Tuesday, April 13, 2021

Unmanned Aircraft Systems Registration Task Force recommendations… not fireproof


Perhaps I am missing the point as ever but any RPA might catch fire in an off. Instantly I saw something that would not fly in South Africa. No requirement for fireproof ID. Here is how its written in South Africa…

Small Fireproof Identification Plate

It is also required to have a small identification plate that is fire proof, with the serial number and registration number of the aircraft (so the aircraft can be identified in the case of a crash or fire).

The ID plate should be securely attached and in a prominent position on the RPAS. 

To me that would just mean go down to the jewelers and get a little engraved plate.

The executive summary from the working Task Force.

The Task Force agreed that it was outside the scope of the Task Force’s objectives to debate or discuss the DOT Secretary’s decision to require registration of sUAS or the legal authority for the implementation of such a mandate. Once that understanding was reached, the Task Force undertook the task to develop and recommend a registration process that ensures accountability for users of the NAS and encourages a maximum level of compliance with the registration requirement, while not unduly burdening the nascent UAS industry and its enthusiastic owners and users of all ages. The Task Force also sought to define a category of sUAS that should be excluded from the registration requirement because they do not present a significant level of risk to the non-flying public and to users of the NAS.

The Task Force recommendations for the registration process are summarized as follows:

1) Fill out an electronic registration form through the web or through an application (app).

2) Immediately receive an electronic certificate of registration and a personal universal registration number for use on all sUAS owned by that person.

3) Mark the registration number (or registered serial number) on all applicable sUAS prior to their operation in the NAS.

While the brief summary above leaves out some details, like the option of serial number registration, it demonstrates the simplicity of the solution recommended by the Task Force members. This simplicity is what allowed for a consensus recommendation to develop. Any registration steps more burdensome than these three simple steps may jeopardize the likelihood of widespread adoption and would undermine the overall registration philosophy that enabled the Task Force to come to consensus.

Although there were often very divergent views, and some decisions were not unanimous, the Task Force reached general agreement on their recommendations to the FAA with the frequent use of votes. Additionally, the general consensus view of the Task Force is that the recommendations on the three objectives are to be presented together as a unified recommendation, with each of the individual recommendations dependent upon elements in the others. Compromises in positions were made whenever possible to obtain a general consensus, and changes to any of the components could further dilute support among the Task Force members and their constituencies for the final recommendations. It should be noted that the Task Force acknowledged that the timeframe provided for deliberations did not allow for in-depth analysis of all the factors involved in instituting a federal requirement for registering sUAS, nor did it allow for an assessment of the impact of such a mandate on the recreational/hobby community.

Based primarily upon an assessment of available safety studies and risk probability calculations, and notwithstanding determinations in other countries with differing weight thresholds, the Task Force recommended an exclusion from the registration requirement for any small unmanned aircraft weighing a total of 250 grams (g) or less. The 250 grams or less exclusion was based on a maximum weight that was defined as the maximum weight possible including the aircraft, payload, and any other associated weight. In manned aircraft terms, it is the “maximum takeoff weight.”

The Task Force also recommends a free, owner-based registration system with a single registration number for each registrant. (They also suggested that if the FAA is required by statute to charge, that the fee should be $0.001). sUAS owners would be required to register with the FAA, prior to operation in the NAS, by entering their name and street address into a web-based or app based registration system.

The system would be powered by an Application Program Interface (API) that would allow multiple app clients to feed registration information into the database, ensuring widespread compliance. Provision of email address, telephone number, and serial number of the aircraft into the system would be optional. Information on U.S. citizenship or residence status would not be required, but there would be a minimum age requirement of 13 years to register.

At the time of registration, each registrant would receive a certificate of registration that contains a unique universal registration number (and the aircraft serial number if provided) that can be used on all sUAS owned by the individual. This registration number would be required to be directly marked on or affixed to each sUAS the registrant owns, prior to outdoor operation. This marking would need to be maintained in a readable and legible condition, and be readily accessible upon visual inspection. If a registrant chose to provide the FAA with the aircraft’s serial number, the registrant would not be required to further mark the sUAS with the FAA-issued registration number , as long as the serial number meets the requirement of being readable, legible, and readily accessible (without the use of tools) upon visual inspection. The Task Force also recommends that the registration process contain some sort of education component which could be similar to the existing content in the Know Before You Fly campaign.

Read the full report RTFARCFinalReport_11-21-15

Gary Mortimer
Gary Mortimer
Founder and Editor of sUAS News | Gary Mortimer has been a commercial balloon pilot for 25 years and also flies full-size helicopters. Prior to that, he made tea and coffee in air traffic control towers across the UK as a member of the Royal Air Force.