Last week I took the time while on a 12 hour train ride to read the the report which is over 200 pages in length. My take is all Mavic 1 and Mavic 2 drones will be subject to remote ID and tracking requirements should the FAA adopt the committee's recommendations. This includes 107 flights as well as recreational flights. No consensus was reached as to which sUAS would be subject to inclusion, so the ARC provided 2 options listed below. If you want to read them, they begin on page page 31 (Applicability of the ID and tracking requirements ) The FAA is expected to make its decision in Sept or Oct 2019.
note: law citations, i.e., 14 CFR 101, refer to the "old" rules.
UAS Identification and Tracking (UAS ID) Aviation Rulemaking Committee (ARC) Final Report September 30, 2017
Excerpt beginning on p.31
Option 1:
Except for those members who strongly favor a weight-based threshold for applicability and those members who strongly oppose an exemption for model aircraft operated in compliance with 14 CFR part 101 (see discussions above in 5.2.3), the ARC recommends that all UAS be required to comply with remote ID and tracking requirements except under the following circumstances:
1. The unmanned aircraft is operated within visual line of sight of the remote pilot and is not designed to have the capability of flying beyond 400’ of the remote pilot.16
2. The unmanned aircraft is operated in compliance with 14 CFR part 101, unless the unmanned aircraft: a. Is equipped with advanced flight systems technologies that enable the aircraft to navigate from one point to another without continuous input and direction from the remote pilot. 16 The ARC is not intending to encompass drone racing at very low altitudes on a closed course that may be authorized by operation, by location, or some other mechanism. 32 b. Is equipped with a real-time downlinked remote sensor that provides the remote pilot the capability of navigating the aircraft beyond visual line of sight of the remote pilot.
3. The UAS is operated under ATC and contains the equipment associated with such operations (including ADS-B, transponder, and communication with ATC).
4. The UAS operation is exempt from ID and tracking requirements by the FAA (e.g., for the purposes of law enforcement, security or defense, or under an FAA waiver).
Option 2:
Except for those members who strongly favor a weight-based threshold for applicability (see discussion above in 5.2.3), the ARC recommends UAS with either of the following characteristics must comply with remote ID and tracking requirements:
1. Ability of the aircraft to navigate between more than one point without direct and active control of the pilot.
2. Range from control station greater than 400’ and real-time remotely viewable sensor.
The ARC further recommends that UAS operating under the following circumstances be exempt from the remote ID and tracking requirement:
• The UAS is operated under ATC and contains the equipment associated with such operations (including ADS-B, transponder, and communication with ATC).
• The UAS operation is exempt from ID and tracking requirements by the FAA (e.g., for the purposes of law enforcement, security or defense, or under an FAA waiver).
Regardless of which option FAA chooses for applicability, the ARC recommends the FAA include a waiver mechanism in the remote ID and tracking rule, to allow individual operations or classes of UAS to deviate from the requirements of the rule if operations are conducted under the terms of a certificate of waiver.
The ARC also recommends the FAA apply the remote ID and tracking requirements to the remote pilot, not to the manufacturer of the UAS. The ARC further recommends the FAA require manufacturers to label their products to indicate whether they are capable of meeting applicable remote ID and tracking requirements. If a product is labeled as capable of meeting remote ID and tracking requirements, such capabilities must be enabled by default and the manufacturer must not present the user with an option to turn off the ID and tracking.
The ARC also discussed whether unmanned aircraft equipped with advanced flight system technologies that are strictly for safety purposes and that keep the aircraft within visual line of sight 33 of the remote pilot, such as a “return to home” feature, should be exempt from remote ID and tracking requirements. The ARC recommends the FAA consider whether such an exemption would be appropriate, provided the safety features cannot be readily altered or reprogrammed. 6
note: law citations, i.e., 14 CFR 101, refer to the "old" rules.
UAS Identification and Tracking (UAS ID) Aviation Rulemaking Committee (ARC) Final Report September 30, 2017
Excerpt beginning on p.31
Option 1:
Except for those members who strongly favor a weight-based threshold for applicability and those members who strongly oppose an exemption for model aircraft operated in compliance with 14 CFR part 101 (see discussions above in 5.2.3), the ARC recommends that all UAS be required to comply with remote ID and tracking requirements except under the following circumstances:
1. The unmanned aircraft is operated within visual line of sight of the remote pilot and is not designed to have the capability of flying beyond 400’ of the remote pilot.16
2. The unmanned aircraft is operated in compliance with 14 CFR part 101, unless the unmanned aircraft: a. Is equipped with advanced flight systems technologies that enable the aircraft to navigate from one point to another without continuous input and direction from the remote pilot. 16 The ARC is not intending to encompass drone racing at very low altitudes on a closed course that may be authorized by operation, by location, or some other mechanism. 32 b. Is equipped with a real-time downlinked remote sensor that provides the remote pilot the capability of navigating the aircraft beyond visual line of sight of the remote pilot.
3. The UAS is operated under ATC and contains the equipment associated with such operations (including ADS-B, transponder, and communication with ATC).
4. The UAS operation is exempt from ID and tracking requirements by the FAA (e.g., for the purposes of law enforcement, security or defense, or under an FAA waiver).
Option 2:
Except for those members who strongly favor a weight-based threshold for applicability (see discussion above in 5.2.3), the ARC recommends UAS with either of the following characteristics must comply with remote ID and tracking requirements:
1. Ability of the aircraft to navigate between more than one point without direct and active control of the pilot.
2. Range from control station greater than 400’ and real-time remotely viewable sensor.
The ARC further recommends that UAS operating under the following circumstances be exempt from the remote ID and tracking requirement:
• The UAS is operated under ATC and contains the equipment associated with such operations (including ADS-B, transponder, and communication with ATC).
• The UAS operation is exempt from ID and tracking requirements by the FAA (e.g., for the purposes of law enforcement, security or defense, or under an FAA waiver).
Regardless of which option FAA chooses for applicability, the ARC recommends the FAA include a waiver mechanism in the remote ID and tracking rule, to allow individual operations or classes of UAS to deviate from the requirements of the rule if operations are conducted under the terms of a certificate of waiver.
The ARC also recommends the FAA apply the remote ID and tracking requirements to the remote pilot, not to the manufacturer of the UAS. The ARC further recommends the FAA require manufacturers to label their products to indicate whether they are capable of meeting applicable remote ID and tracking requirements. If a product is labeled as capable of meeting remote ID and tracking requirements, such capabilities must be enabled by default and the manufacturer must not present the user with an option to turn off the ID and tracking.
The ARC also discussed whether unmanned aircraft equipped with advanced flight system technologies that are strictly for safety purposes and that keep the aircraft within visual line of sight 33 of the remote pilot, such as a “return to home” feature, should be exempt from remote ID and tracking requirements. The ARC recommends the FAA consider whether such an exemption would be appropriate, provided the safety features cannot be readily altered or reprogrammed. 6