NJIT Comment to FAA sUAS NPRM, hyperlinked Page 1 of 2

Last updated: LAA 04/29/15 1133

USDOT, FAA, Docket No. FAA-2015-0150, Notice No. 15-01, Federal eRulemaking Portal Folder

In the Matter of Operation and Certification of Small Unmanned Aircraft Systems Notice of Proposed Rulemaking: (FR No. 2015-03544, ID no. FAA-2015-0150-0017)

Comments of the New Jersey Institute of Technology Unmanned Aircraft Systems Working Group (Short title: “NJIT Comment to FAA sUAS NPRM”)

Submitted: April 24, 2015 CLICK HERE for the full version of the New Jersey Institute of Technology.PDF document

Published: April 29, 2015CLICK HERE for the official filing to Regulations.gov Docket Folder of NJIT’s Rsp to NPRM (Filed as Portal ID: FAA-2015-0150-4089)

T A B L E O F C O N T E N T S All hyperlinks below are only for its respective section. For the entire document, see above hyperlink.

Coverpage Preamble, 2 Introduction, 4 Information About The Commenter, 7 Background, 23 C o m m e n t pp. 24-71 1. The Proposed Rulemaking is an Urgent Matter

pp. 24-33 2. Life-saving and Humanitarianism are constrained, regulated

pp. 33-35 3. Volunteer EMS providers and Fire Departments are affected, regulated

pp. 36-37 4. Time-critical Search and Rescue operations constrained, regulated

pp. 37-40 5. “Rules of the sky” will become as ubiquitous as the “rules of the road”

pp. 40-41 6. Academic and Educational uses affirmed, high schools and universities regulated

pp. 41-43 7. Observations of UAS Test Sites

pp. 44-50 8. Labored and inefficient COA process for Public Aircraft Operations experienced

pp. 50-51 9. Some state(s) already license this activity

pp. 51-55 10. Although bodies or forums already determine UAS liability, the NPRM is silent

pp. 55-56 11. Arguably, Congress intended for sUAS to be flying already. The micro UAS classification. NPRM, p.

9558. pp. 56-58

12. Regarding the UAS Fund Petition. NPRM, p. 9558. pp. 58-61

NJIT Comment to FAA sUAS NPRM, hyperlinked Page 2 of 2

Last updated: LAA 04/29/15 1133

13. The Supreme Court affirms a landowner’s full enjoyment of the land which includes “the immediate reaches of the enveloping atmosphere” pp. 61-62

14. Sense and Avoid, not See and Avoid pp. 62-63

15. The NPRM cost analysis assumptions are flawed pp. 63-64

16. An alternate view of employing advanced safety features. NPRM, p. 9576. p. 64

17. An alternate view on the inclusion of foreign-registered sUA aircraft in this new framework; whether NPRM should “be modified to ensure that it is consistent with any relevant obligations [of the U.S.] under international agreements” NPRM, p. 9554. p. 65

18. Requirements of line of sight provisions of proposed §§ 107.31 and 107.37. NPRM, p. 9560. pp. 65-66

19. An alternate view of the FAA “not [providing] an operator with the emergency powers available to the PIC under § 91.3(b).” NPRM, p. 9559. p. 66

20. An alternate view of the FAA “[creating] a new category of airman certificate for [sUAS] operators.” NPRM, p. 9567. p. 67

21. An alternate view of flight proficiency. NPRM, p. 9568. p. 67

22. An alternate view of knowledge testing. NPRM, p. 9569. p. 67

23. Alternate areas of training, knowledge. NPRM, p. 9569. pp. 67-68

24. A pilot’s perspective of controlled flight training p. 68

25. Model Aircraft or ‘hobbyist umbrella’ caveats pp. 69-70

26. Identification and Registration Marking of proposed § 47.15. NPRM, p. 9584. p. 70

27. An alternate view of intellectual property pp. 70-71

28. An alternative future scenario p. 71