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| 00002182c6df32bfed0efbd77bef27255609860e1973b5c38c9cdfb12e0b6ced | March 21, 2015 Docket Management Facility U.S. Department of Transportation 1200 New Jersey Avenue SE West Building Ground Floor, Room W12-140 Washington, DC 20590 Subject: Comments to FAA Docket Number FAA 2015-0150 To whom it may concern, I truly believes that very-light Unmanned Aircraft Systems (UAS) represent the future of this industry. Therefore I fully support the creation of a micro UAS class that would be ruled with specific standards, and encourage the FAA to create that category. It would allow operations of UAS weighing less than 4.4 pounds in Class G airspace, over people not directly involved in the operation, and would require airmen to self-certify that they are familiar with the aeronautical knowledge testing areas. That approach seems very reasonable since a very light (micro) UAS operating at lower altitudes and at lower speeds, that is made up of materials that break or yield easily upon impact, may pose a much lower risk to persons, property, and other NAS users than a UAS that does not operate within these parameters. Additionally, limiting the micro UAS operation entirely to Class G airspace, far away from an airport, and in close proximity to the operator (as well as limiting the unmanned aircrafts flight path to the operators constant manual control) would significantly reduce the risk of collision with another aircraft. I believe that UAS weighting less than 4.4 pounds and operated within these constraints will meet our business needs and would allow a fast, safe and cost-effective integration of this technology into our workflow. The FAA is considering the following provisions for the micro UAS classification and I approve these provisions: The unmanned aircraft used in the operation would weigh no more than 4.4 pounds (2 kilograms). This provision would be based on the ARCs recommendations and on how other countries, such as Canada, subdivide their UAS into micro or lightweight UAS; The unmanned aircraft would be made out of frangible materials that break, distort, or yield on impact so as to present a minimal hazard to any person or object that the unmanned aircraft collides with. Examples of such materials are breakable plastic, paper, wood, and foam. This provision would be based on the ARCs recommendations; During the course of the operation, the unmanned aircraft would not exceed an airspeed of 30 knots. This provision would be based on the ARCs recommendation, which was concerned with damage that could be done by unmanned aircraft flying at higher speeds; During the course of the operation, the unmanned aircraft would not travel higher than 400 feet above ground level (AGL). This provision would be based on the ARCs recommendations; The operation would be limited entirely to Class G airspace. This provision would be based on Canadas requirements for micro UAS; The unmanned aircraft would maintain a distance of at least 3 nautical miles from any airport. This provision would be based on Canadas requirements for micro UAS. However I would suggest adapting the following provision: The operator would maintain manual control of the flight path of the unmanned aircraft at all times, and the operator would not use automation to control the flight path of the unmanned aircraft. This provision would be based on ARC recommendations and Canadas requirements for micro UAS; I propose instead the following: The operator would have the ability to immediately change the trajectory of the aircraft in real-time, either by using a remote controller or taking manual actions in the related flight management software (Hold position, Return to Home, modify in real-time the trajectory of the aircraft). I understand that the FAAs motivation is to ensure an operator can react immediately to potential dangers, so the ability to change the trajectory of a UAS is crucial, for example in order to avoid a collision. However I believe that flight management software is now advanced enough to reliably meet this need and can be complemented by the use of remote control. Even if using a remote control alone, wording that suggests no use of automation is inaccurate, since from a technical standpoint such unmanned vehicles use automation at some level to control the aircrafts flight path. Respectfully, Robert Farley Jacksonville, FL | 1 | 7d20fcdf03d35e8b2513f9763559fdf3e84fc695857aa44dcc0a17db8e530dd4 |