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AriAscend Whitepaper

Remote Identification of Drones

April 9, 2017

***

Background

In November of 2015, AriAscend shared documents and e-mails that outlined a proposal for in-
air identification of unmanned aircraft systems (UAS) with the Federal Aviation
Administration (FAA), EPIC, DJI, the University of Southern Denmark, and others. The
document attached as Appendix A is the genesis of this white paper.

In July of 2016, Congress passed Public Law 114-190, the FAA Extension, Safety, and Security
Act of 2016. Section 2202 read in part:

The Administrator of the Federal Aviation Administration, in consultation with the


Secretary of Transportation, the President of RTCA, Inc., and the Director of the National
Institute of Standards and Technology, shall convene industry stakeholders to facilitate
the development of consensus standards for remotely identifying operators and owners of
unmanned aircraft systems and associated unmanned aircraft.

Subsequently, in August of 2016, Michael Crenshaw, an undergraduate at the Liberty University


School of Engineering & Computational Sciences validated the ideas put forth in the proposal for
in-air identification of UAS in his paper License Plates for Drones, Resolving Privacy Concerns
Using Remote Identification Technology, Journal of Engineering and Public Policy,
Washington Internships for Students of Engineering, August 15, 2016. (Appendix B)

On March 22, 2017, we submitted our proposal for in-air identification in response to AUVSIs
call for proposals.

On March 29, 2017, the FAA and AUVSI held a session on remote identification at the FAA
Unmanned Aircraft Systems Symposium held in Reston, Virginia. The participants discussed
remote identification and the upcoming FAA Advisory and Rulemaking Committee (ARC)
addressing this issue.

The Issue

UAS or commonly drones have been spotted near airports, critical infrastructure, military
facilities, national parks, and over other sensitive areas. Responding to these incursions, the FAA
and the Department of Defense recently agreed to restrict drone flights up to 400 feet within the
lateral boundaries of 133 military facilities. Even with these flight restrictions, if a UAS intrudes
into these areas, by the time law enforcement arrives the UAS and pilot are often long gone
leaving officers frustrated at not being able to identify the UAS nor find the remote pilot.

In-air identification is one of the most important issues facing the future of the UAS industry.
Beyond FAA flight regulations and restrictions, many states and municipalities have enacted
laws, regulations, and ordinances to regulate UAS. While some regulations may encroach upon
and be preempted by federal law, some provide legitimate protections against invasions of
privacy or address concerns about harassment. However, these regulations are ineffectual
without a way to identify UAS while they are in the air. Without a way to identify the UAS in
flight, there is a lack of accountability resulting in frustrated citizens and law enforcement. In
some cases, this frustration can lead to incidents of self-help vigilantism by citizens.

Pilot Privacy

We share the concerns of DJI (See Appendix C) and believe that any solution should not only
allow for the remote identification of UAS but also protect the privacy of remote pilots. On a
fundamental level, allowing for anyone to look up pilot information could lead to vigilantism
even if no crime has been committed. We suggest that any identification system separate the
digital license plate or ID of the UAS from the FAAs remote pilot database, and that lookup
should be limited to authorized users. Regulations should mirror those that regulate access to
personal information in state motor vehicle records or mirror the Drivers Privacy Protection Act,
18 USC 2721. Only authorized individuals such as law enforcement or attorneys in anticipation
of litigation should be able to perform any cross referencing and lookup of personal information.

We also believe a localized solution is preferable to a networked solution. This is of importance


especially where cell service may be poor or non-existent. A connection should not be required
for operations. Further, we believe that people should only be able to obtain digital IDs of UAS
in their direct line of sight. A networked solution could lead to tracking of UAS which would be
as DJI states, Orwellian and could expose confidential business information.

Accessibility

To be effective, we believe any solution has to be universally accessible. The normal citizen
should be able to capture the encrypted digital ID without having to buy any additional hardware.
Our solution envisions utilizing Bluetooth so that anyone with a cellphone or Bluetooth enabled
handheld device could capture the encrypted digital ID. In essence, it would empower the
average citizen to capture the ID of a UAS that could be potentially harassing them or causing
other issues. Law enforcement could use inexpensive specialized equipment to detect the
encrypted digital ID at longer ranges. Further, a non-networked solution such as ours would still
allow capture of digital IDs even without a cellular or network connection.

Data & Law Enforcement

We also believe that any solution should not only transmit the encrypted digital license plate
but should include encrypted GPS data including information such as location, speed, heading,
and altitude. Non-authorized individuals would be able to see the UAS on a map (or have their
handheld show a directional arrow) on their handheld with a zone of uncertainty. They would not
be able to see an exact location but would see a general area or direction so that they can

determine whether they have obtained the digital ID of the correct UAS. (in case there are
multiple UAS in the air).

The non-authorized user could then transfer the encrypted digital ID and GPS information to an
authorized user who could then look at the actual data. The additional GPS data could give law
enforcement enough information to ascertain whether there is probable cause that there was a
violation or a crime committed. It could also clear a remote pilot of any wrongdoing. If there was
probable cause, the officer could then perform a lookup of the digital ID.

Technology

In our original paper to the FAA and DJI we suggested utilizing Bluetooth beacons. We still
believe that is the best solution at the lowest cost that would satisfy the requirements of security,
pilot privacy, accountability, and accessibility. Bluetooth beacons broadcast information and do
not require a handshake with a receiver making it a much simpler system. Bluetooth technology
continues to evolve and with the advent of Bluetooth 5.0, beacons will have enough range and
will be able to transmit enough data to contain the digital ID and GPS data. With clear line of
sight, Bluetooth 5.0 beacons can transmit 255 bytes up to 400 meters. Further, Bluetooth 5.0
includes new features that detect and minimize interference. Bluetooth modules are also
lightweight, small, and draw little power. This technology is available immediately and could be
quickly integrated into existing platforms and/or flight controllers.

Cost

An important aspect of any system is cost to manufacturers, end users, law enforcement, security
organizations, administrators, the general public, and others. For manufacturers, the cost of the
Bluetooth beacons at volume could drop below $2 per unit. They could either be built into the
UAS or attached to the exterior of a UAS. For law enforcement officers and security
organizations, Bluetooth receivers with directional Yagi antennas could double or triple the
range for as little as $30.

The lookup function could be integrated into the FAA registration platform. The FAA could pay
for the development of the lookup and authorization functions up front and recover costs for
development and administration through a charge for data lookup by authorized users.
Development of the apps could be done by third parties and those third parties could charge for
the app.

Transition

One concern is how to utilize the technology with UAS that are in the market. There are a
number of potential solutions. The first one being the easiest is to only apply the ID requirement
to UAS made after a certain date. This will allow for manufacturers to integrate the systems into
their equipment. Another option is to require UAS to have a simple external beacon that
transmits only the encrypted digital ID. This would alleviate any issues of trying to integrate a
beacon with systems that were not designed to export data such as the GPS information to
another transmitter. The last option would be to have the beacon unit have its own GPS system.

However, that is less desirable as the unit would need to be larger, heavier, and would likely
needs its own power supply. Potential downsides to an external beacon include interference with
either the control or video links of a UAS. However, given that Bluetooth 5.0 detects and
minimizes interference, this may not be a big concern.

Detection Eco-System

We also believe that these beacons should be part of a detection eco-system. While Bluetooth
may be adequate for low altitude operations, we believe that it would make sense to have
different systems for different types of operations. For example, operations that take place at
higher altitudes could complement Bluetooth with ADS-B out. In addition, private and
commercial aircraft could place Bluetooth beacon detectors on board to record the ID and data of
UAS that pass close by. These detectors could also serve as a last resort collision warning
system. Further, ground based detectors could be deployed at low cost around sensitive areas
such as airports, military installations, and critical infrastructure.

Finally, we believe that in some cases, such as UAS below 250-300 grams a digital ID does not
make technological or regulatory sense though that is a policy decision to be made by
policymakers.

Conclusion

Bluetooth beacons are a cost effective, accessible, technologically feasible, localized, and
effective way of creating accountability for UAS and their operators. Our solution provides a
narrowly tailored approach to identify UAS while in the air while preserving pilot privacy. We
hope that these ideas are integrated into the recommendations of the ARC as part of the
identification ecosystem that is necessary to secure our airspace, ensure accountability, and
advance the UAS industry.

Sincerely,

Kenji Sugahara
Author

About the author:

A 5-year veteran remote pilot with a passion for aerial cinematography and photography, Kenji
Sugahara is the CEO of Ariascend Corporation and a principal at Dronescape Consulting. He is
also the Policy Director for the 25,000 member Drone User Group Network. An attorney and one
of the first Part 107 remote pilots in Oregon, he helps advise the Oregon Legislature on drone
issues and is an Oregon Tourism Commissioner. An active member of the community, he serves
as an advisor for a STEM initiative in Yamhill County, Oregon. In September of 2013, he was
part of a team that was the first to fly a UAS inside a state capitol building.

Appendix A
Proposal for In-Air Identification of UAS
Background:

Unmanned aerial systems are proliferating at an amazing rate. People are buying
them for business, hobby, and public purposes. However, there is no means of
identifying the owner/operator of an unmanned aerial system while it is in the air.
In most instances the airframes are too small for identification numbers. Unmanned
aerial systems have been spotted in prohibited areas with no possibility of tracking
down the owner/operator. The Federal Aviation Administration is proposing that all
unmanned aerial systems must be registered to prevent bad behavior. However,
registration would only be effective if law enforcement was able to identify the
owner/operator. In most instances, the unmanned aerial system is flown away and
the owner/operator is never found. There is a significant need for a system that
allows for the identification of an unmanned aerial system while it is in the air, the
capture of altitude and positioning information of the unmanned aerial system, and
the ability to tie the unmanned aerial system to its owner/operator.
Solution:

One possible solution is to utilize Bluetooth Smart Beacons. Each UAS would be
required to have an embedded transmitter that transmits a unique authenticated ID
code along with GPS coordinates on a regular interval. Anyone with a cellphone and
the correct app will be able to obtain the indentification code and GPS track while
the UAS is in range. Authenticated users, such as law enforcement officers will be
able to query the FAA database and obtain the owners information if there is
enough cause to believe that there was a violation. Non-authenticated users will be
able receive the indentification code and GPS track but will not be able to query the
FAA database. However, non-authenticated users will be able to transfer the
information to an authenticated user who will then be able to perform the lookup if
there is enough cause to believe there was a violation.
With the adoption of the newest specification (4.2), BLE will have a range of up to
400 meters. Having the BLE chip tied directly into the power system of the UAS will
allow the BLE beacon to transmit at full power. This distance should cover most use
cases.
The use of BLE will allow for rapid adoption by UAS and flight controller
manufacturers. BLE chips are extremely inexpensive. Other solutions such as
miniaturized ADS-B boards and transmitters such as the one proposed by the
University of Denmark are likely to be expensive. In addition, the required receivers
are likely to be expensive. The use of BLE will allow law enforcement and the public
to use common cellphones instead of having to purchase specialized receivers.
Furthermore, BLE data can be received even without a cellphone connection.

CONFIDENTIAL- By Kenji Sugahara


A diagram of the data flow is attached. (See Fig 1, 2, 3)
With BLE appliances becoming prevalent, it would likely be required that any
identification code have a common sequence of strings at the beginning of the
identification sequence in order to filter out non-UAS BLE identification codes.
Having all UAS outfitted with BLE opens up a multitude of possible uses for the
beacons especially if bi-directional communication is enabled.

Examples:
BLE receivers can be deployed around sensitive installations. These receivers could
detect intrusions by BLE equipped UAS.
Geo-fencing can be defeated in many instances by taping tin foil on top of the GPS
puck. BLE transmitters could be placed around sensitive installations that create a
bubble around the installation. With the right coding, UAS could be programmed to
not intrude into those bubbles.
With bi-directional communication, BLE could be used as a proximity alarm for both
UAS and manned aircraft operators; an alarm of last resort to speak.
Use with UTM:
BLE could be complimentary to any UTM solution. On-board ADS-B could create a
mess on ATC screens if all UAS are using it. BLE could be used for flights below
certain flight levels. ADS-B could be activated for UAS flights that exceed those flight
levels.
Societal benefits to using this technology:

The limited range of BLE preserves the privacy of operators wile providing the
public an avenue to identify UAS that they perceive are "violating" the law. Being
able to identify owners may allay the fears of the public who may be tempted to take
action on their own.

CONFIDENTIAL- By Kenji Sugahara


1. Unmanned Aerial System (UAS)

4. UAS Identification
2. Sensor data: Code 5.
GPS 2. Sensor Data authorized
Altitude 3. Transmitter handheld
Other mobile
device

9. UAS operator and 10. Credentials


UAS information 4. UAS
4. Identification Code Identification Code
2. Sensor Data

8. Internet

6.
non- 4. Identification Code
authorized 2. Sensor Data
handheld
mobile
device 7. Database/
application
server
FIG 1.
Unauthorized Handheld Mobile Device

17 MAP
BEACON NOTIFICATION
SYSTEM

11 ON 4 UAS ID
2 Sensor Data
12 OFF

20 Track while
13 STARRED in range

14 SETTINGS

15 UAS IN RANGE 19 YOU

12312523ADAS123

16 RECENT UAS ID

1234234DA1234555
12312442325RS224 21 Time/Date 22 Send

FIG 2.
Authorized Handheld Mobile Device
Additional Screens

17 MAP 25 Operator of UAS


BEACON NOTIFICATION Identification Code:
SYSTEM 12423534ASD234
4 UAS ID Operator: John Smith
23 Search 2 Sensor Data Address:
123 Main St.
13 Starred 20 Track Brownsville, CA 98753
while in DOB: 12-12-65
range Phone: 908-555-1212

UAS Model: ASGFSDV


Endorsements: Commercial
19 YOU
24 List of UAS
Identification Codes

Lookup
21 Time/Date Operator

FIG 3.

Appendix B
LICENSE PLATES FOR DRONES
Resolving Privacy Concerns Using Remote
Identification Technology
Michael Crenshaw

Abstract
Cars and airplanes are required to display identifying marks (November numbers and license plates) so
that their drivers can be held responsible for wrongdoing. Now with more registered UAS in the United
States than licensed pilots, it is time to implement a similar rule for unmanned flying devices. The
Federal Aviation Administration (FAA) already requires UAS owners to display registration numbers on
their craft, but many are so small that the numbers could not be read at any significant altitude. The
current rule could theoretically aid prosecution of recklessly-flown UAS that crash, but it will be
ineffective in dealing with reckless flyers who do not crash their devices and those who use their devices
to violate privacy. Therefore the FAA should require UAS to emit a low-power radio beacon identifying
the UAS to anyone within a roughly visual-line-of-sight (VLOS) area.

Keywords: drone, UAS, UAV, privacy, surveillance, license plate, beacon, location services
Contents
Abstract ......................................................................................................................................................... 1
Introduction .................................................................................................................................................. 4
Privacy ........................................................................................................................................................... 6
A Brief History......................................................................................................................................... 6
Status Quo Law ....................................................................................................................................... 7
Privacy and Innovation ........................................................................................................................... 8
Privacy and Free Speech ......................................................................................................................... 8
UAS Technology .......................................................................................................................................... 10
Terminology.......................................................................................................................................... 10
Development ........................................................................................................................................ 11
Applications .......................................................................................................................................... 11
UAS Regulations .......................................................................................................................................... 12
Rules for Commercial Operation .......................................................................................................... 12
Hardware Requirements ................................................................................................................ 12
Operator Requirements ................................................................................................................. 13
Operation Limitations .................................................................................................................... 13
Registration .......................................................................................................................................... 13
Coming Regulatory Changes................................................................................................................. 14
Remote Identification (Beacon) Technology .............................................................................................. 15
Possible Beacon Implementations ....................................................................................................... 15
Visible Light-Based Beacon (LightCense) ....................................................................................... 15
Airspace Management Beacon (ADS-B) ......................................................................................... 16
Bluetooth Low Energy (BLE) Beacon .............................................................................................. 16
Risk of Spoofing .................................................................................................................................... 17
Policy Recommendation ............................................................................................................................. 18
Authority............................................................................................................................................... 18
Scope .................................................................................................................................................... 18
Use ................................................................................................................................................. 19
Size ................................................................................................................................................. 20
Contents of the License Beacon ........................................................................................................... 21
Implementation and Enforcement ....................................................................................................... 21
UAS Manufacturers Role............................................................................................................... 21
Risks ...................................................................................................................................................... 21
Benefits................................................................................................................................................. 22
Conclusion ................................................................................................................................................... 23
Introduction
Many groundbreaking technologies, when first developed, raise concerns about possible societal
disruptions.1 The rapid emergence of Unmanned Aerial Systems has been no different. Concerns include
weaponization2, smuggling3, and other physical acts of lawlessness. But a more mundane fear has raised
perhaps even more concern: the threat to privacy.

Unmanned Aerial Systems (UAS) have the unique capability to fly low and in some cases even hover for
sustained periods.4 Yet they do not necessarily offer a clear hint of the operators identity. UAS may be
equipped with information-gathering technology from simple visible-light cameras to infrared heat
sensors. These devices may scan and store sensitive information about people on the ground, offering
little recourse to those surveilled.

Some UAS are so small that they are undetectable to the naked eye when in flight.5 Even when close
enough to be clearly heard, a UASs identifying markings (if any exist) are probably unreadable. This not
only makes UAS potential spying tools, but it makes them particularly dangerous ones because of their
un-detectability and/or anonymity.

In response to concerns of untraceable surveillance activities, privacy advocates have proposed a sort of
remote license plate or license beacon for small UAS where the use of a visible identifier would be
impractical.6,7 This paper defends a recommendation for new Federal Aviation Administration
regulations requiring the installation and use of such a beacon on certain UAS. This requirement is
justifiable as a safety measure analogous to the use of tail number on airplanes, but the additional
privacy protection benefits would be significant.

1
Thierer, Adam. Permissionless Innovation: The Continuing Case for Comprehensive Technological Freedom.
Arlington, Virginia: Mercatus Center at George Mason University, 2016.
2
Stanley, Jay. Five Reasons Armed Domestic Drones Are a Terrible Idea. August 27, 2015.
https://www.aclu.org/blog/free-future/five-reasons-armed-domestic-drones-are-terrible-idea (accessed July 17,
2016).
3
Valencia, Nick, and Michael Martinez. Drone Carrying Drugs Crashes South of U.S. border. January 23, 2015.
http://www.cnn.com/2015/01/22/world/drug-drone-crashes-us-mexico-border/ (accessed July 17, 2016).
4
Though consumer-line UAS usually have under thirty minutes of flight time on one battery charge, advances in
battery technology will continue to stretch this limit.
5
Schlag, Chris. "The New Privacy Battle: How the Expanding Use of Drones Continues to Erode Our Concept of
Privacy and Privacy Rights." Journal of Technology Law & Policy 23 (2013): 1-22.
6
The call for a license beacon originated with the Center for Democracy and Technology (CDT) in response to
privacy concerns.
Hall, Joseph Lorenzo. 'License Plates' For Drones? March 8, 2013. https://cdt.org/blog/license-plates-for-drones/
(accessed July 17, 2016).
7
Amie Stepanovich, at the time with the Electronic Privacy Information Center (EPIC), worked with Dr. Joseph
Hall of the CDT to further develop his ideas. This paper attempts to pick up where they left off and more fully
develop their proposal.
Hall, Joseph Lorenzo, and Amie Stepanovich. "License Plates & Drone Information Requirements." Joseph Lorenzo
Hall. October 12, 2013. https://josephhall.org/misc/darc-license-plates-session.pdf (accessed July 18, 2016).
The first Part will discuss privacy from both a philosophical and a legal perspective, providing a history
and explaining why it is such a contentious issue. The second Part will describe the current state and
likely future of UAS technology. The third Part will discuss current UAS regulations and gesture toward
changes that will arrive as technology develops. The fourth Part will describe the technologies available
to UAS manufacturers to implement a license beacon. The fifth Part will describe the proposed
regulation along with its benefits, risks, and limitations. The sixth Part will conclude.
Privacy
A Brief History
Privacy evades definition. When the U.S. Constitution was penned, the meaning of security against
unreasonable searches and seizures8 was more obvious. But today information thought of as private is
transferred along wires and through the air, passing among various third parties on its way. Social media
offer outlets for information people are willing to share with a loosely-defined set of connections or
friends, but not necessarily the whole world. And still people generally expect this information to
remain secure against outside surveillance. The simultaneous expectation for a right to open
communication and to privacy has been wryly dubbed the privacy paradox.9

People have worried about technologys apparent threats to privacy for a long time. In the 1890 Harvard
Law Review article considered the originating document of the right to privacy,10 Warren and Brandeis
echo a fear which has resounded through the following decades: what is whispered in the closet will be
shouted from the mountain-tops.11

The introduction of the Kodak camera in 188812 raised concerns that it would become highly
disruptive to society because of invasions of privacy.13 In the following decades, court rulings and some
legislation worked to mitigate the privacy impact. And many people simply adapted: they developed
norms about when and where photography was acceptable.14

Despite this and other examples of social adaptation to technology, some predict that the notion of
privacy is moving toward obsolescence as a new generation emerges which has never known a world
without pervasive social networking. But there remains a strong contingent of the population which
simultaneously demands the right to broadcast information to whomever they choose while keeping it
hidden from everyone else.15 Some advocate Privacy Enhancing Technologies to counteract privacy-
diminishing technologies.16 Others demand government protection for privacy,17 identifying UAS

8
U.S. Constitution, amend. 4, sec. 1.
9
Jorstad. "The Privacy Paradox." William Mitchell Law Review 27 (2001): 1503-1526.
10
Bratman, Benjamin E. "Brandeis and Warren's The Right to Privacy and the Birth of the Right to Privacy."
Tennessee Law Review 69 (2002): 623-651.
11
Warren, Samuel D., and Louis D. Brandeis. "The Right to Privacy." Harvard Law Review 4, no. 5 (1890): 193-
220.
12
Kodak. Milestones. n.d. http://www.kodak.com/ek/us/en/corp/aboutus/heritage/milestones/default.htm
(accessed August 4, 2016).
13
Thierer, Permissionless Innovation, 69.
14
Ibid., 69-70.
15
Numerous special interest groups defend privacy rights, including the Electronic Frontier Foundation, the
Electronic Privacy Information Center, the American Civil Liberties Union, and the Center for Democracy and
Technology.
16
Wittes, Benjamin, and Jodie C. Liu. "The Privacy Paradox: The Privacy Benefits of Privacy Threats." Brookings.
May 2015. http://www.brookings.edu/~/media/research/files/papers/2015/05/21-privacy-paradox-wittes-
liu/wittes-and-liu_privacy-paradox_v10.pdf (accessed July 18, 2016).
17
Strahilevitz, Lior Jacob. "Toward a Positive Theory of Privacy Law." Harvard Law Review 126 (2013): 2010-2042.
surveillance as a potential trigger for another Warren and
Brandeis moment.18 Many suggest a combination of technology This paper will assume that
and regulation (e.g. legal protection for encryption technologies19) privacy, whether technically
will be necessary to establish sufficient privacy protections. a right or not, is valuable
Though technology will continue to make the dissemination of and important and should
information progressively easier, history suggests that people will enjoy at least some minimal
continue to demand and develop mechanisms to maintain various legal protection.
forms of privacy. Therefore, this paper will assume that privacy,
whether technically a right or not, is valuable and important and
should enjoy at least some minimal legal protection.

Status Quo Law


There are currently specific laws enumerating corporate responsibilities for protecting consumers
information. The specific laws, however, are limited to sensitive industries such as banking or
healthcare. This cherry-picking mode of privacy protection contrasts with European omnibus privacy
laws which address privacy violations in whichever sector they appear.20 U.S. federal regulatory agencies
are entrusted with the role of filling in the gaps where the letter of the law does not specifically apply.

The FTC has over the past two decades taken an active role in identifying unfair or misleading data
security practices and pursuing corrective action against the offending organizations. 21 Data security
entails ensuring information is not accessible to the wrong people; but the FTC is more concerned about
information which has some material value (e.g. Social Security numbers) rather than merely a private
value. Though the FTC does not hold to a full-liability model for data breaches, it will enforce strict
penalties against companies who mishandle customer data. 22

The FCC is stepping further into the realm of data security regulation, taking a more heavy-handed full
liability approach.23 It remains to be seen whether this regulatory regime will support or at least tease
out the implications of privacy for emerging technologies.

Neither the FTC nor the FCC necessarily have authority to determine what information should be private
or how companies should maintain privacy in a technical sense. But both are able to use their statutory

18
Calo, M. Ryan. "The Drone as Privacy Catalyst." Stanford Law Review Online 64, no. 29 (December 2011): 29-
33.
19
For example, the Electronic Frontier Foundation (EFF) has called on the White House to clarify the executive
stance on encryption of personal devices such as smartphones.
Reitman, Rainey. Where's Obama's Encryption Policy? February 23, 2016.
https://www.eff.org/deeplinks/2016/02/wheres-obamas-encryption-policy (accessed July 17, 2016).
20
Strahilevitz, "Toward a Positive Theory of Privacy Law."
21
The Heritage Foundation. Federal Online Data Security Regulation: Where Are We Going? June 28, 2016.
http://www.heritage.org/events/2016/06/federal-online-data-security-regulation (accessed July 18, 2016).
22
Ibid.
23
Ibid.
power to determine when companies have behaved irresponsibly and then to pursue corrective
measures.

Privacy and Innovation


Some argue that a strict adherence to a strong privacy regime stifles innovation while offering little
benefit in return. For example, massive collections of data are critical to certain emerging business
models, either as the key underlying technology or as a funding mechanism to make a product viable.24
Search engines use past searches to improve personalized results, social networks collect information to
facilitate targeted advertising, and online retailers use past purchases to recommend related products.25
These online features offer a valuable service and may even protect users privacy by replacing
undesired human interactions with digital ones.26 However, the sheer amount of personal data revealed
to online services raises serious privacy concerns.

It has been suggested that psychological harms such as privacy should receive diminished
consideration when regulators approach new technologies because of the overwhelming benefits of
innovation.27 A hands-off approach may be justified, considering the number of now-commonplace
technologies which initially triggered major fears of societal disruption such as the telephone,
photography, transistors, and location services.28 One could argue by analogy that UAS tech will be far
more self-regulating than the more cautious commentators admit.

However even the champions of innovation identify some exceptional moments when regulation may
be appropriate.29 This paper will argue that certain UAS regulations fit within such an exception and that
some privacy protections are necessary while attempts are made to preserve innovation.

Privacy and Free Speech


Demands for privacy have long clashed with demands for free speech. Journalists in particular have
been strong advocates for holding fast to freedom of speech in the face of demands for more strenuous
privacy protections.

UAS have been used by journalists to capture images of everything from natural disaster damage to
costumes of Star Wars characters before the films release.30 While some UAS uses by the media have

24
[T]he collection and analysis of information, facilitated by recent advances in information and
communications technologies, has led to innovation in the operations of firms from online retailers to theme parks
to financial services companies.
Goldfarb, Avi, and Catherine Tucker. Privacy and Innovation. Vol. 12, in Innovation and the Economy, by Josh
Lerner, & Scott Stern, 65-89. Chicago: University of Chicago Press, 2012.
25
Ibid., 67-69.
26
Wittes and Liu, "The Privacy Paradox: The Privacy Benefits of Privacy Threats," 2-3.
27
Thierer, Permissionless Innovation, 46.
28
Ibid., 68-71.
29
Ibid., 33-35.
30
Kakaes, Konstantin. Drones Can Photograph Almost Anything. But Should They? April 21, 2016.
http://www.cjr.org/the_feature/drones_can_photograph_almost_anything_but_should_they.php (accessed July
21, 2016).
seemed more lucrative than others, US case law had erred on the side of protecting the presss right to
gather and publish information of public interest.
UAS Technology
UAS technology is advancing at an amazing rate. Once mostly confined to the R&D departments of
military development organizations31, UAS are now available to everyone from college students to
young children.32 New applications for UAS are emerging constantly as cutting-edge technologies are
fitted for flight. It seems many things that can be done from the ground can be done more effectively
from the air, and things impossible from the ground are now easily accomplished with UAS. This Part will
give an overview of UAS technology, focusing on aspects relevant to privacy concerns.

Terminology
Several terms have been used to describe what people generally think of as belonging to the group of
unmanned flying devices. The term drone carries negative connotations due to its association with
legally- and morally-controversial targeted killings by various military
and intelligence organizations.33,34

The term Unmanned Aerial Vehicle (UAV) provides a friendlier This paper will use the
alternative. It refers only to the flying device and not to the supporting term UAS when
system including remote control(s) and operator(s). The broadest term referring to the flying
is Unmanned Aerial System (UAS), which encompasses not only the device along with its
flying device but also its ground support systems.35 support system and
The Federal Aviation Administrations rules for the Operation and
UAV when referring to
Certification of Small Unmanned Aircraft Systems uses all three terms, the flying device alone.
but UAS is by far the most frequent.36 This paper will favor using the
term UAS referring to either the UAV alone or the entire UAS.

31
The first remotely-piloted vehicle was flown in 1935. There is a long and steady history of military UAS
development since that time, culminating in their recent roles in the Middle East.
Schlag, "The New Privacy Battle, 3-6.
32
Any number of sources could support the relative ease of obtaining a UAS, but this one is particularly poetic.
McKenzie, Bryan. Drones are Here, and not too Expensive. February 17, 2013.
http://www.dailyprogress.com/news/local/mckenzie-drones-are-here-and-not-too-expensive/article_4f810398-
795e-11e2-b598-0019bb30f31a.html (accessed July 29, 2016).
33
Corcoran, Mark. Drone Wars: The Definition Dogfight. February 28, 2013. http://www.abc.net.au/news/2013-
03-01/drone-wars-the-definition-dogfight/4546598 (accessed July 28, 2016).
34
It is the experience of this author that many people are unfamiliar with the more technical terms UAS and
UAV. This unfamiliarity, along with the ongoing decoupling of the term drone from negative images, justifies the
use of the term in this papers title.
35
Corcoran, Drone Wars: The Definition Dogfight.
36
UAS appears in the final rule document 2297 times versus UAV with 52 and drone with 43 (some of those being
in reference to organizations with the word drone in their name). While the battle to suppress the term drone
appears to be waning, strong preferences remain for the less politically-loaded terms.
Federal Aviation Administration, Office of the Secretary of Transportation, and Department of Transportation.
"Operation and Certification of Small Unmanned Aircraft Systems." FAA.gov. June 21, 2016.
https://www.faa.gov/uas/media/RIN_2120-AJ60_Clean_Signed.pdf (accessed July 28, 2016).
Development
UAS have enjoyed most of their development and attention as part of military programs, but have more
recently come to the forefront as domestic tools as well.37 Hobbyist model airplane flyers have made an
easy transition from small airplanes and helicopters (which meet the technical definition of UAS) to the
devices more commonly referred to as UAS (such as quadcopters). The wild popularity of inexpensive
hobbyist UAS such as the DJI Phantom series has rushed drones in front of the public eye.

Legal ambiguity38,39 and restrictions40 have so far prevented UAS from entering the commercial sphere in
force. The next Part will discuss regulatory issues in more depth. This Part will focus on commercial
applications which have successfully navigated the regulatory framework and those which have been
proposed for future implementation. It will also discuss some applications and technologies commonly
used among hobbyists, especially insofar as they impact privacy.

Applications
As an emerging and quickly-developing technology, UAS applications are surfacing on an almost daily
basis. Many are intuitive and uncontroversial, but some developments have sparked extensive public
debate. Because regulations should account for current UAS applications and anticipate future
developments, this section will highlight some of the more prominent UAS uses and gesture toward
those that appear on the horizon.

37
Schlag, The New Privacy Battle, 6.
38
The FAA, while still developing rules for commercial UAS operations, used authority under Section 333 of the
FAA Modernization and Reform Act of 2012 to grant waivers to commercial operators.
Federal Aviation Administration. Section 333. June 24, 2016.
https://www.faa.gov/uas/getting_started/fly_for_work_business/beyond_the_basics/section_333/ (accessed July
30, 2016).
39
To date, commercial development in the United States, especially among small- and medium-sized
enterprises, has been hindered by haphazard FAA rules and regulations and unclear export controls.
Stohl, Rachel, and Shannon Dick. The Feds Just Put the US Back in the Global Drone Race. July 17, 2016.
https://www.wired.com/2016/07/feds-just-put-us-back-global-drone-race/ (accessed July 30, 2016).
40
Yadron, Danny. Amazon and Google's Drone Delivery Plans Hit Snag with New US Regulations. June 21, 2016.
https://www.theguardian.com/technology/2016/jun/21/amazon-google-drone-delivery-new-faa-regulations-
obama (accessed July 30, 2016).
UAS Regulations
For some time, UAS operated in a legal gray zone.41 Hobbyists, researches, and developers operated
their UAS without being certain whether they were breaking the law. In 2012, Congress mandated that
the Federal Aviation Administration (FAA) implement new drone rules by 2015 and provide for the
operation of UAS test sites to aid rule development.42 The FAA implemented a UAS registration process
in December 201543 and then released a more comprehensive set of rules in June 2016.44

Rules for Commercial Operation


The new rules published by the FAA in June 2016 (Part 107) establish the criteria for commercial UAS
operation. Though the ruling does not apply to UAS operated as model aircraft (i.e. for hobby or
recreational use),45 these regulations tend to work as best practices for hobbyist operators.

Hardware Requirements
The UAS must weigh less than 55 lbs. (25 kg). The rule also applies to UAS as light as 0.55 lbs.46 Smaller
UAS are not explicitly regulated by the FAA and pose little threat to other aircraft.

The FAA requires that the UAS operator inspect the hardware before
each flight.47 The operator must also produce the device for FAA For a small UAS in flight,
inspection upon request along with any required paperwork.48 even external markings
The UAS registration number may be marked on the UAS using a may be difficult or
permanent marker, label, or engraving. The marking does not even impossible to read for
have to be externally visible. [It] may also be enclosed in a someone on the ground.
compartment that is readily accessible, such as a battery
compartment.49 For a small UAS in flight, even external markings may
be difficult or impossible to read for someone on the ground.

41
Stohl and Dick, The Feds Just Put the US Back in the Global Drone Race.
42
FAA Reauthorization and Reform Act of 2012, Public Law 112-95. https://www.gpo.gov/fdsys/pkg/PLAW-
112publ95/pdf/PLAW-112publ95.pdf (accessed July 30, 2016).
43
Jansen, Bert. FAA Begins Drone Registry Dec. 21. December 14, 2015.
http://www.usatoday.com/story/news/2015/12/14/drone-registry-faa/77275676/ (accessed July 2015, 2016).
44
Dorr, Les, and Alison Duquette. Press Release DOT and FAA Finalize Rules for Small Unmanned Aircraft
Systems. June 21, 2016. https://www.faa.gov/news/press_releases/news_story.cfm?newsId=20515 (accessed July
30, 2016).
45
Federal Aviation Administration et al., "Operation and Certification of Small Unmanned Aircraft Systems, 68-
80.
46
Federal Aviation Administration. "Summary of Small Unmanned Aircraft Rule (Part 107)." FAA.gov. June 21,
2016. https://www.faa.gov/uas/media/Part_107_Summary.pdf (accessed July 30, 2016).
47
Ibid., 2.
48
Ibid., 3.
49
Federal Aviation Administration. "Unmanned Aircraft Systems (UAS) Frequently Asked Questions/Help."
FAA.gov. July 15, 2016. https://www.faa.gov/uas/faqs/ (accessed August 1, 2016).
Operator Requirements
The operator must be at least 16 years old, pass an aeronautical test, and be vetted by the TSA.50

Operation Limitations
Because of the FAAs focus on airspace safety, there are significant limitations on UAS flight.51

UAS may fly a maximum of 400 feet above ground level.


UAS may fly a maximum of 100 mph.
UAS must yield the right-of-way to all other aircraft.
Flight time is limited to daylight hours.
UAS may not fly over any persons not directly involved in the operation. (i.e. No flying over
strangers)
UAS must always remain within the visual line-of-sight (VLOS) of either the operator or a
designated visual observer.

The VLOS and no flying over strangers requirements limit out many useful commercial applications,
such as Amazons package delivery ambition.52 Some companies will likely seek waivers for very specific
applications such as linear inspection tasks (e.g. railroads and pipelines).53 But innovation will be limited
for UAS until the VLOS and no-strangers restrictions are lifted.

Registration
All UAS operators with devices from .55 to 55 lb. must register with the FAA.54 Recreational operators
must provide their name, address, and email address; and they may operate as many UAS as they want
under one registration.55 Commercial operators must provide the same identification information, but
they must also register each UASs make, model, and serial number.56

50
Federal Aviation Administration. "Summary of Small Unmanned Aircraft Rule (Part 107)." 2.
51
Ibid, 1-2.
52
The article cites the at least one pilot per UAS rule as another significant barrier, because it prevents
automated delivery by a computer system. However, this rule would likely be solved by the same sense and
avoid technology required to lift the VLOS and strangers rules.
Yadron, Danny. Amazon and Google's Drone Delivery Plans Hit Snag with New US Regulations. June 21, 2016.
https://www.theguardian.com/technology/2016/jun/21/amazon-google-drone-delivery-new-faa-regulations-
obama (accessed July 30, 2016).
53
Sievers, Mike. "Small Drone Rules Announced...Now What?" Lexology. June 29, 2016.
http://www.lexology.com/library/detail.aspx?g=f940ed22-5b71-4b3a-a484-281149e0850c (accessed August 1,
2016).
54
Federal Aviation Administration. "Getting Started." FAA.gov. July 21, 2016.
https://www.faa.gov/uas/getting_started/ (accessed August 1, 2016).
55
Federal Aviation Administration. "Unmanned Aircraft Systems (UAS) Frequently Asked Questions/Help."
56
Ibid.
The UAS operator must have their registration information with them whenever operating their UAS and
must present it to any law enforcement official who requests it.57

As mentioned among the hardware regulations, the registration number must be recorded on the body
of the UAS, though not necessarily on an exterior surface.58 The registration number functions as the
license plate or tail number for the UAS. Though presumably the registration number would be used
to return a lost UAS to its owner, the registration database is currently not publicly searchable and only
occasionally searchable to law enforcement. Some operators inscribe contact information on their UAS
in case it is lost.

Coming Regulatory Changes


John S. Langford, CEO of Aurora Flight Sciences Corporation, said at the 2016 American Institute of
Aeronautics and Astronautics (AIAA) Demand for Unmanned convention59 that two barriers remain to
large-scale commercial UAS operation:

1. The development of reliable, affordable detect-and-avoid technology


2. An industry transition from a many-people-per-aircraft-operation model to a many-operations-
per-person model

Technical developments and subsequent regulatory changes will remove both hurdles. Detect-and-avoid
technology is the final step to enabling beyond-VLOS flight. Once that step is taken, privacy advocates
will have no more time to predict issues: their concerns will either materialize or not.

This paper anticipates a time when beyond-VLOS and over-stranger flight will be permissible and
commonplace, because it is at this point that many privacy concerns come into full force.

57
Ibid.
58
Ibid.
59
This author personally attended the convention and made the related notes. There is no publicly-available
recording of the cited event at the time of publication.
John S. Langford, Keynote Address (lecture, AIAA DEMAND for UNMANNED Conference, Washington, D.C.,
June 16, 2016).
Remote Identification (Beacon) Technology
A policy recommendation is only as good as the technology which exists to make it feasible. This section
describes the requirements for an effective license beacon implementation and suggests current and
near-future technology which may fit those requirements.

Possible Beacon Implementations


A couple attempts have been made to implement license-plate-like tools on UAS, but they have thus far
fallen short. For completeness sake, the following sections will first describe the past attempts and then
it will propose a novel solution which may serve as an initial implementation of the recommendation.

Visible Light-Based Beacon (LightCense)


Technologists at UC Berkeley have developed a light-based license plate systems for UAS.60 It relies on
an array of LED lights mounted on the bottom of a UAS emitting patterns of differently-colored lights
which may be interpreted by a smartphone app to provide identification information. The creators of
this technology suggest that one could come to learn different UAS light patterns by memory.

The first problem with this technology is its limitation to true visual line of sight. It is reasonable to think
a privacy-conscious individual would be interested not only in the UAS they can see, but the one
hovering just behind a tree in the distance. Radio frequencies pierce more soft barriers (such as
foliage), making it a slightly more privacy-conscious technology.

Second, there is a question of whether making UAS more visible is wise. People tend to become hyper-
aware of the privacy threat posed by UAS when they can be heard buzzing above.61 Similarly, flashing
visible lights may make people so privacy-conscious that they lose a sense of perspective and make
unreasonable demands in the name of privacy. Similar concerns apply to a lesser extent to radio-
frequency beacons because they are invisible unless explicitly sought using a receiver.

Third, visible lights may be distracting and/or annoying. If UAS regularly fly over highways where drivers
eyes may be drawn away from the road or perhaps over livestock which may be disturbed, then
LightCense may do more social harm than good.

Finally, Lightcense does not offer much room for expansion. A very limited amount of information may
be transmitted by flashing lights, mostly because smartphone cameras have relatively limited recording
frame-rates: even if the UAS could transmit a very fast series of light flashes, the smartphone could only
receive a limited set of them. And speeding up light transitions would defeat one appealing factor of
LightCense the idea that a person could identify a light pattern by memory.

Despite these concerns, LightCense offers an excellent proof-of-concept for a license beacon, albeit in a
different area of spectrum. It shows that there is an interest in technologies which make UAS easily
identifiable by someone with no more hardware than a smartphone and no specialized expertise.

60
LightCense. LightCense A low-altitude identification system for UASs. n.d. http://www.lightcense.co/
(accessed August 1, 2016).
61
Langford, Keynote Address.
Airspace Management Beacon (ADS-B)
By 2020, all piloted aircraft will be required to operate Automatic Dependent Surveillance-Broadcast
(ADS-B) tracking and collision avoidance technology.62 This is the next generation of airspace
maintenance hardware and software and will take a great step toward making the skies safer.

Some have suggested that ADS-B could be implemented on UAS to provide an identification beacon.63
While this could be practical in the far future, for the moment it is ineffective. ADS-B transmitters are
relatively heavy and would be impractical for small UAS.64 Some very light transmitters are available, but
these are not yet approved by the Federal Aviation Administration (FAA). DJI, the worlds largest UAS
manufacturer, has announced a partnership with uAvionix to develop ADS-B technology for UAS.65 But it
will be some time before that technology is ready for broad deployment.

A secondary issue with ADS-B is that receivers are relatively expensive66 and difficult for non-technical
consumers to operate. Ideally, a license beacon would transmit on a frequency usable by smartphones
so that people of all technical backgrounds could safeguard their privacy.

Bluetooth Low Energy (BLE) Beacon


Perhaps the best technology for a license beacon is Bluetooth Low Energy hardware and protocols
designed for location services. Bluetooth emits radio waves in the same bandwidth area as Wi-Fi67 and is
readily interpreted by most smartphone devices.68

Use in Location Services


As of Bluetooth 4 (which is widely used as of this writing), low-energy signals may be emitted containing
identifying information about a geographical location such as an area of a store.69 This technology is
under rapid development because of its promise for making geographical areas into troves of
information for smartphones to delve into. The idea behind location services is that businesses may
place beacons in various important places in their stores so that smartphone users may access

62
Federal Aviation Administration. Equip ADS-B. July 28, 2016. https://www.faa.gov/nextgen/equipadsb/
(accessed August 1, 2016).
63
Hall and Stepanovich. "License Plates & Drone Information Requirements." 5-6.
64
Ibid, 12.
65
DJI. DJI And uAvionix To Release ADS-B Collision Avoidance Developer Kit. July 27, 2016.
http://www.dji.com/newsroom/news/dji-and-uavionix-to-release-ads-b-collision-avoidance-developer-kit
(accessed August 1, 2016).
66
Hall and Stepanovich. "License Plates & Drone Information Requirements." 11-12.
67
Poole, Ian. Bluetooth Radio Interface, Modulation, & Channels. n.d. http://www.radio-
electronics.com/info/wireless/bluetooth/radio-interface-modulation.php (accessed August 2, 2016).
68
Bluetooth Special Interest Group. "Bluetooth SIG Analyst Digest 2H 2014." Bluetooth.org. 2014.
https://www.bluetooth.org/en-us/Documents/Analyst%20Digest%202H2014.pdf (accessed August 2, 2016).
69
Gruman, Galen. What You Need to Know About Using Bluetooth Beacons. July 22, 2014.
http://www.infoworld.com/article/2608498/mobile-apps/what-you-need-to-know-about-using-bluetooth-
beacons.html (accessed August 2, 2016).
information relevant to that area. For example, someone walking through a grocery store may be
prompted with coupons for items physically close to where they are standing.

Because beacons operate one-way, privacy concerns are mitigated.70 A smartphone user can receive
information from a beacon without returning any kind of signal and then choose whether to query some
online service to make further use of the beacons signal.

Potential Use in UAS


Bluetooth beacons may be repurposed to identify not a static (or semi-static) location but to identify a
mobile device. If a smartphone may read a Bluetooth beacon to determine it is physically close to the
pizza isle at a grocery store, then it can read a similar beacon to determine it is physically close to a UAS.
The beacon would be receivable over a roughly line-of-sight area, which is what matters to the privacy-
conscious individual on the ground.

Range Limitations
Bluetooth does, by design, have a limited range. However, two factors make it likely that Bluetooth will
be sufficient for current UAS applications. First, altitude greatly increases the range of signal for Wi-Fi
band radios. As a UAS climbs (and captures a greater line-of-sight for its sensors) its beacon will cover a
larger area. Second, rapid development of Bluetooth for location services means there is a demand for
and progress toward longer-range Bluetooth capabilities. The recent announcement of plans for
Bluetooth 5 promise significantly greater beacon range at a much lower power cost.71

Risk of Spoofing
There is a risk that UAS beacons may be copied in order to make bad behavior attributable to the wrong
UAS owner. If Bluetooth technology is the chosen technology, then safeguards are already being
developed in the context of location services.72 A number of proposals have been brought forward, with
various strengths and weaknesses; but several are sufficient for the purpose of remote UAS
identification.73

70
Sterling, Greg, Jules Polonetsky, and Stephany Fan. Understanding Beacons: A Guide to Beacon Technologies.
December 2014. https://fpf.org/wp-content/uploads/Guide_To_Beacons_Final.pdf (accessed August 2, 2016).
71
Bluetooth Special Interest Group. Bluetooth 5 Quadruples Range, Doubles Speed, Increases Data Broadcasting
Capacity by 800%. June 16, 2016. https://www.bluetooth.com/news/pressreleases/2016/06/16/-bluetooth5-
quadruples-rangedoubles-speedincreases-data-broadcasting-capacity-by-800 (accessed August 2, 2016).
72
Hassidim, Avinatan, Yossi Matias, Moti Yung, and Alon Ziv. Ephemeral Identifiers: Mitigatin Tracking & Spoofing
Threats to BLE Beacons. April 14, 2016. https://developers.google.com/beacons/eddystone-eid-preprint.pdf
(accessed August 2, 2016).
73
Ibid., 2-3.
Policy Recommendation
The Federal Aviation Administration (FAA) should require all sUAS to operate a radio frequency beacon
emitting information about the system including, but not limited to, its registration number. The beacon
should use technology commonly available to consumers, preferably at a very low cost. Transmissions
should be receivable in an area roughly matching the visible line-of sight and readable with inexpensive
(preferably commonplace) hardware. A more detailed discussion of this recommendation and
justification for each part follows.

Authority
The FAA does not have authority to make rules for the sole purpose of protecting civilian privacy.74 But it
does have authority to ensure the safety of other aircraft and people/property on the ground in case of
UAS failure or mishandling. License beacons could be justified by analogy to tail numbers on airplanes.
But there are several reasons why remote identification is uniquely necessary for UAS safety:

UAS sometimes fly away. In case of a loss of communication or some other malfunction, a
UAS may self-pilot somewhere beyond the operators immediate ability to retrieve or even
locate it. A license beacon would allow an observer to identify a fly-away UAS and take
measures to return it to the owners control.
UAS may cause damage during flight. Small UAS have been referred to as flying lawn mowers.
One could fly past or into something vulnerable and then recover and fly away. Outside VLOS,
such a hit-and-run could even occur without the operators knowledge. In the case of a larger
UAS, something could fall from the device and strike something vulnerable below. In either case,
it would be useful to identify the offending UAS.
UAS may be involved in near-miss incidents. A number of apparent UAS near-collisions with
commercial airplanes have been documented. UAS enthusiasts have argued that the airplane
pilots probably misidentified birds. The near-miss statistics have been used as reasons to restrict
UAS development and flight. A license beacon would make it possible to determine whether a
UAS was in the area at the time of the apparent near-miss and even pursue action against the
offending UAS operator.

These three threats to airspace safety are sufficient to warrant FAA action. As one commentator said,
Privacy is a safety issue. The FAA does not need explicit authority in matters of privacy to take
common-sense action which will improve privacy.

Scope
In the spirit of allowing technological development to occur relatively unimpeded, the scope of this
recommendation will be as narrow as possible while still achieving its intended purpose of guarding
civilian privacy. This recommendation should not be misconstrued as calling for an all-seeing database or
map of UAS locations and uses. Rather, the recommendation should be understood solely as meeting
the minimum threshold of letting civilians know what devices are flying immediately above them to allay
privacy concerns.

74
Given the current state of privacy theory and law in the U.S., the FAA probably could not effectively make
privacy-protecting rules even if given explicit jurisdiction in the area.
This recommendation rests on the assumption and seeming reality that the beacon technology it
discusses will not unreasonably burden drone manufacturers. A beacon obviously must take up some
weight, space, and power from the device; ideally the necessary hardware would already be used for
other purposes on the UAS and not require an addition of special hardware.

The beacon may require resources which would otherwise enable some extra feature or application.
This recommendation assumes that the displaced feature(s) would be merely interesting and/or helpful
and not central to the purpose of the UAS. Some sacrifice is necessary, but it should not unnecessarily
hinder technological application and advancement.

Use
Not every UAS application lends itself equally to a license plate requirement. Various groups will likely
defend their use of UAS as not significant enough to regulate or as exceptional in such a way as to justify
an exemption.75 This section will pose a few such arguments and attempt to anticipate others that may
arise.

Commercial
UAS owned or employed by commercial entities seem to fit the simplest argument for license plating.
Commercial entities have an incentive to capture private information for various purposes. Therefore,
due scrutiny should be applied to ensure companies do not unnecessarily infringe upon privacy,
especially without the publics knowledge. License plating of commercial UAS is also easily enforceable
within the FAAs current regulatory scheme because the cost of implementation and maintenance of a
beacon would be far less than the potential cost of non-compliance.

Police
Civil rights advocates will likely offer the strongest support for requiring law enforcement UAS license
beacons. Fears have long existed of an all-seeing Big Brother form of government from which there is
no hope of privacy. Dystopian fears aside, UAS do offer an inexpensive, effective form of surveillance
which could be abused. Therefore law enforcement UAS on routine
missions should be required to emit a license beacon so that civilians take
As a general their concerns to the authorities if they believe there is misuse.
principle, the risk Law enforcement agencies, of course, have a strong argument for the
calculus should favor necessity of UAS operating with relative secrecy and anonymity. Legitimate
transparency. investigative activities may be rendered ineffective if suspects are able to
detect and identify law enforcement UAS from a distance. Some scheme
should be developed by which exceptions to the beacon requirement may

75
For example, the Association of Model Aircraft has opposed any FAA registration process for non-commercial
UAS use, arguing that the FAAs regulation of aircraft does not extend to model aircraft and that AMA
registration should be sufficient.
The AMA Executive Council. Hold Off On Registering. December 17, 2015.
http://amablog.modelaircraft.org/amagov/2015/12/17/hold-off-on-registering-model-aircraft/ (accessed July 26,
2016).
be granted.76 There should also be a system to retroactively grant waivers in emergency scenarios where
typical exemption procedure cannot be effectively followed.

As a general principle, the risk calculus in the waiver process should favor transparency. Only in truly
exceptional circumstances where an operating license beacon would almost certainly jeopardize a
mission should the requirement be waived.

Private
Individual, private UAS owners might make the strongest case for an exemption to the license plate
requirement. Private operators are more likely to simply be hobbyists, taking their quadcopter out for a
fun new view of the local scenery. And as long as the UAS is flown within visual line of sight, it is unlikely
that any invasion of privacy will occur (unless the UAS is flown in, for example, a compact neighborhood
where privacy is mostly protected by tall fences).

At the same time, some of the more sensational invasions of privacy are likely to occur as the result of
individuals actions. For example, the UAS flown to peer into a Seattle womans window appeared to
have been piloted by nosy neighbors and not some commercial interest. Had the woman been able to
collect a reliable identification number for the UAS, she could have pursued legal action against the
offender. An exception for private use would have been negative in this scenario.

But there is also the question of UAS owner privacy. If a hobbyist is flying a UAS in their own back yard
or at a local park, is it really necessary for people in the general vicinity to be able to collect information
about their UAS which may be traceable to the individual? License plates for cars are easily traced by
police, and there is evidence to suggest that civilians may sometimes access information about a car
owner which is only intended for official police business. This could be especially important in the case
of children flying UAS in public spaces risking exposing information such as names and addresses to
strangers.

Finally, there is an important question of enforceability for private UAS operators. Because many UAS
systems are easily modifiable by design (which tends to be a boon for innovation), license beacons could
theoretically be disabled with various ease. Even worse, they could be disabled during some illicit
activity and then re-enabled later, creating an illusion of compliance. High penalties would probably be
the only effective mechanism to ensure compliance, and situations where illegal operation offers high
rewards would not be discouraged by the law alone.

Size
Because of the potential weight and power requirements of a license beacon, some consideration may
be necessary for very small UAS. The Technology section above discusses more in-depth which UAS will
likely be capable of carrying this technology.

76
Law enforcement would have to work with manufacturers and regulators to create a switch to enable and
disable the beacon. A cryptographic key could be provided by the waiver-granting body to check back abuse of the
off switch.
Contents of the License Beacon
The most basic information which should be included in the beacons transmission is the registration
number of the UAS, or another similar number which may be tied to other information such as the
owners name, address, corporate affiliation, etc.

It would be convenient to broadcast more information so that people may quickly assess who is flying
UAS over their heads and why. But this too closely approaches violating the privacy and even safety of
the flyer. If someone becomes angry about the use of a UAS over their back yard, it is probably best that
they be required to go to the police to file a complaint rather than going to the UAS owners front door.

Also, transmitting too much information may trigger the same issue as noisy or overly-visible UAS
(discussed more in the Technology section): people on the ground may become hyper-aware of the
threat to their privacy and overreact against the technology instead of just the offending party.

Therefore information broadcast should probably be limited to an identification number which law
enforcement may trace to an individual or corporation. The already-required registration numbers for
UAS would serve this role perfectly.

Implementation and Enforcement


UAS Manufacturers Role
UAS designers and manufacturers could simply implement beacons in their devices which are difficult to
disable. DJI, the worlds largest small UAS manufacturer, has built-in geo-fencing technology which is not
technically required by FAA regulations.77 But because it is good practice and improves the public image
of UAS, DJI finds it profitable to include the safeguard.

It is also conceivable that UAS operating systems could be used on a licensing basis where the owner
agrees to follow the manufacturers terms of service unless they install a different OS (which most
would probably opt not to do).

Risks
This is a very low-risk recommendation, making it an ideal step toward greater safety and privacy
protections in the U.S. The one major risk this author has identified is the potential for hyper-awareness
of UAS curbing innovation. One expert familiar with UAS technology noted that people become most
concerned about their privacy when they can hear a UAS hovering above.78 Similarly, the ability to
detect otherwise-unnoticed UAS via license beacons could give rise to alarmism.

However, a license beacon would be invisible to bystanders who are not already actively concerned
about their privacy. They would have to intentionally use hardware (or install software on their
smartphone) designed to detect and read the license beacon. Therefore this recommendation would

77
Mandatory geo-fencing controls are only activated in areas sensitive for national security reasons. Other areas
require only a verified DJI account to override that is, the operator must provide credit card information.
DJI. Geospatial Environment Online. n.d. http://www.dji.com/flysafe/geo-system (accessed July 27, 2016).
78
Langford, Keynote Address.
not make bystanders more aware of threats to privacy; rather it would offer a mode of recourse for
those who already feel threatened.

Benefits
Besides the safety benefits described in the Authority section, this recommendation would offer a
practical way for people to pursue action against UAS operators who grossly violate privacy. Records of
beacon recordings could be used as strong evidence in criminal cases and law suits against offending
operators. This will take privacy concerns out of the hands of alarmists and place them back where they
belong: in the courts and in the court of informed public opinion.

This greater sense of security with respect to UAS operations could also provide a boost to UAS
development and utilization. As mentioned above, transformative technology usually requires time and
effort to be made palatable to the public. Greater transparency may help allay paranoia and speed
adoption of emerging UAS technology.
Conclusion
UAS technology is advancing at such a rapid pace that commercial beyond-visual-line-of-sight operations
could become commonplace in the near future. The advanced sensing and recording technologies
carried by these UAS have risen well-founded concerns among privacy rights groups and activists.
Though the state of privacy theory and law in the U.S. is not such that sweeping privacy regulations
would likely be effective, certain common-sense rules should be implemented to curb rising fears.

Federal Aviation Administration rules requiring implementation of license beacons for UAS covered
under Part 107 would be justified as a safety measure and invaluable as a privacy safeguard. The
technology making this practical either already exists or is within easy reach.

License beacons for UAS would allay privacy concerns by allowing people to identify the devices flying
within their visual line of sight and pursue action against offending operators. This recommendation
would have almost no inflammatory effect in privacy concerns because only those already seeking
protection against snooping would bother to read UAS license beacons. And it would hasten adoption of
UAS technology by mitigating a primary concern among those whom it would affect.

License beacons for UAVs are justified, practical today, and just make good common sense.

Appendix C
A DJI Technology Whitepaper

Whats In a Name?
A Call for a Balanced Remote Identification Approach

March 22, 2017

***

The Utility of Remote Identification Technologies


Section 2202 of the 2016 FAA Extension Act contemplates the development of remote
identification technologies for unmanned aircraft systems (UAS). Regulatory proposals in
Europe, including from the European Aviation Safety Agency (EASA), and in European Union
member states such as France and Germany, have also called for remote identification
technology. Indeed, Italy and Denmark apparently already mandate these technologies, in
regulations that seem not to be enforced because the means of compliance do not yet exist.
Remote identification is potentially a problem-solving approach to addressing policy concerns
including security and accountability.
DJI believes that laws of general applicability should apply to drones, just as they do to
other technologies. For example, a law that makes unlawful surveillance illegal should apply to
misconduct using drones as it would apply to misconduct using other types of cameras. These
laws of general applicability have been created by lawmakers over decades and balance
competing interests including privacy interests, community values, national legal traditions,
cultural norms, the First Amendment (and similar doctrines outside the United States), and
journalism interests, among others. The balance reached after decades of legislation and
jurisprudence should not be disrupted each time a new technology comes along. Operational
rules relating to UAS obviously apply as well.
In our many discussions with policymakers and community members around the world, a
theme has emerged about one way in which drones are different from many other technologies:
the remoteness of the operator. Unlike manned aircraft, automobiles, mobile telephones with
cameras, and other imaging devices, drones are remotely operated. In many cases, particularly in
jurisdictions limiting operations to visual line of sight, the operator is near the unmanned aircraft
while in flight and it is not difficult to locate her. In some instances, she is not. In those
instances, if the operator is actually doing something that everyone would readily agree is
unlawful, there is an accountability challenge. Remote identification, properly and reasonably
deployed, could significantly help to address that challenge. It might also provide a measure of
social comfort to those who are unfamiliar with the technology and have anxieties about its use,
founded or unfounded. For security agencies protecting sensitive locations, being able to
identify UAS that are cooperating with an identification regime can suggest a tactical response to
approaching UAS that are not cooperating. For these reasons, DJI supports the concept of
remote identification. However, we urge that the development and implementation of such a
mechanism be thoughtful, tailored to address and solve the actual challenge, and take into
consideration other important interests.
The Privacy Interests of the Operator
We have observed that the privacy interests of the drone operator are often not considered, or
even raised, in policy discussions about remote identification. These interests are significant and
must be taken into account. Across our hundreds of thousands of customers, we have heard from
companies and individuals who have serious and legitimate concerns about the confidentiality of
their drone operations. By way of example, here are a few types of operations that raise
competitive business or other operator privacy concerns:
An alternative energy company scouting out a prospective new wind farm location
A seed company flying regular missions to measure the performance of its newest type of
seed crop
A teenager in her backyard operating a drone for a school science project
A technology firm surveying and mapping land for its new corporate campus
A drone company developing and testing the latest forthcoming product
An insurance adjuster inspecting a storm-damaged property to guard against fraudulent
claims
A journalist engaged in investigative journalism
A drone service company that closely guards information on how many operations it
conducts each week relative to its competitors
These are all examples of companies and individuals who have a legitimate reason not to have
their operations of UAS tracked and recorded, or otherwise made available to far-away observers
who may include competitors. These concerns are analogous to ones in other domains. We do
not constantly track and record the location of motor vehicles, even though doing so would lead
to near-perfect enforcement of motor vehicle laws (the violation of which costs lives each day).
Manned aircraft are not subject to constant surveillance and tracking. In Class G airspace, which
is much of the country, no flight plan is required, and radar may not be active to event detect the
presence of the aircraft. In vast areas of the country, it is possible for a pilot to fly from one
farms grass strip to another, and back again, without anyone else having access to that flight
information including the identity of the pilot. Even when manned aircraft are close enough to
be visually identified by their marked N number, the economics of aircraft ownership compel
limited liability corporations (LLCs) to protect the identity of the owner. And even with the
2
aircraft owners name in hand, it is not possible to learn who was flying the aircraft or why they
were operating without making an inquiry with the owner.
A significant effort to protect against public dissemination of flight tracking data resulted
in the Block Aircraft Registration Request (BARR) program enabled by Congress in the April
2000 Wendell H. Ford Aviation Investment and Reform Act for the 21st Century, Pub. Law 106-
181, Section 729.
In 2011, changes to the BARR program were considered in an FAA Notice of Proposed
Modification to the June 1, 2006 MOA FAA/Subscriber Memorandum of Agreement for
ASDI/NASSI Industry Access and Request for Comments, FAA docket number FAA-2011-0183.
FAA received approximately 630 written comments.
In these comments, organizations such as NBAA and AOPA noted that making an
aircrafts use public compromises its value as a business tool and exposes competitively sensitive
information. A selection of these comments are provided in Appendix B. Final guidance on this
topic was published by the FAA in 2013.
Operators of unmanned aircraft have many of the same interest in privacy, and are poised
to make even greater use of them as a business tool than manned aircraft which they now
outnumber. Although UAS do not carry people, and so do not implicate free movement of
people, identification information does indicate the location of the person operating the UAS,
thus revealing the activities of persons and businesses.
The interest in privacy is, unfortunately, arguably heightened compared to manned
aircraft considering the occasional violent confrontations that UAS operators have faced over the
last few years, including physical assault and gunfire. A system that enables belligerent
individuals to look up the name and address of, and then knock on the door of, a local UAS
operator, is not acceptable and will detrimentally impact UAS operators who are operating safely
and doing nothing wrong. The personal information of the owner (or operator) should be
accessible to law enforcement only, who can investigate complaints of unlawful or dangerous
conduct. Privacy and personal safety interests compel an identification system that protects
operator business interests and discloses personally identifiable information only to law
enforcement agencies.
The Balanced Approach: Non-Networked, Localized ID
The balanced approach that we propose to solving safety, security, and accountability
concerns while taking into account operator privacy and safety, is to create an identification
mechanism that provides localized identification without permanent recording or logging.
Remote UAS identification then becomes analogous to an enhanced version of a car license plate.
An identifier, such as a registration number, together with position information about the drone,
and perhaps some voluntary information if the operator wishes, is transmitted from the drone,
and is available to all receivers that are within range. Authorized receivers of the transmission
who believe the drones operator is violating a regulation or engaged in unlawful acts can record
and investigate, similar to how a license plate might be recorded by someone who is cut off on a
3
road. Radio-based identification is actually better than license plates; it will work through walls,
at greater distances of likely more than a mile given current technologies. In contrast, a license
plate is readable from only a few dozen feet away.
This localized approach is preferred to networked solutions, which raise a number of
concerns. A networked solution requires network connectivity, most typically via mobile phone.
There are various locations that lack reliable data signals, which would thwart the ID system, as
well as provide an excuse to a non-compliant operator. A networked solution also inherently
raises the possibility that all UAS operations will be tracked and recorded for future unknown
exploitation, including enforcement quotas or business espionage. A networked system is also
susceptible to system-wide hacking, or the creation by detractors of false entries of drone
operations that do not exist.
No other technology is subject to mandatory industry-wide tracking and recording of its
use, and we strongly urge against making UAS the first such technology. The case for such an
Orwellian model has not been made. Certainly, we have yet to hear why anyone in Detroit
would need to know who is operating a drone in Denver, or why. A networked system provides
more information than needed, to people who dont require it, and exposes confidential business
information in the process.
A non-networked primary solution is also easier to implement because it can be done by
a single industry constituent who are well positioned to implement it: the manufacturers.
Networked solutions require the manufacturers, data providers, a server resource, the operator,
and the designated receiver of the ID information to all create something that works together,
and to maintain and pay for the upkeep of all the parts (or impose this cost on the operators).
Even if that system could be devised, it will take longer to implement. The best solution is
usually the simplest. The focus of the primary method for remote identification should be on a
way for anyone concerned about a drone flight in close proximity to report an identifier number
to the authorities, who would then have the tools to investigate the complaint without infringing
on operator privacy.
Available Technologies Already Exist
The key to deploying a viable identification system is to leverage and primarily focus on
technology that already exists as the primary method. UAS in widespread use today already
transmit data at significant range, using their command and control and video transmission links.
We propose use of protocols within the existing C2 or video link to transmit identification
information to ground receivers. These control and video links most often make use of the 2.4
GHz and 5.8 GHz bands. To facilitate widespread adoption of this approach, DJI proposes
creating at least one open identification protocol for UAS that use wifi control links, in addition
to protocols that might be developed for other UAS using other control links. Given the life
cycle of this technology, in which we estimate that the typical drone operator purchases a new
model within approximately one year, it ought not be difficult for manufacturers to modify
existing radio transmission protocols to broadcast identification information, and for the majority
of the users to be using the technology within a matter of months from the initial rollout.
4
For UAS operators who choose to build their own UAS, add-on RF modules may be
made available including those that leverage other existing protocols such as Bluetooth; however
we find that add-on modules are disfavored for ready-to-fly products because of potentially
undesired performance impact on the operation of the UAS (such as radio interference, balance
and aerodynamic impacts) for which a manufacturer should not be held responsible.
Additionally, for those less concerned about tracking and privacy, or who do not wish to use
radio identification technologies or add-on modules, a networked alternative system could be
made available, but it should be secondary and optional.
Thus, we propose in concept the following remote identification solutions:
1. Primary: radio frequency transmission to local receivers using existing UA antennas and
modified C2 or video link protocols including one or more open standards
2. Secondary: Add-on modules that make use of one of the link protocols
3. Tertiary: Optional network-based identification system, likely over mobile telephone
connections and the internet

A Note on this Paper


DJI prides itself on working collaboratively on solutions with industry stakeholders and
regulators. This whitepaper was prepared in response to AUVSIs call for papers, within a
limited period of time, for discussion purposes. We look forward to receiving feedback and
incorporating that feedback into a future revision of this paper.

5
Appendix A
Response to AUVSI Areas
In this Appendix we briefly respond to AUVSIs specific inquiries in its call for papers.
Technology Description
Overview of technology concept

Response: The technology in consideration would make use of existing command-and-


control equipment on board the UA to send identification and position information to a
radio receiver, using a protocol to add identification information to the downlink.

Technology Operational Concept


Describe how it would be employed and the user interface application

Response: Law enforcement and others would view an electronic map of the surrounding
area and be able to identify UA operating within radio range.

Describe supporting infrastructure (e.g. internet)

Response: No infrastructure is required.

Define Technology Readiness Level (when could it be fielded for testing/initial


operations)

Response: There could be some level of readiness for initial operations this summer.

Describe reliability assurance and continuity of service features

Response: This approach would be reliable when the UA is within range of the receiver.
There is no server or network posing continuity issues.

Describe utilization of readily available spectrum/communication network(s) (e.g. LTE)

Response: No additional spectrum is required beyond what the UA already uses for
command-and-control.

Highlight limiting factors

Response: Distribution of receivers and the creation of one or more common transmission
protocols.

6
Airborne Component: Describe component(s)/technology that would be on the vehicle. Must be
technologies that will work on a SUAS vehicle (<55lbs).
Light weight
Low power (power source)
Miniaturized in size
Rough order of cost (must be affordable for vehicle equipage)

Response: For UA with compatible control links, no additional weight or power because
the solution uses existing radio equipment. For UA with other control links, perhaps an
add-on RF module at low cost. We do not have a specific cost given that this is a
whitepaper. 2.4 GHz is a common ISM band for almost all drones. Other links are
likely to be licensed spectrum for larger, specialized UAS. As with UAS registration, there
should be a lower limit on any requirement to identify, but this needs to be discussed in
light of safety goals because the FAA registration cutoff of 250 grams strikes as too low,
based on our refined analysis of the calculations performed by the FAA UAS Registration
Task Force.

Ground Component: Describe the ground component(s)/technology needed for identification and
tracking of vehicle.

Response: A radio receiver with a screen for display, which over time may be similar in
cost to existing high-quality RC controllers and portable screens.

7
Appendix B

Selections from Public Comments to FAA-2011-0183

AOPA has significant concerns with the implications on an individuals privacy, confidentiality, security
and personal safety that could result from the proposed changes. Further, it appears the proposed FAA
action is a solution in search of a problem that doesnt exist without due regard for the adverse impact it
may have on private individual citizens because of the unnecessary release of personal information.
AOPA has determined that the proposed changes are dangerous, invasive and unwarranted and the
unintended negative implications are far reaching.

- Melissa Rudinger, AOPA


I don't feel it is anyone else's business where we go. It is not only a privacy issue, but when it
comes to business it is a competitive issue. The competition just does not need to know what we
are doing.
It is the same as tracking where you drive your car.
George Orwell was right on.

- Hal Shevers, Sportsman Market Inc.

The principle concern among corporations is the safety and security of their employees. The
change to the MOA, as proposed, would allow anyone who may have the desire to follow a person a
mechanism through which they can do so real-time by tracking the movement of an aircraft. The
safety and security implications for those persons would become unbounded by this type of
information being made available to both the curious observer and those harboring illicit intentions.
GAMA finds this to be unacceptable.
- Jens Hening, GAMA
As a Chief Security Officer (CSO) for a Fortune 500 company, my primary concern with this
regulation is the public facing information regarding where our senior employees travel from a
security and risk perception (i.e., kidnap and ransom, sabotage, and competitive industrial
espionage). Our corporation prides itself on ethics, corporate responsibility, and shareholder
transparency and the current FAA rules demonstrate compliance in submitting flight plans. Where is
the National Security nexus between public record and compliance in confidence?
- Pete Short

The Notice is flawed for many reasons and should be withdrawn. First, the predicate for the BARR
program since its inception has been as much to protect the privacy interests of private persons and
businesses as it has been about the security of travelers. Yet the Notice belittles the privacy interests of
air travelers.

- Greg Walden, Patton Boggs LLP (on behalf of an anonymous consumer packaged products
manufacturer)

8
Not only is this an unnecessary and irresponsible proposal, it sets a dangerous precedent for the
privacy and safety of our customers. Here are a few examples of how this proposal would negatively
impact people and businesses:

It tramples citizens right to privacy


It facilitates electronic stalking by unknown third parties
It creates an unnecessary competitive vulnerability for American businesses
It singles out general aviation for punitive treatment. It remains illegal for Amtrak or the commercial
airlines to make public the names of their passengers.
It sets a precedent for the government to disclose any private data about individuals that it collects.

- Dan Hinson, Hawker Beechcraft Corporation

As a matter of security for our employees we do not want public access to our aircraft status and
routes. We have no objection to governmental or law enforcement access to this information, but
see no practical value for the public access and in fact consider this a major security issue as it
could alert bad actors as to the location and plans for our aircraft.

- David Barta, Cooper US


Privacy of movement is a fundamental American value. I believe the federal government should, to
the greatest extent possible, protect such information rather than transmit it to anyone in the world
with a computer connection. With this proposal, the government is targeting for broadcast the
movements of those individuals and companies who utilize general aviation airplanes, but the
situation could just as easily involve individuals and companies who utilize an automobile with an E-
Z Pass. I do not believe there is any mode of transportation where the public dissemination of
private movements is warranted.
- Robert Moore, Hewlett-Packard
An attractive woman is in the car next to you at the red light. You lag behind and take down her car
registration and go to your state's DMV website, where they have the car owner's address available
to anyone who puts in the registration number off the vehicle, right??
Wrong!

- Dean Block
It is completely un AMERICAN to have small planes tracked differently than cars. Why don't we
track credit card use, bathroom use, and everything else. Komrade Stalin would be proud.
Seriously, privacy is important. Please don't do this.

- Jay Locke

Eliminating an aircraft operators discretion to restrict real-time access to their aircraft whereabouts
would be an inconsistent position with the government stance on similar data. If this change were to be
enacted it could be argued that APIS or Secure Flight data should be similarly released so that all
passenger manifests for private and airline flights to/from/within the United States should be released
for public scrutiny.

- Daniel Baker, FlightAware

9
the Notice fails to identify any government interest whatsoever that would be advanced by preventing
owners and operators of private aircraft from blocking the disclosure of flight tracking information to
unknown persons.
- Edward Bolen, Jeffrey Shane, NBAA

That the government would seek to undermine such a valuable safeguard without setting forth a
compelling public policy rationale for doing so runs counter to the best interests of American business
and the values and traditions of the Federal Government.

- Michael McCormick, Global Business Travel Association

The FAA's newly proposed limitation ignores the legitimate need for the Block Aircraft Registration
Request (BARR) Program, and runs directly counter to long-established assumptions about
government's role in the protection of privacy.

- Melvin King, Honeywell Flight Operations

10