Comment from UUAS
UUASSupportBusiness
Summary: Rory Johnson, founder of UUAS and a graduate student at Middle Tennessee State University, supports the proposed rule but recommends specific evidentiary standards. He argues that the FAA should adjudicate "aviation safety necessity" based on site-specific evidence rather than assumed national trends, and that operator density should not be used as a proxy for hazard.
I am the founder of UUAS, a small UAS business in Murfreesboro, Tennessee, and a graduate student (M.S. Aviation, Middle Tennessee State University). On July 19, 2026, I published an open-access research series and a complete reconstruction of the FAA UAS Sighting Reports — 21,765 records, November 2014–June 2026 (DOI: https://doi.org/10.5281/zenodo.21444168). These are unverified pilot/ATC reports, not confirmed incidents; read with that caveat, the record shows no significant national trend over 11 years and tracks manned-traffic exposure, not operator geography.
I support a workable Section 2209 process and recommend that the final rule:
Adjudicate "aviation safety necessity" on site-specific evidence, not an assumed national escalation (no significant trend 2015–2025; p = 0.814; Paper 1).
Reject operator/registration density near a facility as hazard evidence — the per-capita association is negative (Spearman ρ = −0.35; Paper 2).
Treat registration and certificate counts as cumulative tallies, not activity measures, and specify allowable quantitative evidence and its limitations (Paper 4).
Restore the complete sighting record to the FAA's public page and publish granted/denied 2209 designations in machine-readable form.
Weigh the burden on low-risk small operators.