AAUS Submission to Public Consultation on Remote Identification Discussion Paper

The Australian Association for Uncrewed Systems (AAUS) is pleased to provide this submission to the Department of Infrastructure, Transport, Regional Development, Communications, and the Arts’ (the Department) discussion paper on Remote Identification (Remote ID).

About AAUS

The Australian Association for Uncrewed Systems is Australia’s oldest and largest industry advocacy group for drones and the emerging Advanced Air Mobility (AAM) sector. AAUS is a not-for-profit organisation which represents the drone and AAM industry across three domains: land, sea, and air. AAUS’ objective is to promote a professional, safe and commercially viable uncrewed system and AAM industry. AAUS achieves this through its industry advocacy and promotion, education and outreach, and networking activities.

AAUS provides a single representative voice for the full breadth of the drone and urban AAM industry. AAUS’ 3,000 members span small-to-large enterprise, manufacturers, licensed and unlicensed operators, training providers, academic institutions, Government, and other supporting technical and professional services in the Australian drone and AAM industry.

General Feedback:

Since commenting on an earlier draft of this Remote ID discussion paper, AAUS has invested significant time and effort on activities to build a more considered position. Activities have included a membership survey, discussion amongst AAUS membership advisory groups and other industry stakeholders. Results from our membership survey are included in the appendix.

Generally, support and feedback on the potential use of Remote ID was mixed and AAUS believes that this stems from an absence of a clear vision on what outcome we are trying to achieve with this technology and how it fits into the broader UTM and technology architecture.

For instance:

• Is the desired outcome one of airspace protection? If so, how this intended to work alongside the NationalDrone Detection System?
• Is the desired outcome one of airspace situational awareness? How does this work in Class G airspace where general aviation does not have a mandate to equip?
• Is the desired outcome to address security concerns?
• Is Remote ID a necessary building block for UTM? If so, does the technology solution require network based Remote ID (NRID)?
• Is registration a necessary building block for Remote ID?
• Does the drone industry have a social license problem and, if so, will Remote ID address this issue?
• Does the drone industry have a non-compliant operational problem and, if so, will Remote ID address this issue?

The suitability and factors that need to be considered in relation to Remote ID vary depending on desired use and the higher level “problem” it is intended to solve. In some cases, Remote ID may not be a suitable
solution at all and consequently, it is hard to provide meaningful feedback without a clear understanding of the context and intended use.

We understand that much of this work may already be occurring in the background within the Department, CASA and Airservices Australia but very little of it is visible to the aviation industry.
AAUS believes that in consultation with the broad aviation industry, the Australian Government and agencies needs to develop a clear vision around a future airspace framework, airspace integration for drones (including the use of UTM) and drone use accountability to determine the most appropriate technical solutions to implement.