Steve Tupper

The University of Missouri has participated in and endorses the comments crafted by APLU and AAU. In summary: The NPRM should address and permit BVLOS UAS Operations under certain conditions.There are many areas of the country and a wide range of commercial activities that could greatly benefit from even limited BVLOS flights, including: agriculture, surveying, fish and wildlife management, and resource surveying. Hence not all locations should be considered the same for purposes of permitting BVLOS operations. The current NPRM provides a great deal of flexibility to operators of microUAS. However, the restrictions in the proposed rules apply equally whether one is flying a UAS that weighs 2 pounds and one that weighs 55 pounds. A class of micro UAS based on weight could expand opportunities without greatly increasing risks and the requirements for a Micro UAS Operators Certificate could be simplified or eliminated entirely. The UAS Operator and the Visual Observer should not be required to be close enough to communicate verbally. Reliable cell phones and radios are ubiquitous and are used in a wide range of commercial and public safety situations. and use of these common means allows the advantage for the Observer to have a different perspective than that of the Operator. Requiring close proximity limits the range of available perspective. Quantifying maximum distances for VLOS operations may ultimately be less safe. Establishing a maximum range for VLOS operations may give persons a false sense of security that they are still operating legally because they are within the numerical limits, in circumstances where the actual conditions do not allow the Operator to distinguish the direction of travel. Under these circumstances, trying to quantify VLOS distances actually makes the operation less safe.