Give The FAA Preemptive NPRM Feedback

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Be sure to tell them you are ready to get to work legally and share your ideas for progress etc. Tell them that regular access to the NAS in 2020 is unacceptable. SHare your thoughts on pilot and observer certification, aircraft certification and limitations on autonomous aids.


https://www.faa.gov/about/office_org/headquarters_offices/avs/stakeholder_feedback/arm/

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    Administrator Huerta,

     

    I would like to share a few concerns that have come to light after reading the recently released UAS roadmap documentation.

     

    Many in the small business end-user stakeholder community are concerned about the timeline for regular access to the NAS. While it is completely understandable that rulemaking takes time, the FAA has been working this issue since the mid 2000’s. These same stakeholders find it hard to believe that we are close to 10 years into the process and even harder to believe, with little or nothing to show.

     

    The small UAS ARC put out their recommendations on April 1, 2009, yet we still haven’t seen the NPRM. The NPRM was supposed to be released for public comment almost 2 years ago. Sadly, it appears that we will miss the December 2013 NPRM timeline we were told about this spring/summer.

     

    The references to the current UAS ARC continuing the work of the sUAS ARC and recommendations for the NPRM are disheartening as there is no small business stakeholder representation in on or around that committee. A tragedy as this affected stakeholder group potentially has the most to lose.

     

    This work of the current rulemaking committee is a finical make-or-break for the small business end-user stakeholder. References made to “develop standards” or, facilitate the development of standards” for pilot certification and aircraft certification are ambiguous and disheartening for those of us safety minded stakeholders and end-users trying to build a legal, business plan.

     

    Even more disconcerting is the class 2 medical requirements for operators of smaller UAS and the far standoff distances from airports. All of this coupled with a very limited flight envelope coupled with the lack of a public algorithm for ADS-B have many concerned that the domestic UAS industry will be stillborn.

     

    This stakeholder group asks that the FAA address some of these concerns by examining the pragmatic work done by some of the European countries like the U.K. et al.

     

    Thank you for your consideration on this matter, John Q. Stakeholder

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