Coming Soon…A Small UAS NPRM ??

As we wait for OIRA to complete its cost/benefit analysis of the proposed small UAS rules, it appears that FAA may have inadvertently given us all a sneak peek at what to expect.  According to a recent article, a quick fingered UAS enthusiast who was browsing on was able to download a copy of a document purporting to be FAA’s own analysis  of the costs and benefits of the new rules before it was quickly taken down.

One of the most interesting pieces of information in the report is confirmation of something that Plane-ly spoken as long expected, a private pilot’s license will not be required for commercial UAS operations.  Instead, there will be a new UAS Operators Certificate that will be tailored specifically for UAS operations.  In order to get the new license, the applicant will have to pass a test and demonstrate knowledge of:

  1. applicable regulations relating to small unmanned aircraft system rating privileges, limitations, and flight operation;
  2. airspace classification and operating requirements, obstacle clearance requirements, and flight restrictions affecting small unmanned aircraft operation;
  3. effects of weather on small unmanned aircraft performance;
  4. small unmanned aircraft system configuration management;
  5. emergency procedures;
  6. crew resource management;
  7. radio communication procedures;
  8. determining the performance of small unmanned aircraft;
  9. physiological effects of drugs and alcohol;
  10. aeronautical decision-making and judgment; and
  11. airport operations

In addition to the new licensing requirements, the document also confirms that there will be a requirement for aircraft registration, and applicants will have to undergo a background check.

The document also contains hints at alternatives considered by the FAA but not included in the current rule.  It appears that the FAA looked seriously at allowing pilots to fly using FPV technology.  The FAA, however, concluded that there was not enough data to do a meaningful safety analysis, and that proposal has been rejected.  The FAA also considered separate rules for UAS weighing less than 4.4 pounds, which it classified as micro-UAS.  While this proposal is not in the draft rule, the FAA has specifically invited public comment on whether the final rule should include these provisions.

If anything, the market assumptions underlying the FAA’s analysis seems quite conservative.  The FAA estimates that for the first 3 years after the rules go into effect, there will be approximately 3,200 UAS registered each year.  The FAA expects that to fall off to about 1,400 per year in the following 2 years.  The FAA assumes that approximately 20 percent of commercial UAS will be retired each year, for a total of 7,500 UAS operating after 5 years.

So, it appears that release of the small UAS rule is finally in the home stretch.  As soon as the NPRM becomes available, Plane-ly spoken will provide you with our full analysis.

(Originally posted February 14, 2015)

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