On April 24, 2015, I filed comments on behalf of NetMoby, Inc., in the Federal Aviation Administration (FAA),
Department of Transportation’s Notice of
Proposed Rulemaking in Docket No. FAA-2015-0150, Operation and Certification of Small Unmanned
Aircraft Systems, 80 FR 9543
(February 23,2015). The FAA summarized the NPRM as follows:
The FAA is proposing to amend its regulations to adopt specific
rules to allow the operation of small unmanned aircraft systems in the National
Airspace System. These changes would address the operation of unmanned aircraft
systems, certification of their operators, registration, and display of
registration markings. The proposed rule would also find that airworthiness
certification is not required for small unmanned aircraft system operations
that would be subject to this proposed rule. Lastly, the proposed rule would
prohibit model aircraft from endangering the safety of the National Airspace
System.
The key element of the NPRM was to allow
for the first time the commercial operation of
UAS, or, as the opening sentence
of the NPRM’s Executive Summary states: “This rulemaking proposes operating
requirements to allow small unmanned aircraft systems (small UAS) to operate
for non-hobby or non-recreational purposes.”
Specifically, the FAA proposed to
add a new part 107 to Title 14 Code of Federal Regulations (14 CFR) to allow
for routine civil operation of small UAS in the NAS and to provide safety rules
for those operations.
The NPRM totaled 195 pages when initially
published. The FAA invited comments on
70 issues. The FAA received 4,591 comments from such
entities as NASA, NOAA, the NTSB, state
and local governmental authorities, academic institutions, as well as UAS and
other trade groups, corporations and individuals.
The link to the comments I filed on
behalf of NetMoby, Inc. is here. I will address the major issues addressed in
those comments elsewhere in this blog.
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