FAA, Drones and Registration . . . It’s Coming

The FAA’s proposed model aircraft registration system has taken a major step forward.  The Aviation Rulemaking Committee (ARC) has delivered its report to the FAA with a wide range of recommendations.  When the proposal was originally announced, virtually nothing was known about what types of aircraft would be registered, who would have to register, and when registration would take place.  Under the proposal in the ARC report, the registration requirement is surprisingly broad.

When the project was announced, it was unclear whether the registration threshold for aircraft would be set based on weight, performance, or a combination of the two.  The ARC Report has decided to go with a weight-based approach, and has set the bar much lower than most people expected.  The Report recommends that all model aircraft weighing less than 250 grams (8.8 ounces) be subject to registration.  At a little over a half-pound, this will sweep up all but the smallest toys.

Obviously, setting the weight limit this low means that the number of vehicles to register will be enormous.  To deal with the problem, the report recommends a system where the owner, and not the vehicle itself, be registered.  Upon signing up, each owner would be given a certificate of registration with a unique owner registration number.  This number would have to be placed on any model aircraft they own.  Children as young as 13 would be eligible to register.  The owner must provide name and address, with phone number, email address and an aircraft serial number optional.  The operator, i.e. the person flying the aircraft does not have to register.  The FAA will be the custodian of the information that is collected.

The ARC Report also notes that compliance with the new system will only be successful if it is easy for owners to use.  The current aircraft registration system, with its reliance on paper forms with multiple carbon copies, is not up to the task.  The ARC recommends that the FAA’s system be both web and app based to make use as streamlined and easy as possible.

So, how did the Committee reach the conclusion that model aircraft as light as half a pound should be registered?  The ARC Report notes that there is a lack of scientific studies of the risks of UAS operation.  It should also be noted that there is not even a large body or “real world” data on model aircraft injuries due to the enviable safety record the hobby enjoys.  The ARC focused primarily on a study done by MITRE dealing with injuries from falling objects, and concluded that at 250 grams, there would be an acceptable risk of injuries from an aircraft falling from 500 feet, taking into account air resistance and terminal velocity.

The ARC report is a very important part of the FAA’s process, but it is not the end.  The FAA has made clear that the final rule will be based not only on the ARC Report but also on the four thousand comments filed in the Federal Register.  The one thing we know for sure, registration is definitely coming.

(Originally posted November 23, 2015)

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