The comment letter, submitted by university legal counsels and academic leaders, addresses the Federal Aviation Administration’s (FAA) Notice of Proposed Rulemaking (NPRM) concerning the operation and certification of small unmanned aircraft systems (UAS). The authors commend the FAA's progress in regulating UAS while emphasizing the longstanding, safety-conscious use of model and unmanned aircraft in higher education for teaching, research, and recreation. The letter expresses strong support for key provisions of the NPRM, particularly the proposal to require an Operator Certificate instead of a Private Pilot’s License, and the decision against mandatory airworthiness certification for small UAS operated by trained individuals under controlled conditions, as both measures would facilitate innovation and education without compromising safety.
However, the letter recommends several refinements to the proposed rule to better support research and educational activities. These include explicit recognition that public institutions may operate under the same rules as civil operators, the inclusion of an Operator in Command (OIC) role to supervise student use of UAS, and the establishment of a distinct regulatory category for micro-UAS with proportionately minimal requirements. The comment also urges the FAA to allow reasonable flexibility for advanced UAS operations—such as beyond-line-of-sight and autonomous activities—where risks are controlled, and to affirm the authority of landowners, notably educational institutions, to regulate UAS operations within their immediate airspace. The counsel concludes that these adjustments would strengthen public safety, ease administrative burdens, and foster continued American leadership in aviation innovation through research and education.
COGR signed on to a comment letter to the FAA on its proposed rule for the Operation and Certiification of Small Unmanned Aircraft System.
