Last week, NAAA submitted comments on two Petitions for Exemption to the Federal Aviation Administration (FAA). These petitions, both from Uncrewed Aircraft System (UAS) light show companies, were seeking relief from portions of the 14 CFR Part 48 requirements for registration and marking of small UAS. The basis for each company’s claim is financial, as they have thousands of UAS in inventory that require individual marking, registration and (every three years) reregistration.
One petition was merely seeking an alternative process to renew all their previously registered/marked UAS at once (think a spreadsheet of registration numbers). The other petition sought to apply for a single registration number for their entire swarm of UAS, though it was not clear how they would achieve this through the specific sections of the CFR they requested exemption from.
NAAA commented against the concept of a single registration number being used for an entire UAS swarm but in favor of the FAA providing an alternative method for standard reregistrations to be applied for in a batch format to relieve unnecessary administrative overhead within both the private sector and the FAA itself. However, NAAA also used these comments as a platform to continue imparting the importance of UAS safety to the FAA. An excerpt, included in both comments, is copied below:
NAAA has a shared goal with the FAA of enhancing aviation safety, not abating it. As incremental changes are continually made with precedent-setting exemptions to 14 CFR regarding UAS, NAAA grows increasingly concerned of the hazard posed for crewed aircraft. Alone, exemptions such as this may not seem significantly impactful. However, put together in the broader context, it appears that the FAA has found itself on a path toward prioritizing the integration of UAS into the NAS over the safety of crewed aviation.
NAAA would like to reiterate to the FAA its position that the safety of crewed aircraft should always be prioritized, and that UAS should always give the right-of-way to crewed aircraft. Regarding beyond visual line-of-sight (BVLOS) operations, NAAA also reiterates to the FAA that detect and avoid (DAA) systems should be certified and that shielded operations, as prescribed by the UAS BVLOS Aviation Rulemaking Committee (ARC), should not be permitted in any environments or under any circumstances. NAAA has continually urged the FAA to prioritize safety regarding these matters, most recently in a 2022 letter regarding the UAS BVLOS ARC Final Report and again in a 2023 comment on Docket FAA-2023-1256 regarding BVLOS operations.
You can view the petitions, as well as NAAA’s comments on them, at the links below: