March 03, 2020

Wing Files Comment to FAA NPRM on Remote ID

Wing is committed to the safe, open, and secure use of airspace, and we support the remote identification of drones (Remote ID). Remote ID is an important capability that will help promote responsible flying and improve security.

However, the FAA’s proposed Remote ID rules pose some challenges. Wing recommends the following amendments to better support the diverse UAS ecosystem, protect privacy, and enable hobbyists to continue sharing the skies. Together, these changes will help maximize opportunities for compliance, improving safety and security outcomes for all airspace users. 

  • 1 - The rule should identify required performance. Different Remote ID systems may be more appropriate for different operations. Standard UAS operators should be permitted to use either broadcast or network Remote ID, subject to meeting performance requirements for message element content, accuracy, frequency, and latency in their specific operating environment. 
  • 2 - The rule should mitigate risks to privacy. Unlike multi-passenger aircraft flying between known airports, UAS operate between hospitals, businesses, and individual homes. Sensitive information can be inferred from the UAS position, including information about customers using UAS services. Privacy and commercial sensitivity may be compromised by unrestricted access to real time data by third parties or unrestricted access to retained data by government. The disclosure of this data is not necessary for effective implementation of Remote ID, and the rule can protect privacy while supporting legitimate safety and security objectives. To that end:
    • a. The rule should permit operators to use network Remote ID to mitigate the risks of unrestricted data collection or aggregation associated with broadcast Remote ID. 
    • b. The rule should impose restrictions on data sharing and retention by Remote ID UAS Service Suppliers (USS), and require Remote ID USS to incorporate technical mitigations against unrestricted data collection or aggregation. 
    • c. The rule should permit operators to shield their control station position from public observers when transmitting via Remote ID USS. This message element would be available to the FAA.
    • d. The rule should outline a legal process governing access to retained data if that data is directly or indirectly identifiable. Access should be limited to certain purposes related to compliance, accident investigation, and security. The use of aggregated data should be subject to strict de-identification protocols.
  • 3 - The rule should support all airspace users. Hobbyists should be able to share the skies. Standard and Limited categories should be distinguished based on relevant risk factors. Design and production requirements should apply only to highly automated UAS that are produced for sale to third parties or commercial use. Limited UAS should mean UAS not subject to these requirements. Limited UAS operators should be permitted to declare their flight intent via a Remote ID USS, similar to declarations for access to controlled airspace under the FAA’s Low Altitude Authorization and Notification Capability (LAANC).
  • 4 - The rule should adopt consensus standards for message elements. Message elements should be aligned to the ASTM International ‘Standard for Remote ID and Tracking’ (ASTM standard) to reflect established industry consensus about the feasibility and effectiveness of particular message elements, such as barometric altitude and emergency status. 
  • 5 - The rule should expand and clarify exceptions. Community based organizations should be permitted to apply for and renew FAA-recognized identification areas beyond 12 months. Further, the final rule should outline factors that weigh in favor of an authorized exception for aeronautical research.

To view Wing's comments in their entirety visit here.