Rusinko FAA Legal Opinion

Getting your Trinity Audio player ready...

The original FAA interpretation is located here. 


Mr. John Rusinko

Re: Small Unmanned Aircraft Registration – 14 C.F.R. Pa1ts 47 and 48

Dear Mr. Rusinko:
This letter is provided in response to your letter dated December 17, 2015 to the Federal Aviation Administration (FAA) Office of the Chief Counsel seeking a legal interpretation. In your request for a legal interpretation you ask whether you must register model aircraft that you do not anticipate operating for two to three years.1

A small um11anned aircraft owner need only register aircraft operated in the national airspace system (NAS). See 14 C.F.R. §§ 47.3(b) and 48.15. Thus, you need not immediately register those small unmanned aircraft that you do not anticipate flying for two to three years. As long as you complete the registration process provided by either, 14 C.F.R. pa1t 47 or 14 C.F.R. pait 48 prior to operation of your small unmanned aircraft in the NAS, you will be in compliance with aircraft registration requirements. See 14 C.F.R. §§ 47.3(b), 48.S(a) and 48.15.

This response was prepared by Sara Mikol op, an attorney in the Regulations Division of the Office of the Chief Counsel, and was coordinated with the Civil Aviation Registry Division (AFS-700) and the UAS Integration Office. If you need further assistance, please contact our office at (202) 267-3073.

Lorelei Peter
Assistant Chief Counsel for Regulations

1 For purposes of this legal interpretation, we assume that when your letter refers to model aircraft that are “larger models” that those model aircraft are small unmanned aircraft (less than 55 lbs.).