sUAS Operation and Certification NPRM: The sUAS Operation and Certification NPRM requested comments on what information should be required for registration. A few commenters provided feedback as to whether small UAS owners should be required to provide additional information during the registration process so that UAS could be categorized. Amazon,

American Farm Bureau Federation and an individual stated that small UAS owners should not be required to provide any additional information beyond what is currently required of manned aircraft. The University of North Dakota’s John D. Odegard School of Aerospace Sciences recommended that FAA adopt a simplified information-gathering process to include the

following data: manufacturer identification (if applicable); known performance and limitations;

physical size, weight, and characteristics; and, if self-built, a list of major components similar to that provided by commercial manufacturers. The commenter stated that this minimal information would allow for future safety-related research by establishing base categories from which

comparisons could be made. NOAA and Schertz Aerial Services, Inc. suggested that FAA


impose similar requirements as those imposed on amateur-built aircraft. According to NOAA, UAS owners should be required, at a minimum, to describe the aircraft by class (UAS), size, color, number of motors/props/wings, serial number, make, and model. Predesa, LLC

recommended that digital photos or video recordings of the aircraft, as well as written records of manufacturers’ part numbers of supporting equipment used by the operator, can satisfy the need for additional information to accurately describe a non-standardized small UAS.

Clarification/ Request for Information: A majority of commenters stated that only basic information should be collected during the registration process because of commenters’ concerns about data security. Several commenters suggested that commercial UAS operators should provide more in-depth information than recreational operators. The vast majority of commenters, including individuals and organizational stakeholders, stated that owner/business name, address, telephone number, email address, and description of the UAS should be collected during the registration process. Some commenters further broke down the UAS’s description to include make, model, manufacturer’s serial number, weight, range, performance capability, flight controller serial number and whether the UAS was purchased or home-built. Many commenters also suggested that registrants should upload a picture of the UAS. Several commenters

suggested that date of sale/purchase, point of sale, date of operation, intended use and geographic location of primary use would also be helpful information. AMA members also stated that their AMA member numbers should be collected.

To provide further information about the aircraft owner, many commenters suggested that the operator’s date of birth, driver’s license, Social Security Number, and number of aircraft owned should be provided during the registration process. Other commenters specifically objected to providing their Social Security Numbers because of concerns about data security. A


few individuals who identified as hobbyists stated that insurance information and professional license numbers should also be collected during registration. A small number of commenters suggested registrants should provide their passport numbers, credit card numbers, nationality, and proof of citizenship.

EPIC stated that the FAA should limit the collection of registrant information to what is necessary to maintain the aircraft registry and UAS safety. In particular, EPIC stated that the FAA should not collect “highly restricted personal information,” including “an individual’s photograph or image, social security number, medical or disability information.”37

EPIC also recommended that the FAA require disclosure of each UAS’s technical and surveillance capabilities, including data collection and storage. EPIC asserted that UAS are

“surveillance platforms” that are able to carry a multitude of different data-collection technologies, including high-definition cameras, geolocation devices, cellular radios and disruption equipment, sensitive microphones, thermal imaging devices, and LIDAR. EPIC further asserted that UAS owners should be required to make clear at registration the specific capabilities of any video or audio surveillance technologies the UAS is carrying. EPIC stated that the public should not be left to wonder what surveillance devices are enabled on a UAS flying above their heads. EPIC further stated that the registration framework the FAA is considering does not go far enough, and should include a requirement that a UAS broadcast its capabilities and its registration number during operation, to allow members of the public and law

enforcement officials to easily identify the operator and responsible party.

37 To support its position, EPIC cited to and quoted from 18 U.S.C. 2725(4). Title 18 of the United States Code covers Crimes and Criminal Procedure. Section 2725 covers the definitions used in Chapter 123 – Prohibition on Release and Use of Certain Personal Information from State Motor Vehicle Records.


EPIC also suggested that the FAA consider collecting aggregate data to assist research into UAS flights and usage. EPIC clarified, however, that such research data should not include personal information.

Task Force: To ensure accountability, the Task Force recommended the FAA require all registrants to provide their name and street address, with the option to provide an email address or telephone number. While the Task Force recognized that a registrant’s email address and telephone number may be useful for the FAA to disseminate safety-related information to UAS owners, the Task Force nevertheless believed disclosure of such information should be optional.

Because the Task Force recommended the FAA institute an owner-based registration system, it believed registrants should not be required to provide any vehicle information, such as serial number or make and model of the UAS, during the registration process. Registrants

should, however, have the option to provide the aircraft’s manufacturer serial number, so that the serial number can then be used to satisfy the marking requirement. Additionally, to ensure the broadest possible participation, this registration system should make no distinction for, or impose additional requirements upon, sUAS manufactured or purchased outside the United States.

IFR Requirement: For small unmanned aircraft used exclusively as model aircraft, the FAA adopts the Task Force recommendation to provide only basic contact information (name, address, and email address) for the small unmanned aircraft owner. This basic contact

information is appropriate for registration of small unmanned aircraft intended to be used

exclusively as model aircraft because owners typically only operate one aircraft at a time, which limits the variables in terms of owner identification. Accordingly, the FAA is requiring an applicant’s name, physical address, mailing address if the applicant does not receive mail at their physical address, and email address. An accurate mailing address is necessary because the FAA


often relies on regular mail via the United States Postal Service to provide notice of

administrative actions, serve enforcement documents and provide other information. Although email will reduce the agency’s reliance on regular mail for certain purposes such as the provision of educational material, a mailing address is still required to support the agency’s compliance and enforcement actions.

At this time, the FAA will not be accepting manufacturer name, model name, and serial number from individuals registering small unmanned aircraft intended to be used exclusively as model aircraft. However, as discussed in the preamble discussion on registration marking, the Administrator will continue to evaluate whether serial number can serve the purpose of aircraft identification and in the future, may require use of serial number for aircraft marking purposes in place of an FAA-issued registration number. In that case, this information would be acquired at point of sale by a manufacturer.

The agency considered comments pertaining to the use of a membership number issued by an aeromodeling club such as the AMA as the registration number for an individual. After considering the design of the web-based information system, which will automatically assign a registration number to each individual applying for registration, the FAA determined that use of an aeromodeling club registration number would add unnecessary complexity.

For persons expecting to operate small unmanned aircraft as other than model aircraft, in addition to the same basic contact information required for model aircraft, registrants must provide aircraft-specific information. A manufacturer and model name, and serial number must be provided for each aircraft being registered. As previously noted, based on the agency’s experience with exemptions issued under section 333 of Public Law 112-95, persons seeking to operate small unmanned aircraft other than as model aircraft are expected to conduct a higher


volume of operations, utilize multiple aircraft and at times conduct multiple simultaneous

operations across the country, which thereby introduces more risk into the NAS. Moreover, these entities may operate multiple identical small unmanned aircraft at one time in different locations, with different persons operating the owner’s aircraft. Accordingly, the FAA has determined that aircraft data is necessary to identify aircraft used as other than model aircraft due to the range of variables with respect to the operations they conduct. The aircraft-specific data will also allow the agency to assess the demand of these small unmanned aircraft on the NAS and whether additional safety-related actions are necessary as the FAA works to integrate sUAS into the NAS.

With respect to the Task Force’s recommendation that the provision of an email address should be optional, the FAA generally agrees that personal information that is not necessary for law enforcement and FAA to identify an owner should not be a mandatory entry. However, in this instance, an email address is necessary to create an account for a web-based registration system that includes email delivery of the Certificate of Aircraft Registration. Additionally, email allows for targeted delivery of educational other safety-related materials directly to small unmanned aircraft owners. Thus, the FAA has determined that an email address will be required for registration under part 48. However, individual’s email addresses would not be released to the general public. For more information regarding the privacy protections afforded to this system and intended use of the data, please review the privacy impact assessment for this rulemaking, as well as the accompanying System of Records Notice (SORN), available for review in Docket No. DOT-OST-2015-0235.

Regarding other suggested information, such as date of birth, Social Security number, driver’s license number, or specific information about components or capabilities of small


unmanned aircraft being registered, the FAA believes the data identified in new part 48 is sufficient for the purposes of this registry and is the minimum that would be necessary for connecting an individual to their aircraft.

In document [Docket No.: FAA ; Amdt. Nos. 1-68, 45-29, 47-30, 48-1, ] Registration and Marking Requirements for Small Unmanned Aircraft (Page 98-104)