On January 28, 2020, Skyward provided a summary of the FAA’s Remote Identification for Unmanned Aircraft Systems (UAS) Notice of Proposed Rulemaking (NPRM). Over the last two months, Skyward, along with Verizon at large, has been reviewing the technical and operational impacts of the proposed Remote ID regulations. While we generally support the NPRM’s proposals, there are areas in which we seek modifications. We have submitted comments to the FAA, but we want to provide our customers with a summary of our comments, and the thinking behind those comments.
1. Performance Based Standards for Remote ID
We urge the FAA to adopt performance-based standards to the maximum extent practicable. While the FAA meets this with many of the proposed regulations, there are notable exceptions. For example, we would prefer to see a performance standard for altitude, that is “altitude must be accurate +/- x feet.”
The discussion regarding USS and message elements could benefit from a performance-based standard too. Rather than identify technical means, we believe the rule would benefit from a clear and concise statement — such as “the message elements must get to an FAA-approved UAS Service Supplier (USS) in real-time, unless in an area entirely lacking connectivity. Then the message elements must be broadcast over the air and operations are limited…”
2. Expedite Implementation of Remote ID
The timeline is unnecessarily long. The technology is available for comprehensive and quick implementation of the model in which message elements are shared with interoperable FAA-approved entities.
NASA and the FAA have been working for years on a model for Unmanned Traffic Management (UTM), with the stated goal of “Enabling Civilian Low-altitude Airspace and Unmanned Aircraft System Operations.” Meanwhile, NASA’s space program received instruction in December 2017 through Space Directive 1 to return to the moon and has since committed to “landing American astronauts, including the first woman and the next man, on the Moon by 2024.” (As a side note, if you are thinking about using a UAS to video any space launches, we urge you to check with NASA, the FAA, and our InFlight app for airspace restrictions.) If we can strive to land on the moon in 2024, we can certainly implement Remote ID well in advance of that milestone!
3. USS Interoperability
In order to realize the vision of complex and integrated low-altitude UAS operations, the FAA must make USS interoperability a regulatory requirement. Although we believe this the intent of the FAA, it is not explicitly required in the proposed regulations. All UAS operations should be required to transmit their message elements in real-time to an FAA-approved USS, unless the internet is entirely unavailable — this is the only way to guarantee interoperability. Broadcast should be considered only where this situation exists, and it generally occurs in less-complex airspace.
A patchwork of UAS — some transmitting to USS of their choice and others broadcasting only as far as their particular RF signal will travel — degrades safety of the National Airspace System. There will be no authoritative source for data and it simply becomes a law enforcement tool. It does not provide situational awareness to operators of other aircraft, manned or unmanned, and it does not provide any appreciable increase in Detect and Avoid capability for operators.
4. Cybersecurity and Privacy for Operators
We further believe that all Remote ID providers must be an FAA-approved USS. USS providing Remote ID through a Memorandum of Agreement with the FAA allows for security and authentication in a way that broadcast-only Remote ID will never deliver. Under a USS Remote ID solution, the USS could authenticate operator identity; that is, the USS could confirm the identity of the UAS operator when the operator connects to the USS.
Certified Remote ID USS is also the only reliable way to minimize the cyber vulnerabilities to UAS in the NAS. The United States’ telecommunications sector overall has a long history of protecting against cyber threats to customers’ security and ensuring the reliability and resilience of communications services against all manner of hazards, including cyber threats. Based on this experience, Verizon is well-positioned to maintain network and operational security. It has a significant base of cyber security professionals, and its provision of Remote ID will benefit from the substantial cybersecurity investments Verizon and other providers have made. We also have strict privacy protections, and our requirements meet the strictest US and global privacy laws. Messages broadcast over unlicensed and non-proprietary spectrum cannot meet this level of assurance. We are confident in our cyber teams and believe Remote ID providers whose systems fail to maintain a minimum level of reliability should not maintain FAA certification.
Although we have no control over the FAA’s technical implementation timeline, we continue to participate with industry organizations to prepare the groundwork for Remote ID. In that regard, we fully support ASTM F3411-19 (Standard Specification for Remote ID and Tracking). We are a member of the ASTM working group that developed F3411-19 and continue to review it in response to the NPRM. We have urged FAA to consider the ASTM’s vision of interoperability in order to enable complex operations such as Beyond Visual Line of Sight. While the standard does allow for broadcast Remote ID, it does not recommend one or the other. Rather, it focuses on technical means of implementation and consistently addresses an interoperable system. This cannot work if the regulations allow for both broadcast and transmitted Remote ID at the operator’s whim.
5. Trust UAS Pilots
Finally, we support Remote ID operators and wish the NPRM had reflected a greater appreciation for the professionalism of UAS pilots. UAS are aircraft, and in our experience the vast majority of UAS pilots seek to comply with FAA regulations — even when they are frustrated with the slow progress of UTM expansion. For this reason, we do not support the interlock feature in UAS (§§ 89.310(d) for Standard UAS and 89.320(d) for Limited UAS) since this is a command and control feature, not a Remote ID feature. Not only does it show a lack of trust in operators, but it would require airframe-specific integration and unnecessarily restrict the ability to obtain a Means of Compliance — therefore limiting operator access to UAS.
Leveraging Verizon’s extensive commercial wireless network along with Skyward’s role as an industry leader in UAS, Verizon and Skyward will continue to work with both the public and private sectors to advance UAS operations, enabling organizations to reap the benefits of UAS operations to advance their business goals. Skyward joined other industry stakeholders last fall to test a USS platform designed to create a standard means for USS to cooperate in providing Remote ID services, and we look forward to more demonstrations this year.
I spoke of Artemis earlier, and will close with Apollo. NASA identifies the Apollo Primary Guidance, Navigation and Control System as the genesis of modern fly-by-wire systems and one of the greatest lasting impacts of the Apollo program. Even though the new Orion Multi-Purpose Crew Vehicle is significantly more automated than the Apollo Command Module, NASA still relies on the astronaut to make final decisions — recognizing that a computer cannot predict every flight requirement or navigate every decision matrix. UAS may be unmanned aircraft, but there is a human pilot in the loop and that system is operating in a National Airspace System that includes all forms of aircraft. Remote ID regulations must reflect this.