NBAA called the FAA’s proposed rulemaking governing small unmanned aircraft systems a “good start,” but made dozens of recommendations to strengthen the rulemaking. “Given the sheer magnitude of the task before the agency in creating a regulatory framework for this new category, the NPRM provided a reasonable approach,” said Doug Carr, vice president of regulatory and international affairs for the association. NBAA endorses the requirements that small UAS be conducted in daytime visual conditions and within the line of sight at all times. It also agrees with requirements for operators to obtain a certificate and pass a knowledge exam.
NBAA noted that UASs need to be integrated in a deliberate way. “This means UASs should not share the same airspace with manned aircraft until they have equivalent certification and airworthiness standards as manned aircraft, including the ability to take timely directions from air traffic control and to be able to sense and avoid other aircraft and UAS,” the association said.
As for specific recommendations, NBAA expressed concern with the potential for UASs to use air traffic control frequencies until the operator is familiar with terminologies and procedures used by manned aircraft. Similar to the General Aviation Manufacturers Association, NBAA also sought a 400-foot. altitude limitation for separation rather than the proposed 500 feet. NBAA further called for approval requirements for UAS operators flying within three miles of airports in Class G airspace, as they already are proposed for airports in other airspace classes.