Associated Equipment Distributors

Associated Equipment Distributors (AED) is an international trade association representing companies involved in the distribution, rental, and support of equipment used in construction, mining, forestry, power generation, agriculture and industrial applications. Our 500 distributor member companies account for more than $15 billion of annual sales of construction equipment and related supplies and services in the U.S. and Canada. Our average distributor member achieves more than $40 million per year in revenues and employs more than 80 people. Nearly all of the industries that AED members serve will be impacted by the integration of small unmanned aircraft systems (sUAS) into the national airspace system (NAS). AED offers its comments of general support for the NPRM, and commends the Federal Aviation Administration (FAA) on a relatively simple proposed solution to sUAS integration. The agencys reasonable approach and its understanding of the economic and social benefits of commercial operations, evident in this NPRM, pave the way for long-term growth, and further opportunity to safely expand the uses of sUAS. While AED is generally supportive of the NPRM, the association sees room for improvement in two specific ways: First, the final rule should provide more clarity as to what constitutes directly participating in the operation of the sUAS. While the preamble to the NPRM indicates that direct participation is limited to the operator and the visual observer, the proposed regulatory language does not afford clarity on this point. AED encourages the agency to provide a definition of direct participation in the regulation, and to consider allowing consenting individuals, such as employees and contractors at a construction site, to be included in that definition. Second, AED asks the agency to reconsider the strict visual line of sight (VLOS) requirement. The association appreciates the risk based approach to the proposed rule, and understands the purpose behind limiting commercial sUAS operation to VLOS. However, sUAS technology is advancing at a rate that poses a challenge to maintaining relevancy in the regulations. Strictly limiting sUAS operations to VLOS impedes the potential use of the technology to support socially-beneficial operations such as pipeline inspections, forest fire monitoring, search and rescue operations, etc. The agency should draft more flexibility into the rule to allow for beyond line of sight operations (BLOS) as technology advances, and those operations are able to satisfy the agencys legitimate concern for safety. Allowing more flexibility in the rule now for future technological development will save both industry and the agency considerable resources, given the complex and lengthy rulemaking process.