Measure Sends Letter to Senate on FAA Reauthorization
Measure today sent the following letter to the Senate Commerce Committee with input on the FAA Reauthorization Act of 2016:
Dear Chairman Thune and Ranking Member Nelson,
On behalf of Measure UAS, Inc., I would like to offer our comments regarding the Unmanned Aircraft Systems (UAS) subtitle in the manager’s amendment to the Federal Aviation Administration Reauthorization Act (FAARA) of 2016. Measure is one of the nation’s leading Drone as a Service® companies, providing turnkey flight operations to a wide variety of enterprise customers. We served on the UAS Registration Task Force in November of 2015, and have received a number of groundbreaking approvals from the FAA for commercial UAS operations.
Specifically, we urge Members of the Committee to amend Sections 2126, 2127, 2129, 2130, and 2139.
Sec. 2126(d): This section places the onus of demonstrating the necessity of pilot certifications for commercial UAS operators (including airman certificates, a medical certificate, or a minimum number of flight hours) on the Secretary of Transportation. In our considerable experience, it is impossible to ensure that commercial operations will be performed safely & responsibly without requiring operators to have demonstrated competency in drone operation. Thus, Measure contends that obtaining these certifications (as is currently required under the 2012 FAA Modernization and Reform Act) should remain part of the requirements for commercial drone operators, and should remain so until such time as interested stakeholders can demonstrate that relaxing these requirements will not threaten the integrity of the NAS.
Sec. 2127(a)(2): Contends that advancements in miniaturization of safety technologies,including for aircraft weighing under 4.4lbs, have increased economic opportunities for using drones while reducing kinetic energy and risk compared to larger drones. While weight is a large factor in risk, the standard of 4.4lbs is an arbitrary weight based on convenience, not evidence. Currently the only weight threshold supported by actual data is 250 grams, the standard established by the UAS Registration Task force as the threshold weight for drone registration. This is the only standard that has been supported by experimental data and physics-based calculations, and until compelling, factual, and data-based arguments exist for other weight thresholds, Measure opposes drafting regulations for drones based upon weight.
Sec. 2129(a)(1): Measure would like to clarify what is meant by the phrase “model aircraft.” We believe any UAS flown strictly for hobby and recreational purposes qualifies as a model aircraft. It should be emphasized that model aircraft are aircraft flown for non-commercial purposes, and the language should be tightened to prevent commercial users from abusing the “model aircraft” classification as a way to avoid certification.
Sec. 2130(a)(1): Measure believes that an electronically administered aeronautical knowledge and safety test is insufficient to demonstrate pilot competency. State governments sensibly do not allow new drivers to take the road without demonstrating competency in actual operations. By the same token, new pilots should also accrue a minimum number of flight hours and demonstrate competency in operating unmanned aircraft.
Sec. 2139(a): Gives exemption and certificate authorization priority to public UAS engaged in emergency response activities. We believe that certified private UAS engaged in emergency response activities should also receive top priority in these situations, as public agencies can and do contract with privately-held drone operators and service providers. Allowing only public operators to obtain these exemptions and certificates would severely inhibit economic growth in the rapid response sectors of the commercial drone industry.
Measure has worked hard since its inception to ensure that commercial UAS operations are done in a manner that is always safe, legal, and insured. We are concerned that moving quickly to open the industry to inexperienced and uncertified operators may prove hazardous to people and property, and detrimental to the integrity of the NAS. We would like to thank you for your consideration of our perspective. We are confident that the FAARA will be the next step to safe and responsible UAS integration in the United States, and we look forward to working with you to help build that reality.
Brandon Torres Declet