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APLU & AAU Submit Comments to FAA & NTIA on Use of Small Unmanned Aircraft Systems

April 29, 2015

The Association of American Universities (AAU) and APLU last week provided comments to two federal agencies regarding the use of small unmanned aircraft systems (sUAS).

The two associations submitted comments to the Federal Aviation Administration (FAA) on April 24 in response to a notice of proposed rulemaking on integration of sUAS into the National Airspace System (NAS) and a separate set of comments to the Department of Commerce National Telecommunications and Information Administration (NTIA) on April 20 in response to a request for comments on privacy, transparency, and accountability issues related to the use of sUAS.

APLU and AAU have been urging the FAA to recognize that the use of sUAS for research and educational purposes serves very different ends from the use of sUAS for commercial purposes. Universities currently use sUAS to conduct important and wide-ranging research—much of which is federally sponsored—on topics ranging from animal health, plant toxicology, entomology and sustainable nutrient management to architecture, aviation and aerospace engineering. They also use sUAS for teaching purposes and to inspect infrastructure. Unfortunately, under current FAA rules governing the use of sUAS by commercial entities, universities have been experiencing difficulty obtaining approval from the FAA to perform such research and teaching activities.

“Our institutions have a strong interest in taking advantage of the significant extant benefits of UAS, as well as in researching the potential of UAS to increase America's competitiveness and enhance the social good,” the associations wrote to the FAA. “Across the country, our universities are seeking to utilize UAS to improve research and development efforts, inspect infrastructure, and teach students. In addition to utilizing UAS to conduct research, our universities’ faculty experts are studying UAS-related issues particularly relevant to the emerging public debate on the use of UAS, ranging from aviation safety to privacy. For these reasons, we have urged the expeditious fulfillment by the FAA of its Congressional mandate, established in the FAA Modernization and Reform Act of 2012, to develop a plan to safely integrate UAS into the NAS.”

AAU and APLU urged the FAA to allow university researchers – who have a long record of safely using sUAS – to fly sUAS beyond line of sight and encouraged the agency to create a new micro-UAS classification. The two associations also expressed concern that the current FAA proposal places too many restrictions and administrative burdens on sUAS operators. They further recommended that the agency create a student operator certificate to accommodate faculty who want students to fly sUAS as part of their classes.

In APLU and AAU’s submission to the NTIA, the associations asserted that, because universities use sUAS for research rather than commerce, any regulations should distinguish universities from other entities. The letter added that as the NTIA begins the process of engaging with multiple stakeholders to develop best practices, the NTIA Working Groups should include academic researchers and faculty, particularly those who offer subject matter expertise in the areas of the First Amendment, privacy, and aviation.     

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