[continued from previous message]

persons operating UAS at FAArecognized identification areas under §
89.120.
187
XIX. Regulatory Notices and Analyses
Changes to Federal regulations must undergo several economic analyses.
First, Executive
Order 12866 and Executive Order 13563 direct that each Federal agency
shall propose or adopt a
regulation only upon a reasoned determination that the benefits of the
intended regulation justify
its costs. Second, the Regulatory Flexibility Act of 1980 (Pub. L.
96-354) requires agencies to
analyze the economic impact of regulatory changes on small entities.
Third, the Trade
Agreements Act of 1979 (Pub. L. 96-39) prohibits agencies from setting standards that create
unnecessary obstacles to the foreign commerce of the United States. In developing U.S.
standards, this Trade Act requires agencies to consider international
standards and, where
appropriate, that they be the basis of U.S. standards. Fourth, the
Unfunded Mandates Reform Act
of 1995 (Pub. L. 104-4) requires agencies to prepare a written
assessment of the costs, benefits,
and other effects of proposed or final rules that include a Federal
mandate likely to result in the
expenditure by State, local, or tribal governments, in the aggregate,
or by the private sector, of
$100 million or more annually (adjusted for inflation with base year
of 1995). The FAA has
provided a more detailed Preliminary Regulatory Impact Analysis of
this proposed rule in the
docket of this rulemaking. This portion of the preamble summarizes
this analysis.
In conducting these analyses, the FAA has determined that this
proposed rule: (1) has
benefits that justify its costs; (2) is not an economically
“significant regulatory action” as defined
in section 3(f) of Executive Order 12866; (3) will have a significant
economic impact on a
substantial number of small entities; (4) will not create unnecessary
obstacles to the foreign
commerce of the United States; and (5) will not impose an unfunded
mandate on state, local, or
tribal governments, or on the private sector by exceeding the
threshold identified above.
188
A. Regulatory Evaluation
1. Key Assumptions and Data Sources
The FAA’s analysis of the proposed rule is based on findings from the
Unmanned
Aircraft Systems Identification and Tracking Aviation Rulemaking
Committee (UAS-ID ARC),
as well as data and information from the FAA and industry
stakeholders. The analysis for the
regulatory evaluation is based on the following assumptions and data
sources:
A. Retrofits
An important assumption used in this analysis involves the
availability of retrofits. Based
on information from UAS producers81, part of the existing fleet of UAS
could be retrofit to
comply with remote identification requirements with relative ease and
minimal cost (e.g., by a
software update or “push” through the internet) and this could be
achieved within the first year
after the effective date of the final rule given the availability of FAA-accepted means of
compliance.82 This would enable early compliance with remote
identification for persons
operating a portion of the existing UAS fleet and those UAS purchased
during the proposal’s 24-
month period before compliance with production requirements.
Based on industry information and market research, the FAA estimates
at least 93% of
the current part 107 fleet and at least 20% of the current
recreational fleet would be eligible for

81 The FAA received information from industry on the potential to
retrofit during Executive Order 12866 meetings
from September through December, 2019. Information from these meetings
will be available in the docket of this
rulemaking. Under Executive Order 12866, OIRA meets on regulatory
actions with any interested party to discuss
issues on a rule under review. Under OIRA procedures, the OIRA
Administrator or his/her designee meets with
outside parties during a review and the subject, date, and
participants of the meeting are publicly disclosed on
Reginfo.gov along with any written materials received from outside
parties on rules under review
(https://reginfo.gov/public/do/eo/neweomeeting).
82 Producers of UAS with Remote ID, including those that retrofit,
would be required to meet proposed performance
standards using an FAA-accepted means of compliance for remote
identification.
189
retrofits, thus minimizing the costs for operators and producers.83
This is based on industry
information suggesting that small UAS at a certain level of design specification and operational
capability would likely have system and connectivity capabilities that
could be retrofit through a
software update.
The FAA reviewed UAS registered to part 107 operators and found 93% of
the existing
part 107 UAS fleet may have technical capabilities to be retrofit
based on information received
by industry (i.e., could support software updates through internet).84
The FAA identified the top10 registered aircraft by producer and
researched registered model specifications online. The
FAA found each of the registered models within this group had internet
and Wi-Fi connectivity,
ability to transmit data, receive software uploads, and had radio
frequency transceivers, among
other technology such as advanced microprocessors. Figure 1 provides
the breakdown of
manufacturers of registered part 107 UAS that could retrofit
representing 93% of part 107
registered UAS fleet.
Figure 1. Part 107 Unmanned Aircraft Registrations by
Manufacturer
Producer/Manufacturer
UAS
Registrations
% Share of
Total
Cumulative
% Share

83 Assuming retrofits can be made under an FAA-accepted means of
compliance, some producers would not need to
delay compliance. Retrofits may indicate producers need less
modification of existing UAS models to comply with
the proposal. In addition, the availability of retrofits would
minimize impacts for some operators of UAS purchased
without remote identification equipment who would otherwise need to
upgrade or buy a new UAS equipped for
Remote ID, especially those operated under part 107 for commercial
purposes that would not receive any
commercial value or benefit from operating at an FAA-recognized
identification area.
84 This is 93% of the part 107 “consumer” grade aircraft could be
retrofit. Additionally, the FAA assumes the entire
fleet of part 107 “professional” grade UAS could be retrofit.
190
-- Part 107
DJI 252,678 78.1% 78.1%
Intel 13,147 4.1% 82.2%
Yuneec 9,725 3.0% 85.2%
Parrot 7,928 2.5% 87.7%
GoPro 5,980 1.8% 89.5%
3dr 4,687 1.4% 91.0%
Holy Stone 2,580 0.8% 91.8%
Autel 2,677 0.8% 92.6%
Hubsan 1,278 0.4% 93.0%
Kespry 1,143 0.4% 93.3%
Source: FAA, Part 107 UAS Registrations, October 2019 point-in-time
count.

The FAA has limited information on the manufacturers and types of UAS
in the
recreation fleet because part 48 registration currently allows limited recreational flyers to register
multiple small unmanned aircraft under a single Certificate of
Aircraft Registration. However,
published market information finds 36% of the North America fleet is manufactured by one
producer (DJI)
85 that provided information to the FAA suggesting they could
retrofit. The FAA
estimates that about 20% of the recreational fleet is comprised of
aircraft manufactured by DJI
that could be retrofit. This estimate was developed by multiplying the
combined part 107 and
recreational unmanned aircraft fleet by 36%, and then subtracting DJI
aircraft registered under
part 107.
86

85 Source: 2017 Skylogic Research, a firm tracking the drone industry
found 36% of the units sold in North America
in the $500 to $1000 range are manufactured by DJI ( https://www.vox.com/2017/4/14/14690576/drone-marketshare-growth-charts-dji-forecast).
For purposes of this analysis, the 36 percent is used as a proxy for
the share of DJI
units in the U.S. fleet.
86 The FAA made the following calculations to estimate the portion of
the modeler fleet that are DJI: (i) Multiplied
the year 1 combined UAS sales forecast developed for the proposed rule
by 36 percent to estimate the number of
DJI units sold for recreational and part 107 purposes during year 1;
(ii) Multiplied the year 1 part 107 sales forecast
by 71% to estimate portion of part 107 sales that were DJI; and, (iii) Subtracted “b” from “a” to estimate year 1
191
Therefore, the FAA assumes UAS purchased in year 1 that are retrofit
would allow the
aircraft to “continue flying” under the limited or standard remote identification requirements
after the compliance date of the final rule. UAS sold in year 1 that
could not be retrofit would
likely not meet the limited or standard remote identification
requirements after year 3. Persons
that own unmanned aircraft in this group of “legacy” UAS without
remote identification
equipment would have potential “loss of use” associated impacts since
this proposal does not
include grandfathering.
87 The retrofit assumptions above were used in this analysis to
estimate
the effects of retrofits on the costs of the proposal and its
compliance period.
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 FAAaccepted means of compliance?
? 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 effective date of the final rule?

recreational sales of DJI units. Based on these calculations, DJI
recreational units sold in year 1 accounted for about
20% of the recreational units sold in year 1.
87 Persons operating UAS without remote identification equipment would
always be required to operate within
visual line of sight and within an FAA-recognized identification area.
Persons operating UAS without remote
identification equipment would need to travel and incur costs of
operating within an FAA-recognized identification
area.
192
? Would it be possible to retrofit by a software or firmware update
through an internet
download?
? How would a retrofit solution meet the proposed tamper resistance
and labelling
requirements? Would a software push be able to meet requirements for
tamper resistance
or would it require hardware? How would you meet labelling
requirements under a
retrofit scenario (e.g., would you mail the label)?
? Would retrofits meet the limited or standard remote identification requirements?
? 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)?
? 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.
B. Period of Analysis & Valuation of Impacts
? The analysis uses 2019 constant dollars. Year 1 of the period of
analysis, which would
correlate with the effective date of the final rule, is used as the
base year.
193
? The FAA uses a ten-year time period of analysis to capture the
effects of the proposed
compliance period and recurring effects of the proposed rule.
88
? The analysis includes the proposed two-year phase-in period for
compliance by persons
responsible for the production of UAS from the effective date of the
rule. Operators have
one additional year beyond this compliance date to comply with the
provisions of the
final rule.
? The FAA uses a three percent and seven percent discount rate to
quantify present value
costs and cost savings as prescribed by OMB in Circular A-4.89
C. Affected UAS Fleet/Characteristics
? The analysis of costs and cost savings of this proposed rule are
based on the fleet forecast
for small unmanned aircraft as published in the FAA Aerospace Forecast 2019-2039.
90
The forecast includes base, low, and high scenarios. The analysis
provides a range of net
impacts from low to high based on these forecast scenarios. The FAA
considers the
primary estimate of net impacts of the proposed rule to be the base
scenario.
? Based on the FAA fleet forecast for small unmanned aircraft, the FAA estimates the
average number of aircraft owned by each part 107 operator to be 2.4
and the average
number owned by each recreational flyer to be 1.4 aircraft. The FAA
assumes the average
lifespan for unmanned aircraft operated by these two groups is three
years based on FAA

88 The FAA typically uses a five-year time period for Regulatory
Impact Analysis of UAS rulemakings to align with
historical and current FAA UAS Forecasts (see https://www.faa.gov/data_research/aviation/aerospace_forecasts/media/Unmanned_Aircraft_Systems.pdf).
In
addition, the FAA acknowledges uncertainty in estimating incremental
impacts of this proposed rule beyond five
years due to rapid changes in UAS technology and innovation.
89 OMB Circular A-4, Regulatory Analysis (2003), https://www.whitehouse.gov/sites/whitehouse.gov/files/omb/circulars/A4/a-4.pdf. 90 FAA Aerospace Forecast Fiscal Years 2019-2039 at 30-33, available
at http://www.faa.gov/data_research/aviation/aerospace_forecasts/media/FY2019-39_FAA_Aerospace_Forecast.pdf
194
research related to the its annual aerospace forecast, UAS
registration information,
information from recreational and model unmanned aircraft owners, and
a review of
literature.91
? The FAA assumes members of a nationwide community based organization
own, on
average, two aircraft92, which may have an average lifespan that
exceeds ten years. As a
result, members of a nationwide community-based organization may not
incur the same
pattern of maintenance and replacement costs as other recreational
flyers.93
D. Producers (Manufacturers)
? Based on the FAA part 48 unmanned aircraft registry, the FAA
estimates that 83 percent
of small unmanned aircraft sold in the United States are produced by
foreign entities.

91 A review of articles and papers further supports an average
three-year lifespan for a small UAS. The review found
life expectancy is influenced by many factors, such as flight
conditions, frequency of use, and quality of
maintenance. Lifespan is also affected by rapid advances in
technology, which can result in “planned obsolescence”
of older UAS models due to manufacturers advancing new capabilities
that drive consumer satisfaction and demand
at additional costs. UAS lifespan is expected to last similar to other
consumer electronics within the same price
range. In the United States, smart phones are replaced after 32
months, on average, while laptops have an average
lifespan of 2-4 years (see the 2018 NPD Mobile Connectivity Report; https://www.npd.com/wps/portal/npd/us/news/press-releases/2018/the-average-upgrade-cycle-of-a-smartphone-inthe-u-s--is-32-months---according-to-npd-connected-intelligence/).
Other information published by the European
Union Aviation Safety Agency (“EASA”; https://www.easa.europa.eu/sites/default/files/dfu/GTF%20- %20Report_Issue2.pdf#page=93&zoom=100,0,13. p.47), the Civil Aviation
Authority of Israel (https://en.globes.co.il/en/article-proposals-drawn-up-for-regulating-drones-in-israel-1001270656),
and academia
(see for example, http://eng.fau.edu/research/fmri/pdf/Y1R1-17_Final_figliozzi.pdf, p.
34), suggests the range is
probably one year to three years, with EASA suggesting a span of one
to four years.
92 The FAA has heard that the Academy of Model Aeronautics (AMA) has a membership of about 200,000 and each
member has nine aircraft on average. This would equate to a 1,800,000
AMA Fleet. The FAA plans to reach out to
the AMA to confirm the average number of unique aircraft owned by its
members (i.e., an estimate adjusted for
double-counting of shared aircraft that includes operational aircraft
weighing more than 0.55 pounds)
93 Based on research of ownership trends and discussions with UAS
enthusiasts, the FAA assumes that CBO
members spend more money to purchase or build their model aircraft and
to maintain their aircraft such that the
aircraft last much longer than that of the “average” recreational
flyer. Additionally, members of CBOs are expected
to own more model aircraft, on average, compared to other recreational
flyers.
195
? Each UAS producer will incur an estimated one-time cost of $313 for
the purchase of a
remote identification standard from a consensus standards body.94
? The FAA estimates that potentially as many as 157 U.S. and 324
foreign producers would
submit a declaration of compliance for 313 U.S. and 787 foreign models
of UAS for FAA
acceptance by year 1 or 2 of the analysis period depending on their
ability to retrofit.
95
During each of the remaining years of the analysis period, the FAA
assumes an additional
nine new producers would submit a declaration of compliance annually
for one model of
unmanned aircraft each, and nine new models will be produced by
preexisting producers,
for a total of eighteen new models of UAS annually.
96
? The FAA assumes that five percent of the declarations of compliance
submitted by
persons responsible for the production of standard remote
identification UAS and limited
remote identification UAS to the FAA would not be accepted. The
declaration of
compliance would then be rewritten and resubmitted to the FAA for
acceptance, and the
FAA would accept the resubmission.
? Producers 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 proposed part 89.
E. Remote ID USS

94 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.
95 Based on analysis of the Association for Unmanned Vehicle Systems International (AUVSI) Unmanned Systems
& Robotics Database.
96 Based on analysis of the Association for Unmanned Vehicle Systems International (AUVSI) Unmanned Systems
& Robotics Database.
196
? The FAA estimates that ten entities will request to become Remote ID
USS and nine of
the entities will be approved by the FAA by the end of year 1 in the
analysis period. For
each of the nine remaining years of the analysis period, the FAA
assumes one additional
entity will request to become a Remote ID USS annually which will then
be approved by
the FAA.
97
? Each Remote ID USS applicant will be required to submit an
application package to the
FAA requesting to become an FAA-qualified Remote ID USS. The FAA
determines that
each application package submitted will not exceed 40 pages98 and will
take the applicant
25 hours per page to complete at a fully burdened wage of $92.72 per
hour (a fully
burdened wage includes pay and benefits).
99
? The FAA assumes each entity operating a UAS would be required to
subscribe to a
Remote ID USS at a rate of $2.50 per month or $30 per year.
100 Entities that operate UAS
without remote identification may only operate within FAA-recognized identification
areas and are not required to subscribe to a Remote ID USS.
F. Other

97 Source: FAA subject matter expert.
98 See Section 6.5 Application Package Specifics, page 8. (Source: https://www.faa.gov/uas/programs_partnerships/data_exchange/laanc_for_industry/media/FAA_USS_LAANC_Onb
oarding_Process.pdf.) The FAA determines that the Remote ID USS
applicant package will be more complex than
the application package for LAANC.
99 Based on information from the regulatory analysis of the 2019
proposed rule, Operations of Small Unmanned
Aircraft Systems Over People (https://www.regulations.gov/docket?D=FAA-2018-1087). The regulatory
analysis
estimated it would take a small UAS manufacturer 25 hours per page of representative activity to compile
information, draft, review, and approve remote pilot operating
instructions. This estimate is used as a proxy for the
time required by a USS service provider applicant to complete each
page of the application package submitted to the
FAA.
100 FAA review of subscription costs to USS for LAANC range from 0$ to
$5 per month. The average of $2.50 is
used for the regulatory analysis. In this analysis, the FAA assumes
the subscription cost will be a flat rate and will
not vary by the number of UAS operated by an entity. UAS service
providers may charge additional fees for other
services not related to this proposed rule.
197
? The FAA assigns the United States Department of Transportation
guidance on the hourly
value of travel time savings for personal purposes (for limited
recreational flyers only).
This value is equal to $14.21 per hour and is applicable for the
ten-year analysis
period.
101
? The FAA assumes that all Academy of Model Aeronautics (AMA) flying
sites will
submit requests to become FAA-recognized identification areas, and
that 90 percent of
the requests will be approved. The remaining ten percent are assumed
to be in sensitive
areas and therefore will not be approved to become an FAA-recognized identification
area.
? The FAA estimates it will conduct 2,002 investigations of UAS
incidents annually for
each year of the analysis period and that each investigation will
range between 1 and 40
hours.102
The FAA requests comments, with supporting documentation, on these
assumptions.
2. Benefits Summary
The FAA is proposing to require the remote identification of UAS
operating in the
airspace of the United States. Remote identification of UAS provides situational awareness of
operations conducted in the airspace of the United States, fosters accountability of the operators
and owners of UAS, and improves the capabilities of the FAA and law
enforcement to
investigate and mitigate careless, hazardous, and noncompliant
operations. The ability to know

101 Time savings is estimated to be median hourly wage plus benefits
as described in the U.S. Department of
Transportation Revised Departmental Guidance on Valuation of Travel
Time in Economic Analysis ( Sept. 27,
2016).
102 The FAA conducted 2,002 investigations in FY 2018.
198
the location of UAS operating in the airspace of the United States,
and to identify and locate their
operators, creates a safer environment. This, in turn, enhances safety
in air commerce and the
efficient use of the airspace of the United States.
First and foremost, the implementation of these proposed remote
identification
requirements would allow the FAA, as well as law enforcement entities,
to have access to new
information to help them be better able to perform their
responsibilities in protecting users of the
airspace as well as people and property on the ground. Remote
identification of UAS would
enable the FAA, national security agencies, and law enforcement
entities to have near real-time
awareness of UAS users in the airspace of the United States. This
information could be used to
distinguish compliant operators from those potentially posing a safety
or security risk.
There has been an increase in UAS sightings near airports, some of
which have caused
travel disruptions and significant financial costs.103 While remote identification alone will not
stop such occurrences, the FAA expects the duration of the event can
be reduced by the remote
identification capabilities in this proposed rule.104 London’s Gatwick
Airport was closed due to
unmanned aircraft sightings in July 2017 and again in December 2018.
In July 2017, a
spokesperson for the airport reported that operations were suspended
twice in one day, for a
period of nine minutes, and again for a period of five minutes. In the
December 2018 incident,

103 The FAA has been compiling a database of UAS sightings since
November 2014. The database is compiled
mostly from reports by pilots submitting statements of possible UAS
sightings or encounters to the FAA’s air traffic
control facilities, but it also contains reports submitted by the
general public, law enforcement, air traffic controllers,
and others. The reports typically involve sightings of UAS operating
around airports or airborne manned aircraft.
The FAA analyzed 7,285 records from the database for the 48-month
period starting with January 2015 and going
through December 2108. During this time, UAS sightings have increased
almost two fold, going from about 100
reports per month to just under 200 reports per month. The FAA
acknowledges that the data is often not sufficient
for the FAA to conduct investigations, and that reported sightings
could involve UAS operating in a safe and
authorized manner. However, the increase in reported sightings is
indicative of a proliferation of UAS operating in
the airspace.
104 http://www.digitaljournal.com/tech-and-science/technology/q-a-recent-airport-shutdowns-need-droneinterdiction-technology/article/543680.
Accessed February 26, 2019.
199
Gatwick was closed twice during the holiday travel rush, once for
almost 36 hours as police
worked to identify those operating unmanned aircraft in the area.105
The December closures
affected approximately 150,000 passengers and resulted in
approximately 1,000 flight
cancellations,
106 which cost the airlines and the airport approximately $64.5
million107 and $20
million, respectively.108 Flights at London Heathrow Airport were
suspended in January 2019
after a sighting of an unmanned aircraft.109 The suspension of flights
lasted approximately one
hour.
The Dubai International Airport experienced closures due to
unauthorized unmanned
aircraft activity in 2015, 2016, and 2019.110 In 2015, the
unauthorized activity caused the airport
to shut down for 55 minutes. In 2016, unauthorized UAS activity closed
the airport three more
times. Two of the closures lasted 30 minutes each, and one closure
lasted for 115 minutes.
Estimated losses for the three closures that occurred in 2016 totaled
$16.6 million.111 During the
airport’s most recent closure (February 2019), flight departures were
suspended for 32 minutes.
According to the Emirates Authority for Standardization and Metrology,
airports in the United
Arab Emirates suffer financial losses averaging $95,368 per minute due
to unauthorized UAS
activity.

105 https://www.theguardian.com/uk-news/2018/dec/21/gatwick-airport-reopens-limited-number-of-flights-dronedisruption.
Accessed February 26, 2019.
106 https://www.independent.co.uk/travel/news-and-advice/gatwick-drones-arrests-flight-delay-cancelled-airportchristmas-travel-latest-update-a8695846.html.
Accessed February 26, 2019.
107 http://fortune.com/2019/01/22/gatwick-drone-closure-cost/.
Accessed February 26, 2019. Extrapolated from
EasyJet’s announcement that it lost $19.3 million in revenue and
customer welfare costs during the shutdown.
EasyJet reported 400 flight cancellations, and that the incident
affected 82,000 of their passengers, for whom it paid
an average of $160.90. Accessed February 26, 2019.
108 https://www.independent.co.uk/travel/news-and-advice/gatwick-drone-airport-cost-easyjet-runway-securitypassenger-cancellation-a8739841.html.
Accessed February 26, 2019.
109 https://www.thenational.ae/world/europe/flights-briefly-stopped-at-heathrow-airport-over-drone-sighting1.810964.
Accessed February 26, 2019.
110 http://www.digitaljournal.com/tech-and-science/technology/q-a-recent-airport-shutdowns-need-droneinterdiction-technology/article/543680
111 https://www.arabianbusiness.com/content/375851-drone-costs-100000-minute-loss-to-uae-airports
200
In the United States, New Jersey’s Newark Liberty International
Airport experienced a
closure in January 2019 after receiving two separate reports of a UAS
sighting. The FAA
reported that 43 flights were required to hold while nine flights were
diverted during the event
that lasted for 21 minutes.112 On February 21, 2019, flights at Dublin
Airport in Ireland were
delayed for 30 minutes due to unauthorized unmanned aircraft activity,
and on March 22,
Frankfurt International Airport suspended operations for 29 minutes
after an unmanned aircraft
was spotted in the area.
113,114 Frankfurt International Airport was closed again on May 9 for
a
period of 28 minutes due to a UAS sighting. The May 9 closure resulted
in the cancellation of
143 departures with an additional 48 arrivals diverted to other
airports.115
Currently, personnel that conduct law enforcement and compliance
activities lack the
ability to have near real-time awareness of UAS users in the airspace
of the United States. These
challenges are an impediment to the FAA’s mission of ensuring the
safety of the airspace of the
United States. For example, over 200 unmanned aircraft were detected
in the no-fly-zone of the
2018 Albuquerque International Balloon Fiesta in spite of the FAA prohibition.116 This proposed
rule could have aided the FAA to identify the operators of these
unmanned aircraft.
The FAA believes this proposed rule is crucial for the development of
UTM, which
would enhance the safety and efficiency of the airspace of the United
States. The FAA is
collaborating with other government agencies and industry stakeholders
to develop UTM, which

112 https://www.reuters.com/article/us-usa-drones/faa-details-impact-of-drone-sightings-on-newark-airportidUSKCN1PH243.
Accessed February 26, 2019.
113 https://dronelife.com/2019/02/22/flights-were-grounded-at-dublin-airport-after-another-drone-sighting/.
Accessed
February 26, 2019.
114 https://www.ecnmag.com/news/2019/03/drone-sightings-interrupt-germanys-frankfurt-airport
115 https://www.france24.com/en/20190509-drone-sighting-briefly-grounds-flights-frankfurt-airport
116 https://www.krqe.com/news/balloon-fiesta/hundreds-violate-faa-s-no-drone-fly-zone-at-balloonfiesta/1510662538.
Accessed December 18, 2018.
201
would be separate from, but complementary to, the ATM system. As of mid-December 2018,
there were 1.27 million unmanned aircraft in the unmanned aircraft
registry. This is over five
times greater than the number of active manned aircraft registered
with the FAA. While ADS-B
is currently used to track manned aircraft and is mandated for manned
aircraft in certain airspace
after January 1, 2020, it was not designed to incorporate millions of
unmanned aircraft on the
same network. Instead, the FAA envisions a community-based traffic
management system,
where UAS operators have the responsibility to participate in a safe
operating environment. This
vision for UTM includes services for flight planning, communications, separation, and weather,
among others.
The FAA also believes remote identification would provide greater
situational awareness
of UAS operating in the airspace of the United States to other
aircraft in the vicinity of those
operations, and provide information to airport operators. Manned
aircraft, especially those
operating at low altitudes where UAS operations are anticipated to be
the most prevalent, such as
helicopters and agricultural aircraft, could carry the necessary
equipment to display the location
of UAS operating nearby. In addition, we expect towered airports will
use remote identification
information for situational awareness, especially for landing and
takeoff operations. Further, an
aircraft preparing to take off from a non-towered airport in Class G
airspace may have access to
greater information than is currently available.
Remote identification is a key stepping stone to facilitating the
ability to conduct BVLOS

[continued in next message]

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