NetMoby - Petition for Reconsideration

Kelly Law UASOpposeBusiness
Summary: NetMoby, Inc., a company incorporated in the District of Columbia, opposes the FAA's Final Rule because it prohibits the use of small unmanned aircraft systems (sUAS) for transporting property for compensation or hire between locations within the District of Columbia. The company argues that this exclusion is arbitrary and capricious, as it relies on anachronistic legislation from 1958 and fails to provide a rational connection between the facts and the regulatory choice.
NetMoby, Inc., respectfully submits this Petition For Reconsideration pursuant to 5 U.S.C. 553 and 14 C.F.R. I I. I 01, in reply to the Federal Aviation Administration (FAA),Department of Transportation's Final Rule in Operation and Certification of Small Unmanned Aircraft Systems, 81 FR 42063 (June 28, 2016), Docket No. FAA-2015-0150 (FAA Final Rule"). NetMoby filed comments in response to the Notice of Proposed Rulemaking ("NPRM") in Docket No. F AA-2015-0150 on April 24, 2015, and thus has standing to file this Petition for Reconsideration. NetMoby asks for reconsideration specifically of the provision of the FAA Final Rule which addresses the use of sUAS ("sUAS") from transportation of property for compensation or hire between locations within the District of Columbia. The FAA's adoption of this regulation for sUAS will most likely bar the use of sUAS from transportation of property for compensation or hire between locations within the District of Columbia permanently, in the absence of a waiver of the applicable rules. As a copany incorporated in the District of Columbia, which has previously been awarded a waiver pursuant to Section 333 of the FAA Modernization and Reform Act of2012, Public Law 112-95 (P.L. 112-95), in Exemption No. 16314, Regulatory Docket No. FAA-2015-7428, NetMoby will be directly and adversely affected by the adoption of this provision of the Final Rule. Accordingly, NetMoby submits as follows. This Petition for Reconsideration was delivered by U.S. Mail on August 23, 2016 to US Department of Transportation Docket Management Facility 1200 New Jersey Avenue, SE (West Building) Building Ground Floor Room W12-140 Washington, DC 2059

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