Below is the introduction. The source (above) links to the original, a copy is mirrored here.
On behalf of the Competitive Enterprise Institute (“CEI”), we respectfully submit
these comments in response to the Federal Aviation Administration’s (“FAA”) Interim
Final Rule Regarding Registration and Marking Requirements for Small Unmanned
Aircraft (“IFR”). CEI is a nonprofit, nonpartisan public interest organization that
focuses on regulatory policy from a pro-market perspective.2 CEI previously filed
comments in response to the FAA’s Request for Information Regarding Electronic
Registration for UAS (“RFI”).
Our comments develop the following points:
FAA lacks the statutory authority to mandate the registration of all unmanned
aircraft systems (“UAS”); and
FAA fails to justify its invocation of the good cause exception to the
Administrative Procedure Act (“APA”) to dispense with public notice and comment.