Skip to content

Southern Fried Science

Over 15 years of ocean science and conservation online

  • Home
  • About SFS
  • Authors
  • Support SFS

Science Flyers: My comment to the FAA regarding proposed new drone regulations.

Posted on April 8, 2015April 8, 2015 By Andrew Thaler
Science

I submitted the following to the FAA regarding docket number FAA-2015-0150: Operation and Certification of Small Unmanned Aircraft Systems. Comments can be filed online, but I also sent an actual, physical letter. If you care about the regulation of drone in US airspace, you have until April 24, 2015 to submit you own.


I am a marine ecologist based in Virginia, with plans to operate small Unmanned Aircraft Systems in the conduct of marine ecologic research.

With regards to the FAA’s recently proposed regulations for the Operation and Certification of Small Unmanned Aircraft Systems, I find that the vast majority of suggested restrictions and requirements to be both reasonable and not particularly onerous for those wishing to operate UAS’s for commercial purposes. I commend the FAA for taking a pragmatic approach to UAS regulation. In particular, I support the requirement for a comprehensive knowledge test, which will be separate from and less expensive than a full pilot’s license. I also appreciate the recognition that UAS technology is advancing so quickly that a certification of airworthiness for specific airframes will place an undue burden on commercial pilots and force them to operate vehicles several generation behind the state of the art. I also approve of a special exemption for “microdrones”, which have significantly a lower safety risk and allow UAS pilots additional freedom in their use of very small vehicles.

I approve of the requirement that operators maintain visual line-of-sight, however, in the proposed regulations, there are make no provisions for autonomous flight. Autonomous flight dramatically changes the relationship between the aircraft and the operator and is an essential component of ecological surveys, allowing drones to fly straight transects and pinpoint sampling sites. This points to a more specific problem with the proposed regulations: in current form, there is little clarity regarding the role of scientists and other researcher in relation to UAS use. Will ecologists fall under the same restrictions as commercial drone pilots, or will they be treated more similar to hobbyist?

I urge the FAA to adopt a “Science Flyer” certification, similar to the American Association of Underwater Scientists “Science Diver” program. To wit, science divers have enhanced training requirements over recreational SCUBA divers, but less than professional commercial divers. A Science Flyer program could span a similar gap, with more training requirements than a hobbyist but fewer restrictions than a commercial UAS operator and could also provide additional training and certification to allow for autonomous operation.

Finally, the requirement that UAS users go through a TSA background check before being certified seems wholly unnecessary. Not only will this add extra expenses to UAS operators and add 6 to 8 weeks to the certification process, but, it does not improve national security in any meaningful way, because there are no restrictions on buying or building UAS’s, only flying them, and hobbyists are not required to undergo any certification. If someone wanted to threaten national security with a UAS, they would simply not apply for a commercial license.

The vast majority of commercial drone users are almost certainly going to be photographers, many of whom will not be full-time photographers, but will, like many freelancers, be supplementing their income. Which means that they will be able to make a reasonable, if tenuous, case for operating a model aircraft recreationally and skip the entire certification process. The more complex and onerous the process, the more people will try to find loopholes to get out of it, and a TSA check will only serve to discourage some borderline commercial operators from undergoing commercial training and certification.

I want UAS operators to be safe and responsible. I’d actually prefer that all UAS pilots, including hobbyists, undergo a basic safety course, in much the same way that most states require boaters to take a US Coast Guard approved boating safety course. If it could be done online, even better. A TSA review would simply discourage a subset of drone pilots from pursuing certification without adding any value to national security.

Share this:

  • Share on Bluesky (Opens in new window) Bluesky
  • Share on Facebook (Opens in new window) Facebook
  • Share on Reddit (Opens in new window) Reddit
  • Share on Threads (Opens in new window) Threads
  • Share on WhatsApp (Opens in new window) WhatsApp
  • Share on Mastodon (Opens in new window) Mastodon

Related

Tags: drones FAA

Post navigation

❮ Previous Post: Yoda, Yoga, and the Fish of Cannery Row
Next Post: How a 10 Million Year old fossil, a smart phone, and a 3D printer recharged my #OceanOptimism. ❯

You may also like

Conservation
10 ways drones can save the ocean
June 27, 2014
Conservation
How will the FAA’s proposed rules impact drone use for research and conservation?
February 16, 2015
Weekly Salvage
Valuing the deep sea, send @mcmsharksxx to Antarctica, deep-sea mining takes a dive, explore Kiribati, and more! Monday Morning Salvage: July 9, 2018
July 9, 2018
Weekly Salvage
Monday Morning Salvage: January 2, 2017
January 2, 2017

Popular Posts

What Ocean Ramsey does is not shark science or conservation: some brief thoughts on "the Shark Whisperer" documentaryWhat Ocean Ramsey does is not shark science or conservation: some brief thoughts on "the Shark Whisperer" documentaryJuly 2, 2025David Shiffman
Here's how to join my IMCC8 symposium, "Ocean Science Communication: What's New and What's Next?"Here's how to join my IMCC8 symposium, "Ocean Science Communication: What's New and What's Next?"April 22, 2026David Shiffman
That's not a blobfish: Deep Sea Social Media is Flooded by AI SlopThat's not a blobfish: Deep Sea Social Media is Flooded by AI SlopDecember 19, 2025Andrew Thaler
What is a Sand Shark?What is a Sand Shark?November 12, 2017Chuck Bangley
Fun facts and FAQs about Megalodon, Maryland's new (and definitely extinct) official state sharkFun facts and FAQs about Megalodon, Maryland's new (and definitely extinct) official state sharkApril 15, 2026David Shiffman
Here are some ocean conservation technologies that I'm excited aboutHere are some ocean conservation technologies that I'm excited aboutFebruary 19, 2026David Shiffman
Reflections on science and my role in it, ten years since my Ph.D. defenseReflections on science and my role in it, ten years since my Ph.D. defenseApril 1, 2026David Shiffman
Join Me at Upwell: A Wave of Ocean Justice — Our Fourth Year!Join Me at Upwell: A Wave of Ocean Justice — Our Fourth Year!March 24, 2026Angelo Villagomez
Here's what I teach my students about finding jobs in marine biology and conservationHere's what I teach my students about finding jobs in marine biology and conservationApril 10, 2024David Shiffman
Urea and Shark OsmoregulationUrea and Shark OsmoregulationNovember 15, 2010David Shiffman
Subscribe to our RSS Feed for updates whenever new articles are published.

We recommend Feedly for RSS management. It's like Google Reader, except it still exists.

Southern Fried Science

  • Home
  • About SFS
  • Authors
  • Support SFS


If you enjoy Southern Fried Science, consider contributing to our Patreon campaign.

Copyright © 2026 Southern Fried Science.

Theme: Oceanly Premium by ScriptsTown