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