26 August 2014

The Association for Unmanned Vehicles Systems International (AUVSI)
today submitted official comments to the U.S. Department of
Transportation in support of Amazon’s bid to test its planned UAS
delivery service Prime Air.

“Amazon wants to test their systems outdoors in the U.S., opposed to
overseas,” AUVSI President & CEO Michael Toscano wrote to the
Department of Transportation. “Amazon’s exemption adequately addressed
the safety requirements in a number of federal aviation regulations, and
there is a compelling need for the FAA to allow Amazon to test their
systems to ensure the next evolution in package delivery happens in the
U.S. first.”

In an effort to accelerate the commercial use of UAS, the FAA
announced in May that it would consider granting exemptions for certain
low-risk commercial UAS applications under Section 333 of the FAA
Modernization and Reform Act of 2012, exemptions that would allow some
industries to fly before the finalization of the small UAS rule. The FAA
received an exemption from Amazon in July to begin testing of unmanned
aircraft for package delivery in the U.S.

“Amazon says 86 percent of the products they sell weigh less than
five pounds, which will allow them to be used on their small unmanned
delivery aircraft,” Toscano wrote. “We hope the FAA uses any and all
means to allow Amazon to test their systems domestically in a safe and
responsible manner.”

Accelerating commercial UAS use will not only help businesses like
Amazon harness the tremendous potential of UAS, it will also help unlock
the economic impact and job creation potential of the technology. In a
report issued last year, AUVSI found that the UAS industry is poised to
create over 100,000 new jobs and more than $80 billion in economic
impact within the first 10 years following the integration of UAS into
the national airspace system.

In addition to supporting exemptions for certain low-risk commercial
applications, AUVSI has been pressing the FAA to accelerate the pace of
its small UAS rulemaking, which has already been delayed several years.

“The commercial UAS industry will not be allowed to fully take off
until regulations, not just exemptions, are finalized,” Toscano added.
“Troublingly, FAA officials have publicly said the regulations will take
at least 16 months after the public comment period ends before it is
finalized. That is simply unacceptable.”

On April 8, 2014, AUVSI and 32 other association representing the
manned aviation community, air traffic controller, and future users of
UAS, including agriculture groups, realtors, media organizations, and
public safety organizations, sent a letter to the FAA strongly
encouraging the agency to not only grant exemptions, but also expedite
the public notice and comment for small UAS rulemaking.

The FAA announced that it also will consider regulatory exceptions
for other commercial applications including power line inspections and
flare stack inspections. AUVSI recently filed comments in support of an
exemption request from Yamaha to use UAS for precision agriculture.
AUVSI is also supporting seven production companies seeking exemptions
to use UAS for filmmaking and movie production.

AUVSI’s full comments in support of Amazon’s exemption request may be found here.

Amazon’s exemption request to the FAA may be found here.