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BREAKING: DOT Accepting Public Comments on UAS Registration Requirements

E. (Ted) Tazewell Ellett

E. (Ted) Tazewell Ellett,

Washington, D.C.

Lisa Ellman

Lisa Ellman,

Washington, D.C.

Matthew J. Clark

Matthew J. Clark,

Northern Virginia

Gretchen A. West

Gretchen A. West,

Silicon Valley

Patrick R. Rizzi

Patrick R. Rizzi,

Washington, D.C.

23 October 2015
On Monday, October 19, the Department of Transportation (DOT) announced the creation of a task force charged with developing a registration process for unmanned aircraft systems (UAS), or drones, for both commercial and hobbyist use. Secretary Foxx directed the task force to deliver its recommendations by November 20, with the goal of having final registration rules in place by mid-December.
BREAKING: DOT Accepting Public Comments on UAS Registration Requirements

In a surprise move, DOT just published a document, Clarification of the Applicability of Aircraft Registration Requirements for UAS and Request for Information Regarding Electronic Registration for UAS, to the Federal Register.  DOT is soliciting recommendations on all aspects of the UAS registration process, including which UAS should be exempt from the registration requirement.

The clarification and request for information requests that comments be received within 15 days after publication in the Federal Register, which is November 6, although the comment period reportedly will remain open for the near future.  Of course, given the Secretary’s expedited timeline, comments submitted after November 6 will be less likely to influence the recommendations made by the UAS registration task force.

In addition to clarifying applicable statutory requirements regarding UAS registration, DOT is requesting “information and recommendations regarding what information and registration platform would be appropriate for UAS registration and ways to minimize the burden to the regulated community.” DOT is also requesting comments on which UAS, in terms of weight or performance capabilities, should remain exempt from the registration requirements because of the negligible risk they pose to the national airspace system (NAS).

To facilitate the task force’s work in developing UAS registration procedures, DOT is requesting information and data from the public in areas such as:

  • At what point should registration occur (e.g. point-of-sale or prior-to-operation)? How should transfers of ownership be addressed in registration?
  • Consistent with past practice of discretion, should certain UAS be excluded from registration based on performance capabilities or other characteristics that could be associated with safety risk, such as weight, speed, altitude operating limitations, duration of flight? If so, please submit information or data to help support the suggestions, and whether any other criteria should be considered.
  • How should a registration process be designed to minimize burdens and best protect innovation and encourage growth in the UAS industry?
  • Should the registration be electronic or web-based? Are there existing tools that could support an electronic registration process?

Whether you are a UAS manufacturer, operator, or user, the comment period offers all industry stakeholders an opportunity to shape UAS regulation and policy. If you are interested in submitting comments, or if you have any questions regarding the process, please do not hesitate to contact us.

E. (Ted) Tazewell Ellett

E. (Ted) Tazewell Ellett,

Washington, D.C.

Lisa Ellman

Lisa Ellman,

Washington, D.C.

Matthew J. Clark

Matthew J. Clark,

Northern Virginia

Gretchen A. West

Gretchen A. West,

Silicon Valley

Patrick R. Rizzi

Patrick R. Rizzi,

Washington, D.C.

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