Michael Kotrous and I submitted a comment to the FAA about their Remote ID proposals. While we agree with the need for a “digital license plate” for drones, we’re skeptical that requiring an Internet connection is necessary and that an interoperable, national drone traffic management system will work well.
The FAA deserves credit for rigorously estimating the costs of their requirements, which they set at around $450 million to $600 million over 10 years. These costs largely fall on drone operators and on drone manufacturers for network (say, LTE) subscriptions and equipment.
The FAA’s proposed requirements aren’t completely hashed out, but we raised two points of caution.
One, many many drone flights won’t stray from a pre-programmed route or leave private property. For instance, roof inspections, medical supply deliveries across a hospital campus, train track inspections, and crop spraying via drone all remain on private property. They all pose a de minimis safety concern to manned aircraft and requiring networking equipment and subscriptions seems excessive.
Two, we’re not keen on the FAA and NASA plans for an interoperable, national drone traffic management system. A simple wireless broadcast from a drone should be enough in most circumstances. The FAA proposal would require drone operators to contract with UAS Service Suppliers (USSs) who would be contractors of the FAA. Technical standards would come later. This convoluted system of making virtually all drone operations known to the FAA is likely run aground with technical complexity, technical stagnation, FAA-blessed oligopoly in USS or all of the above.
The FAA instead should consider allowing states, cities, and landowners to make rules for drone operations when operations are solely on their property. States are ready to step in. The North Dakota legislature, for instance, authorized $28 million a few months ago for a statewide drone management system. Other states will follow suit and a federated, geographically-separated drone management system could develop, if the FAA allows. That would reduce the need for complex, interoperable USS and national drone traffic management systems.
Further reading:
Refine the FAA’s Remote ID Rules to Ensure Aviation Safety and Public Confidence, comment to the FAA (March 2020), https://www.mercatus.org/publications/technology-and-innovation/refine-faa%E2%80%99s-remote-id-rules-ensure-aviation-safety-and
Auctioning Airspace, North Carolina Journal of Law & Technology (October 2019), https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3284704
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