FPVFC Responses to FAA Requested Comments
Throughout the NPRM, the FAA has asked a series of questions where they are looking for advice. The following is the FPVFC’s answers to those specific questions.
Section IX. Changes to Registration Requirements, E. Request for Comments Regarding Serial Number Requirements
The FAA understands that some UAS may not have ANSI/CTA-2063-A compliant serial numbers. The FAA would like comments on whether it should require owners of UAS without remote identification to obtain an ANSI/CTA-2063-A compliant serial number and to list it in the Certificate of Aircraft Registration or the Certificate of Identification.
The FAA also welcomes comments on whether the Agency should issue ANSI/CTA-2063 compliant serial numbers to such aircraft when registered or re-registered by their owners.
The FAA also seeks specific comments on whether UAS producers should be required to affix the serial number to the exterior of all standard remote identification UAS. Please explain why or why not and provide data to support your response.
Initial FPVFC response: The FPVFC proposes a model where an electronic serial number module may be moved from one sUAS to another. One serial number for each recreational UAS is not required. The FPVFC proposes the current situation where a pilot registers himself or herself for all his or her recreational UAS and then affixes this same registration number on all his or her UAS should suffice for Remote ID UAS used for recreational purposes.
Section X. Operating Requirements for Remote Identification, C. Internet Availability and Transmission to a Remote ID USS
The FAA seeks public comment on whether there are ways to address this extremely unlikely situation where all Remote ID USS become unavailable at the same time but the internet remains available (this situation would mean no Standard or Limited Remote Identification UAS would be able to take off within the framework of the rule as proposed.
Initial FPVFC response: For Recreational flight ops, a connection to the Internet via a smart device and then submission of flight authorization through LAANC should suffice. This explicitly means for Limited Remote ID, there would be no requirement to electronically prevent the UAS from taking off if connection with a Remote USS is not possible. And, there would be no Internet connection during flight for a recreational flight.
(XII. D. 2) XII. Means of Compliance, D. Minimum Performance Requirements, 2. Automatic Remote ID USS Connection from power up to shutdown rather than takeoff to landing
Standard and Remote ID require Internet connection from takeoff to landing. The FAA welcomes comments on whether the connection should be required from takeoff to landing or whether it should be required from start up to shut down.
Initial FPVFC Response: The requirement should be that connectivity is required from takeoff to landing (at most). There would be no safety benefit from extending this requirement to power up to shutdown. If a connection with a Remote USS is required for take-off, there is no apparent benefit from connecting prior to takeoff.
(XII. D. 9) XII. Means of Compliance, D. Minimum Performance Requirements, Section 9. Message Transmission
The FAA has not required proposed any requirements on how a Standard or Limited Remote ID UAS connects to the Internet or if that transmission of Remote ID elements by come from the control station or the unmanned aircraft. The FAA understands, however, that there are concerns about the impact that connecting to the internet directly from the unmanned aircraft (as opposed to the control station) could have on networks that use radio frequency spectrum, including interference, network stability, or other effects. The FAA seeks comments on these potential effects, recognizing that issues of interference or other impacts to communications networks are independently reviewed by the FCC. The FAA requests that comments indicate any drawbacks or impacts to users or license holders of either licensed or unlicensed spectrum. Additionally, the FAA seeks feedback regarding whether any existing UAS are capable of connecting to the Internet from the unmanned aircraft, and if so, what methods are used for those connections.
Initial FPVFC Response: As the WiFi network which is proposed for use by Remote ID is terrestrial and not aeronautical, the infrastructure is not aimed to the sky. For the reason that better signals are likely at or near the ground level, the FPVFC proposes the Internet connection not be required to be from the UAS.
(XII.D.11) XII. Means of Compliance, D. Minimum Performance Requirements, 11. Message Elements Performance Requirements
As proposed in § 89.310(j) for standard remote identification UAS and § 89.320(j) for limited remote identification UAS, the FAA would require that all UAS with remote identification meet certain minimum requirements regarding the transmission of the message elements including the minimum performance requirements related to positional accuracy, barometric pressure, message latency, and message transmission rate. The FAA invites comments on whether the parameters for the message elements performance requirements proposed in § 89.310(j) and § 89.320(j) are appropriate and requests commenters submit specifics, supported by data, to sustain their position.
Initial FPVFC Response: The FPVFC does not understand why altitude, message latency and transmission rate are required. Location and signal strength should suffice to maximize the UAS remains in connection with the ground station (and consequently, the Remote USS).
XII. Means of Compliance, E. Other Performance Requirements Considered
The FAA considered imposing additional performance requirements as part of an acceptable means of compliance; however, the FAA believes that the current proposal reflects the minimum requirements necessary to achieve the intent of the proposed rule. Regardless, the FAA acknowledges that imposing additional requirements could add value to the remote identification of UAS and further integration into the National Airspace System. The FAA welcomes comments on whether the final rule should incorporate additional performance requirements, including but not limited to any of the ones addressed in this section.
Initial FPVFC Response: Any additional performance requirements should be linked to mission operations. For example, for BVLOS, additional sensors and communication of that sensor data to the control station would improve safety such as ADS-B in to alert the operator at the control station of manned aircraft.
XII. Means of Compliance, E. Other Performance requirements
The FAA considered several potential requirements that it ultimately decided were not necessary to include in the proposed minimum performance requirements. The FAA considered but chose not to propose the following:
Other message elements such as certain UAS operator contact information or other aircraft or control station information such as velocity, direction, route, or altitude above ground level;
Initial FPVFC Response: Absolutely no operator contact information. This creates privacy issues for the operator in addition to physical safety risks for the operator. With respect to velocity, direction, route and AGL, with the required lat/lon and requirement to submit a flight plan, this data can be calculated at the control station and would be a redundant requirement to transmit this. None of this data needs to be transmitted to the Remote USS.
Equipment interface requirements such as the appropriate connections between GPS receivers, altimeters, and the remote identification message compiler, the communication protocol between the aircraft and the control station through which remote identification message data is exchanged, or protocols and interfaces between UAS, internet providers, and Remote ID USS;
Initial FPVFC Response: An emphatic yes, but with real-time encryption. Any standards for protocols improve safety as no translators are required from device to device. In addition, standard protocols lowers development and maintenance costs of software of the transceiver equipment.
Flight data recording features to store remote identification information within the UAS; Requirements for connection indications such as a separate indication of whether the UAS is connected to the internet and its connection to a specific Remote ID USS, an indication of the transmission latency, or a notification of the specific Remote ID USS to which the UAS is connected; or
Initial FPVFC Response: This should be linked to mission operations and should not be required for recreational UAS.
Transmission or broadcast requirements during a command and control lost-link event.
Initial FPVFC Response. No additional requirements should be proposed. The current requirements for Standard and Limited to land as soon as is practicable places responsibility on the remote operator as it should be.
Although the FAA is not proposing these features in the minimum performance requirements, the FAA requests comments on whether and why any should be required.
(XII.A) XIII. Design and Production Requirements, A. Applicability of Summary Requirements. Comments on UAS Kits
The FAA requests comments about whether persons should be allowed to produce kits for sale that contain 100 percent of the parts and the instructions for assembly necessary to build a fully functioning UAS without remote identification capability. Once assembled, such UAS without remote identification would be required to either have the unmanned aircraft weigh less than 0.55 pounds or operate only within an FAA-recognized identification area.
Initial FPVFC Response: This is a critically important topic. We propose that amateur-built UAS with less than 100% components procured from one vendor should be allowed to fly as Standard or Limited Remote ID UAS. This could be achieved with excellent safety results by requiring only specific components or sub-assemblies to be procured from FAA approved producers. Further, these sub-assemblies or modules could contain the ANSI/CTA-2063-A serial numbers. And, for Limited and Standard Remote ID UAS, a single module should be allowed to be plugged into all of the owner’s UAS. This would achieve the safety requirements of associating individual serial numbers with operators. There is not a need for UAS to have the same rigor of Sub-part F for all the components of a remote UAS below 55 pounds.
XVII. Proposed Effective and Compliance Dates. Waivers required for operations over people or nighttime operations?
The FAA is seeking comments about whether certain UAS operations currently conducted under waiver, such as operations over people or nighttime operations, should be required to comply with remote identification prior to being authorized under a waiver or regulation. For example, should the FAA require UAS to comply with remote identification as a condition precedent to granting a nighttime waiver or authorizing operations over people?
Initial FPVFC response: As proposed by the DAC Remote equipage team, no waiver should be required for an operator to fly a standard or Limited Remote ID UAS over people or at night. This would provide an important incentive for UAS operators to comply early with Remote ID.
XVII. Proposed Effective and Compliance Dates. Incentives for early compliance
The FAA believes that early compliance may benefit both industry and UAS operators and encourages regulated parties to implement remote identification of UAS sooner than the compliance dates established in this proposed rule. The FAA invites comments providing specific proposals and ideas on how to build an early compliance framework into the regulation. The agency is interested in comments related to how an early compliance framework would work and how it would fit into the overarching remote identification framework proposed by the FAA.
The FAA would also consider providing incentives that the FAA can reasonably provide to parties that adopt remote identification as early as possible. The FAA invites comments on possible incentives for early compliance.
Initial FPVFC Response: As proposed in the DAC Remote ID equipage proposal, incentives could include:
Contract Preference for Federal contracts
Part 107 waiver application prioritization
FAA publicly accessible database of FAA approved producers of Standard and Limited Remote ID UAS
Airspace access which would otherwise be a restricted area (e.g. National Parks on established dates)
Insurance incentives - reduced cost to operators
State and local government incentives to provide additional takeoff and landing locations and relief from other restrictions
Industry Recognition - common logos, certifications, etc.
(XIX.A.1) XIX. Regulatory Notices and Analysis, A. Regulatory Examination, 1. Key Assumptions and Data Sources, A. Retrofits Retrofits to meet proposed remote identification requirements
The FAA requests comments on the capability of retrofits to meet the proposed remote identification requirements. Specifically, the FAA requests information and data from producers of affected UAS in response to the following questions that can be used to inform this analysis. Please provide references and sources for information and data.
As a producer of UAS affected by this proposal, would you be able to retrofit your current UAS models to comply with the proposed rule given the availability of FAA accepted means of compliance?
Initial FPVFC Response: We estimate there are approximately 150,000 recreational UAS operators flying FPV in the U.S. Virtually all of these owner / operators build their own equipment. From anecdotal experience the FPVFC operators do not know any FPV operator with fewer than 10 FPV UAS which are also unequipped. None of this fleet of approximately 1.5 million UAS are capable of a firmware upgrade to become Standard or Limited Remote ID UAS compliant.
Initial FPVFC Response: IF, the proposed rule would allow for additional hardware, which would include a serial number as well as the required communication device (transponder for Standard Remote ID UAS) to be added to existing, non-equipped UAS, a high percentage of the existing FPV UAS fleet, estimated above at 1.5 million units could be retrofitted.
Do you have information that would assist in the early development of means of compliance that would be available for retrofits for the following scenarios a) before the effective date of the final rule, which is 60 days after the publication date of the final rule, and b) within one year after the effective date of the final rule?
Would it be possible to retrofit by a software or firmware update through an internet download?
Initial FPVFC Response: For the fleet of 1.5 million FPV UAS described above, the answer is an emphatic no. Additional hardware would be required.
How would a retrofit solution meet the proposed tamper resistance and labeling requirements? Would a software push be able to meet requirements for tamper resistance or would it require hardware? How would you meet labeling requirements under a retrofit scenario (e.g., would you mail the label)?
Initial FPVFC Response: As a hardware retrofit would be required, tamper-proofing could be created in firmware which would be burned in along with the serial number.
Would retrofits meet the limited or standard remote identification requirements?
Initial FPVFC Response. A retrofit would comply if the amateur-built limitations of 100% single-producer built are waived.
What are the costs of retrofits to the producer and the owner/operator?
In lieu of a software push through the internet, what other methods could producers use to facilitate retrofits (e.g., mail-in programs or physical retrofit drop-off locations)?
Initial FPVFC Response: For the FPV Fleet described here, there would only be replacement hardware after a consolidation of the transponder/serial number module were combined with other UAS components (e.g. Video transmitter, Flight Controller, C2 receiver)
If retrofits are not an option for certain makes and models, would you offer operators “buy-back” or “trade-in” incentives to replace UAS without remote identification equipment? If so, please describe the incentive and the process.
The FAA also solicits comments on the capability of producers of UAS weighing greater than 55 pounds to retrofit aircraft to be compliant with remote identification requirements.
Comments Invited (Tips)
The FAA invites interested persons to participate in this rule-making by submitting written comments, data, or views. The agency also invites comments relating to the economic, environmental, energy, or federalism impacts that might result from adopting the proposals in this document. The most helpful comments reference a specific portion of the proposal, explain the reason for any recommended change, and include supporting data. To ensure the docket does not contain duplicate comments, commenters should send only one copy of written comments, or if comments are filed electronically, commenters should submit only one time. The FAA will file in the docket all comments it receives. Before acting on this proposal, the FAA will consider all comments it receives on or before the closing date for comments. The agency may change this proposal in light of the comments it receives.
Standards and work FAA should incorporate and adopt principles of:
ASTM WK65041 Remote ID and Tracking Overview
ARC - UAS Identification and Tracking Aviation Rulemaking Committee Sept. 2017
DAC Remote ID equipage input, approved by DAC for FAA submission on Oct. 17, 2019
ANSI/CTA-2063-A UAS Serial number
