CEI Comments Responding To the FAA Request for Information on Registration of Unmanned Aircraft Systems

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On behalf of the Competitive Enterprise Institute (“CEI”), I respectfully submit these comments in response to the Federal Aviation Administration’s (“FAA”) Request for Information Regarding Electronic Registration for UAS.

CEI is a nonprofit, nonpartisan public interest organization that focuses on regulatory policy from a pro-market
perspective. Our comments develop the following points:

  1. FAA lacks jurisdiction to mandate registration for all unmanned aircraft systems (“UAS”);
  2. Mere registration, whether point-of-sale or prior-to-operation, will do little to mitigate UAS safety risks; and
  3. FAA cannot dispense with required notice and comment rulemaking requirements by way of the good cause exception to the Administrative Procedure Act (“APA”).


CEI is deeply concerned by FAA’s approach to UAS registration. We request the agency to address our comments on: FAA’s lack of jurisdiction to mandate registration for all UAS; the lack of evidence supporting registration as an effective safety risk mitigation method; and FAA’s inability to expedite the rulemaking by invoking the good cause exception to APA notice and comment requirements. We look forward to further participation.