On behalf of the Competitive Enterprise Institute (“CEI”), I respectfully submit these comments in response to the Federal Aviation Administration’s (“FAA”) notice of proposed rulemaking in the matter of Operation and Certification of Small Unmanned Aircraft Systems (“NPRM”). CEI is a nonprofit, nonpartisan public interest organization that focuses on regulatory policy from a pro-market perspective.
Our comments develop the following points:
- It is unclear why FAA is citing its FAA Modernization and Reform Act of 2012 (“FMRA”) Section 333 authority as the basis for this rulemaking;
- FAA does not adequately consider beyond-visual-line-of-sight (“BVLOS”) and sense-and-avoid automated operations; and
- FAA should adopt a risk-based, technology-neutral approach to safety regulation to best promote small unmanned aircraft system (“sUAS”) innovation and national airspace system (“NAS”) integration.