Jeremy Gillula, Ph.D.

Electronic Frontier FoundationSupportAdvocacy
Summary: The Electronic Frontier Foundation (EFF) is requesting a 60-day extension of the comment period for the proposed regulations on small unmanned aircraft systems. They argue that the current notice has not reached a broad enough audience, particularly non-professional users who will be significantly impacted by the rules.
The attached file contains the following letter: Given the wide impact the FAAs proceeding on the Operation and Certification of Small Unmanned Aircraft Systems (docket ID FA A-2015-0150) is likely to have, we believe it is vital that the general public be given the chance to weigh in with their comments. One of the great benefits of sUAS technology is its ease of use, enabling people who would not have the time or money to become professional pilots to use sUAS to make their jobs easier. For example, journalists, educators, home inspectors, farmers, and artists could all make use of sUAS in their occupations without having to become full-time sUAS operators. Unfortunately, it seems that news of the NPRM has primarily circulated among people who are already part of the Unmanned Aerial Systems and model aircraft communitiespeople whose professional lives already revolve around sUAS. EFF is concerned that the very people whom the proposed regulations are likely to impactpeople who might want to use sUAS without it becoming the center of their professionsare not aware of the current proceeding. To help deal with this concern, EFF recently launched a campaign encouraging our members to submit comments. However, we believe that given the tremendous impact this rulemaking will have (especially on people who may not realize it is taking place), it would be in the best interest of both the public and the FAA if the FAA extended the comment period. Doing so would allow more potentially impacted stakeholders to comment, thus providing the FAA with a more robust record on which to make its decisions. As Mr. Zuccaro of Helicopter Association International said, we need to get this NPRM right. We second his request for a 60-day extension in the official comment period for docket FAA-2015-0150.

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