NAAA is making available a draft version of its comments to the FAA on the agency’s proposed small unmanned aircraft system (UAS) rulemaking. As reported in the Feb. 15 edition of NAAA’s eNewsletter, the FAA has given interested parties until April 24 to share their concerns on the NAAA’s proposed rule regarding small UAS. NAAA has a number of concerns with the rule including the following;

• No ADS-B Out requirement
• No Strobe lighting requirement
• No medical requirements – while the rule relies on line-of-sight, the operator is required to self-certify they can physically meet this requirement.  
• No airframe certification – operator just needs to perform a preflight inspection
• No pilots license or UAV experience necessary – written test only
• No aviation orange and white painting

NAAA urges all members to comment and share your safety concerns with the FAA related to this proposal. To submit comments be sure it is on your company letterhead and identified by docket identification (ID) number FAA-2015-0150 (see page one of NAAA’s comments). To send comments electronically visit the link: http://www.regulations.gov/#!submitComment;D=FAA-2015-0150-0017

If submitting comments by mail use the following address:

Docket ID FAA-2015-0150

Docket Operations, M-30

U.S. Department of Transportation (DOT)

1200 New Jersey Avenue SE, Room W12-140,

West Building Ground Floor,

Washington, DC 20590-0001

Comments can also be faxed to 202-493-2251, be sure to include the docket ID FAA-2015-0150.  NAAA will also be urging numerous national aviation groups and agricultural groups submit comments ensuring low-level aviation safety is addressed in FAA sUAS regulations.