FAA RemoteID compliance; an inconvenient truth

June 20, 2024 admin News

FAA RemoteID compliance; an inconvenient truth

What is the current status of RemoteID compliance in the USA? What does it actually mean? And are there examples of non-compliant broadcast RemoteID product on the market?

In the USA, you can only buy new drones with RemoteID included, or buy add-on devices for legacy/privately build drones. These products need to have an approved FAA Declaration of Conformity (DoC).

In this blog post we try to answer these questions. We will make another post about compliance of direct RemoteID products in the EU.

Summary

Yes. there are non-compliant RemoteID products on the USA market. Examples: manufacturer Holystone uses stand-alone RemoteID broadcast modules in their drones, but in their accepted FAA Declaration of Compliance they claim to use so-called standard RemoteID solutions instead (mandatory for new drones). Also, their RemoteID broadcast module is highly non-compliant. (This is based on our own tests of their device.) Next, the FT EZ ID RemoteID broadcast module uses a non-existing FCC ID. This can be a DoC registration error, but without a valid FCC ID, you can not use the product in the USA. On the other hand, the Phoenix UAS mRID RemoteID broadcast module uses an antenna that does not meet the minimum RemoteID power output power and antenna pattern requirements.

Track our official letter with complaints to the FAA here.

Frequently Asked Questions

What is relevant broadcast RemoteID regulation in the USA?

Manufacturers need to comply to:

  1. The ASTM standard F3586-22 broadcast RemoteID Means of Compliance (MoC) with additions
  2. The Federal regulation Remote Identifcation 14 CFR Part 89

The F3586 focuses on the technical requirements, whereas the 14 CFR Part 89 is more generic and also discusses production, auditing and other requirements. When a manufacturer submits a DoC with the FAA, it agrees that the product is compliant with above standards/regulation, see this screenshot.

What does an accepted FAA DoC mean?

It is only a (legal) statement in which the manufacturer states to the FAA that the broadcast RemoteID product is compliant with the FAA RemoteID regulation. It does not mean that the product is actually compliant.

Can I use such RemoteID product outside the USA?

In most cases no. There are strong similarities between broadcast/direct RemoteID in the USA, Europe and Japan, but each region has specific requirements. If that module is not approved/certified for that region, you are not allowed to use it. For instance, in Europe you need to be able to configure/enter an operatorID. In Japan, the RemoteID product needs to communicate via Bluetooth to an app.

How do you know if a broadcast RemoteID product is non-compliant?

You don’t know, unless someone files a compliant with the FAA about potential non-compliance. (Or if the manufacturer informs the FAA about non-compliance.) If that is the case, the FAA can request the manufacturer for an external audit report. This is stated in 14 CFR 89.515(b)(2). See also How can manufacturers make sure their product is compliant with the FAA broadcast RemoteID regulation?

What happens if a broadcast RemoteID product is non-compliant?

This depends on the decision of the FAA. The FAA could remove non-compliant RemoteID products from the market. This is stated in 14 CFR 89.540 Basically, an accepted DoC can be rescinded/revoked. If that would the case, those products would become useless in the USA. An example of rescinded DoC can be found here.

How can manufacturers make sure their product is compliant with the FAA broadcast RemoteID regulation?

A manufacturer can carry out an independent audit. Such audits are required by the FAA regulation anyway. Read more why audits are important. Our broadcast RemoteID products have been externally audited.

How do I know if a broadcast RemoteID product is really compliant with the FAA regulation?

Ask the shop or manufacturer if the product has audited. Also, make sure if you can update the firmware of the product. Nowadays, a lot of non-compliance issues can be solved by a firmware update. For drones with standard RemoteID, it is mandatory that the pilot can monitor continuously the RemoteID functionality. If you can’t find anything about this in the manual or app, the drone is very likely non-compliant.

Why are you doing this?

In our view, there are non-compliant broadcast RemoteID products on the market. This has negative impact on manufacturers that try to make compliant products, but also has negative impact on end-users which need to buy another RemoteID product if their product turns out to be non-compliant.

Are you not just trying to put dirt on your competitors?

See above. In the long run, all stake holders in the drone ecosystem want to have compliant products and fair competition. For the examples we mentioned in this blog post, we did extensive research: we bought and tested products. Also, we did desk research and we consulted experts within the ASTM committee on RemoteID.

How many products on the market are non-compliant?

We don’t know. We have only mentioned in this article products that are in our opinion for sure non-compliant. It could well be that there are more non-compliant products. Our main focus is and will be on our own products.

Are you filing formal complaints with the FAA for these non-compliant products?

Yes, we do. We have sent formal complaint to the FAA by email and by Fedex. Track the shipment here.

How long does it take before the FAA would make a decision regarding these products?

This is unknown. If there are updates, we will update this post.

Examples of non-compliant products

Below is a list of products that is in our view non-compliant. There could also be more non-compliant products on the market. For each product we list the reason(s) why we filed a complaint with the FAA. The actual list of non-compliance items could very well be bigger. A significant part of this review relies on public available official documents (such as FCC reports). This information may be incomplete, outdated or incorrect.

Holystone HS600

The Holystone HS600 is a drone. It has an accepted FAA DoC RID000000327 for standard RemoteID.  Standard RemoteID is different than the RemoteID regulation for add-ons (14 CFR 89.315). For instance, requirements for standard RemoteID (14 CFR 89.310) are:

  1. broadcasting live operator position (so if the operator moves, the position is updated in the RemoteID signal)
  2. show always the RemoteID status to the pilot (“The unmanned aircraft must continuously monitor the remote identification functionality from take off to shutdown and must provide notification of malfunction or failure to the person manipulating the flight controls of the unmanned aircraft system.“)

(There are more requirements for standard RemoteID.)

The Holystone HS600 product seems to have a RemoteID add-on built into the drone. The user manual does not mention anything about the live RemoteID status. Also this product review, shows that the RemoteID signals are broadcast using Bluetooth, whereas the FCC identifier mentioned in RID000000327 is 2AJ55HOLYSTONEZS This FCC ID is about a 5 GHz WLAN chip and does not mention anything about Bluetooth capability. The user manual also does not mention anything about RemoteID. It is also strange that the product has been designed in 2020 and apparently this design supports RemoteID functionality, although in 2020 the standard did not exist.

Reason for filing a non-compliance complaint with the FAA: Holystone uses a RemoteID broadcast module in the HS600, but registered it as standard RemoteID solution with the FAA. Also, the add-on itself is non-compliant with the RemoteID regulation, more info here. In addition, this HSRID01 add-on has a preset for this drone type in the configuration app.

Holystone HS720R

The Holystone HS720R is a drone. It has an accepted FAA DoC RID000000402 FCC identifier mentioned in DoC RID000000402 is 2AJ55HOLYSTONEZW This FCC ID mentions both 2.4 GHz and 5 GHz WLAN. It has a BLE chip (2.4 GHz), but the output power is -1.42 dBm which is too low for RemoteID (see section 7.8.1 Power of F3586-22). We suspect the same as with the HS600, an external RemoteID broadcast is built into the drone. The user manual also does not mention anything about RemoteID.

Reason for filing a non-compliance complaint with the FAA: Holystone uses a RemoteID broadcast module in the HS720R, but registered it as standard RemoteID solution with the FAA. Also, the add-on itself is non-compliant with the RemoteID regulation, more info here. In addition, this HSRID01 add-on has a preset for this drone type in the configuration app.

Holystone HS720G

The Holystone HS720G is a drone. It has an accepted FAA DoC RID000000411 FCC identifier mentioned in DoC RID000000411 is 2AJ55HOLYSTONEZW This FCC ID mentions both 2.4 GHz and 5 GHz WLAN. It has a BLE chip (2.4 GHz), but the output power is -1.42 dBm which is too low for RemoteID. We suspect the same as with the HS600, an external RemoteID broadcast is built into the drone. The user manual also does not mention anything about RemoteID.

Reason for filing a non-compliance complaint with the FAA: Holystone uses a RemoteID broadcast module in the HS720G, but registered it as standard RemoteID solution with the FAA. Also, the add-on itself is non-compliant with the RemoteID regulation, more info here. In addition, this HSRID01 add-on has a preset for this drone type in the configuration app.

Holystone HS720E

The Holystone HS720E is a drone. It has an accepted FAA DoC RID000000462 FCC identifier mentioned in DoC RID000000462 is 2BBPCHOLYSTONEFE This FCC ID mentions both 2.4 GHz and 5 GHz WLAN. It has a BLE chip (2.4 GHz), but the output power is 0.72 mW which is too low for RemoteID. We suspect the same as with the HS600, an external RemoteID broadcast is built into the drone. The user manual also does not mention anything about RemoteID.

Reason for filing a non-compliance complaint with the FAA: Holystone uses a RemoteID broadcast module in the HS720E, but registered it as standard RemoteID with the FAA. Also, the add-on itself is non-compliant with the RemoteID regulation, more info here. In addition, this HSRID01 add-on has a preset for this drone type in the configuration app.

Holystone HS720

The Holystone HS720 is a drone. It has an accepted FAA DoC RID000000472 FCC identifier mentioned in DoC RID000000472 is 2BBPCHOLYSTONEFE This FCC ID mentions both 2.4 GHz and 5 GHz WLAN. It has a BLE chip (2.4 GHz), but the output power is 0.72 mW which is too low for RemoteID. We suspect the same as with the HS600, an external RemoteID broadcast is built into the drone. The user manual also does not mention anything about RemoteID.

Reason for filing a non-compliance complaint with the FAA: Holystone uses a RemoteID broadcast module in the HS720, but registered it as standard RemoteID solution with the FAA. Also, the add-on itself is non-compliant with the RemoteID regulation, more info here. In addition, this HSRID01 add-on has a preset for this drone type in the configuration app.

Holystone HS700E

The Holystone HS700E is a drone. It has an accepted FAA DoC RID000000458 FCC identifier mentioned in DoC RID000000458 is 2BBPCHOLYSTONEFE This FCC ID mentions both 2.4 GHz and 5 GHz WLAN. It has a BLE chip (2.4 GHz), but the output power is 0.72 mW which is too low for RemoteID. We suspect the same as with the HS600, an external RemoteID broadcast is built into the drone. The user manual also does not mention anything about RemoteID.

Reason for filing a non-compliance complaint with the FAA: Holystone uses a RemoteID broadcast module in the HS700E, but registered it as standard RemoteID solution with the FAA. Also, the add-on itself is non-compliant with the RemoteID regulation, more info here. In addition, this HSRID01 add-on has a preset for this drone type in the configuration app.

Holystone HS900

The Holystone HS9o0 is a drone. It has an accepted FAA DoC RID000001150 FCC identifier mentioned in DoC RID000001150 is 2AJ55HOLYSTONEZS This FCC ID is similar to the Holystone HS600. Therefore the same remarks apply.

Reason for filing a non-compliance complaint with the FAA: Holystone uses a RemoteID broadcast module in the HS900, but registered it as standard RemoteID solution with the FAA. Also, the add-on itself is non-compliant with the RemoteID regulation, more info here.

Holystone HS600D

The Holystone HS6o0D is a drone. It has an accepted FAA DoC RID000001175 FCC identifier mentioned in DoC RID000001175 is 2AJ55HOLYSTONEOW The user manual of the HS600D points to the HS600 manual. Therefore the same remarks apply.

Reason for filing a non-compliance complaint with the FAA: Holystone uses a RemoteID broadcast module in the HS6o0D, but registered it as standard RemoteID solution with the FAA. Also, the add-on itself is non-compliant with the RemoteID regulation, more info here.

Holyton HT70

The Holyton HT70 is another brand of Holystone and is a drone. It has an accepted FAA DoC RID000001612 FCC identifier mentioned in DoC RID000001612 is 2AJ55HOLYSTONEOW (similar to the HS600D). Therefore the same remarks apply.

Reason for filing a non-compliance complaint with the FAA: Holystone uses a RemoteID broadcast module in the HT70, but registered it as standard RemoteID solution with the FAA. Also, the add-on itself is non-compliant with the RemoteID regulation, more info here.

Holyton HT60

The Holyton HT60 is another brand of Holystone and is a RemoteID broadcast module. It has an accepted FAA DoC RID000001611 FCC identifier mentioned in DoC RID000001611 is 2AJ55HOLYSTONEOW (This is similar to the HS600D and HT70). This is odd. How can the same FCC ID be used both for RemoteID broadcast module and a drone. The photos in the FCC documentation show a drone, not an add-on device.

Reason for filing a non-compliance complaint with the FAA: Holystone uses an FCC ID for the Holyton HT60 that points to a drone and not an add-on. You cannot register a drone as RemoteID broadcast module.

Holystone HSRID01/HSRID02

The Holystone HSRID01 is a RemoteID broadcast module. There is also the model HSRID02, but this points to the same FCC ID. Hence, on a technical level they are equal. They have an accepted FAA DoC RID000000290 and FAA DoC RID000001281 and the FCC identifier mentioned is 2AJ55HOLYSTONEBM

We bought the HSRID01 device and tested it. It is highly non-compliant. Some non-compliance issues:

  1. It does not broadcast in the mandatory Bluetooth Legacy and Bluetooth 5 Long Range format
  2. The take-off position changes during flight
  3. The output power is too low

Are there more non-compliance issues? Yes, we found more, but above already shows that the device is highly non-compliant. It is also very odd that the configuration app forces users to select an aircraft model, that includes most Holystone models. This seems to confirm that the same module is used for Holystone drones that are registered as a standard RemoteID solution.

It does not broadcast in the mandatory Bluetooth Legacy and Bluetooth 5 Long Range format

We captured the RemoteID signals of the HSRID01 using the procedure described here. The captured wireshark files can be found here (Bluetooth Legacy) and here (Bluetooth 5 Long Range). The requirement for Bluetooth legacy and Long Range are described in F3586-22, section 4. One of the requirements is that the Bluetooth signals should be Non-connectable, Non-scannable. The HSRID01 uses a different type as can be seen in the wireshark files.

The take-off position changes during flight

We mounted the HSRID01 on a drone for a test flight up to +/- 500 meter distance. During this flight, the take-off position did change multiple times. At some point the take-off position moved more than 300 meter.  See this screenshot. 14 CFR 89.320(h)(3) specified a maximum error of 100 ft.

The output power is too low

According to the FCC ID documents, the output power is -0.89 dBm with an antenna gain of 0.59 dBi In total, is this -0.3 dBm. The minimum/average output power for Bluetooth (specified in section 7.8.1 of the F3586-22 standard) is +3 dBm. It means that the output power of the HSRID01 is too low.

Reason for filing a non-compliance complaint with the FAA: see above. Output power too low, take-off position changes during flight, the device does not broadcast in the mandatory Bluetooth format.

FT EZ ID

The FT EZ ID is a RemoteID broadcast module. It has an accepted FAA DoC RID000000223 and the FCC identifier mentioned is NRF52840

Reason for filing a non-compliance complaint with the FAA: The FT EZ ID uses a non-existing FCC ID in the FAA DoC. (It is the name of the Bluetooth chip instead.) This can be a DoC registration error, but the used FCC ID cannot be found here. 14 CFR 89.530(c)(4) requires that a valid FCC ID should used. A common approach for designing electronics with radio functionality, is to use a radio module (and not individual RF chips). Those modules have already an FCC ID (provided by the module manufacturer). FT EZ ID does not use such radio module (proof). In such case, the manufacturer of the RemoteID broadcast module needs to test the product by an EMC certification lab in order to get a FCC ID. Without an FCC ID, you are not allowed to use the product in the USA. FCC ID is important, because otherwise important radio parameters like output power, in/out-of-band emissions are unknown. Also, it does not meet the label requirements of 14 CFR 89.525

Phoenix UAS mRID

The Phoenix UAS mRID is a RemoteID broadcast module. It has an accepted FAA DoC RID000000679 and the FCC identifier mentioned is 2AC7Z-ESPC3MINI1 This is a radio module with internal antenna. In technical terms, it uses the Inverted F Antenna design. This is a well-known design for modules with an internal antenna. The antenna pattern of such antenna is described here: https://www.ti.com/lit/an/swra117d/swra117d.pdf

FAA RemoteID output power and antenna pattern requirements (Bluetooth transmissions) (section 7.8.1/Annex X2. POWER LEVEL RATIONALE)

The F3586-22 MoC has the following requirements. The RemoteID broadcast module should provide a sufficiently high power transmission that generally emits in an omni-directional pattern. For this, the manufacturer has two options:

a) The average Effective Isotropic Radiated Power (EIRP) around the horizontal plane of the antenna system shall be at least +3 dBm (for Bluetooth transmission) and the Peak to Average gain around the horizontal plane of the antenna system shall be no more than 4 dB (for Bluetooth transmission). The average EIRP is calculated by adding the conducted power into the antenna system to the average gain of the antenna system in the horizontal plane; or

(b) The minimum EIRP around the entire horizontal plane of the antenna system shall be at least +3 dBm (for Bluetooth transmission). The minimum EIRP is calculated by adding the conducted power into the antenna system to the minimum gain of the antenna system in the horizontal plane.

These options are intended to allow for use of manufacturer data sheets to demonstrate compliance. The Horizontal Plane is defined as a plane of the transmission pattern that approximately corresponds to the horizontal plane during the most common average orientation of the vehicle when flying.

The F3586-22 MoC also has a section: 8.9.5 Broadcast Module and Standard Omni-directional Test, but this section is considered as a extra verification step, that the antenna pattern of the product is still sufficient Omni-directional when it is mounted on a drone. A manufacturer of RemoteID product should pass both section 8.9.5 and show compliance using manufacturer data sheets (of the used RF system/antenna).

Inverted F Antenna pattern

The antenna patterns of this antenna type are described in  https://www.ti.com/lit/an/swra117d/swra117d.pdf on page 8 and 9 for the XY plane for both vertical and horizontal polarization. They are shown here and here for reference. A first look shows that the antenna pattern is not so omni-directional, The vertical polarization pattern shows a minimum power of -28 dBm and a Peak to Average gain of about 6 dB (manual calculation based on this graph: assess the output power per 15 degree bin and calculate the peak and average). The horizontal polarization pattern shows a minimum power of -26.5 dBm and a Peak to Average gain of about 5 dB (manual calculation based on this graph: assess the output power per 15 degree bin and calculate the peak and average). These values are not enough to meet the requirements in section 7.8.1/Annex X2. POWER LEVEL RATIONALE of the F3586-22 MoC. For option a) the Peak to Average gain is too high. And for option b) even a +18 dBm transmit output power (add 18 dB to the antenna pattern values) would mean that some parts of the antenna pattern are still below the +3 dBm output power level threshold.

Reason for filing a non-compliance complaint with the FAA: The Phoenix UAS mRID does not meet the minimum power output power and antenna pattern requirements set by the F3596-22 MoC, section 7.8.1. Also, it does not meet the label requirements of 14 CFR 89.525

In general, in our opinion all RemoteID products that use an inverted F antenna, will not meet the FAA RemoteID power output power and antenna pattern requirements.

Disclaimer

A significant part of this review/article relies on public available official documents (such as FCC reports). This information may be incomplete, outdated or incorrect. If we receive new information, we will update this page accordingly.