Remote Control Aerial Platform Association NPRM Response

As an association with a long history of participation in the Global UAS airspace integration effort, which includes membership on the sUAS ARC (order 1110.150), and standards groups ASTM, RTCA and Eurocae (through the ICI), and the Beyond Visual Line Of Sight Action Team (BVLOS), we concur with most of what is contained in the FAA’s proposal for sUAS rulemaking.

Our members have many years of empirical knowledge gained and refined from years of real world operations and applications prior to the 2007 policy clarification in other FAA sanctioned or excluded activities.

The micro UAS category concept has in it many of the ideas and notions put forth by the by RCAPA in a proposed special rule for micro UAS, the framing of which started during the sUAS ARC, with participants and also representatives from ALPA and AOPA. (attached) To see some of the concepts and verbiage from the RCAPA proposal in the NPRM is encouraging. We maintain that this proposal, while limited, will give folks a low burden method of entry and represents a safer and more practical solution to that which has been transpiring in the NAS for many years. The proposal and its suggestion of community-based standards would allow for quick changes to remedy any unforeseen shortcomings that may or may not surface with a dynamic and ever evolving technology.

While we have no scientific data to back these assertions, a cursory Google search should produce a sampling of videos that may serve to reinforce the notion.

While 55lbs and 100 miles an hour may be beyond our comfort level, we have no scientific data to prove it safe or unsafe and will defer to they FAA’s expertise on the upper limits of what is safe for small unmanned aircraft systems.

We applaud the FAA’s forward thinking and leadership as it pertains to what is undeniable the future of aviation.

For the RCAPA:

Patrick Egan

Gene Robinson

The Full response sUAS Exemption RCAPA