ACUAS Submits Formal Comments to FAA’s NPRM

On March 13, 2015 the ACUAS submitted its formal comments on the FAA’s Notice of Proposed Rulemaking (NPRM) for the commercial use of small Unmanned Aircraft Systems (sUAS). The ACUAS supports the proposed regulations as a useful and intelligent first step toward commercial sUAS integration, and encourages the FAA to move quickly to implement the new rules.

Despite the efforts of under-informed media and well-funded special interests who tried to push their own agendas and pressure the FAA to design regulations favorable to one group or another, the FAA deserves full credit for taking on the difficult challenges of sUAS integration and developing an effective solution on its own. The FAA has done its job well to move the United States toward successful industry-wide integration of sUAS, and the ACUAS looks forward to seeing the benefits reach our members.



FAA-2015-0150; Operations and Certification of Small Unmanned Aircraft Systems

Public Comment on Notice of Proposed Rulemaking

by The Association of Commercial Unmanned Aircraft Systems (ACUAS)

13 March, 2015


To Administrator Huerta and the FAA’s Unmanned Systems Integration team,


As an organization representing the interests of the professional users of small Unmanned Aircraft Systems (sUAS) technology, it is a great pleasure for the Association of Commercial Unmanned Aircraft Systems (ACUAS) to express praise and overall support for the proposed regulations for the commercial use of sUAS. As your administration clearly understands, there are considerable benefits ahead for the growing number of businesses, organizations, and private citizens who wish to explore the potential useful and constructive applications of sUAS for commercial purposes, and the United States certainly deserves to see these benefits compound as the industry develops.

Although many had expected and prepared for drawn out debates over the details of regulatory requirements and the costly burdens that could have been placed upon businesses, this proposal by the FAA has put forth an incredibly simplified solution that effectively bypasses a majority of issues that a more complicated or restrictive proposal would have faced. By directly addressing the needs of the public, the FAA has provided a level playing field for all commercial operations and has rendered much of the lobbying for special interests unnecessary. We commend the FAA for its forward thinking that takes us a giant leap ahead and allows the sUAS industry to focus on smart new developments instead of politics and legal arguments.

At the same time as the ACUAS praises this useful proposal we also wish to call upon the FAA to continue looking forward as Unmanned Aircraft Systems steadily grow in importance in our economy and our lives. Specifically, as demand continues to grow for more complex operations than these initial proposed regulations allow, such as beyond-line-of-sight, night, or other operations not expressly permitted in this NPRM, the ACUAS would like to see further regulation helpful to integrating new technological solutions to practical challenges and safety requirements as they become available. Although we cannot yet know what new developments we will see in the future we can certainly expect many new advancements. We must therefore leave ourselves an opportunity to open pathways to additional types of operations as they become technologically feasible.

By focusing on the correct fundamental priorities now the FAA is setting our industry up for long-term success and growth. Therefore we see in the details of this NPRM not only an important first step, but a useful foundation – an outline of a roadmap that could lead us for many years to come. Our aviation community is not just ready to integrate another new technology, but rather we are preparing in many ways for a fundamental shift in the future of this and other industries. The future of aviation promises to look quite unlike its past. We thank you for sharing our vision of prosperous new growth, open and encouraging to all who wish to be involved in safe and beneficial commercial sUAS operations.



David Thurlow

Executive Director

Association of Commercial Unmanned Aircraft Systems (ACUAS)

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