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Drone Registration Requirements: Our Comments to the DoT and FAA

Logan Campbell - Logan@Aerotas.com

As the owner of a commercial UAS company and long-time hobbyist, I agree that the safety of the national airspace is of critical importance.  However, registration requirements for UAS could seriously limit the pace of innovation in the industry, and the freedom of hobbyists and enthusiasts to engage in their desired pursuits.  

The ability to freely build, design, fly, and alter experimental model aircraft is what allowed the UAS industry to develop.  It allows for a culture of innovation that will produce technologies that benefit the entire world.  Requiring registration on hobbyist and homemade aircraft would restrict this culture and hinder the development of the industry.  Model aircraft manufacturers and operators have coexisted safely with the national airspace for decades without registration requirements, and this safe coexistence through the AMA should be allowed to continue.  

The requirements for registration and which devices are registered must be unambiguous, such as those based on weight or size.  Ambiguous rules, such as commercial versus recreational distinctions, will restrict the industry by not allowing manufacturers or operators to clearly understand which regime they operate under.  This ambiguity would increase litigation costs, and be an overall detriment to the industry.  

All registration information should be kept private, and not be publicly available without special request, following the precedent of car registration records. UAS are different from traditional manned aircraft, and their records should not be treated the same.  

RECOMMENDATION

In order to foster an environment of innovation and support a safe hobby, while improving the safety of the national airspace, the best solution is to require registration only on high-volume production aircraft.  The biggest risk comes from the accessibility of powerful and capable aircraft to huge segments of the population who are not as intrinsically dedicated to safety as traditional hobbyists or low-volume manufacturers.  For several decades, low-volume producers and hobbyists have shown a dedication to national airspace safety.

By restricting registration requirements exclusively to models that are produced in volumes greater than a specified value (e.g., 5,000 units per year), then hobbyists and enthusiasts are free to operate and innovate safely, while the less-educated and higher-risk operators are required to register.  This would additionally have to be tied to a weight minimum so as to not restrict toys that pose no threat to the national airspace.  

By adopting a volume-based registration requirement, hobbyists, enthusiasts, and innovators are all freed from burdensome and potentially complex requirements, and issues such as modifications, changing individual parts, and serial number availability become less significant.  Further, the highest risk segments are still required to register, allowing for accountability and education where it matters most. 

 

 

Logan is the founder and CEO of Aerotas.  He graduated from Harvard Business School in 2015 and brings experience in a broad range of industries, including agriculture, real estate, and finance.  A lifelong tinkerer and avid UAV enthusiast, Logan also has hundreds of hours of flight experience over a broad set of different UAV types.