Overview
Title
Agency Information Collection Activities: Requests for Comments; Clearance of a New Approval of Information Collection: Operation of Small Unmanned Aircraft Systems Over People
Agencies
ELI5 AI
The government wants to make sure that tiny flying machines, like drones, are safe and can be flown over people. They are asking people who own these drones to keep track of all the fixes and checkups their drones get, but some people think they might have underestimated how many people this really affects and how much work it will take.
Summary AI
The Federal Aviation Administration (FAA) is seeking public comments on a proposed new information collection regarding small unmanned aircraft systems (UAS) that have an airworthiness certificate. This collection will require operators and owners to maintain records of all maintenance, status of parts, compliance with airworthiness directives, and inspection status of their aircraft. The FAA estimates that this requirement will apply to around two operators per year, each managing a fleet of 100 UAS, leading to an annual burden of approximately 100 hours for keeping these records. This effort ensures the safety and reliability necessary for UAS operations over people.
Abstract
In accordance with the Paperwork Reduction Act of 1995, FAA invites public comments about our intention to request Office of Management and Budget (OMB) approval for a new information collection. The collection involves operators and owners of small unmanned aircraft systems (UAS) issued an airworthiness certificate under Part 21, and mandates that these entities must retain records of all maintenance performed on their aircraft and records documenting the status of life- limited parts, compliance with airworthiness directives, and inspection status of the aircraft. These records are used to validate that aircraft are maintained in a manner that ensures the reliability associated with having an airworthiness certificate and that the operations-over-people privileges afforded to category 4 operations continue to be appropriate. The owner or operator may keep these records electronically or by paper.
Keywords AI
Sources
AnalysisAI
The Federal Aviation Administration (FAA) has issued a notice requesting public comments on a new information collection proposal concerning small unmanned aircraft systems (UAS) that are certified for airworthiness. This collection mandates that owners and operators keep detailed maintenance records for the UAS, including details about part statuses and compliance with safety directives. The actions are aimed at ensuring the reliability and safety of these aircraft when they are operated over people.
General Summary
This document outlines the FAA's proposed process for collecting information related to the maintenance and compliance of small UAS. According to the FAA, this requirement will affect approximately two operators per year, each handling around 100 UAS. The anticipated maintenance and record-keeping burden is estimated at around 100 hours annually. The FAA believes that keeping detailed records will support the safety validations necessary for conducting operations over people.
Significant Issues and Concerns
Several points of concern arise from this notice:
Underestimation of Market Participation: The FAA's estimation that only two owners each year will be impacted may not accurately capture the scale of the industry. This conservative estimate might fail to account for the complexities and variations in UAS operations, leading to potential underestimations of compliance costs and enforcement difficulties.
Vague Frequency Description: The document describes the frequency of necessary recordkeeping as "on occasion," a term which is not specific. This could lead to confusion among operators about the precise obligations they must meet, potentially complicating compliance efforts.
Potential Underestimation of Workload: Given the scale of handling a fleet of 100 UAS and the requirement for diligent record-keeping, the annual burden estimate of just 100 hours appears low. Accurately assessing the time and administrative labor required for managing these records is crucial for operators’ preparedness.
Lack of Penalty and Enforcement Information: The document does not provide details on penalties or enforcement actions for non-compliance with the recordkeeping requirements. This gap could leave operators uncertain about the consequences of failing to meet these new obligations, potentially leading to issues in alignment and adherence to the rules.
Impact on the Public and Stakeholders
Broad Impact on the Public: This initiative underscores a commitment to ensuring that the use of UAS complies with safety regulations, which benefits public safety. By ensuring meticulous record-keeping, the FAA aims to maintain high safety standards, particularly as drone operations increase over populated areas.
Impact on Specific Stakeholders:
UAS Operators and Owners: These stakeholders face new responsibilities and potential costs associated with maintaining compliance records. While this might initially seem burdensome, compliance with these regulations could elevate trust and safety in UAS operations, benefiting operators who engage responsibly.
Regulatory Bodies and Law Enforcement: Effective implementation and enforcement depend on clear guidelines and realistic projections. The current document may need refinement to ensure regulatory bodies are equipped to handle the compliance landscape created by this rule.
In conclusion, while the FAA's proposal seeks to reinforce safety through vigilant record-keeping, the document may not fully account for the operational realities faced by UAS stakeholders. Addressing the outlined concerns could create a more balanced and effective regulatory framework.
Issues
• The document estimates that only 2 owners per year will be affected, which might underrepresent the actual market participation and could lead to an underestimation of enforcement and compliance costs.
• The phrase 'On occasion' in describing the frequency of recordkeeping is vague and could benefit from clarification to specify more precise intervals or triggers for action.
• The calculation of '100 hours per year' total annual burden seems low given the number of UAS and frequency, suggesting potential underestimation of the labor and administrative requirements.
• The document lacks details on potential penalties or consequences for non-compliance with recordkeeping requirements, which could lead to ambiguity in regulatory enforcement.