November 24, 2015      

The aviation rule making committee submitted its recommendations for drone registration (PDF) on Nov. 21. I’m not going to cover the legal issues with drone registration that I made in the previous blog. I will only briefly discuss the recommendations, a few potential problems with the recommendations, and what happens next in the rulemaking process.

First, here’s a recap of the UAS registration task force’s recommendations:

What category of UAS is covered by the registration requirement?
UAS that weigh under 55 pounds and above 250 grams maximum takeoff weight, and are operated outdoors in the NAS.

Do owners need to register each individual UAS they own?
No. The registration system is owner-based, so each registrant will have a single registration number that covers any and all UAS that the registrant owns.

Is registration required at point-of-sale?
No. Registration is mandatory prior to operation of a UAS in the NAS.

What information is required for the registration process?
Name and street address of the registrant are required. Mailing address, email address, telephone number, and serial number of the aircraft are optional.

Is there a citizenship requirement?

Is there a minimum age requirement?
Yes. Persons must be 13 years of age to register.

Is there a registration fee?

Is the registration system electronic or web-based?
The system for entry of information into the database is web-based and also allows for multiple entry points, powered by an API that will enable custom apps to provide registry information to the database and receive registration numbers and certificates back from the database. Registrants can also modify their information through the web or apps.

Read the complete recommendation report from the drone registration task force.

How does a UAS owner prove registration?
A certificate of registration will be sent to the registrant at the time of registration. The certificate will be sent electronically, unless a paper copy is requested, or unless the traditional aircraft registration process is utilized. The registration certificate will contain the registrant’s name, FAA-issued registration number, and the FAA registration website that can be used by authorized users to confirm registration information. For registrants who elect to provide the serial number(s) of their aircraft to the FAA, the certificate will also contain those serial number(s). Any time a registered UAS is in operation, the operator of that UAS should be prepared to produce the certificate of registration for inspection

Does the registration number have to be affixed to the aircraft?
Yes, unless the registrant chooses to provide the FAA with the aircraft’s serial number. Whether the owner chooses to rely on the serial number or affix the FAA-issued registration number to the aircraft, the marking must be readily accessible and maintained in a condition that is readable and legible upon close visual inspection. Markings enclosed in a compartment, such as a battery compartment, will be considered “readily accessible” if they can be accessed without the use of tools.

Now, let’s look at a few potential issues with these recommendations:

Inability for Non-Government Parties to Check

If registration data is hidden from the public, then how does one check on the recreational individual to make sure they are compliant? It seems that only law enforcement will have access to this database to protect people’s privacy. Local AMA fields won’t have a way to validate compliance.

Validation of the Name and Address

How does the FAA validate the name and address submitted? If the data that is put in is bad, then the data coming out will be bad. An individual could just put in a false name or address and no one could check unless they went to his address or somehow obtained his driver’s license.

Remember that the whole point of registration is to track down the negligent or bad individuals who use a drone. Bad individuals most certainly won’t provide a name and address, unless they were on a one-way mission like the Paris attack. Law enforcement would just run the check and find the false name and false address in the database to match the false name and false registration on the registration paperwork.