Kelly Comments in New UAS Rulemaking


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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