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Today is the last day for public comment on the FAA’s proposed rules on drones!

Hi folks,
As you may know, the U.S. Federal Aviation Administration released preliminary rules governing the operation of “small unmanned aerial systems” (“sUAS,” or more simply, drones) a couple of months ago. The FAA’s process for adopting new rules includes a period where the public is allowed to comment on the preliminary rules before they are finalized. Today is the last day of that public comment period, so if you are a photographer or filmmaker who either uses drones as one of your tools or wants to, this is your last opportunity to have your voice heard! If you want to make your voice heard and submit a comment using the easy online process, there are instructions below on how to do so, as well as a sample comment that I’ve written.

The FAA’s proposed rules cover all manner of issues relating to the flying of drones, and include, among many other proposals, the following:

1) The FAA will define all craft weighing less than 55 pounds as sUAS, and will treat all sUAS equally
2) Drone pilots will be required to take certification classes and pass a written exam to pilot drones and register their aircraft
3) Drones will be limited to flying no higher than 500 feet above ground level in altitude and no faster than 100 miles per hour
4) Drones will be required to be flown only within the pilot’s line-of-sight
5) Drones will be prohibited from flying over uninvolved bystanders

In general I think most of the rules are reasonable, however I do have a number of quibbles, so yesterday I wrote a comment which I submitted. My biggest issue with the rules as they are proposed is that popular drones such as DJI Phantom models are tiny (less than 3 pounds) compared to the 55-pound systems they are being lumped in with. Phantoms that weigh 2.2 pounds pose far less of a safety risk to the public and other aircraft than much larger and heavier systems, so it isn’t fair that they would be lumped in with these larger systems and regulated as strictly and heavily, especially considering that Phantoms are far more popular and numerous than larger, heavier (and more potentially dangerous) systems.
My comment is as follows:

In regards to Proposed Rule FAA-2015-0150, “Operation and Certification of Small Unmanned Aircraft Systems”:
- A wide array of commercial enterprises have a legitimate business interest in flying small unmanned aircraft systems (“sUAS”), and an even wider array of American consumers will benefit from these business’s ability to do so.
- The complexity, skill required to operate, and potential safety hazards to both the operator and third parties resulting from the operation of sUAS are all far less than those of manned aircraft. Therefore the licensing and regulatory requirements to operate sUAS must be commensurately less intensive and demanding than the licensing and regulatory requirements of operating manned aircraft.
- It is reasonable and appropriate for both hobbyist and commercial sUAS operators to be required to fulfill licensing and regulatory requirements to operate sUAS, provided those requirements are appropriate to the level of complexity, skill required to operate, and potential safety hazards posed by sUAS, as described above. The licensing and regulatory requirements must be inexpensive and minimally time consuming for hobbyists and small commercial operators to complete.
- The vast majority of sUAS units in the United States weight less than 5 pounds. Therefore, the proposed rule’s equal treatment of all sUAS weighing less than 55 pounds is unrealistic and inappropriate. Hobbyist and commercial sUAS exist ranging from mere ounces in weight through and exceeding hundreds of pounds in weight, with commensurately differing levels of capability and potential safety hazard. Appropriate sUAS rules and regulations must reflect the realities of the differing levels of complexity, skill required to operate, and potential safety hazards posed by the variety of sUAS.


If you would like to submit a comment of your own, simply go to the regulations.gov page for this specific proposed rule using the link below, then click on the blue button on the top right that reads, “Comment Now!”:
If you agree with the comment that I wrote, feel free to copy and paste the text above into your comment! (You can choose to include your name with your comment, or if you prefer you can submit your comment anonymously!).

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