three-year compliance period was unacceptable
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. To reduce the delay in
implementing remote
identification, the owner/operator compliance period was reduced from
three years down 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 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. Given the average
three-year UAS lifespan, the
three-year operational compliance period would likely assist producers
in depleting existing noncompliant inventories with reduced impact
compared to the proposed one-year compliance
period.
Under this alternative, net present value 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, net present
value costs are $392.6 million with annualized net cost of $55.9
million. These costs are lower
than the costs of the proposed rule: the proposal results in present
value costs of about $582
252
million at a three percent discount rate with annualized net costs of
about $68.2 million, and net
present value costs of about $473 million at a seven percent discount
rate with annualized net
costs of about $67.4 million. This alternative would likely minimize
impacts on small entities
affected by this proposed rule. This alternative does not include
impacts and costs related to the
loss of use associated with UAS that cannot be retrofit and earlier
Remote ID USS subscription
fees that would occur under the proposed rule.
iii. FAA-Provided Remote Identification Services
The proposed rule assumes that Remote ID USS will come forward to
offer remote
identification services to individuals 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 is uncertain
how it would recoup
costs for these services, at least in the short run. The FAA chose the preferred 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, on-line advertising, or “value added”
services that can be
purchased from the service provider. The FAA requests comments on
alternatives for remote
identification services that would minimize cost to small entities.
253
C. International Trade Impact Assessment
The Trade Agreements Act of 1979 (Pub. L. 96-39), as amended by the
Uruguay Round
Agreements Act (Pub. L. 103-465), prohibits Federal agencies from
establishing standards or
engaging in related activities that create unnecessary obstacles to
the foreign commerce of the
United States. Pursuant to these Acts, the establishment of standards
is not considered an
unnecessary obstacle to the foreign commerce of the United States, so
long as the standard has a
legitimate domestic objective, such as the protection of safety, and
does not operate in a manner
that excludes imports that meet this objective. The statute also
requires consideration of
international standards and, where appropriate, that they be the basis
for U.S. standards.
The FAA has assessed the potential effect of this proposed rule and
determined that it
ensures the safety of the American public and does not exclude imports
that meet this objective.
As a result, this proposed rule is not considered as creating an
unnecessary obstacle to foreign
commerce.
The FAA has considered the ongoing work of international organizations
and other
countries. No international (e.g., ICAO) standards currently exist for
the types of operations the
FAA proposes in this rule. The FAA will maintain its awareness of
other countries’ and
international organizations’ work in developing potential standards
relevant to UAS operations.
D. Unfunded Mandates Assessment
Title II of the Unfunded Mandates Reform Act of 1995 (Pub. L. 104-4)
requires each
Federal agency to prepare a written statement assessing the effects of
any Federal mandate in a
proposed or final agency rule that may result in an expenditure of
$100 million or more (in 1995
dollars) in any one year by State, local, and tribal governments, in
the aggregate, or by the
254
private sector; such a mandate is deemed to be a “significant
regulatory action.” The FAA
currently uses an inflation-adjusted value of about $155 million in
lieu of $100 million.
Although this proposed rule is a significant regulatory action, it
does not contain a
mandate that would impose costs of more than $155 million annually. As
a result, the
requirements of Title II of the Act do not apply.
E. Paperwork Reduction Act
The Paperwork Reduction Act of 1995 (44 U.S.C. 3507(d)) requires that
the FAA
consider the impact of paperwork and other information collection
burdens imposed on the
public.
There are several new information collections that the FAA is
proposing as part of this
rule, as well as an existing information collection that is proposed
to be revised.
1. New Information collection: Additions to Small Unmanned Aircraft Registration
System
In this rule, the FAA is proposing to require that all persons
registering small unmanned
aircraft under part 48 include one or more telephone number(s) of the applicant, and the
manufacturer, model, and serial number of the unmanned aircraft as
part of the registration
information. This information would then be included on the
Certificate of Aircraft Registration.
The FAA recognizes that persons who currently register their small
unmanned aircraft
intending to use the small unmanned aircraft as other than a model
aircraft are already required
to provide the manufacturer, model, and serial number, if available,
under § 48.100(a). The FAA
proposes to require all persons who register their small unmanned
aircraft to include
manufacturer name, model name, serial number, and telephone number(s)
in the registration.
255
Thus, some persons who have previously registered small unmanned
aircraft, but did not include
telephone number, manufacturer, model, and serial number information,
would be required to
update the registration of that aircraft.
The FAA is also proposing to require all individuals intending to use
the small unmanned
aircraft exclusively as a model aircraft to include the telephone
number(s) of the applicant, and
the manufacturer, model, and serial number of each small unmanned
aircraft in the registration.
Requiring the telephone number(s), manufacturer, model, and serial
number would necessitate
amending the registration for all registered model aircraft.
Additionally, the FAA 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,
regardless of its intended use.181 This
means that every small unmanned aircraft registered under part 48
would need to have its own
Certificate of Aircraft Registration.
As has been discussed, the FAA recognizes that some small unmanned
aircraft would
already have serial numbers, while others would require the FAA to
assign serial numbers as part
of the process of amending the registration. Requiring owners of
unmanned aircraft to provide
their telephone numbers as part of the registration process would
assist FAA and law
enforcement to disseminate safety and security related information to
the registrant in near realtime.

181 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.
256
Therefore, the FAA is proposing a new information collection,
Additions to Small
Unmanned Aircraft Registration System, to reflect the additional
burden of adding the telephone
number, manufacturer, model, and serial number to each registration
and to reflect the burden of
having each unmanned aircraft registered separately.
Use: The FAA would use the telephone number, manufacturer, model, and
serial number
to assist with the remote identification of unmanned aircraft systems.
The serial number, which
may be transmitted as the unique identifier of an unmanned aircraft,
would help to identify the
aircraft and associate the aircraft with its owner. The FAA would use
the telephone number of
the owner to disseminate safety and security-related information to
the registrant.
Table 11: Small Unmanned Aircraft Registration – Limited Recreational Operations
Incremental Hourly Burden and Cost ($Mil.)
Year Registrations
Hourly
Burden
Total
Cost
($Mil.)
1 442,623 12,082 $0.17
2 335,236 8,040 $0.11
3 372,127 8,899 $0.13
Total 1,149,986 29,021 $0.41
Row and column totals may not sum due to rounding.
2. New Information Collection: Identification of Foreign-Registered
Civil
Unmanned Aircraft Operating in the Airspace of the United States
The FAA is proposing to extend the operational requirements of part 89
to persons
operating foreign civil unmanned aircraft in the United States. These
persons would have to
comply with the remote identification requirements, which means that
these persons would have
to operate foreign civil unmanned aircraft that qualify as standard
remote identification UAS,
257
limited remote identification UAS, or that have no remote
identification equipment but are
operated within an FAA-recognized identification area.
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. The notice would include the following information to
allow FAA to associate an
unmanned aircraft to a responsible person:
(1) The name of the operator and, for an operator other than an
individual, the name of
the authorized representative providing the notification.
(2) The physical address of the operator and, for an operator other
than an individual, the
physical address for the authorized representative. If the operator or authorized representative
does not receive mail at the physical address, a mailing address must
also be provided.
(3) The physical address of the operator in the United States.
(4) One or more telephone number(s) where the operator can be reached
while in the
United States.
(5) The email address of the operator or, for an operator other than
an individual, the
email address of the authorized representative.
(6) The aircraft manufacturer and model name.
(7) The serial number of the aircraft.
(8) The country of registration of the aircraft.
(9) The registration number of the aircraft.
258
Once a person submits a notice of identification, the FAA would issue
a confirmation of
identification. A person operating a foreign-registered unmanned
aircraft in the United States
would have to maintain the confirmation of identification at the UAS’
control station and would
have to produce it when requested by the FAA or a law enforcement
officer. The holder of a
confirmation of identification would have to ensure that the
information provided remains
accurate and is current prior to operating a foreign registered civil
unmanned aircraft system in
the United States.
Use: The FAA would use information provided by operators of
foreign-registered civil
unmanned aircraft operating in the airspace of the United States to
identify those aircraft.
Table 12: Notice of Identification (Unit Cost)
Year
Minutes to
Establish
Account182
Additional
Minutes Per
Aircraft
Total
Minutes
Part 107
Opportunity Cost
of Time
($1.55/Minute)183
Recreational Flyer
Opportunity Cost
of Time
($0.237/Minute)184
1 5 1 6 $9.30/notification $1.42/notification
2 5 1 6 $9.30/notification $1.42/notification
3 5 1 6 $9.30/notification $1.42/notification

182
https://www.faa.gov/news/updates/media/2015-12-13_2120-AK82_RIA.pdf.
See Page 13 of the Regulatory
Impact Analysis of the Interim Final Rule Regulatory Evaluation for
the Registration and Marking Requirements for
Small Unmanned Aircraft. RIN 2120-AK82.
183 The FAA estimates the wage earned by Part 107 operators to be
similar to that of a fully burdened wage
(compensation + benefits) of an FAA technical subject matter expert,
which is $92.72 per hour ($1.55 per minute).
184 Department of Transportation Departmental Guidance on Valuation of
Travel Time in Economic Analysis,
September 27, 2016. Table 4 Recommended Hourly Values of Travel Time
Savings, Page 17. In constant dollars,
the hourly value of time for personal travel is $14.21 per hour ($.237
per minute). This value is used as a proxy for
the value of time of someone operating UAS for recreational
operations.
259
3. New Information Collection: Remote Identification Means of
Compliance,
Declaration of Compliance, and Labeling Requirements
i. Means of Compliance
The FAA is proposing to require persons who develop standards that the
FAA may
accept as means of compliance for the production of UAS with remote identification to submit
those standards for review and acceptance by the FAA. The means of
compliance would include
requirements for producer demonstration of how the UAS with remote identification performs its
intended functions and meets the performance requirements by analysis,
ground test, or flight
test, as appropriate. A person who submits a means of compliance that
is accepted by the FAA
would be required to retain the following data for as long as the
means of compliance is accepted
and an additional 24 calendar months: all documentation and
substantiating data submitted for
the acceptance of the means of compliance; records of all test
procedures, methodology, and
other procedures, if applicable; and any other information necessary
to justify and substantiate
how the means of compliance enables compliance with the remote
identification requirements of
part 89.
Use: The FAA would use the means of compliance as a way for persons
responsible for
the production of standard remote identification UAS or limited remote identification UAS to
demonstrate compliance with the requirements for remote identification
of UAS.
Table 14: Means of Compliance
Hourly Burden and Cost
Year MOC
Submitted
Total
Pages
Hrs Per
Page
Total
Hrs
Cost Per
Hour Total Cost
1 1 12 1 12 $92.72 $1,112.64
2 1 12 1 12 $92.72 $1,112.64
3 1 12 1 12 $92.72 $1,112.64
260
Year MOC
Submitted
Total
Pages
Hrs Per
Page
Total
Hrs
Cost Per
Hour Total Cost
Total 3 36 3 36 $3,337.92
Row and column totals may not sum due to rounding.
ii. Declaration of Compliance
The FAA is proposing to require persons responsible for the production
of UAS with
remote identification to produce those UAS to meet the minimum
performance requirements of
the rule using an FAA-accepted means of compliance. To demonstrate
that a UAS has been
produced using an FAA-accepted means of compliance, producers would be
required to submit
to the FAA a declaration of compliance containing:
? The name, physical address, telephone number, and email address of
the person
responsible for production of the standard remote identification UAS
or limited remote
identification UAS.
? The UAS make and model.
? The UAS serial number, or the range of serial numbers for which the
person responsible
for production is declaring compliance.
? The means of compliance used in the design and production of the UAS
and whether the
UAS is a standard remote identification UAS or a limited remote
identification UAS.
? Whether the declaration of compliance is an initial declaration or
an amended
declaration, and if the declaration of compliance is an amended
declaration, the reason
for the amendment.
? A declaration that the person responsible for the production of the
UAS:
261
o Can demonstrate that the UAS was designed and produced to meet the
minimum
performance requirements of standard remote identification UAS or
limited
remote identification UAS by using an FAA-accepted means of
compliance.
o Will, upon request, allow the Administrator to inspect its
facilities, technical data,
and any UAS produced with remote identification, and to witness any
tests
necessary to determine compliance with part 89, subpart D.
o Will perform independent audits on a recurring basis, and whenever
the FAA
provides notice of noncompliance or of potential noncompliance, to
demonstrate
compliance with the requirements of subpart F of part 89, and will
provide the
results of those audits to the FAA upon request.
o Will maintain product support and notification procedures to notify
the public and
the FAA of any defect or condition that causes the UAS to no longer
meet the
requirements of subpart F of part 89, within 15 calendar days of the
date the
person becomes aware of the defect or condition.
A person who submits a declaration of compliance that is accepted by
the FAA would be
required to retain the following data for 24 calendar months after the cessation of production of
the UAS with remote identification: the means of compliance, all
documentation, and
substantiating data related to the means of compliance used; records
of all test results; and any
other information necessary to demonstrate compliance with the means
of compliance so that the
UAS meets the remote identification requirements of part 89.
Use: The FAA would use the declaration of compliance to determine that
the person
responsible for the production of standard remote identification UAS
or limited remote
262
identification UAS has demonstrated compliance with the requirements
for remote identification
of UAS.
Table 13: Declaration of Compliance
Hourly Burden and Cost ($Mil)
Year DoC
Submitted
Pages
Per
DoC
Hours Per Page Hourly Burden Cost Per
Hour Total Cost
1
2 1,155 50 1 hour 57,750 $82.93 $4.79
3 19 50 1 hour 945 $82.93 $0.08
Total 1,174 58,695 $82.93 $4.87
Row and column totals may not sum due to rounding.
iii. Labeling
For standard remote identification UAS and limited remote
identification UAS, the
proposed rule would require the person responsible for production of
the UAS to label the
unmanned aircraft to show that it was produced with remote
identification technology that meets
the requirements of the proposed rule and to indicate whether it is a
standard remote
identification UAS or a limited remote identification UAS. The label
would be in English and be
legible, prominent, and permanently affixed to the unmanned aircraft.
The proposed labeling
requirement would assist the operator to know that his or her UAS is
eligible to conduct
operations within the airspace of the United States.
Use: The proposed labeling requirement would assist the FAA and owners
and operators
of UAS to determine if the UAS meets the remote identification
requirements of the proposed
rule.
Table 14: Labeling Requirement
Hourly Burden and Cost ($Mil.)
Year Number of
Platforms
Hours Per
Design
Hourly
Burden
Cost
Per
Hour
Total
Cost
263
1
2 1,100 2 2,200 $82.93 $0.182
3 18 2 36 $82.93 $0.003
Total 1,118 2,236 $0.185
Row and column totals may not sum due to rounding.
4. New Information Collection: UAS Remote Identification Message
Elements
The FAA is proposing that 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 Identification UAS Service
Suppliers (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. 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.
Under this proposed rule, no person would be able to operate a UAS
required to have
remote identification within the airspace of the United States unless
the UAS is capable of
connecting to the internet and transmitting certain remote
identification message elements
throughout the operation. Persons operating UAS would comply with
remote identification in
one of three ways. First, standard remote identification UAS would
connect to the internet and
transmit remote identification message elements through that internet connection to a Remote ID
USS and broadcast those message elements directly from the unmanned
aircraft. These message
elements would include the UAS Identification (either the unmanned
aircraft’s serial number or
session ID), latitude, longitude, and barometric pressure altitude of
both the control station and
the unmanned aircraft, a time mark, and an emergency status code that
would transmit only when
264
applicable. A standard remote identification UAS that could no longer
broadcast the message
elements would have to land as soon as practicable.
Second, limited remote identification UAS would be required to connect
to the internet
and transmit similar remote identification message elements through
that internet connection to a
Remote ID USS. If the connection to the internet were unavailable or
if the UAS could no longer
transmit remote identification message elements to a Remote ID USS,
the unmanned aircraft
would not be able to take off. Limited remote identification UAS would
be designed and
produced to operate no more than 400 feet from the control station,
cannot broadcast remote
identification message elements, and would have to be operated within
visual line of sight.
The third way to comply with the UAS remote identification
requirements would be to
operate a UAS without remote identification at an FAA-Recognized
Identification Area. Because
these types of operations do not involve any information exchanges
with a Remote ID USS, they
were not considered as part of this information collection.
Use: The remote identification message elements would be sent from the
UAS to the
Remote ID USS over the internet. The Remote ID USS would, in turn,
transmit the information
collected to the FAA as required. To implement remote identification,
the FAA anticipates
establishing a cooperative data exchange mechanism between the FAA and
Remote ID USS.
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 UAS to 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 owner of the unmanned aircraft or the location
of the UAS is required. At
this time, it is unknown how often exchanges between the FAA and
Remote ID USS would
265
occur. The following table shows the number of estimated respondents
that would transmit
messages through the internet to a Remote ID USS and the number of
Remote ID USS that
would exchange data with the FAA.
Table 15: Transmit USS Message Elements
Year Remote ID
Respondents
Remote ID
USS
Respondents
1
2 422,498 10
3 972,258 11
Total 1,394,756 26
5. New Information Collection: Application for FAA-Recognized
Identification
Areas
The FAA is proposing that community- based organization (CBO)
representatives
submitting applications for flying sites to become FAA-recognized identification areas may
apply for such establishment in a form and manner acceptable to the
FAA. The application
would collect certain information regarding the location of the flying
site, and require the CBO
representative to confirm certain information regarding the site.
An applicant for an FAA-recognized identification area would be
required to submit: (1)
the name of the CBO making the request; (2) a declaration that the
person making the request
has the authority to act on behalf of the CBO; (3) the name and
contact information, including
telephone number, of the primary point of contact for communications
with the FAA; (4) the
physical address of the proposed FAA-recognized identification area;
(5) the latitude and
longitude coordinates delineating the geographic boundaries of the
proposed FAA-recognized
266
identification area, and (6) if applicable, a copy of any existing
letter of agreement regarding the
flying site.
Use: Applications would permit CBOs recognized by the Administrator to
apply for
FAA-recognized identification area status.
Table 16: CBO Request for FAA-Recognized Identification Area Hourly
Burden and Cost
($Mil)
Year
Requests
Submitted
Pages Per
Request
Total
Pages
Hrs Per
Page
Total
Hours
Hourly
Burden Total Cost
1 2,500 4 10,000 0.5 5000 $58.12 $0.29
2
3
Total 2,500 10,000 5,000 $0.29
Row and column totals may not sum due to rounding.
6. Requirements for which Information Collections are not Proposed
i. Existing Information Collection 2120-0042: Aircraft Registration
While the FAA is proposing to clarify in new § 47.14 that all unmanned
aircraft
registering under part 47 must include a serial number as part of the registration, the FAA is not
proposing to revise existing information collection 2120-0042,
Aircraft Registration. The
inclusion of a serial number in registrations under part 47 has always
been required and a
revision to this information collection is not necessary.
ii. Existing Information Collection 2120-0021: Certification: Pilots
and Flight
Instructors
While the FAA is proposing to require that new questions regarding
remote identification
of UAS be included on the initial and recurrent aeronautical knowledge
tests described in
§ 107.73, and that new training be included in the initial and
recurrent training described in
267
§ 107.74, for persons seeking a remote pilot certificate with a small
UAS rating, the FAA does
not believe that the addition of these questions would necessitate
further time on the part of
applicants to complete the test or training. Therefore, the FAA is not proposing to revise existing
information collection 2120-0021, Certification: Pilots and Flight
Instructors.
iii. Remote ID USS
While the FAA envisions the use of Remote ID USS for the transmission
of UAS remote
identification information, the FAA is still developing the concepts
and requirements for those
USS. Because the FAA is uncertain at this time regarding the
requirements for application by
persons to be Remote ID USS, the FAA is not proposing here to
establish an information
collection for Remote ID USS.
Individuals and organizations may send comments on the information
collection
requirement to the address listed in the ADDRESSES section at the
beginning of this preamble
by [INSERT DATE 60 DAYS AFTER DATE OF PUBLICATION IN THE FEDERAL
REGISTER]. Comments may also be submitted to the Office of Management
and Budget, Office
of Information and Regulatory Affairs, Attention: Desk Officer for
FAA, New Executive Office
Building, Room 10202, 725 17th Street, NW, Washington, DC 20053.
F. International Compatibility and Cooperation
In keeping with U.S. obligations under the Convention on International
Civil Aviation, it
is FAA policy to conform to International Civil Aviation Organization
Standards and
Recommended Practices to the maximum extent practicable. The FAA has
reviewed the
corresponding ICAO Standards and Recommended Practices and has
identified no differences
with these regulations. Additionally, the FAA regularly reaches out to
its international partners
268
on a bilateral and multilateral basis to harmonize regulations to the
maximum extent possible.
The FAA’s international outreach efforts include the following:
? Discussions with the Switzerland Federal Office of Civil Aviation
(FOCA) regarding
plans for use of remote identification to facilitate U-Space185
operations and plans to
allow multiple UAS Service Suppliers to serve a range of U-Space
operators in concept
similar to current and future FAA USS plans;
? Collaboration with the European Aviation Safety Agency (EASA) on the
EASA U-Space

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