Background
The FAA’s UAS Identification and Tracking (“UAS ID”) Aviation Rulemaking Committee (ARC) published its final report on December 19, 2017. The ARC, which was chartered to provide recommendations to the FAA regarding technologies available for remote identification and tracking of Unmanned Aircraft Systems (UAS), was charged with three objectives:
Report
The membership of the ARC included representatives from a wide range of stakeholders, including: the general aviation community, industry member organizations, law enforcement agencies, public safety organizations, manufacturers, researchers and standards organizations. The group recommended two methods for UAS to provide remote ID and tracking information to public authorities:
The ARC could not reach consensus on what threshold of UAS operations would be subject to ID and tracking requirements. However, it did recommend two options, both of which would essentially result in UAS used for recreational purposes (i.e., by hobbyists) not being covered. The ARC also recommended that, regardless of which option for applicability the FAA chose, the following UAS should be exempt from remote ID and tracking requirements:
In addition, the ARC further recommended that the FAA:
Analysis
Being able to remotely identify and track UAS will be critical to resolve the safety and security concerns that must be addressed before UAS can achieve their full potential. The ARC’s report is an important step to address these concerns. However, the report also highlights the challenges associated with a technology with such a wide range of uses. For example, many businesses that plan to use UAS for commercial purposes object to the exemption of UAS used for recreational purposes from those requirements. Industry’s concern is that, given the large number of UAS operated by hobbyists, a remote ID and tracking system that does not include these systems will be ineffective. Consequently, there is still a good deal of work to be done before these issues are resolved.