Comment from Hokumalamalama Productions LLC

Comments on NPRM: Unmanned Aircraft Flight Restrictions (Section 2209) As an FAA Part 107 certified remote pilot who operates drones strictly for commercial enterprise, I am writing to oppose the "advanced notice" transit requirement in the proposed Unmanned Aircraft Flight Restrictions (UAFRs). Piling administrative hurdles onto vetted professionals is an ineffective security strategy that penalizes those already following the rules while doing nothing to deter bad actors or uncertified hobbyists. The security concerns driving this NPRM are not caused by Part 107 pilots. Commercial operators invest significant time and money to study airspace, pass federal examinations, and undergo TSA background checks to ensure safe and responsible operations. Our drones are tools for business, not toys for social media fame. The root of the security risk stems from uncertified flyers who can easily purchase highly capable, enterprise-grade hardware without any verification of licensing, training, or intent. Instead of creating an ambiguous, burdensome pre-flight notification system that disrupts time-sensitive commercial workflows, the FAA should leverage the technology it has already mandated: Remote ID. Rather than treating every drone silhouette as an anonymous threat, the FAA should implement an extra data transfer protocol within the Remote ID broadcast framework. This protocol would allow a certified pilot’s Remote ID signal to transmit a secure, verified token indicating "Part 107 Certified Status." When transiting a standard UFR, a facility's security team would instantly see that a vetted, background-checked professional is in the airspace. This solves the facility's security concern through automated data tracking without forcing a business owner to file redundant paperwork for every transit. I urge the FAA to reject the manual notification model for Part 107 pilots. Instead, the final rule should grant a complete transit exemption to Part 107 operators, utilizing an updated Remote ID protocol to broadcast our verified professional status to ground security in real-time.