8 April 2014
Michael Huerta
Administrator
Federal Aviation Administration
800 Independence Avenue, SW
Washington, DC 20591
Dear Administrator Huerta:
Since the Federal Aviation
Administration (FAA) was tasked with overseeing the safe integration of
Unmanned Aircraft Systems (UAS) into the National Airspace System (NAS), it has
implemented a number of key steps to further this important process. However,
the publication of the Notice of Proposed Rulemaking (NPRM) for small UAS
remains a missing and critical piece of the puzzle. Meanwhile, the recent FAA
v. Pirker decision underscored the immediate need for a safety structure
and regulatory framework for small UAS.
The potential benefits for UAS
cannot be underestimated. Whether it is helping farmers improve crop yields,
assisting first responders with search and rescue missions, or advancing
scientific research, UAS are capable of saving time, saving money and, most
importantly, saving lives. In fact, it is estimated that this industry will
create more than 100,000 jobs and $82 billion in economic impact during the
first decade following integration. But with each passing day that commercial
integration is delayed, the United States continues to fall behind.
The safety of our skies and
fellow citizens is our top priority. That is why we support regulations to
govern the technology. We recommend the FAA use all available means, including
Section 333 of the FAA Modernization and Reform Act of 2012, to allow for some
limited UAS operations, subject to the Secretary of Transportation’s safety
determination, before the small UAS rule is finalized.
The current regulatory void has
left American entrepreneurs and others either sitting on the sidelines or
operating in the absence of appropriate safety guidelines. The recreational
community has proven that community-based safety programming is effective in
managing this level of activity, and we highly encourage the FAA to allow
similar programming to be used to allow the small UAS industry to establish
appropriate standards for safe operation. Doing so will allow a portion of the
promising commercial sector to begin operating safely and responsibly in the
national airspace.
The time for resolution has
come, and we cannot afford any further delays. The technology is advancing
faster than the regulations to govern it. While the FAA has indicated its
intention to appeal the Pirker decision to the full National Transportation
Safety Board (cc’d), we strongly encourage the FAA to simultaneously expedite
its public notice and comment for small UAS rulemaking as soon as possible.
Sincerely,