Comment Now on FAA DOT Proposed UAS Registration.

Comment Now on FAA DOT Proposed UAS Registration.

 

 

 

Below are the questions posed about sUAV regustration on the FAA DOT website.  

 

 

1. What methods are available for identifying individual products? Does every UAS sold have an individual serial number? Is there another method for identifying individual products sold without serial numbers or those built from kits?

 

2. At what point should registration occur (e.g. point-of-sale or prior-to-operation)? How should transfers of ownership be addressed in registration?

 

3. If registration occurs at point-of-sale, who should be responsible for submission of the data? What burdens would be placed on vendors of UAS if DOT required registration to occur at point-of-sale? What are the advantages of a point-of-sale approach relative to a prior-to-operation approach?

 

4. Consistent with past practice of discretion, should certain UAS be excluded from registration based on performance capabilities or other characteristics that could be associated with safety risk, such as weight, speed, altitude operating limitations, duration of flight? If so, please submit information or data to help support the suggestions, and whether any other criteria should be considered.

 

5. How should a registration process be designed to minimize burdens and best protect innovation and encourage growth in the UAS industry?

 

6. Should the registration be electronic or web-based? Are there existing tools that could support an electronic registration process?

 

7. What type of information should be collected during the registration process to positively identify the aircraft owner and aircraft?

 

8. How should the registration data be stored? Who should have access to the registration data? How should the data be used?

 

9. Should a registration fee be collected and if so, how will the registration fee be collected if registration occurs at point-of-sale? Are there payment services that can be leveraged to assist (e.g. PayPal)?

10. Are there additional means beyond aircraft registration to encourage accountability and responsible use of UAS?

 

Comments received by November 6, 2015 would be most helpful in assisting the UAS registration task force in developing its recommendations. The comment period will remain open after this period and the Department will consider the comments received, in addition to the UAS registration task force's recommendations, in developing a stream-lined registration process for small UAS, including model aircraft.

 

 Below are the questions and answers as written by the AMA - use these or your own ideas.

 

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 imminent threat to others in the airspace; however, the real solution lies with education and enforcement.