Current Federal Regulatory Actions Concerning UAS

The FAA Reauthorization Act contains a Section 333 “Certain Rules for Special Unmanned Aircraft Systems.” Beginning in spring of 2014 various companies and organizations wanting to use UASs commercially filed petitions with the FAA under Sec. 333. The section requires the FAA to “determine if certain unmanned aircraft systems may operate safely in the National Airspace System before completion of [final rulemaking].” NAAA has been, and will continue to comment on these petitions (when they are available for comment), stressing that many of the exemptions these entities have requested—which include exemption from aircraft certification requirements—should not be allowed. In its comments, NAAA has also pushed for aforementioned UAS safety integration requirements that include equipping the UASs with strobes, ADS-B Out and operation only within line of sight. Further, NAAA encouraged the FAA to require a pilot certificate for commercial operation of UASs, an “N number” to aid in identification of the aircraft in the event of an incident or accident, and, as aforementioned, for the FAA to establish airworthiness standards and require an airworthiness certificate before permitting UAS use for commercial flight. The FAA has approved nearly 2,000 of these petitions and while not granting all of NAAA’s requests, the FAA did add a requirement, based on NAAA’s safety concerns, requiring the UAS operators to file NOTAM 48 hours prior to flight. Additional requirements included requiring an “N-number,” private pilot certificate, line of sight operation, and preflight inspection. The FAA also announced that the UASs would be limited to daytime operation until nighttime visibility concerns are adequately addressed. Unfortunately, many of these safety requirements are absent in the FAA’s proposed small UAS rule.

Continue to Concerns with Efficiency Statements

Updated October 2015 

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