11 Big Problems with the FAA’s Mandatory Drone Registration


  • The DOT’s Announcement Can Be Viewed Here.
  • The FAA’s request for comments is here.
  • The underlying FAA report of drone sightings is located here.
  • The Academy of Model Aeronautics responded to the report with an analysis located here.

Second Update: An individual took the time and responded to this post. I posted my reply at the bottom.

 

Update: Just to clarify, my point is not to “troll” the FAA, I think geofencing will produce far better results by preventing problems as opposed to pointing to who might have done it after something has happened. The uneducated new recreational flyers are the ones I believe causing the problems. Having manufacturers voluntarily “lock” the drones until an unlock access code is provided after an introductory ground school would produce better results. One way to sweeten the pot is not just provide “how to fly safely” video tutorials but also “how to get that awesome shot” tutorials. Education, not enforcement is a better strategy. If anyone higher-up in the FAA is reading this, please contact me so I can help you promote safety in the national airspace. 🙂

 

Note: The FAA DID publish their drone registration regulations. I wrote an in-depth article on Why the FAA’s Drone Registration Requirements Are ILLEGAL

 

Oklahoma City is where aircraft registration gets processed. The aircraft registration process still involves carbon copy forms, which must be filled out perfectly and sent in for an aircraft to be registered. They are extremely, I mean extremely, picky on registration based upon my experience. (If you need help with registration, contact me.) If the paperwork is completed correctly, they will send you back an “N” registration which is required to be displayed on the aircraft. The reason for the “N” is the aircraft is tied to the country it operates in. (Think of license plates where the state is listed on the plate.) N = United States, C or CF = Canada, XA, XB, or XC = Mexico, B= China, JA= Japan, SU= Egypt, etc. The complete list is here at 4-1-1.  So N12345 is a U.S. registered aircraft while XA12345 is a Mexican registered aircraft.

 

Current Registration Requirements for Drones:

Commercial drone operators are required to obtain a 333 exemption or fly under Part 107. The exemptions being given out say, “All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.” This is in addition to the manned aircraft which are registering with the FAA.  This is currently ONLY for commercial drones while recreational drones are not required to register their drones.

 

Proposed Registration:

“The Department of Transportation is reviewing whether the FAA has the authority to require drones be registered at their point of sale, Transportation Secretary Anthony Foxx told CBS News on Friday.”[1]

 

Furthermore, Senator Feinstein’ s “Consumer Drone Safety Act’’ requires “that a consumer drone be detectable and identifiable to pilots and air traffic controllers, including through the use of an identification number and a transponder or similar technology to convey the drone’s location and altitude[.]”[2]

 

Moreover, Cory Booker’s Commercial UAS Modernization Act prohibits the operations of commercial small unmanned aircraft “unless the owner has registered the aircraft under section 3(a) of the Commercial UAS Modernization Act.”[3]

 

In the FAA’s explanations in the Notice of Proposed Rulemaking (“NPRM”) regarding unmanned aircraft it said, “The FAA’s statute, [49 U.S.C. 44101], prohibits the operation of an aircraft unless the aircraft is registered. Pursuant to this statutory prohibition, this proposed rule would require small unmanned aircraft to be registered with the FAA using the current registration process found in 14 CFR part 47.” The NPRM later showed the proposed rule, “No person may operate a civil small unmanned aircraft system for purposes of flight unless[,] . . . [t]he small unmanned aircraft being operated has been registered with the FAA . . . .”[4]

 

Just today NBC announced, “The federal government will announce a new plan requiring anyone buying a drone to register the device with the U.S. Department of Transportation[.]”[5] Just FYI, the DOT supervises the FAA which explains why they are involved.

 

The clear trajectory of all this is that commercial drone aircraft will be required to be registered and possibly also recreational aircraft. This presents interesting problems so let’s dive into the facts.

 

Sales:

Bloomberg indicated that “Amazon is selling more than 10,000 drones a month[.]”[6] 3DR “is expected to top $40 million in sales in 2015, which would roughly translate to about 53,000 units”[7] and in 2014, “DJI sold about 400,000 units–many of which were its signature Phantom model–and is on track to do more than $1 billion in sales this year, up from $500 million in 2014.”[8]

 

On top of the drone sales, manned aircraft have been sold and already use some of the N numbers. For 2012, it was estimated that there were 209,034 aircraft in general aviation.[9]

 

The Proposed Laws and Regulations Intersecting with the Forecasted Sales.

Let’s get into the math. Let’s assume that all drones have to be registered. How many different combinations are possible?

 

“All U.S. civil aircraft registration numbers are prefixed by an N. The registration number, apart from the N prefix, is made up of one to five symbols, the last two of which may be alphabetical. This alphabetical suffix must be preceded by at least one numerical symbol. The lowest possible number is N1. A zero never precedes the first number. For example: N1 through N99999, all symbols are numeric. N1A through N9999Z, single alphabetical suffix. N1AA through N999ZZ, double alphabetical suffix. Note: To avoid confusion with the numbers zero and one, the letters O and I are never used as alphabetical suffixes.”[10]

 

This is how the math works out. Yes, I had to go to my friend who is an actuary to help with this. 🙂 Here is what he said:

For 1 symbol: 1 through 9 can be used so= 9
For 2 symbols: (1 thru 9) and (digits 0-9 and 24 letters)= 9×34=306

For registration numbers of length three or more we have to break it into cases:
Case I: The next-to-last symbols is a NUMBER
Case II: The next-to last symbol is a LETTER
And we remember the rule that a letter can not precede a number.

For 3 symbols:
Case I: (1 thru 9) and (digits 0-9) and (digits 0-9 and 24 letters)= 9x10x34=3060
Case II: (1 thru 9) and (24 Letters) and (24 letters)= 9x24x24=5184

For registration numbers of length 4 or 5 we remember that only the last two symbols can be letters

For 4 symbols:
Case I: (1 thru 9) and (digits 0-9) and (digits 0-9) and (digits 0-9 and 24 letters)= 9x10x10x34= 30600
Case II: (1 thru 9) and (digits 0-9) and (24 Letters) and (24 letters)= 9x10x24x24=51840

For 5 symbols:
Case I: (1 thru 9) and (digits 0-9) and (digits 0-9) and (digits 0-9) and (digits 0-9 and 24 letters)= 9x10x10x10x34 = 306000
Case II: (1 thru 9) and (digits 0-9) and (digits 0-9) and (24 Letters) and (24 letters)= 9x10x10x24x24= 518400

Adding up all possibilities gives 915,399 total possible registration numbers.

 

The reason for the 34 is 10 numbers + 25 letters. The letters I and O cannot be used because they can be confused with the numbers 1 and 0.

 

Further compounding this problem is “A Certificate of Aircraft Registration issued under this paragraph expires three years after the last day of the month in which it is issued.” 14 CFR 47.40(a)(3).

 

Moreover, it is easier to register a drone than transfer registration. If you crash the drone, you’ll have crazy headaches trying to transfer registration of the N-number to the new drone as opposed to just registering a new N number.

 

At this pace, we are going to run out of N numbers in the future.

Proposed Solutions

  • Open up the first 3 spaces to allow also the use of letters. (The FAA must go through the rule making process for this but it is unclear how this would work with the FMRA).
  • Require re-registration of a drone every year. (Currently it is every 3 years as per regulation. This needs to be changed via the rule making process but still the FMRA might cause problems.)
  • Make the N number registration transfer easy so people just don’t keep registering drones. (This can be solved by some type of internet portal as opposed to the difficult paper process now.
  • Add an additional 6th space or 7th (still must go through the rule making process)

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Jonathan Rupprecht

Mr. Rupprecht is an aviation attorney who focuses on drones. Read more about his background as a commercial pilot, flight instructor, Embry-Riddle Aeronautical University grad, and legal author. He has had media appearances on Forbes, Newsweek, Politico, NPR, Marketwatch, The Independent, Motherboard, and other sources. Feel free to send Jonathan a message here.