NPRM UPDATE
We are now just weeks away from the publication of the FAA Notice of Proposed Rulemaking (NPRM) for small Unmanned Aircraft Systems (sUAS). Assuming the rulemaking process remains on track, the FAA has targeted mid-December 2011 for the release of its proposed sUAS rule. It is extremely important that every AMA member, modeler, and aeromodeling enthusiast understands the NPRM process and participates in the public comment period.
What is an NPRM?
An NPRM is a formal notice to the public by a government agency—in this case the FAA—stating its intent to create new regulations or modify existing regulations. The NPRM procedure is required and defined by the Administrative Procedure Act and was created by Congress to require agencies such as the FAA to listen to comments and concerns of the people whom the regulation will likely affect.
The NPRM is published in the Federal Register and typically provides 60 to 90 days for public comment and replies from any interested party. An NPRM may be followed by a Further Notice of Proposed Rulemaking (FNPRM) if comments from the initial NPRM drastically change the proposal to the point where further comment is required.
The NPRM will include:
- A summary of the proposed rule.
- The scope of the regulation.
- The exact regulatory language being proposed.
- The time period and the means for public comment.
Comments may be submitted electronically, mailed, hand-delivered, or faxed.
Will your comments make a difference?
Absolutely. Every comment received will be read and addressed. Comments will be broken down by the section of the regulation to which they apply and grouped with similar issues and concerns. A response will be drafted for each issue, and the FAA rationale and response to the comments will be published in the Final Rule.
The proposed sUAS rule is new regulation that will have a broad and sweeping impact on the aviation community and will literally change our world. The NPRM will engender thousands—if not hundreds of thousands—of comments from stakeholders on all sides of the issue. In order to ensure our views prevail, we will need a strong unified voice.
During our recent Congressional Awareness campaign, nearly 30,000 individuals sent letters of concern to their congressional delegation—a substantial response. However, we are going to need three or four times that number if we're going to affect changes and improvements to the proposed rule.
AMA actions and how to stay informed
AMA is working toward providing its members a simple and effective means for responding to the NPRM. AMA will also provide analysis and commentary on the impact of the proposed rule and suggestions for improving the rule before the sUAS Final Rule is published (expected in late 2012).
Timely updates can be found on:
- AMA website: www.modelaircraft.org
- Facebook: "Like" AMAGov
- Twitter: twitter.com/AMAGov
—Rich Hanson Government and Regulatory Affairs
Transcribed from original scans by AI. Minor OCR errors may remain.


