Ale Bhm

Dear Sir or Madam, I am sending the following comments to the proposed rule for SUAS operation and cerification: 1) I suggest the approved ICAO terminology would be appropriately used in order not to cause confusion: a) "Operator. A person, organization or enterprise engaged in or offering to engage in an aircraft operation. Note. In the context of remotely piloted aircraft, an aircraft operation includes the remotely piloted aircraft system." b) "Remote pilot. A person charged by the operator with duties essential to the operation of a remotely piloted aircraft and who manipulates the flight controls, as appropriate, during flight time." Sometimes, the operator and remote pilot are the same and only person, but nevertheless this distinction should be kept for legal and harmonisation reasons. 2) I fully agree on requiring the aircraft registration number but also a fireproof identification plate should be required and enforced to be placed in the RPA according to ICAO Annex 7. This is a good practice in the Czech Republic (it contains the nationality and registration mark and additionally also the operator name and phone. If the SUAS causes damages, at least the plate can be found in the wreckage (even multicopter without combustion engine are vulnerable to fire on board (from batteries)). 3) "Small unmanned aircraft may not operate over any persons not directly involved in the operation." - it should be extended to a safety horizontal barrier, not only directly above people, but also not in an unsafe proximity (for multicopters this should be twice the actual height AGL).