Clarification/Request for Information: Most commenters favored a requirement to register the owner36 of the UAS instead of a requirement to register the UAS itself. Under this registration scheme, each owner would receive a single, unique registration number that would cover every UAS that person owns. Many commenters pointed out that this is how the AMA handles registration. Commenters asserted that a requirement to register each individual UAS is impractical and overly burdensome, particularly in light of the fact that most recreational users own multiple (often many) UAS. Commenters also pointed out that many UAS owners, especially those who build their own aircraft, regularly replace parts, as well as trade and sell their aircraft with other UAS owners. Those commenters asserted that a requirement to register the owner instead of the aircraft would alleviate the burdens associated with re-registering an
36 Some commenters said the registration requirement should apply to the “owner” while other commenters said it should apply to the “pilot” or “operator.” Because these commenters were largely members of the model aircraft community, and therefore both the owners and operators of their aircraft, this seems to be a distinction without a difference.
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aircraft each time such an event occurs. Commenters also claimed that registration of the owner of a UAS is all that is necessary to satisfy the DOT and FAA goals of traceability and
accountability.
EPIC stated that a UAS registration requirement is an “absolutely essential” requirement to establish accountability for use of “autonomous surveillance devices” in the United States.
EPIC further stated, however, that to ensure that the registry fosters accountability and responsibility among UAS operators, the registry must include provisions addressing privacy issues “to ensure a comprehensive baseline set of protections that facilitate the safe integration of drones.”
Union Pacific Railroad similarly stated support for “reasonable measures by the FAA to encourage accountability and responsibility among all UAS operators, including recreational users of sUAS.”
A number of commenters recommended that the FAA implement a licensing system like the FCC uses to register amateur radio operators. Commenters drew comparisons between amateur radio operators, most of whom own many different pieces of radio equipment, and hobby aircraft modelers, many of whom own many different model aircraft. Commenters explained that under the FCC licensing system the operator, not the equipment, is licensed for non-commercial operations after passing a safety test. Commenters asserted that registration alone does not guarantee a model aircraft operator understands the rules of safety for operating in the NAS, so a licensing system with a testing component may be the best way to ensure safe operations in the NAS. One commenter acknowledged that licensing model aircraft operators would require a change in the law, but stated his belief that there is wide support for this in both Congress and the modeling community.
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One commenter recommended that individuals be required to pass a background check before getting a license for UAS operations. Other commenters said the registration system should be more like the systems to obtain a license to hunt or to operate a boat, and less like firearm registration.
In contrast to those commenters who advocated for an owner-based registration system, Delair-Tech stated that each entry in the registration database “should be attached to exactly one UAV.” Aviation Management said the FAA should consider independent registration for a UAS operator in addition to registration of the unmanned aircraft and all of its support systems, including the ground control station.
The National Air Transportation Association expressed its support of the registration requirement, but acknowledged the ability to track an unsafe or noncompliant UAS back to the operator is limited to incidents in which the UAS is disabled, but not too damaged to obtain registration information. Several commenters, including the Competitive Enterprise Institute, questioned the usefulness of a registration number for identification purposes asserting a registration number would be impossible to read during flight, would only be useful after an incident has occurred and only if the UAS is recovered. Some commenters said affixing the name and contact information of the owner to or in the aircraft will serve the same purpose with much less expense. Other commenters said because it will be very easy for an individual to ignore the registration requirement, the small benefit of registration will be greatly outweighed by the burden placed on the model aircraft industry and the cost of implementing and
maintaining the system.
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NAAA and CoAA said registration will help track down who is responsible after an accident, but noted that FAA will not be able to enforce illegal and unsafe operations without requiring UAS to be equipped with an ADS-B like system through which to trace them.
Task Force: The Task Force recommended an owner-based registration system to achieve the goals of accountability and compliance. Under the Task Force scheme, the FAA would issue a single registration number to each registrant that would be used to identify all unmanned aircraft owned and operated by that registrant.
IFR Requirement: The FAA sought to integrate the Task Force recommendation and comments regarding an owner registration approach while also considering the best public policy with respect to small unmanned aircraft registration. As addressed in the preamble discussion
“Registration Process,” the registration system will differentiate between small unmanned aircraft intended to be used exclusively as model aircraft and small unmanned aircraft intended to be used as other than model aircraft in that different information will be collected for each population.
Small unmanned aircraft intended to be used exclusively as model aircraft will be registered with a single Certificate of Aircraft Registration issued to the aircraft owner. As with all other small unmanned aircraft, registration must be completed prior to operation of a small unmanned aircraft exclusively as a model aircraft. Owners of small unmanned aircraft intended to be used as model aircraft must complete the registration application process by submitting basic contact information, such as name, address, and email address. The owner will receive a Certificate of Aircraft Registration with a single registration number that constitutes the
registration for each of this particular owner’s aircraft. There would be no limit to the number of small unmanned aircraft registered under the owner’s registration. This approach serves the
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purpose of the statutory aircraft registration requirement because each small unmanned aircraft must bear the owner’s registration number, thus allowing for the aircraft and its owner to be identified.
The agency notes that, once an aircraft is no longer exclusively used as a model aircraft, then the owner must complete a new registration application in accordance with the requirements for aircraft used as other than model aircraft.
The owner of a small unmanned aircraft intended to be used as other than a model aircraft must complete the registration application by providing aircraft-specific information in addition to basic contact information. The owner will receive a Certificate of Aircraft Registration with a registration number for each individual aircraft registered.
The agency determined that this registration approach is necessary for entities intending to use small unmanned aircraft as other than model aircraft because, based on the agency’s experience with exemptions issued under section 333 of Public Law 112-95, these entities are expected to conduct a higher volume of operations, utilize multiple aircraft and at times conduct multiple simultaneous operations across the country, which introduces more risk into the NAS.
In contrast, a small unmanned aircraft owner who operates small unmanned aircraft exclusively as a model aircraft is expected to use only one of his or her aircraft at a time and to do so on a less frequent basis than a person conducting operations with small unmanned aircraft intended to be used as other than as a model aircraft.
Components of the owner registration approach will still be available for small unmanned aircraft used as other than model aircraft in that the agency will utilize an owner profile for the registration website under which multiple aircraft can be registered. Owners will have a single
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profile that contains all of their aircraft, and although they may register multiple aircraft under that profile, each aircraft must have a unique number that exists under that profile. The FAA notes that persons using small unmanned aircraft other than as model aircraft will not be able to use the part 48 registration system until March 31, 2016.
The FAA notes that commenters comparing the registration requirement to licensure misconstrue the purpose of registration. While registration allows the agency an opportunity to educate sUAS operators, the primary purpose of registration is to identify the aircraft owner.
F. Registration Process