On October 22, 2015, the U.S. Department of Transportation (DOT) and the Federal Aviation Administration (FAA) published a notice of clarification and request for comment regarding the applicability of aircraft registration requirements for unmanned aircraft systems (UAS), commonly referred to as drones. Previously, DOT exercised discretion in determining which UAS it required to register with FAA. Commercial UAS operators authorized through the Section 333 exemption process have been required to register. Citing the need to enforce personal accountability for safe operation as more UAS enter the national air space, DOT has now determined that all UAS, including model aircraft, will be required to register. DOT has convened a registration task force to evaluate a streamlined registration system for small UAS.
DOT requests comments on ten registration issues. These include, for example:
- Should certain UAS be excluded based on performance capabilities or other characteristics such as weight, speed, operating altitude, or duration of flight?
- How should a registration process be designed to minimize burdens and best protect innovation and encourage growth in the UAS industry?
- Should a registration fee be collected, and if so, how?
- Are there additional means beyond registration to encourage accountability and responsible use of UAS?
Comments are requested by November 6, 2015, but the comment period will remain open thereafter. The registration task force will provide its recommendations by November 20, 2015.