The document is a formal comment submitted by a coalition of major U.S. universities and academic associations in response to the Federal Aviation Administration's (FAA) Notice of Proposed Rulemaking regarding Remote Identification of Unmanned Aircraft Systems (UAS). The signatories express strong support for the general principle of requiring remote identification for UAS, highlighting its importance in aiding law enforcement agencies, including campus police, to identify and potentially contact UAS operators involved in unsafe or suspicious activities. They acknowledge the FAA’s efforts to enhance U.S. aviation safety through these regulations.
However, the commenters raise specific concerns about proposed limitations surrounding FAA Recognized Identification Areas (FRIAs)—designated geographic zones where certain UAS can operate within visual line of sight. While they support the establishment of FRIAs, the universities advocate for expanded eligibility to create such areas, recommending that universities, not just community-based organizations, be authorized to petition for their recognition. Additionally, they argue that the FRIA application period should not be restricted to the first 12 months following the rule's implementation, and that the eventual phase-out of FRIAs could hinder valuable research and educational opportunities involving amateur-built and research-focused UAS. The document concludes by emphasizing the need for ongoing support for these initiatives to ensure the continued safe, lawful, and innovative use of UAS in academic environments.
