An Open Letter to the FAA

On December 26, 2019, the FAA sent an email to its subscribers illustrating ways in which the Administration plans to remotely identify drones over the next few years. The full proposal has been posted here: https://www.federalregister.gov/documents/2019/12/31/2019-28100/remote-identification-of-unmanned-aircraft-systems

The FAA plans to control drone usage in one of three 3 ways: Standard, Limited, and FRIA.

There are several problems with all of these methods of tracking drones:

  1. Standard Remote Identification assumes that drone pilots will always have a stable internet connection everywhere they fly – this is simply false. There are many locations we fly commercially that have spotty internet connections but require drones at those areas to get the job done. This requirement will also significantly decrease drone performance as drone manufacturers now need to implement Remote ID technology on board the sUAS, reducing battery life and running the risk of interfering signals with other drones in the area.
  2. Limited Remote Identification severely limits a commercial flyer’s ability to service the client. In construction, for example, many areas requiring a survey extend beyond a 400ft radius around the pilot due to the nature of the work. Limiting the pilot to this “bubble” in effect eliminates the need for the drone altogether as lateral distance is critical in getting the photos needed to complete an aerial map, a survey, or a complete photogrammetry of a job site. Additionally, if there is an emergency requiring aerial assistance by emergency services, you are, in effect, hindering the ability of the drone pilot and emergency services to save a life.
  3. Both Standard and Limited Remote Identification options send out personal data of the pilot and drone to the general public – why? There is absolutely no need for the general public to be aware of what I am doing privately, especially if I am flying a drone on private property with the property owner’s permission. Moreover, sharing my private information to the general public essentially acts as an advertisement for someone to rob my expensive drone, especially if they have my drone model, my name, and my address all made conveniently available. Not only is this a massive violation of my privacy, but it also facilitates the ability for someone to steal a very expensive tool that many of us rely on for work.
  4. Remote ID technology will not only decrease drone battery performance, but it will also increase costs that we, the consumer, will need to pay. These costs include manufacturing costs that will be passed onto consumers, subscription costs for broadcasting drone locations, and power costs to keep the drone operational. The only people who lose in this scenario are the commercial drone pilots who have already expended a significant amount of cash on the drones they currently own and the certifications and training they received for the FAA. Moreover, drones on the market today will become obsolete overnight as they are not equipped with the technology the FAA is requiring in their Remote ID proposal.
  5. Pigeon-holing drone operators without Remote ID technology to FAA-Recognized Identification Areas will kill the hobby altogether. The whole point of owning and operating a drone is to fly it to hard-to-reach areas – to places people normally cannot go – to see things we normally cannot see. We, as drone enthusiasts, have no desire to be locked into a fixed location to fly a drone over an area that doesn’t have much to offer for the drone photographer.
  6. If it’s not broken, don’t fix it. There hasn’t been a single incident in drone history involving a drone and aircraft collision. When I purchase a car from a dealership, I’m not required to install a tracking device on my car for the DMV to track me. So why are trying to do this to drones?

This proposal is working against the interests of the pilots it is trying to service. The commercial drone industry as it operates today will come to a screeching halt as costs rise to accommodate these Remote ID requirements and future generations of flyers are discouraged from flying altogether from the rising costs of the hobby and the limitations as to where they can fly. Drone pilots are already restricted enough as it is – why are we restricting them even further?

RMA HD