AUVSI Submits Official Comments in Support of Trimble Navigation's FAA UAS Petition

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By: Ben Gielow



On 21 July, AUVSI submitted official comments to the Federal Register
supporting Trimble Navigation Limited’s exemption petition to permit
commercial operation of their UX5 aircraft which weighs 5.5 pounds and
performs precision aerial surveys that consist of still photographs
taken by onboard cameras. AUVSI wrote in its comments:



“The use of small unmanned aircraft systems (UAS) for agriculture,
mining, and professional surveying will save time, money, and possibly
lives, by not jeopardizing a human in a manned aircraft. Trimble’s
petition outlines at least an equivalent level of safety over manned
aircraft, and should be approved.”



“In the opinion of AUVSI, Trimble’s exemption outlines at least an
equivalent level of safety over the use of a manned aircraft and they
have adequately addressed the safety requirements in a number of federal
aviation regulations. In fact, many of the safety requirements
outlined by Trimble mirror what the FAA currently requires public
aircraft certificates of authorization (COAs) holders to meet, such as:
flying in Class G airspace; operating in uncongested or unpopulated
areas; flying over private or controlled-access property; with the
permission of the landowner; operated within visual line of sight;
using visual flight rules; during daytime; less than 400 feet above the
ground; away from airports; after issuing a public notice to airmen; and
with a trained operator. If the FAA deems these requirements safe for
public aircraft, it should do the same for commercial aircraft.”



“The commercial UAS industry will not be allowed to fully take off until
regulations, not just exemptions, are finalized. Troublingly, FAA
officials have publically said the small UAS rule will take at least 16
months after the public comment period ends before it is finalized.
This is simply unacceptable. Congress gave the FAA broad authority to
allow for commercial UAS activities before rulemaking is complete.
Therefore, we urge the FAA to immediately create a registration,
training, and approval process for all very small UAS that only weigh a
few pounds and pose minimal risk to people in the air or on the ground.
The kinetic energy generated by an aircraft that only weighs a few
pounds poses little risk to people on the ground or in the air, and
operated safely and responsibly, could actually increase safety by not
jeopardizing a human in a conventional manned aircraft doing risky
low-flight operations.”



Although the FAA has solicited comments on two petitions, there are many
more being submitted on almost a daily basis. All must be posted on
the Federal Register for public comments. If you have not already done
so, you should weigh in by searching the Federal Register. Otherwise,
feel free to contact us at advocacy@auvsi.org for more information about
the process.