31 Questions the FAA Wants you to Answer

By Arthur Holland Michel

Last Sunday, the Federal Aviation Administration unveiled a draft set of rules for the non-recreational use of drones in domestic U.S. airspace. The FAA recognizes that its proposed rules are not perfect, and that they could be greatly improved with a little help of the public. And so, before these rules can be set in stone, the FAA will provide the public with an opportunity to comment on these rules (this is a required part of the rulemaking process). This period of comment, which will last 60 days (but could be extended to 90 days) is an important step in the process, as it allows the public to draw the FAA’s attention to issues, concerns, and factors that it may have overlooked. The FAA takes seriously the comments it receives.

The public can comment on absolutely any part of the proposed rules draft, but the FAA has highlighted a number of issues that it would especially like the public to comment upon. Here are 30 questions, phrased in layman’s terms, that the FAA wants you to answer. Details for how to submit a public comment are provided at the bottom of this post.

We provide page numbers for the sections of the proposed rules corresponding to each question.

  1. How much money would these rules save the U.S. economy? The FAA wants to measure the economic impact of these rules so it can determine whether the benefits of the rule would outweigh the costs of implementing and maintaining it. p16
  1. Should the FAA have different, less restrictive rules for drones that weigh less than 4.4 lbs? And if it should, are there any risks it should take into account? The FAA has said it is particularly interested in the public’s thoughts on this matter. p59
  1. How can the FAA make better use of its six test sites? p32
  1. Should drones with advanced safety features that mitigate some of the safety concerns underlying the rules be exempt from certain rules? And how should the FAA determine which drones should be exempt? p36
  1. Should drones be allowed to tow objects? p40
  1. Should drones registered overseas be allowed to operate in the U.S.? p44
  1. A cornerstone of the proposed rules is the requirement that drone pilots maintain a direct line of sight with the drone at all times, but many have claimed that this rule would significantly restrict drone applications. So, is there any reason why this requirement should be lifted, and if so, how could it be lifted while keeping operations safe? p13
  1. Should the rules require that very small drones be made out of materials that shatter on impact, thus reducing harm to people if they are struck by one? p58
  1. The FAA allows the Pilot in Command of manned aircraft to break certain flight rules  during an emergency situation. Should drone operators be granted the same permission? (The FAA thinks not) p62
  1. Certain drone flight will require a second person to act as a visual observer, to help the pilot track the drone. Should this visual observer be required to remain within shouting distance of the pilot? p65
  1. Should the visual observer be required to get certification? (Pilots will need to be certified). p66
  1. The proposed rules do not allow operators to use First Person View systems to get around the requirement that the pilot be able to see the drones with the naked eye at all times? But are there any ways that FPV could be used safely in the place of line-of-sight? And should the FAA be open to granting exemptions to its naked eye requirement once FPV technology gets better? p70
  1. The proposed rules would not require a maximum boundary for the area within which a pilot can fly a drone, but should it? And if so, what should that limit be? p76
  1. Should the FAA allow drones to be launched and operated from cars? The proposed rules would not permit this, but they would permit the operation of drones from boats. p77
  1. Is the proposed 500 ft ceiling for all drone flights too high or too low, or is it just right? p79
  1. Should there be a speed limit for drones? The FAA thinks it should be 100 mph. p80
Credit: Boeing
  1. Should drone operators be classified a a new category of airmen? p97
  1. Should 16 year old be allowed to apply for a drone pilot certificate? Would reducing the minimum age expand the academic use of drones? p98
  1. Should drone operators be required to demonstrate flight proficiency and aeronautical knowledge? p103
  1. The FAA proposes a knowledge test for certification to fly drones, but should a training course be required instead? p104
  1. What areas should the knowledge test cover? In other words, what do drone operators need to be tested on? p107
  1. Should drone pilot licenses expire after a certain amount of time? And if so, when should they expire? p114
  1. Should drones have to display their registration number according to the requirements for manned aircraft, or should they get their own set of display requirements (that is, font size, color, etc)? p130
  1. Should drone makers install fireproof identification information on every drone, to aid in investigations after an accident? p131
  1. What kinds of accidents and incidents should drone operators report to the FAA? If an accident only causes minimal property damage or injury, should it be reported, or forgotten?  p134
  1. If you have ever operated a drone in a country that already has regulations, what was it like? Was it stricter, or more lenient than these rules? p154
  1. Should we be allowed to use drones to transport and deliver goods? p40
  1. The proposed rules would prohibit the use of drones at night. Is there any reason the FAA should reconsider this rule. If so, how could pilots ensure that nighttime operations are safe? p71
  1. Should drone pilots have to pass a medical test? p116
  1. Should Alaska have different drone rules? The state is much less densely populated than the lower 48 states, and during the winter it gets much less daylight. p162
  2.  Should there be a blanket rule for all drones under 55lbs, or should there be separate rules based on weight of the drones (i.e. stricter rules for heavier drones)? p54

The comment period will be open when the proposed rule is published in the Federal Register. Visit here to find out whether or not it has been published.

When it is published, this is how you can make a comment: 

Federal eRulemaking Portal: Go to http://www.regulations.gov and follow the online instructions for sending your comments electronically.

Mail: Send comments to Docket Operations, M-30; U.S. Department of Transportation (DOT), 1200 New Jersey Avenue, SE., Room W12-140, West Building Ground Floor, Washington, DC 20590-0001.

Hand Delivery or Courier: Take comments to Docket Operations in Room W12- 140 of the West Building Ground Floor at 1200 New Jersey Avenue, SE., Washington, DC, between 9 a.m. and 5 p.m., Monday through Friday, except Federal holidays.

Fax: Fax comments to Docket Operations at 202-493-2251. Privacy: In accordance with 5 USC 553(c), DOT solicits comments

Comments also should be submitted to the Office of Management and Budget, Office of Information and Regulatory Affairs, Attention: Desk Officer for FAA, New Executive Office Building, Room 10202, 725 17th Street, NW., Washington, DC 20053.

The FAA adds this note for would-be commenters: “The most helpful comments reference a specific portion of the proposal, explain the reason for any recommended change, and include supporting data. To ensure the docket does not contain duplicate comments, commenters should send only one copy of written comments, or if comments are filed electronically, commenters should submit only one time….Before acting on this proposal, the FAA will consider all comments it receives on or before the closing date for comments.”

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