You're raising valid points generally but read 89.110 for Standard Remote Identification. If internet is not available the drone must broadcast the information

You're raising valid points generally but read 89.110 for Standard Remote Identification. If internet is not available the drone must broadcast the information elements directly. This does preclude 'limited remote identification' UAS from operating without any local internet and of course no remote identification UASes will be stuck in the FAA sandboxes. Definitely some rough edges in this that will hopefully get eviscerated in public comments.