CIE.ORG Comments on "FAA's Unlawful Drone Registration Mandate"

Source: https://cei.org/sites/default/files/Marc%20Scribner%20and%20Ryan%20Radia%20-%20FAA%20IFR%20UAS%20registration%20comments.pdf

Publish date: 20160115

Author: Marc Scribner and Ryan Radia

Original Copy:

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:

  1. FAA lacks the statutory authority to mandate the registration of all unmanned aircraft systems (“UAS”); and
  2. FAA fails to justify its invocation of the good cause exception to the Administrative Procedure Act (“APA”) to dispense with public notice and comment.

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