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Analysis of the DOT/FAA announcement that operators will be required to register their unmanned aircraft.

News

U.S. Transportation Secretary Anthony Foxx Announces Unmanned Aircraft Registration Requirement

Transportation Secretary Anthony Foxx and FAA Administrator Michael Huerta announced the creation of a task force to develop recommendations for a registration process for unmanned aircraft.

Secretary Foxx said, “Registering unmanned aircraft will help build a culture of accountability and responsibility, especially with new users who have no experience operating in the U.S. aviation system. It will help protect public safety in the air and on the ground.”

Administrator Huerta said, “Registration will help make sure that operators know the rules and remain accountable to the public for flying their unmanned aircraft responsibly.  When they don’t fly safely, they’ll know there will be consequences.”

For a video of the UAS registration announcement, see USDOT Press Conference [27 minutes].

These stakeholders were onstage at the announcement:

• The Association for Unmanned Vehicle Systems International
• Academy of Model Aeronautics
• Air Line Pilots Association
• American Association of Airport Executives
• Helicopter Association International
• PrecisionHawk
• AirMap

See also, Statements of support for DOT’s approach to UAS registration

The Problems with Mandatory Drone Registration

Jonathan Rupprecht, Esq., a commercial pilot and flight instructor with Rupprecht Law lays out 11 problems with UAS registration, including the number of available N-numbers, the definition of a UAS for registration purposes, the effectiveness of registration, DOT/FAA authority or jurisdiction to require registration, and where the funding will come from.

UAVUS Response to DOT Federal UAV Registry Announcement

The US Association of Unmanned Aerial Videographers (UAVUS) says they support “…the development of a streamlined registration process for small UAVs that meet an appropriate threshold for size, weight, and capabilities.”

UAVUS also feels the announced registration proposal is “…overly ambitious, and could add to the confusion created by the absence of the FAA’s final rulemaking for the commercial use of small UAVs.”

DOT Accepting Public Comments on UAS Registration Requirements

Hogan Lovells reports that “To facilitate the task force’s work in developing UAS registration procedures, DOT is requesting information and data from the public.” Comments can be submitted until November 6, 2015.

Clarification of the Applicability of Aircraft Registration Requirements for Unmanned Aircraft Systems (UAS) and Request for Information Regarding Electronic Registration for UAS

Docket FAA-2015-4378 has provision for the public to submit comments that give feedback to the following questions:

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?

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I Was a Drone Warrior for 11 Years. I Regret Nothing

Lt. Col. T. Mark McCurley is a retired Air Force pilot and former human intelligence operator. He flew remotely piloted aircraft for over a decade and was the squadron commander of the mission that killed American terrorist Anwar al-Awlaki. This piece is partly adapted from his recently released memoir, Hunter Killer: Inside America’s Unmanned Air War.