NPRM in Reader’s Digest Form


The comment period is now closed, and it will be some time before the final document will emerge. for review, references to the related (page numbers) are provided in the handy reference guide below.

The complete news conference call audio is here.


The document and comments may still be viewed at Regulations.Gov  (Docket FAA-2015-0150) Here are the comments, totaling 4,551.

Here is a summary of the main issues upon which comments were requested.

  1. The FAA invites comments on how it can improve or further leverage its test site program to encourage innovation, safe development and UAS integration into the NAS. (32)
  2. FAA invites comments as to whether the final rule should relax operating restrictions on small UAS equipped with technology that addresses the concerns underlying the operating limitations of this proposed rule, for instance through some type of deviation authority (such as a letter of authorization or a waiver). (36)
  3. FAA invites comments, with supporting documentation, on whether external-load UAS operations and towing UAS operations should be permitted, whether they would require airworthiness certification, whether they would require higher levels of airman certification, whether they would require additional operational limitations, and on other relevant issues. (40)
  4. The FAA will consult with the Secretary to determine the process through which it might permit foreign-owned small unmanned aircraft to operate in the United States. The FAA invites comments on the inclusion of foreign-registered small unmanned aircraft in this new framework. (44)
  5. The FAA invites comments regarding whether the proposed rule needs to be modified to ensure that it is consistent with any relevant obligations of the United States under international agreements. (44)
  6. The FAA invites comments, with supporting documentation, on whether the regulation of small UAS should be further subdivided based on the size, weight, and operating environment of the small UAS. (54) (Micro UAS)
  7. Without the risk mitigation provided by frangible-material construction, the FAA would be unable to allow micro UAS to operate directly over a person not involved in the operation. The FAA notes that, currently, a majority of fixed-wing small UAS are made out of frangible materials that would satisfy the proposed requirement. The FAA invites comments on whether it should eliminate frangibility from the micro UAS framework. (58)
  8. to assess the risk to other airspace users posed by the lesser restricted integration of micro UAS into the NAS. The FAA notes, however, that due to statutory constraints, the FAA would be unable to eliminate the requirement to hold an airman certificate and register the unmanned aircraft even if it were to adopt a micro UAS approach in the final rule. The FAA invites comments on whether it should eliminate frangibility from the micro UAS framework. (59)
  9. the FAA proposes not to provide an operator with the emergency powers available to the PIC under § 91.3(b). The FAA invites comments on this issue. (62)
  10. The FAA invites comments on whether a separate operator-in-command position should be created for small UAS operations. (62)
  11. FAA invites comments as to whether defining a new crewmember position as an “operator” would cause confusion with the existing terminology. If so, the FAA invites suggestions as to an alternative title for this crewmember position. (63)
  12. The FAA invites comments on whether the visual observer should be required to stand close enough to the operator to allow for unassisted verbal communication. (65)
  13. The FAA invites comments on whether an airman certificate should be required to serve as a visual observer. (66)
  14. The FAA also invites suggestions, with supporting documentation, for other ways in which a first-person-view device could be used by the operator without compromising the risk mitigation provided by the proposed visual-line-of-sight requirement. (69)
  15. The FAA also invites comments on whether it should permit operations beyond visual line of sight in its final rule, for example through deviation authority, once the pertinent technology matures to the extent that it can be used to safely operate beyond visual line of sight. (69)
  16. FAA invites comments on whether a flight termination system or other technological equipage should be required and how it would be integrated into the aircraft for small UAS that would be subject to this proposed rule. The FAA also invites comments, with supporting documentation, as to the costs and benefits of requiring a flight termination system or other technological equipage. (75)
  17. FAA invites comments on whether the horizontal boundary of the contained area of operation should be defined through a numerical limit. If the boundary is defined through a numerical limit, what should that limit be? (76)
  18. The FAA invites comments, with supporting documentation, on whether this proposed 500-foot ceiling should be raised or lowered. (78)
  19. the FAA proposes to limit the speed of small unmanned aircraft to 87 knots (100 mph). The FAA invites comments on whether this speed limit should be raised or lowered or whether a speed limit is necessary. (80)
  20. This proposed requirement is similar to a requirement that currently exists in § 91.7(b), which requires the PIC to “discontinue the flight [of an aircraft] when unairworthy mechanical, electrical, or structural conditions occur.” The FAA invites comments on the issues discussed in this section. (91)
  21. The FAA also invites comments as to the costs and benefits of requiring small UAS operators to perform maintenance and inspections pursuant to existing regulations. (91)
  22. The FAA notes that the minimum age necessary to apply for an airman certificate to operate a glider or a balloon category aircraft is 16 years old. The FAA invites comments on whether the minimum age necessary to apply for an unmanned aircraft operator certificate should similarly be reduced to 16 years old in the final rule. The FAA also invites comments as to whether reducing the minimum applicant age to 16 years old would further enable academic use of small UAS. (98)
  23. The FAA invites comments on whether these applicants should be required to demonstrate flight proficiency and/or aeronautical experience. If so, what flight proficiency and/or aeronautical experience requirements should the FAA impose? The FAA also invites comments as to the costs and benefits of imposing these requirements. (103)
  24. The FAA invites comments on the proposed areas of knowledge to be tested on the initial knowledge test. The FAA also invites comments as to whether the initial knowledge test should test any other areas of knowledge. (110)
  25. The FAA invites comments on whether the small UAS aeronautical knowledge test should have an option for online test-taking (111)
  26. Based on the FAA’s experience with the existing 24-month flight review cycle, a recurrent knowledge test that is given every 24 months would ensure that the small UAS operator properly maintains the pertinent aeronautical knowledge. The FAA invites comments on this proposed requirement. FAA invites comments on whether the small UAS recurrent aeronautical knowledge test should have an option for online test-taking.(112)
  27. The FAA invites comments as to whether this certificate should expire after a certain period of time. If so, when should the certificate expire? (114)
  28. The FAA invites comments on whether non-military COA pilots should be permitted to take the recurrent knowledge test instead of the initial knowledge test in order to obtain an unmanned aircraft operator certificate. (117)
  29. the FAA estimates that it could take about 6 to 8 weeks after receipt of an application for the FAA to issue an applicant an unmanned aircraft operator certificate with a small UAS rating. The FAA invites comments with suggestions for how this period could be reduced. The FAA also notes that the TSA will continue to examine certificate holders after FAA issuance of a certificate. (119)
  30. the FAA is proposing to limit positive identification and acceptance of an application to those persons who are either: (1) already authorized to accept and sign airman applications (FAA personnel, DPEs, and ACRs); or (2) are already required to verify identity under the TSA’s regulations (CFIs). Knowledge testing centers do not fit into either of these categories, and thus, this proposed rule would not allow them to accept airman applications. The FAA invites comments on whether knowledge testing centers should be allowed to accept airman applications. (122)
  31. ..small unmanned aircraft, which would not be type-certificated under this proposed rule, come in a variety of forms, many of which are not currently standardized. This situation is likely to continue as the small UAS market will continue broad innovation until designs emerge that are well balanced against the tasks found to be best served by this segment of aviation. To enable the FAA to both identify particular aircraft against a stated description as well as to identify and share safety related information as it develops, the FAA invites comments as to whether small unmanned aircraft owners should be required to provide additional information during the registration process. FAA invites comments as to whether small unmanned aircraft owners should be required to provide additional information during the registration process. The FAA anticipates that the additional information requirement imposed on small unmanned aircraft could be similar to the requirements imposed on amateur-built aircraft under 14 CFR 47.33(c), as amateur aircraft pose the same lack-of-standardization issues as a small UAS. (128)
  32. The FAA invites comments on whether a small unmanned aircraft should be required to display its registration number in accordance with Subpart C of part 45. If compliance with Subpart C should not be required, what standard should the FAA impose for how a small unmanned aircraft displays its registration number in order to fulfill its safety oversight obligation regarding small unmanned aircraft operations? The FAA invites comments with supporting documentation on this issue. (130)
  33. the FAA does not believe that the safety benefits of requiring small UAS manufacturers to install fireproof plating with their identification information would be sufficient to justify the costs of doing so. The FAA invites comments, with supporting documentation, as to the costs and benefits of mandating compliance with Subpart B of part 45.The FAA also invites comments, with supporting documentation, on whether alternative methods of small-UAS manufacturer marking should be required. (131)
  34. The FAA emphasizes that this proposed reporting requirement would be triggered only during operations that result in injury to a person or property damage. The FAA invites comments as to whether this type of accident-reporting should be required. If so, what is the threshold of property damage that should trigger the accident reporting requirement? (134)
  35. The FAA invites comments on the inclusion of foreign-registered small unmanned aircraft in this new framework. (154)

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