Find this and comment here!documentDetail;D=FAA-2015-4378-0001 Thanks Steve Zeets for the heads up.



Office of the Secretary

Federal Aviation Administration

14 CFR Chapter I

[Docket No. FAA-2015-4378]


Clarification of the Applicability of Aircraft Registration Requirements for Unmanned Aircraft Systems (UAS) and Request for Information Regarding Electronic Registration for UAS


AGENCY: Department of Transportation and Federal Aviation Administration.

ACTION: Clarification and request for information.


SUMMARY: This document clarifies the applicability of the statutory requirements regarding aircraft registration to UAS, including those operating as model aircraft. In addition, the DOT announces the formation of a UAS registration task force to explore and develop recommendations to streamline the registration process for UAS to ease the burden associated with the existing aircraft registration process.


This document requests 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.


In addition, we request comment on which UAS, based on their weight or performance capabilities, warrant a continued exercise of discretion with respect to requiring registration because of the negligible risk they pose to the national airspace system (NAS).


DATES: This clarification goes into effect [INSERT DATE OF PUBLICATION IN THE FEDERAL REGISTER]. To assist the task force in developing its recommendations, the


Department requests that comments in response to the request for information be submitted to



The docket will remain open after this time and the Department will consider all comments received in developing a registration process.


ADDRESSES: You may submit comments by any of the following methods:

• Federal Rulemaking Portal: Follow the instructions for submitting comments.

• Fax: 202-493-2251.

• Mail: Dockets Management System; U.S. Department of Transportation, Dockets Operations, M-30, Ground Floor, Room W12-140, 1200 New Jersey Avenue, S.E., Washington, DC 20590-0001.

• Hand Delivery: To U.S. Department of Transportation, Dockets Operations, M-30, Ground Floor, Room W12-140, 1200 New Jersey Avenue, S.E., Washington, DC, 20590-0001, between 9:00 a.m. and 5:00 p.m., Monday through Friday, except Federal holidays.

Instructions: Include the agency name and docket number FAA-2015-4378 for this document at the beginning of your comment. Note that all comments received will be posted without change to including any personal information provided. If sent by mail, comments must be submitted in duplicate. Persons wishing to receive confirmation of receipt of their comments must include a self-addressed stamped postcard.


Privacy Act: Anyone is able to search the electronic form of any written communications and comments received into any of our dockets by the name of the individual submitting the document (or signing the document, if submitted on behalf of an association, business, labor

union, etc.). You may review DOT’s complete Privacy Act Statement at


Docket: You may view the public docket through the Internet at or in person at the Docket Operations office at the above address (See ADDRESSES).

FOR FURTHER INFORMATION CONTACT: Questions regarding this document may be directed to Earl Lawrence, Director, FAA UAS Integration Office, 800 Independence Ave. SW, Washington DC, 20591; phone: (202) 267-6556; email:






In the FAA Modernization and Reform Act of 2012 (Pub. L. 112-95) (the Act), Congress mandated that the DOT, in consultation with other government partners and industry stakeholders, develop a comprehensive plan to safely accelerate the integration of civil UAS in the NAS.


Since 2012, the Department has made progress in enabling UAS operations, through issuing exemptions under section 333 of the Act to permit commercial operations; creating a UAS test site program to encourage further research and testing of UAS operations in real-world environments; issuing a notice of proposed rulemaking, Operation and Certification of Small Unmanned Aircraft Systems (RIN 2120-AJ60) (small UAS NPRM), that sets forth a framework for integrating small UAS operations in the NAS; and developing a Pathfinder program to encourage research and innovation that will enable advanced UAS operations.


A foundational statutory and regulatory requirement that the Department has employed for each of these integration programs is aircraft registration and marking. In order to operate in the NAS, the Department must ensure that operators are not only aware of the system in which they are operating, but that we also have a means to identify and track the UAS to its operator. One means to accomplish this is through aircraft registration and marking. To date, UAS operators that the Department has authorized have been required to register their UAS through the FAA’s existing paper-based registration process under 14 CFR part 47. As an exercise of discretion, historically we have not required model aircraft to be registered under this system.


UAS hold enormous promise for our economy and for the aviation industry. But for the industry to develop to its full potential, we have to ensure that it develops safely. Over the past several months, we have received increasing reports of unauthorized and unsafe use of small UAS. Pilot reports of UAS sightings in 2015 are double the rate of 2014. Pilots have reported seeing drones at altitudes up to 10,000 feet, or as close as half-a-mile from the approach end of a runway. In recent weeks, the presence of multiple UAS in the vicinity of wild fires in the western part of the country prompted firefighters to ground their aircraft on several occasions.


These UAS operations are unsafe and illegal. However, only a small percentage of these incidents have resulted in enforcement actions against individuals for unsafe or unauthorized UAS operation because identifying an individual or entity responsible for the dangerous operation of UAS is very difficult. This situation is troubling to the unmanned aircraft industry, to responsible model aircraft users, and to users of the NAS, all of whom always put safety first.


The risk of unsafe operations will only increase as more UAS enter the NAS. Some retailers

have projected huge holiday sales. We are committed to ensuring that the U.S. continues to lead the world in the development and implementation of aviation technology, and in doing so, that we create a space for the creativity, innovation and exploration that will drive this industry forward in the years and decades ahead. At the same time, we must create a culture of accountability and responsibility among all UAS operators. To maintain safety in the NAS, the Department has reconsidered its past practice of exercising discretion with respect to requiring UAS to be registered, consistent with statutory requirements of 49 U.S.C. 44101-44103, and has determined that registration of all UAS is necessary to enforce personal accountability while operating an aircraft in our skies.


Federal law requires that a person may only operate an aircraft when it is registered with the FAA. 49 U.S.C. 44101(a).1 “Aircraft” is defined as “any contrivance invented, used, or designed to navigate, or fly in, the air.”2 49 U.S.C. 40102(a)(6). In 2012, Congress confirmed that UAS, including those used for recreation or hobby purposes, are aircraft consistent with the statutory definition set forth in 49 U.S.C. 40102(a)(6). See Pub. L. 112-95, sec. 331(8), 336 (defining an unmanned aircraft as “an aircraft that is that is operated without the possibility of direct human intervention from within or on the aircraft,” and model aircraft as “an unmanned aircraft that is capable of sustained flight in the atmosphere, flown within visual line of sight of the person operating the aircraft, and flown for hobby or recreational purposes”); see also Administrator v. Pirker, NTSB Order No. EA-5730, at 12 (Nov. 17, 2014) (affirming that the statutory definition of aircraft is clear and unambiguous and “includes any air aircraft, manned or unmanned, large or small.”). Because UAS, including model aircraft, are aircraft, they are subject to FAA regulation, including the statutory requirements regarding registration set forth in 49 U.S.C. 44101(a), and further prescribed in regulation at 14 CFR part 47.

Historically, the FAA, through the exercise of its discretion, has not enforced the statutory requirements for aircraft registration in 49 U.S.C. 44101 for model aircraft. As evidenced by the recent reports of unsafe UAS operations, the lack of awareness of operators regarding what must be done to operate UAS safely in the NAS, and the lack of identification of UAS and their operators pose significant challenges in ensuring accountability for responsible use. Without increased awareness and knowledge of the statutory and regulatory requirements for safe operation, the risk of unsafe UAS operations will only rise. Aircraft identification and marking will assist the Department in identifying owners of UAS that are operated in an unsafe manner, so we may continue to educate these users, and when appropriate, take enforcement action.


Requiring registration of all UAS, including those operated for hobby or recreation, embraces and applies the Academy of Model Aeronautics’ (AMA)’s policy of identification to UAS operators who may not be modelers registered with the AMA. Additionally, it would ensure consistency with other UAS operations currently required to be registered, such as public aircraft, those operated under exemptions, and certificated aircraft, as well as those operations contemplated in the small UAS NPRM.


Based on the Department’s experience in registering small UAS authorized by exemptions granted under the authority of section 333 of the FAA Modernization and Reform Act of 2012, and the comments received on the proposed registration requirements in the small UAS NPRM, it is apparent that the current paper-based system for aircraft registration is too burdensome for small UAS, to include model aircraft. To facilitate compliance with the statutory obligation for registration, the DOT is currently evaluating options for a streamlined, electronic-based registration system for small UAS.


The Department has convened a UAS registration task force, under the FAA’s authority in 49 U.S.C. 106(p)(5) to designate aviation rulemaking committees. This task force will provide recommendations on the type of registration platform needed to accommodate small UAS, as well as the information that will need to be provided to register these aircraft. The UAS registration task force also will explore and provide recommendations on whether it is appropriate for the FAA to continue to exercise discretion with respect to requiring registration of certain UAS based on their weight and performance capabilities. The task force will meet and provide its recommendations to the Department by November 20, 2015. To facilitate the task force’s work, we are requesting information and data from the public in the following areas:


1. What methods are available for identifying individual products? Does every UAS sold have an individual serial number? Is there another method for identifying individual products sold without serial numbers or those built from kits?


2. At what point should registration occur (e.g. point-of-sale or prior-to-operation)? How should transfers of ownership be addressed in registration?


3. If registration occurs at point-of-sale, who should be responsible for submission of the data? What burdens would be placed on vendors of UAS if DOT required registration to occur at point-of-sale? What are the advantages of a point-of-sale approach relative to a prior-to-operation approach?

4. 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.


5. How should a registration process be designed to minimize burdens and best protect innovation and encourage growth in the UAS industry?


6. Should the registration be electronic or web-based? Are there existing tools that could support an electronic registration process?


7. What type of information should be collected during the registration process to positively identify the aircraft owner and aircraft?


8. How should the registration data be stored? Who should have access to the registration data? How should the data be used?


9. Should a registration fee be collected and if so, how will the registration fee be collected if registration occurs at point-of-sale? Are there payment services that can be leveraged to assist (e.g. PayPal)?


10. Are there additional means beyond aircraft registration to encourage accountability and responsible use of UAS?


Comments received by [INSERT DATE 15 DAYS AFTER DATE OF PUBLICATION IN THE FEDERAL REGISTER] would be most helpful in assisting the UAS registration task force in developing its recommendations. The comment period will remain open after this period and the Department will consider the comments received, in addition to the UAS registration task force’s recommendations, in developing a stream-lined registration process for small UAS, including model aircraft.


Issued in Washington, DC on October 19, 2015.

Anthony R. Foxx,

Secretary of Transportation.

Michael P. Huerta,

Administrator of the Federal Aviation Administration.

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  • We can all imagine the day when we have flying cars as well...  doesn't mean we regulate cars now to have transponders and pilot training in anticipation of flying cars in the future.  Although, I might be an advocate for that if I was designing the technology that would be used to comply with the flying car regulations. So I guess that makes sense for some in this conversation.

  • It's so stupid that seems as clearly "political" decision

  • Moderator

    Well said Philip

  • @Gary - I agree. In a few years, most will have forgotten the early, wild west days of the drone industry and will accept the new conditions under which society says they must operate. 

    Here's another thought about the future...

    Let's imagine that the technologies needed for much safer drone operations were available and affordable today. By that I mean, drones that communicate their positions to control towers, are aware of other nearby aircraft and of no-fly zones, and have the ability to avoid airborne collisions via sense and avoid technologies. 

    Now..., even IF those technologies were available, some form of standardization would be required in order to be integrated into the existing aviation systems. We couldn't have independent solutions from (say) DJI, 3DR, and many other manufacturers, and expect them all to be smoothly integrated into existing aviation systems, right? This is where additional drone regulations will be needed in the future -- in order to enforce new standards. 

    I only mention this because we can all likely envision the day when these technologies will become available. And we can also likely agree that regulation will be needed to enforce standards to enable integration. In other words, we should all expect more regulation. 

    Drones are still relatively new. Governments, users, and technologies still have some catching up to do, as the industry matures and goes through this inevitable transition. 

    At this point, it's up to everyone to try and work together to move this industry forward -- in a safe and sensible way. We're getting there. It's going to take some time, some evolution, and some pain. Avoiding a major calamity is an essential and worthwhile goal. A disaster caused by a drone will be absolutely terrible for everyone. 

    Don't panic. Nobody is out to get you. And everyone involved wants the industry, the hobby and the innovation to flourish and avoid calamity. Even the government. 

  • Gary, just as the DOT is incorporating 'driver-less cars' into the mainstream by first certifying self-parking features, and allowing for 'city cars' to off-road vehicles, there will be a tiered structure of regulatory & legal oversight.

    All:  As hobbyists and commercial UAV designers, engineers, and builders, we must participate in contributing to the discussion.  The world has changed since 9/11 and the spread of inexpensive flight control systems.  Do we let a Chinese company (DJI) control the < 2 kg AUW class?, or can y'all craft some data-derived definitions?

    FAA has already defined 'aircraft', 'rotorcraft', 'helicopter', 'glider', 'kite', . . . they don't have definitions for the multitude of configurations of remotely piloted heavy-than-air sustained flight aircraft.

       Help the working group linked above to do the most good for the most people. 

  • Moderator

    @Vinnie re locked cabinet, in South Africa the answer is yes and part of the safety and security requirements. You also have to go on a course to learn about that. I really can't get it out of my head that folks over there think its going to get easier to operate. This is how the security stuff looks

    Security Awareness Training is required for all staff involved with handling, deployment and storage of RPAS to complete Security Awareness training (part 101).


    Aviation Security Awareness Training Program provides fundamental information with regards  to the Civil Aviation Act and the Part 109 Security Regulations to employees performing duties in the airport environment . The training provides a basic level of proficiency in the Aviation Security Procedures.

    This Training should be completed by all airline personnel, airport fire service staff, aircraft maintenance staff, air traffic control unit staff, cabin crew, retail outlet staff, construction workers, and any person who works at an airport or has access to the airside or security restricted areas on a regular basis or short-term period.

    It is specifically required in part 101 for such security awareness training to be completed.

    Perhaps as RPA go to work around the world things are tightening up as they did for cars at the dawn of motoring. We may look back in five years time and feel lucky to be part of the good old days and hanker back to flying before the man became involved.

    Youngsters will know not of what we speak.

  • I am a 'hobby operator'.  I hold no self loathing.

    I only address < 50% of the comments on this thread, on this site.

    "we should all just wait for the benevolent FAA and its coalition of commercial interests to divide up the carcass."


    Gary gave you the website already.  Please take the time to participate.

    PS:  Full disclosure;  well, F7 and spell check is my friend!  Grammar, yah, not so much. . . 

  • BFF = Best Friends Forever (welcome to the Internet)

    You represent the FAA position and attack anyone who doesn't think or agree with the way you think which is seems to be (correct me if I'm wrong) that we should all just wait for the benevolent FAA and its coalition of commercial interests to divide up the carcass.

    In that press conference and the release of data from the FAA (as has been posted here) there is clear bias against hobby operators. Even in your statements, claiming we all are irresponsible, it is evident how you feel. You don't know me, or what I do,or how I fly. You just assume, which is frankly pretty off putting. Lots of good people work for the FAA, nobody is claiming that isn't true. But you know as well as I do that their priority is not the hobbyist. It is up to us as a community and "hobby drone" industry to be our own advocates and force our way into the discussion.

    If you can take an step back, I challenge you to tell me how a "registration first" strategy increases manageability or airspace safety. There is a lot of common ground we can agree on I think, but assuming that anyone who is against a registration first strategy is irresponsible guarantees that we will never find it.

    So if your response is going to be more spelling error corrections, you might as well save it. We are all impressed.
  • "Anyone who didn't agree with you should be called names."

    BFF = noun (name calling?)

    irresponsible = adjective

    I was exposing your lack of reasoned analytical process on my last post, not your spelling ability.

    I definitely have dogs in this fight, as does everybody on this site and everybody in/under our NAS.  Hence the multi-faceted working group that is working on this issue.  There are a list of 'alphabet soup' groups that have are responsible for this policy.

    My dogs:  I own 6 multicopters, from 105 mm up to a carbon 550 mm 6s 11" props that hauls my GoPro.  3 are PixHawks or derivatives.

    I don't fly my fixed wing RC as much anymore, but i have a shelf full, most of it is in the kids' room.

    As with Philip (I don't know him, no), yes, I have been in aerospace since I attended A&P school at 17. I earned a couple of degrees in engineering wrenching out of my toolbox and I have been working as an mechanical systems engineer in aerospace since.

    No, I do not work in any professional capacity with UAS nor UAVs.  As you have determined, that is quite easily verifiable through public sources.  If you had the capacity for reasoned analysis.


  • Internet spelling police for the win! Nothing says "I'm an adult with something to contribute" like critiquing spelling on an Internet forum.

    Did you run out of ideas? Or is it that like your friend there you stand to gain from increased regulation?

    How's life at the FAA by the way? You know generally in a policy debate people with integrity identify if they have a dog in the fight.
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