By now, nearly everyone should be aware that the FAA and DOT are considering requiring registration of some sUAS and have created a task force to help develop that process.
As part of these efforts, the DOT and FAA have asked for public input on the issue and have identified 10 questions in the document titled “Clarification of the Applicability of Aircraft Registration Requirements for Unmanned Aircraft Systems (UAS) and Request for Information Regarding Electronic Registration for UAS” that can be found at www.regulations.gov/#!docketDetail;D=FAA-2015-4378.
AMA asks that its members review the questions and offer comments. The government website for this project is cumbersome and only allows a person to either type comments into a text box or to upload a file. To help, however, we are offering suggested comments to the questions we feel would impact our membership the most. Feel free to provide your own comments on the registration of model aircraft. We want the DOT to know your thoughts on registration, whether you think its beneficial and necessary to ensure for safe operation in the National Airspace System (NAS) or state any objections or limits you would have to a registration process. Discuss any concerns you might have or suggestions with establishing thresholds of who or what should be exempted from registration and what method of registration would you favor.
If you prefer, you can paste these comments directly into the response box. It’s important that you submit your comments by November 6, 2015. Comments offered after this date will still be accepted, but might not carry as much weight as those submitted by the deadline.
Q: Consistent with past practice of discretion, should certain UAS be excluded from registration based on performance capabilities or other characteristics?
A threshold must be established under which sUAS/model aircraft are exempt from registration. Model aviation, operated within the safety programming of the Academy of Model Aeronautics (AMA), has an impeccable 80-year track record of operating safely and simply requiring AMA members to now register their aircraft would have no impact on that record.
The sUAS that lack the capability to fly beyond line of site by using either first-person view, or those sUAS that lack onboard navigational systems that allow the aircraft to fly missions beyond visual line of site, should likewise be exempt because they pose little or no threat to other users of the airspace. This would include all sUAS that fall into the toy category.
Q: How should a registration process be designed to minimize burdens and best protect innovation and encourage growth in the UAS industry?
Registration should involve only those platforms whose technological capabilities exceed a certain level. That threshold needs to be identified by using substantive, relevant data and not merely be a subjective point selected with nothing to support it. The process should be as automated as possible and minimally intrusive so as to only collect the data needed to identify the platform, if necessary.
AMA members have used a system of aircraft identification for decades where members place their names and addresses or AMA numbers on their models. This should be acceptable for AMA members as an alternative means of complying with the registration process.
Q: What type of information should be collected during the registration process to positively identify the aircraft owner and aircraft?
The only necessary data would be an identifying number/algorithm that connects through a database the name and address of the owner. Other information could be selected as appropriate such as an email address or telephone number.
Q: Are there additional means beyond aircraft registration to encourage accountability and responsible use of UAS?
Although registration of some platforms might have a minimal impact on the small number of users flying irresponsibly, most enthusiasts are accountable and want to fly safely. This is why it is so important that the DOT and FAA focus more of their efforts on education and training and increase their support of AMA’s and AUVSI’s efforts with the Know Before You Fly program.
Finally, the most important thing the FAA can do is to step up its efforts in taking enforcement action against anyone doing something that rises to the level of causing an eminent threat to others in the airspace; however, the real solution lies with education and enforcement.