Regulatory, Safety

sUAS NPRM – The FAA Wants Your Input

By By Mark Colborn | April 8, 2015


It’s difficult to believe, but the FAA is actively soliciting our opinion on a variety of issues related to small unmanned aircraft systems (sUAS). Regardless of your feelings on this subject, don’t miss this rare opportunity to help shape the future of aviation. The comment period will end April 24.

Many entrepreneurs in the U.S. want to use sUASs for non-recreational purposes. In the long-awaited 195-page Notice of Proposed Rulemaking (NPRM), entitled Operation and Certification of Small Unmanned Aircraft Systems, the FAA outlines a plan that makes it less cumbersome for businesses and public safety agencies to fly sUASs. Police and fire can chose to operate under the proposed Part 107 rules as civil aircraft, or continue to operate as public use. But operating under public use will require agencies to undergo the Certificate of Waiver or Authorization (COA) process. The proposals in the NPRM that so far have garnered the most attention include see-and-avoid rules (or line-of-sight), impact damage mitigation, and operator certification requirements.

The FAA is charged with protecting the safety of the NAS and is steadfast regarding the concept of see-and-avoid. Until emergent collision avoidance technologies undergo vigorous testing and are proven reliable, the FAA will require operators to always be within line-of-sight of their machines. This explicitly rules out drone package delivery – to the chagrin of corporate at Amazon.


The agency is considering less restrictive rules for sUASs less than 4.4 pounds. Machines this small can be made out of materials that break up on impact, thus mitigating injury to persons or damage to property on the ground. The FAA is particularly interested in public feedback on this micro-UAS proposal.

It also wants small UAS operators to pass an aeronautical knowledge test, then obtain an unmanned operator certificate with a sUAS rating. The exact procedures for how this will be accomplished are not clearly defined in the document. Perhaps the FAA is planning to create a new category of airman certificate with several privilege level class ratings covering all future UAS types - for instance, issuing small UAS and micro-UAS class ratings first, followed in a few years by autonomous UAS operator class ratings? The FAA only expressed the need to test a potential non-recreational sUAS operator’s aeronautical knowledge. But licensed pilots are already tested on this subject. The website - - has received several comments that question the need (and expense) for currently licensed pilots to obtain this extra rating.

They are also interested in opinions on the following:

• Can drones be launched from vehicles?

• Is the 500 ft. AGL altitude restriction too high or too low?

• Should sUAS operators be allowed to deviate from FAA regulations in the event of an emergency?

• Is the proposed speed limit of 100 mph too fast?

• Should drones be allowed to tow objects or banners?

• Should registration numbers be displayed on drones, and do they need to be fire resistant for identification following a crash?

• Should drones be allowed to fly at night? This restriction would directly affect non-recreational sUAS deployment in Alaska, and the FAA wants to know if the rules should be different for this region.

• The current proposal allows a 17-year-old to obtain an operator certificate. Can that age be lowered?

Knowing the potential beneficial applications of sUASs to society, the FAA also recognizes that insufficient data exists to properly integrate this technology into the airspace above 500 ft. AGL. They want non-recreational operators to report any crashes resulting in damage to property, or injury to persons.

The FAA requests public comment on any portion of the proposed rule. Since aviation safety is the purview of the FAA, not our privacy concerns, comments should strictly address safety of flight issues. Comments can be filed by mail, via fax, in person, or electronically at Aviation as we know it is changing. Don’t miss this unique opportunity to guide this explosive industry - and the FAA - into the future.

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