Operation and Certification of Small Unmanned Aircraft Systems

The commenter, speaking from the perspective of a pilot and a civilian, supports the creation of regulations for small unmanned aircraft systems (UAS). They argue that regulations are necessary to ensure safety, prevent mid-air collisions with manned aircraft, and provide transparency regarding why these drones are flying.

The commenter argues that the proposed regulations are overly restrictive and will stifle the commercial drone industry by maintaining visual line-of-sight requirements. They suggest that the rules are excessive compared to other transportation technologies and advocate for easing these restrictions to allow for viable commercial use cases like long-distance transport.

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.

An individual drone operator is proposing an amendment to the regulations regarding sUAS operations near airports. They argue that flights remaining below 200 feet and within property boundaries should not require contacting an Air Traffic Control Tower (ATCT).

The commenter supports the FAA's effort to develop the new rule but expresses concern regarding UAV operations in busy Class G airspace. They request that the FAA include specific exceptions requiring authorization for UAV operations near high-traffic airports like Boulder City Airport.

The commenter argues that the FAA's jurisdiction over low-altitude sUAS operations (0-200 feet AGL) over private property exceeds its legal authority and infringes on property rights. They propose exempting these localized, low-altitude commercial flights from Part 107 licensing requirements, suggesting that such activities should instead be regulated by state and local laws.

Ryan Bemis, a small agricultural drone spraying business owner, supports the new regulations but urges the FAA to create a specific category for drones weighing under 500 lbs. He argues that current weight thresholds may exclude smaller businesses and suggests that agricultural drones with specific safety features (like geo-fencing and obstacle avoidance) should have their own regulatory category to keep costs and risks manageable.

A private hobbyist who has flown RC aircraft for many years expresses satisfaction with the current flight requirements. They request that no new policies or changes be added to the existing structure for operating small unmanned aircraft systems.

Jonathan Lester, a long-time RC aircraft pilot and commercial pilot, opposes the proposed rules for small unmanned aircraft systems. He argues that the current self-regulated system managed by the AMA is sufficient for line-of-sight flights and that FAA oversight, licensing, and transponder requirements are unnecessary and burdensome.