Remote ID

Beyond the Buzz (episode 2) - Remote ID  

September 19, 2024 

Erin Roesler: Hi, welcome to Beyond the Buzz, Northern Plains UAS Test Site’s monthly webinar that discusses all things UAS. This is hosted in collaboration with The Hive here in Grand Forks, North Dakota. Today, we are discussing understanding UAS remote ID rules, so welcome, everyone, to today’s webinar on FAA UAS remote ID. 

Remote ID is a critical aspect of operating drones in the U.S. and how we manage and operate in our airspace system. Today, we’ll break down what it is, why it matters, and how you can ensure you are in compliance. 

I’m Erin Roesler, the deputy executive director for the Northern Plains UAS Test Site, and I’m here with Jake DeForest. 

Jake DeForest: Hi, I’m Jake DeForest, director of operations here at Northern Plains, and I’ll be leading us off through this presentation. So without further ado, let’s dive into some of the most common questions we get about remote ID. 

So, first, Jake, what is remote ID and why is it important? 

Jake DeForest: Remote ID, or the FAA definition, is meant to be a digital license plate for drones. It allows the FAA, law enforcement agencies, and other authorized parties to identify drones in flight, providing information about who is flying the drone and where the operator is located. That allows the FAA or law enforcement to act on that information. 

Why is it important? It helps with security, especially for events like football games and similar gatherings. Knowing who is flying, when, and where is something we’re seeing more and more in traditional aviation with ADS-B. Most of us probably use FlightRadar24 or some other app that shows who is flying in the airspace, and this is just an extension of that to UAS as well. 

So who is required to comply with remote ID? 

Jake DeForest: The compliance regulation is very broad in definition. Section 89.101 is the applicability rule, and it states that any aircraft or unmanned aircraft registered under Part 47 or Part 48 must comply. Part 47 is traditional aircraft registration, so think large UAS. Part 48 is small UAS, meaning under 55 pounds but greater than 0.55 pounds. 

That means something as large as an MQ-9 could be required to have remote ID. In reality, that is not the most likely path because there is an exception in 89.101 for aircraft transmitting ADS-B out. More likely, large UAS will use that path for compliance. The rule is shaped around making sure all aircraft that are registered are transmitting some sort of data about their location. 

So if you can’t achieve that through ADS-B out, then you are looking at remote ID. Really, all SUAS flown for commercial or recreational purposes are required to have remote ID since the rule went into compliance in March. 

Erin Roesler: So it doesn’t matter if I’m commercial or just flying for recreation, I still have to comply with the rules? 

Jake DeForest: Yes. Whether you’re flying in the park for fun, taking pictures of the river, or you’re a real estate company taking photos of houses or commercial property, you need to comply. 

So how do I comply with the rules? 

Jake DeForest: There are three categories you can fall into. The first is standard remote ID. This is typically accomplished by the UAS manufacturer, and it’s something that is always on. When you turn on the drone and go fly, it’s already broadcasting. 

The second is a broadcast module. The module is a self-contained unit that you attach to the drone somehow, whether by glue, Velcro, or another method. That requires more upkeep because you have to make sure it’s charged, since it has a battery onboard, and you have to remember to turn it on before flying. 

The third is to fly in a FRIA, which is a FAA-recognized identification area. These are typically set up around recreational flying fields or sometimes educational institutions. Within those zones, you are not required to have remote ID on your aircraft. 

So the three ways to comply are standard remote ID, a broadcast module, or operating in a FRIA where you are exempt. 

Erin Roesler: We’re at The Hive, which has a lot of startup and development companies. Some of those may be aircraft manufacturers or even remote ID manufacturers. If I can’t get remote ID to work right away, is there a process for developing an aircraft or design where compliance is difficult? 

Jake DeForest: Yes, there are some paths to seek an exemption from the remote ID rules. If you determine that you can’t comply, or it is difficult to comply, during development phases, Section 89.120 does provide an exemption path. 

It is limited to operations for aeronautical research or to show compliance with the regulation. So if you’re building an aircraft and working to integrate remote ID in a standard format, but you’re not sure it is working yet or you just want to do a check flight, you can use 89.120 as an exemption path. 

What you cannot use 89.120 for is day-to-day commercial operations once you are fully up and running. You still have to follow the remote ID regulations after that phase. 

Erin Roesler: How do you get that exemption? 

Jake DeForest: It’s actually a fairly easy process. You just send an email to the FAA explaining what you want to do. For example: “We’re from Northern Plains UAS Test Site. We do aeronautical research with a lot of our platforms, and we’d like to seek exemption through 89.120.” 

That’s essentially what we submitted for our exemption, and we received it a few weeks later. It was a fairly straightforward process with a pretty quick turnaround. 

Erin Roesler: We’ve had different projects and flight test events where, because we are trying to work on UAS integration into the entire National Airspace System, we’ve had to seek this exemption to test very specific scenarios, whether that be counter-UAS measures or unmanned traffic management work. We want to make sure we’re testing every possible case. 

If you are in one of those scenarios where you are developing remote ID modules, developing an aircraft design, or refining a system and you want to do test flights before full compliance, an exemption is a great option. As you said, just send an email explaining why, how, and who you are, and then go from there. 

Is there any guidance on what you should include in that email? 

Jake DeForest: There isn’t a lot of guidance on what to include. I’d recommend including who you are and a broad scope of the work you’re trying to accomplish through the exemption. That’s really it. It can be that simple, at least from my experience. 

Erin Roesler: Maybe a time period too, like how long you want the exemption for, whether it is six months or 10 years. 

Jake DeForest: Yes, that could be helpful too. 

Erin Roesler: What happens if something goes wrong and I’m actually not in compliance with the regulation? 

Jake DeForest: The potential penalties for non-compliance with remote ID are what you would typically expect: enforcement actions from the FAA. There is potential for fines or suspension of your license if you are found to be operating without remote ID in a negligent manner. 

The letter shown here does not deal with remote ID non-compliance. It actually deals with someone busting altitude, but it shows that the FAA does have the ability to use remote ID now and identify who the pilot is. In that case, an individual was operating above 400 feet around a music festival, and the FAA was able to trace the aircraft back to the registered pilot. They also determined that the person had a Part 107 certificate. 

So down the line, you could see similar letters where the FAA identifies aircraft not operating correctly with remote ID and issues fines or suspensions. In many cases, the first approach is education: “Did you realize there were rules you were supposed to be following?” before the FAA moves to suspensions. 

Erin Roesler: So if you made a genuine mistake, it’s not like you should expect a fine the next day. 

Jake DeForest: Right. 

Erin Roesler: I want to comply, but what if I bought a UAS that doesn’t have built-in remote ID, or I’m not sure whether it does? How would I find out? 

Jake DeForest: The best place to start is the manufacturer’s documentation that came with the platform. If you bought it secondhand, you may be able to find that documentation online through the manufacturer’s website. That should tell you whether the aircraft is remote ID compliant or not. 

There should also be markings on the aircraft stating that it has remote ID capability, along with the serial number. If you can’t find that information, there is also the FAA’s Declaration of Compliance website. That website contains a list of all aircraft that have gone through the standard remote ID process and have an accepted declaration of compliance on file with the FAA. 

That list includes all the manufacturers, and it also includes modules. So if your aircraft is not standard remote ID compliant and you want to use a module to comply, all of those modules with a declaration of compliance will also be listed there. 

Erin Roesler: If I find that my drone is not standard compliant, and I want to use a module, what do I do if it doesn’t have built-in remote ID? Can I retrofit it? What are my options? 

Jake DeForest: There are a couple of paths depending on what your aircraft is and how deep into the weeds you want to get. The easiest solution is to attach a module. You can use the Declaration of Compliance website to determine which modules are compliant and which one works best for your application, size, weight, and attachment method. 

These are self-contained units, so it really is just a matter of sticking it on, making sure the battery is charged, and you’re good to go. 

The second solution, more for manufacturers, is to use a module that integrates into the aircraft rather than a stick-on unit. That is tied into the flight controller and has its own requirements to get it up and working. It is more focused on the engineering side, including loading the right firmware and going through the declaration of compliance process yourself to show that your manufactured drone is compliant. 

That path exists and is doable, but it is a little more involved than just sticking on a module and saying, “Okay, we’re good to go.” 

Erin Roesler: Are there any differences between standard remote ID and broadcast ID other than attaching a module? 

Jake DeForest: There are some differences, though they are minor in what the module actually broadcasts. The data is fairly similar, mainly the position of the aircraft. 

What standard remote ID gets you is a difference in what regulations apply to the type of flights you can do. With standard remote ID, if you have a waiver, you can apply beyond visual line of sight, including daisy-chain visual observers or other approved methods. 

If you are flying with just a module, there is a caveat in the regulations that says you can’t do that anymore with the module. So it is a little more restrictive with a module than with standard remote ID. 

The reason is that the FAA wants to push the idea that all drones should eventually be equipped with standard remote ID and that it should be automatic, so it does not rely on someone remembering to switch on a module or attach it correctly. 

Erin Roesler: What information does remote ID broadcast? Does it broadcast my name, Social Security number, or address? 

Jake DeForest: No, it will not broadcast your address or anything like that. It really only broadcasts the location of the drone, the registration information for the drone, your FAA number, the serial number for your remote ID module, and, with standard remote ID, the position of the operator. 

That is intended to help law enforcement and others determine where to find the operator if there is a bad actor. 

So it is information about the drone itself: the serial number of the remote ID unit, the drone’s registration number, the aircraft’s position, and the operator’s position where the ground control station is located. That’s really it. 

Erin Roesler: As we wrap up, what are some best practices to make sure I’m following the rules? 

Jake DeForest: First, if you don’t fly regularly or have an older drone, like a Mavic 2, make sure the aircraft is updated. A lot of older drones achieved standard remote ID through a firmware update, so keeping your aircraft current helps ensure compliance. You still need to verify that the firmware update actually includes remote ID. 

Second, if you are using a module, make sure it is in good condition and actually broadcasting. You can check with an app that reads remote ID. There are several available now. Also make sure it is charged before you fly and that whatever method you use to attach it is still working. 

Third, keep up to date with regulations and guidance by attending webinars and staying informed. 

Erin Roesler: Thank you to everyone who joined us today, both in person and online. We hope this helped clarify the FAA UAS remote ID rules and answered some of your questions about compliance. 

If you have further questions, contact us at the Northern Plains UAS Test Site through our website and submit a question form. We’re happy to help. Please join us next month on Beyond the Buzz. Thank you again to our host, The Hive, and happy flying.