Request for Comments - FAA Rulemaking

Request for Comments on the Federal Aviation Administration’s (FAA) Proposed Rulemaking Regarding Unmanned Aircraft Systems (UAS)

The Federal Aviation Administration (FAA) published a notice of proposed rulemaking (NPRM) requesting comments on the remote identification of unmanned aircraft systems (UAS). The purpose of the NPRM is to set the groundwork for the FAA to develop a traffic management system for UAS. The NPRM found here, sets out a process and definitions for doing this. The goal is to address safety, national security and law enforcement concerns regarding the further integration of UAS into U.S. airspace while also enabling greater UAS operational capabilities. The notice proposes that the rules would require UAS identification three years after publication of the final rule, which is estimated to take two years. 

Below is a summary of the remote identification NPRM. At a minimum, IAAPA intends to comment on: the continued need for the Applications for Designation process because of the unique safety and security concerns of attractions; concern over the smaller UAS not addressed in this rulemaking; location of FAA designated areas and their proximity to attractions; and timing and availability of UAS data transmission.  

The NPRM generally proposes that UAS weighing more than 0.55 pounds would need to have one of two kinds of UAS manufacturer embedded identification or the operation would be limited to a defined FAA recognized geographic area.  All UAS would need to be registered.  

  • Standard remote identification (the majority of UAS). A UAS with remote identification capability would connect to the internet and transmit through that connection to a remote ID service supplier. This would have to be broadcast directly from the UAS from take-off to landing.  
  • Limited remote identification UAS is a UAS that is designed and produced to restrict operation to no more than 400 feet from its control station, is capable of connecting to the internet and transmitting the remote identification message elements through that internet connection and cannot broadcast remote identification message elements. Persons operating a limited remote identification UAS would be required to operate within visual line of sight and ensure the UAS complies with all FAA requirements. 
  • UAS without remote identification. While the majority of UAS would be in the first two categories, a limited number of UAS would not be required to have remote identification. This small number of amateur built and previously manufactured UAS could be operated within line of sight and within an FAA-recognized identification area defined as a geographic area where UAS without remote identification can be operated. A community-based organization recognized by the Administrator would have to petition the FAA for establishment of this area. It is anticipated that this group of UAS would gradually phase out. 

If you have any comments or suggestions that you would like IAAPA to include in its formal comment, please send them to by Friday, February 14.