RCAPA comments on registration

After a decade of working with the FAA and other stakeholders on safe integrating UAS into NAS, we are disappointed with the lack of tangible progress. This latest effort only serves to erode further the community’s confidence in an administrative process that has been ongoing now for 23 plus years (See attached graphic). 4910- 9X sounds distinctly vague and open-ended. It relies heavily on UAS industry stakeholder’s to design, build, run and maintain another system or process that is supposed to assuage the manned aviation stakeholder’s misgivings as well as, satisfying the regulatory charge of maintaining the safety of the NAS. However, this is supposed to be accomplished with little or no direction from the regulating authority. This formula has been tried numerous times in the past with lackluster results.

Do we know what the risk is? Has the data from each “near miss” incident package per FAA order 8020.11. been compiled, has it been made public? Furthermore, was any of the following information gathered on all of these incidents?

ATC audio recordings and or transcripts Radar data regarding the event Statements, emails, and notes by

ATC and Flight Standards Personnel Interview summaries with the flight crew Copies of any written or audio communications with the flight crew of regional jet or airline personnel.

Flight Standards documentation, synopsis, or reports of any attempts to identify unmanned operators. Were there any communications with unmanned operators?

Without public disclosure of this information, how are we to discern if these instances constitute a Critical, Potential or No Hazard situation? Furthermore, how do we discern the effectiveness of ‘The Know Before You Fly’ campaign? Did it miss the mark, or is it public drone awareness that is responsible for the doubling in reported incidents/sightings?

Most fair-minded people understand the need for accountability, but in this instance the list of questions in 4910-9X is so vague and vacuous it is improbable that they could be answered and address accurately on such an aggressive timeline. The timeline also raises procedural questions, for example, will there be time to conduct a credible economic impact study? Furthermore, if these are “aircraft” as the FAA, NTSB and Congress contend, doesn’t a registration scheme already exist?