RTF ARC Recommendations

Final Report

November 20, 2015

Unmanned Aircraft Systems (UAS) 

Registration Task Force (RTF) 

Aviation Rulemaking Committee 

(ARC)

Task Force Recommendations 

Final Report

November 21, 2015
November 21, 2015 Page i

Table of Contents

1. BACKGROUND........................................................................................................... 1

2. OBJECTIVES AND SUMMARY OF ACTIVITIES OF THE TASK FORCE...................... 2

3. EXECUTIVE SUMMARY.............................................................................................. 4

4. TASK FORCE RECOMMENDATIONS......................................................................... 6

4.1 Minimum Requirements for UAS that Would Need to be Registered (i.e., exclusion from the 

registration requirement)................................................................................................... 6

4.2 The Registration Process........................................................................................... 10

4.2.1 What information should be collected?.................................................................. 10

4.2.2 At what point should registration occur? Should the system be electronic or web-based?

................................................................................................................................ 11

4.2.3 Should a registration fee be imposed?.................................................................... 12

4.2.4 Should there be an age limit for registration? .......................................................... 12

4.3 Methods for Proving Registration and Marking ............................................................ 12

4.3.1 Certificate of Registration .................................................................................... 13

4.3.2 Marking Requirement.......................................................................................... 13

4.3.3 Penalties and Enforcement .................................................................................. 13

5. CONCLUSION........................................................................................................... 14

6. APPENDIX Summary of Task Force Recommendations..................................................A-1
November 21, 2015 Page 1

1. BACKGROUND 

The Federal Aviation Administration (FAA) chartered the Unmanned Aircraft Systems (UAS) 

Registration Task Force (RTF) Aviation Rulemaking Committee (ARC) (Task Force) to provide 

recommendations to the FAA “on registration requirements and process for small UAS, including 

those used for commercial purposes, and all model aircraft.” 

Federal law (49 U.S.C. § 44101(a)) requires that a person may only operate an aircraft when it is 

registered with the FAA. An “aircraft” is defined as “any contrivance invented, used, or designed to 

navigate, or fly in, the air” (49 U.S.C. § 40102(a) (6)). In 2012, Congress confirmed that UAS, 

including those used for recreation or hobby purposes, are aircraft consistent with the statutory 

definition set forth in 49 U.S.C. § 40102(a)(6). See Pub. L. 112-95, §§ 331(8), 336. The FAA 

currently requires civil UAS operators who have been granted operational authority by exemption to 

register their aircraft. The FAA would also require registration for civil UAS that would be 

operating under the proposed rule titled Operation and Certification of small UAS (sUAS). See 80 

FR 9544 (Feb. 23, 2015). 

Although the FAA does not currently enforce the requirement for sUAS used for hobby or 

recreational purposes to be registered, the rapid proliferation of these aircraft in the national airspace 

has caused the FAA to reevaluate this policy in the interests of public safety and the safety of the 

National Airspace System (NAS). On October 22, 2015, the Department of Transportation (DOT) 

and the FAA published the Clarification of the Applicability of Aircraft Registration Requirements 

for Unmanned Aircraft Systems (UAS) and Request for Information Regarding Electronic 

Registration for UAS (Clarification and RFI). See 80 FR 63912. The Clarification and RFI did three 

main things: (1) clarified that the statutory requirements regarding aircraft registration of UAS apply 

to aircraft used for recreational or hobby purposes; (2) announced the formation of this Task Force; 

and (3) facilitated the Task Force’s work, requesting information and data from the public in 10 

specific areas. 

The stated objective of the Task Force was to develop recommendations for the creation of a 

registration process, which ultimately would contribute to an enforceable rule imposed by the FAA. 

The FAA stated that the intent of establishing this registration framework was to promote a culture 

of accountability while achieving a maximum level of compliance.

The FAA scoped the Task Force’s objectives at inception, and advised them that deliberations and 

recommendations were not dependent on the issuance or enactment of new regulation(s) or 

legislation, thus bound by existing statutes and rules. Additionally, the FAA advised the Task Force 

that recommendations should only consider sUAS operations covered under existing laws or 

statutes for which the FAA has direct oversight or responsibility (e.g., indoor sUAS operations were 

outside of the scope of discussion).

Recommendations from the Task Force are within the bounds of its charter, and may be used at the 

FAA’s discretion. The FAA may incorporate all, some, or none of the recommendations provided 

in any rulemaking activity, as well as take any future steps deemed necessary by the Agency to ensure 

compliance with the registration requirement. The work of the Task Force is an important step 

toward promoting a safety culture, but it is by no means the only action that can be taken. Any 
November 21, 2015 Page 2

implemented registration system must align with the Agency’s priorities of safety, education, and 

accountability.

2. OBJECTIVES AND SUMMARY OF ACTIVITIES OF THE TASK 

FORCE 

The Task Force was comprised of individuals from a diverse group of aviation and non-aviation 

perspectives. The Task Force members were:

● 3D Robotics (3DR)

● Academy of Model Aeronautics (AMA)

● Aerospace Industries Association (AIA)

● Air Line Pilots Association (ALPA)

● Aircraft Owners and Pilots Association (AOPA)

● Amazon Prime Air

● Amazon Retail

● American Association of Airport Executives (AAAE)

● Association for Unmanned Vehicle Systems International (AUVSI)

● Best Buy

● Consumer Technology Association (CTA)

● DJI

● General Aviation Manufacturers Association (GAMA)

● GoogleX

● GoPro

● Helicopter Association International (HAI)

● International Association of Chiefs of Police (IACP)

● Management Association for Private Photogrammetric Surveyors (MAPPS)

● Measure

● National Association of State Aviation Officials (NASAO)

● National Business Aviation Association (NBAA)

● Parrot

● Precision Hawk

● Small UAV Coalition

● Walmart

The FAA charged the Task Force with the following three objectives:

1. Develop and recommend minimum requirements for UAS that would need to be registered.

● Factors to consider include, but are not limited to: technical capabilities and 

operational capabilities such as size, weight, speed, payload, equipage, and other 

factors such as age of operator. 

2. Develop and recommend registration processes.

● Factors to consider include, but are not limited to: electronic means for 

registration, data retention and storage, fee collection, and information required 

to be submitted for registration.
November 21, 2015 Page 3

3. Develop and recommend methods for proving registration and marking.

● Factors to consider include, but are not limited to: how certificates will be issued 

and how a UAS will be able to be identified with the registered owner.

To support the FAA in establishing a unique small UAS (sUAS) registration process, the Task Force 

members participated in preliminary interviews with the FAA between October 22, 2015 and 

October 30, 2015. To facilitate initial discussions, the Task Force was asked to consider the 

following questions:

1. What methods are available for identifying individual products? Does every UAS sold have 

an individual serial number? Is there another method for identifying individual products sold 

without serial numbers or those built from kits?

2. At what point should registration occur (e.g., point-of-sale (POS) or prior to operation)? 

How should transfers of ownership be addressed in registration?

3. If registration occurs at POS, who should be responsible for submission of the data? What 

burdens would be placed on vendor of UAS if DOT required registration to occur at POS? 

What are the advantages of a point-of-sale approach relative to a prior-to-operation 

approach?

4. Consistent with past practice of discretion, should certain UAS be excluded from registration 

based on performance capabilities or other characteristics that could be associated with 

safety risk, such as weight, speed, altitude operating limitations, duration of flight? 

5. How should a registration process be designed to minimize burdens and best protect 

innovation and encourage growth in the UAS industry?

6. Should the registration be electronic or web-based? Are there existing tools that could 

support an electronic registration process?

7. What type of information should be collected during the registration process to positively 

identify the aircraft owner and aircraft?

8. How should the registration data be stored? Who should have access to the registration data? 

How should the data be used? 

9. Will the data be used primarily to hold registrants accountable for accidents or intentional 

misuse? If so, how will this affect registration by consumers? How will registration be 

enforced?

10. To encourage awareness, should the registration process include an acknowledgment of UAS 

safe operating rules?

11. Should a registration fee be collected and if so, how will the registration fee be collected if 

registration occurs POS? Are there payment services that can be leveraged to assist (e.g., 

PayPal)?

12. How will a registration program affect sales of drones, future innovation, and the positive 

economic impacts of the use of drones?

13. The effort to register all aircraft will have costs to government, consumers, industry, and 

registrants. What are these costs, and are these costs clearly outweighed by the benefits to 

aviation safety?

14. Are there additional means to encourage accountability and safe responsible use of UAS?

The Task Force met to discuss the three main objectives over a three-day period between 

November 3, 2015 and November 5, 2015. Administrator Huerta opened the meeting by asking the 

Task Force to keep in mind the need to ensure a strong culture of safety and responsibility in the 

National Airspace System (NAS). The Administrator also highlighted the desire to make registration 
November 21, 2015 Page 4

as easy as possible for sUAS owners and operators, and to relieve them of burdens associated with 

registration of larger manned aircraft. The FAA briefed participants on the current statutory 

requirements and international obligations for aircraft registration before the group began initial 

discussions on a streamlined registration process and minimum requirements for sUAS that need to 

be registered. The Task Force was also notified that there is an existing FAA contract in place that 

could be leveraged to build a baseline registration system and that their input would help frame the 

parameters for the new system and determine how information could be fed into the system and 

accessed. The Task Force was then presented with a summary of the most current public comments 

submitted in response to the Clarification and RFI. 

Following the introductory briefing, the industry chair led an open discussion for the group to raise 

questions and share thoughts regarding the three main objectives of the Task Force. This discussion 

focused on the goals of the registration process: to educate users on the safe operating rules for 

sUAS and the need to link the aircraft to the owner or operator in the event of an incident or 

accident. The Task Force recognized a need to connect responsibility for the aircraft to the owner 

of the aircraft. The Task Force also agreed that any recommendations need to be rooted in 

concerns for safety and applicable safety data, where available. The afternoon session of the first 

day focused on the first objective of the task force: whether certain sUAS should be excluded from 

registration. The Task Force acknowledged that this should be a risk-based decision. There was 

much discussion about the low level of risk that we accept today for manned aircraft operations and 

what is the appropriate level of risk to accept for unmanned aircraft operations, based on the data 

that is available, and based on distinctions made in other jurisdictions that have identified a lowestweight cutoff for sUAS regulation.

On day two of the meeting, the co-chairs led with a brief recap of the Day 1 discussion regarding 

which sUAS should be required to be registered and outlined the goals for the Day 2 discussion, 

which focused on developing and recommending a registration process and means for proving 

registration methods and marking sUAS. For this session, the Task Force created breakout groups 

to help facilitate discussion amongst the members. The third day of the meeting began with a 

review of the previous days’ work, followed by a facilitated discussion to develop consensus 

recommendations on the three objectives.

From these discussions, the Task Force developed high-level recommendations for sUAS 

registration requirements and processes that address the questions posed by FAA. The 

recommendations in this report reflect the final statements of the Task Force.

3. EXECUTIVE SUMMARY 

The Task Force agreed that it was outside the scope of the Task Force’s objectives to debate or 

discuss the DOT Secretary’s decision to require registration of sUAS or the legal authority for the 

implementation of such a mandate. Once that understanding was reached, the Task Force 

undertook the task to develop and recommend a registration process that ensures accountability for

users of the NAS and encourages a maximum level of compliance with the registration requirement, 

while not unduly burdening the nascent UAS industry and its enthusiastic owners and users of all 

ages. The Task Force also sought to define a category of sUAS that should be excluded from the 

registration requirement because they do not present a significant level of risk to the non-flying 

public and to users of the NAS. 
November 21, 2015 Page 5

The Task Force recommendations for the registration process are summarized as follows: 

1) Fill out an electronic registration form through the web or through an application (app).

2) Immediately receive an electronic certificate of registration and a personal universal 

registration number for use on all sUAS owned by that person.

3) Mark the registration number (or registered serial number) on all applicable sUAS prior to 

their operation in the NAS.

While the brief summary above leaves out some details, like the option of serial number registration, 

it demonstrates the simplicity of the solution recommended by the Task Force members. This

simplicity is what allowed for a consensus recommendation to develop. Any registration steps more 

burdensome than these three simple steps may jeopardize the likelihood of widespread adoption and 

would undermine the overall registration philosophy that enabled the Task Force to come to 

consensus. 

Although there were often very divergent views, and some decisions were not unanimous, the Task 

Force reached general agreement on their recommendations to the FAA with the frequent use of 

votes. Additionally, the general consensus view of the Task Force is that the recommendations on 

the three objectives are to be presented together as a unified recommendation, with each of the 

individual recommendations dependent upon elements in the others. Compromises in positions 

were made whenever possible to obtain a general consensus, and changes to any of the components 

could further dilute support among the Task Force members and their constituencies for the final 

recommendations. It should be noted that the Task Force acknowledged that the timeframe 

provided for deliberations did not allow for in-depth analysis of all the factors involved in instituting 

a federal requirement for registering sUAS, nor did it allow for an assessment of the impact of such 

a mandate on the recreational/hobby community.

Based primarily upon an assessment of available safety studies and risk probability calculations, and 

notwithstanding determinations in other countries with differing weight thresholds, the Task Force 

recommended an exclusion from the registration requirement for any small unmanned aircraft 

weighing a total of 250 grams (g) or less. The 250 grams or less exclusion was based on a maximum 

weight that was defined as the maximum weight possible including the aircraft, payload, and any 

other associated weight. In manned aircraft terms, it is the “maximum takeoff weight.” 

The Task Force also recommends a free, owner-based registration system with a single registration 

number for each registrant. (They also suggested that if the FAA is required by statute to charge, 

that the fee should be $0.001). sUAS owners would be required to register with the FAA, prior to 

operation in the NAS, by entering their name and street address into a web-based or app based 

registration system. The system would be powered by an Application Program Interface (API) that 

would allow multiple app clients to feed registration information into the database, ensuring 

widespread compliance. Provision of email address, telephone number, and serial number of the 

aircraft into the system would be optional. Information on U.S. citizenship or residence status 

would not be required, but there would be a minimum age requirement of 13 years to register. At 

the time of registration, each registrant would receive a certificate of registration that contains a 

unique universal registration number (and the aircraft serial number if provided) that can be used on 

all sUAS owned by the individual. This registration number would be required to be directly marked 

on or affixed to each sUAS the registrant owns, prior to outdoor operation. This marking would 
November 21, 2015 Page 6

need to be maintained in a readable and legible condition, and be readily accessible upon visual 

inspection. If a registrant chose to provide the FAA with the aircraft’s serial number, the registrant 

would not be required to further mark the sUAS with the FAA-issued registration number , as long 

as the serial number meets the requirement of being readable, legible, and readily accessible (without 

the use of tools) upon visual inspection. The Task Force also recommends that the registration 

process contain some sort of education component which could be similar to the existing content in 

the Know Before You Fly campaign.

4. TASK FORCE RECOMMENDATIONS 

4.1 Minimum Requirements for UAS that Would Need to be Registered (i.e., 

exclusion from the registration requirement)

The Task Force accepted as a baseline that the registration requirement will only apply to sUAS (i.e., 

aircraft weighing less than 55 pounds) that are operated outdoors in the NAS. Beyond that baseline, 

however, the FAA asked the Task Force to recommend additional minimum requirements for sUAS 

that would need to be registered. In particular, the agency asked the Task Force to consider factors 

including, but not limited to, technical capabilities and operational capabilities such as size, weight, 

speed, payload, equipage, and other factors such as the age of the operator. 

The safety of the non-flying public and of other users of the NAS was central to the Task Force’s 

determination of what category of sUAS to recommend for exemption from the registration 

requirement. With considerations of safety in mind, the Task Force addressed the possibility of 

recommending an exclusion based on various factors, including: weight (alone and in combination 

with altitude or kinetic energy), mass, speed, kinetic energy, payload, equipage (e.g., camera, GPS), 

and operational capabilities, such as the ability to navigate the airspace, the ability to operate above a 

certain altitude above ground level (AGL), the ability to operate beyond visual line of sight (BVLOS) 

of the operator, the ability to operate autonomously, and flight duration. 

The Task Force ultimately agreed to use a mass-based approach to determine an appropriate 

category of sUAS to recommend for exclusion from the registration requirement. This was based 

upon the probability of a catastrophic event occurring (i.e., death or serious injury) due to a collision 

between an sUAS and a person on the ground. Because of the lack of data on UAS-aircraft 

collisions, engine ingestion, propeller, and rotor impacts by UAS, the probability of a catastrophic 

event occurring due to those events was not part of the consideration. This approach best satisfied 

the Task Force’s concerns about safety and provided a minimum weight threshold for registration 

that is easy to understand and apply and would therefore encourage compliance. The formula 

considered was identified to the group as a standard aviation risk assessment formula used in 

consideration of manned aircraft safety. 
November 21, 2015 Page 7

The free fall ground level velocity (V) of an object from 500 feet (ft.) (~152 meters (m)) above 

ground in a vacuum is determined by contemplating potential and kinetic energy exchange, thus:

V = �2 ∗ g ∗ h = (2gh)

1

2 = �2 ∗ 9.81

m

s2 ∗ 152m �

1

2

V = 54.6

m

s (~122

mm

hr

)

The terminal velocity, however, of such an aircraft in free fall through air will be lower than this 

value and will vary, dependent on effective projected area and drag. For ease of administration and 

sUAS owner understanding, the task force strongly advised a mass-based approach for determining 

the generally safe threshold below which an sUAS would not need to be registered. In order to 

define such a mass threshold, several assumptions need to be made, thus:

Drag coefficient: Cd = 0.3

Projected area: S = 0.1m ∗ 0.2m = 0.02m2

A DDD DD a S L L L: ρ = 1.225

k

m3

The terminal velocity in free vertical fall through air at sea level is then the steady state condition 

where:

D FF F (m ∗ g) FD = 1

2 ρ CdV2

D FF F �m ∗ 9.81

m

s2� = FD = 1

2 ∗ �1.225

k

m3� ∗ (0.02m2) ∗ (0.3) ∗ V2

The kinetic energy (KE) expressed in Joules of an object of mass (M), moving at velocity (V) is 

determined by the following formula:

KK = 1

2 m 2
November 21, 2015 Page 8

Referencing information from a 2012 MITRE report (which further references a United Kingdom 

Ministry of Defense 2010 study), an object with a kinetic energy level of 80 Joules (or approximately 

59 foot-pounds) has a 30% probability of being lethal when striking a person in the head.1

Solving for mass and velocity, this equates to an object weighing 250 grams traveling at a terminal 

velocity of 25 meters/second or approximately 57 miles per hour.

Using these results, it is reasonable to estimate the probability of such a lethal event occurring per 

sUAS flight hour, by the following approach:

Peeeee = MMM −1 ∗ �

SUUU

Sh

� ∗ ( ∗

Sh

Ss

) ∗ E ∗ Pl

SUAS= Area of UAS,

Sh = Area of human,

Ss = Area of surface,

n = Number of humans

Peeeee =

SUUU ∗ � Ss

� ∗ E ∗ Pl

MMM

Where:

PPPPPP PP D D D = Ss

(For these purposes, we have used population density numbers reflecting a relatively densely packed 

urban environment. We have done so despite the fact that sUAS operations are prohibited over 

unprotected persons not connected to the operation). 

MTBF = mean time between failures (of the sUAS in hours).

Exposed fraction (EF) = fraction of people outdoors and directly exposed to the 

falling object at any one time.

 1 “A New Paradigm for Small UAS,” Andrew Lacher and David Maroney, available at

https://www.mitre.org/sites/default/files/pdf/12_2840.pdf ;“Lethality Criteria for Debris Generated From Accidental 

Explosions,” Jon Henderson, available at http://www.dtic.mil/cgi-bin/GetTRDoc?AD=ADA532158.
November 21, 2015 Page 9

If we assume the following values:

MTBF = 100 hours

PPPP D D D = 10,000 mm2 ~ 0.0039

m2

SUU = 0.1 ∗ 0.2 = 0.02 m2 N : a aa

= E FF F = 0.2

P = P o L ha = 0.3

Then, the likelihood (or probability, P) of a catastrophic event can be estimated as:

Peeeee = 0.02 ∗ 0.0039 ∗ 0.2 ∗ 0.3

100

Pevent = 4.7x10-8, or less than 1 ground fatality for every 20,000,000 flight hours of an sUAS

Considering that the acceptable risk levels for commercial air transport are on the order of 1x10-9

, 

and general aviation actual risk levels are on the order of 5x10-5

, this level of risk at 4.7x10-8 seems to 

present a reasonably acceptable risk level to the Task Force for sUAS that meet the aforementioned 

assumptions. Some members of the task force questioned why sUAS risk level would ever be 

required to exceed the current general aviation risk level of 5x10-5

.

Based on that calculation, the Task Force recommends that the FAA exempt from the registration 

requirement any unmanned aircraft weighing 250 grams or less. The 250 grams or less exclusion 

was based on a maximum weight that was defined as the maximum weight possible including the 

aircraft, payload, and any other associated weight. In manned aircraft terms, it is the “maximum 

takeoff weight.” 

It is important to note, however, that this recommendation is interdependent on the Task Force’s 

other recommendations on the registration process. The Task Force spent considerable time 

discussing and deliberating about what the appropriate weight threshold should be. While general 

agreement was ultimately reached on the 250 gram weight, there were Task Force members who 

believed it was too conservative, as the weight could negatively impact the credibility of the sUAS 

registration program and thus lessen compliance levels because it would require registration of some 

sUAS generally considered to be in the “toy” category. Others took the opposite view that there 

should be no registration exemption for UAS of any size. There was also concern that other 

countries are considering or have already established regulatory cutoffs at much higher weights of 1 

kilogram or 2 kilograms. Some also felt there was insufficient time afforded to fully evaluate the 

calculations and assumptions made that resulted in the 250 gram cutoff weight, particularly because 

the typical approved operation of small UAS, unlike the typical operation of manned aircraft, does 

not involve flight over unprotected people. 
November 21, 2015 Page 10

Certain members of the Task Force asked that it be noted that this is a nascent industry with very 

little experiential data to inform the assumptions and that periodic review of the data may be 

warranted. Certain task force members noted that the FAA’s 25 years of bird strike data show that 

fatal aircraft accidents caused by small and medium birds (weighing four pounds on average) are 

extremely rare despite the presence of billions of birds within the low altitudes where small UAS 

typically fly, and urged the FAA to select a weight that posed a similar safety risk. Task force 

members representing manned aircraft organizations expressed specific concerns that data on UASaircraft collisions, engine ingestion, propeller, and rotor impacts by UAS was not available when 

determining the weight threshold. All members urged the FAA to expedite its work currently 

underway in this area.

Consensus was reached for a registration system that provides registrants with a single registration 

number to be used on every aircraft they own and, where applicable, permits registrants to use the 

manufacturer’s permanently affixed serial number to satisfy the marking requirement. See

discussions below in sections 4.2 and 4.3.2, respectively. It should also be noted that the 250 gram 

weight threshold was agreed to for registration purposes only and was not a validation of the 

underlying assumptions for any purpose other than the registration requirement. It was agreed by all 

members that this threshold, arrived at under the circumstances described, should not be used by 

the FAA to establish operational restrictions or categories in any future rulemaking unless safety 

concerns require the FAA to take appropriate action. 

4.2 The Registration Process 

The Task Force approached its discussions of the registration process with two goals in mind – to 

ensure accountability by creating a traceable link between aircraft and owner, and to encourage the 

maximum levels of regulatory compliance by making the registration process as simple as possible. 

To achieve the twin goals of accountability and compliance, the Task Force recommends the FAA 

institute a simple, owner-based registration system in which the FAA issues a single registration 

number to each registrant which covers all sUAS owned by that registrant. The Task Force also 

adopted recommendations related to: (1) the information to be collected during the registration 

process; (2) the point at which registration should occur; (3) whether the registration process should 

be electronic or web-based; (4) whether a registration fee should be imposed; and (5) whether there 

should be a minimum age limit for registration. Because the Task Force is recommending an 

owner-based registration system, questions concerning how to deal with transfers of ownership are 

easily addressed by the registrants’ marking methods. 

4.2.1 What information should be collected? 

Registrant Contact Information

To ensure accountability, the Task Force recommends the FAA require all registrants to provide 

their name and street address, with the option to provide an email address or telephone number. 

While the Task Force recognizes that a registrant’s email address and telephone number may be 

useful for the FAA to disseminate safety-related information to sUAS owners, the Task Force

nevertheless believes disclosure of such information should be optional. With the exception of 

information released to authorized law enforcement agencies and state transportation and aviation 

offices, the Task Force urges the FAA to prevent the release of any personal information that the 
November 21, 2015 Page 11

agency is not specifically required by law to disclose. Because this new requirement will impact 

unmanned aircraft owners who do not have the means to protect their identities and addresses 

behind corporate structures (as some manned aircraft owners currently do), it is important for the 

FAA to take all possible steps to shield the information of privately owned aircraft from 

unauthorized disclosure, including issuing an advance statement that the information collected will 

be considered to be exempt from disclosure under FOIA.

Aircraft Information

Because the Task Force is recommending the FAA institute an owner-based registration system, it 

believes registrants should not be required to provide any aircraft information, such as serial number 

or make and model of the sUAS, during the registration process. Registrants should, however, have 

the option to provide the aircraft’s manufacturer serial number, so that the serial number can then 

be used to satisfy the marking requirement (as discussed below, in section 4.3.2). Additionally, to 

ensure the broadest possible participation, this registration system should make no distinction for, or 

impose additional requirements upon, sUAS manufactured or purchased outside the United States.

Citizenship Status

With the goals of encouraging the growth of the sUAS industry and compliance with the registration 

requirement in mind, the Task Force recommends there be no U.S. citizenship or residency 

requirement for registration eligibility. This requirement, which makes sense with respect to the 

owners of passenger aircraft, does not match the way this technology is used by foreign visitors, 

students and others who are in the United States temporarily. If, however, the FAA does include a 

U.S. citizenship or residency requirement, the Task Force recommends that the Agency use its 

discretion to permit owners not eligible to register to operate in the U.S. by applying for an 

expedited waiver from the registration requirement for a specified, limited period of time (consistent 

with §41703(a)(4)). Eliminating the citizenship requirement would help achieve the goal that sUAS 

owners are known to the FAA for safety purposes.

4.2.2 At what point should registration occur? Should the system be electronic or webbased?

As noted above, 49 U.S.C. § 44101(a) stipulates that a person may only operate an aircraft when it is 

registered with the FAA. As such, the majority of the Task Force believes the FAA cannot require 

registration of sUAS at the point-of-sale. Some members of the Task Force expressed the opinion 

that maximum compliance can best be achieved with point-of-sale registration and those members 

therefore encourage the FAA to include it as one of several options for registration. Several other 

members of the Task Force pointed out that, because the FAA’s authority extends only to operation

of aircraft, point-of-sale registration cannot be mandated. 

 

An important registration attribute that the Task Force members could broadly agree on was that in 

order to promote greater acceptance of the registration requirement, the registration process should 

be as quick and easy as possible. The Task Force encourages the FAA to consider implementing 

additional methods and strategies to maximize compliance with the registration requirement but 

without adding cumbersome steps into the process.
November 21, 2015 Page 12

The Task Force believes the registration process should be web-based, and that the FAA should 

create an online registration system that allows for multiple entry points through an Application 

Program Interface (API). This would allow, for example, an sUAS manufacturer or trade 

organization to develop an app that communicates through an API by which it can register its 

customers or members by submitting registration information directly to the FAA database on their 

behalf. Examples of multiple entry points are web apps, web portals, web browsers, cell phone 

apps, plug-ins, etc.

The registration information required and the certificate of registration received would be the same 

regardless of what point of entry is used into the registration system. The online registration system 

should provide an option for owners to edit and delete their registration information, as well as to 

view and print physical copies of their registration certificates through access to a passwordprotected web-based portal. 

4.2.2.1 Training and education in conjunction with operator registration

Recognizing how important it is that all users of the NAS receive information on safety in the NAS, 

the Task Force recommends the registration process contain some sort of education component and 

acknowledgment, with controls in place such that the registration process would be incomplete until 

the registrant has acknowledged receipt of this information. The information provided could be 

similar to the existing content in the Know Before You Fly program.

4.2.3 Should a registration fee be imposed?

To encourage a high level of compliance with the registration requirement, the Task Force believes 

the FAA should not impose a registration fee. In the event that the FAA must charge a fee for legal 

reasons, the Task Force suggested a de minimis fee of 1/10th of one cent ($0.001).

4.2.4 Should there be an age limit for registration?

All sUAS flown outdoors and exceeding 250g maximum flight weight must be registered. However, 

consistent with the Children’s Online Privacy Protection Act, 15 U.S.C. §§ 6501-6505, the Task 

Force recommends a requirement that individuals be 13 years or older to register an sUAS. 

Although acknowledging that some sUAS may be operated by persons younger than 13, the Task 

Force would thus recommend that registered sUAS owners be 13 years of age or older, and that 

children under that age operate sUAS under a parent or guardian’s registration. 

4.3 Methods for Proving Registration and Marking

The FAA charged the Task Force with developing and recommending methods for proving 

registration and marking. Factors to consider included, but were not limited to, how registration 

certificates will be issued and how an sUAS will be able to be identified with the registered owner 

(i.e., a marking requirement).
November 21, 2015 Page 13

4.3.1 Certificate of Registration 

The Task Force recommends that the FAA issue a certificate of registration to each registrant at the 

time of registration. The certificate should be issued electronically (perhaps in PDF format), unless 

the registrant specifically requests a paper copy. The Task Force recommends that a web or app 

based system provide registered users with the ability to view and print physical copies of their 

registration certificates through access to a password-protected portal. Should the FAA provide for 

generation and mailing of physical certificates, where requested, the Task Force did not object to a 

reasonable cost-based fee being charged by the FAA for such a service. The certificate should 

contain the registrant’s name, the registrant’s FAA-issued registration number, and the address of 

the FAA registration website that is accessible by law enforcement or other authorities for the 

purposes of confirming registration status. For registrants who elect to provide the serial number(s) 

of their aircraft, the certificate should also contain those serial number(s). The Task Force 

encourages the FAA to include safety and regulatory information with the certificate of registration. 

Any time a registered sUAS is in operation, the operator of that sUAS should be prepared to 

produce a legible copy of the certificate of registration for inspection, in either electronic or printed 

form. 

4.3.2 Marking Requirement

Because the main goal of registration is to create a connection between the aircraft and its owner,

the Task Force recognizes that it is necessary to mark each registered sUAS with a unique identifier 

that is readily traceable back to its owner. The Task Force recommends two options for complying 

with this marking requirement. Specifically, registrants can either affix their FAA-issued registration 

number to the aircraft or they can rely on a manufacturer’s serial number that is already permanently 

affixed to the aircraft. An sUAS owner may only rely on the manufacturer’s serial number, however, 

if the owner provided that serial number to the FAA during registration and if it appears on the 

owner’s certificate of registration. 

The Task Force further recommends a requirement that the owner and operator ensure that all 

markings be readily accessible and maintained in a condition that is readable and legible upon close 

visual inspection prior to any operation. The Task Force believes that markings enclosed in a 

compartment, such as a battery compartment, should be considered “readily accessible” if they can 

be easily accessed without the use of tools. 

4.3.3 Penalties and Enforcement

The Task Force recommends that the FAA establish a clear and proportionate penalty framework 

for violations. Current registration-related penalties (perhaps exceeding $25,000) were established in 

order to address and deter suspected drug traffickers and tax evaders who failed to register aircraft 

as part of larger nefarious schemes. Any person flying an sUAS, including consumers and juveniles, 

may now find themselves inadvertently in violation of this new system. The Task Force 

recommends that the FAA expressly establish a reasonable and proportionate penalty schedule that 

is distinct from those relating to traditional manned aviation. To the extent the FAA does not feel it 

has authority to alter penalty ranges indicated by statute, the Task Force recommends a change be 

made to Order 2150.3B, FAA Compliance and Enforcement Program, to set out the enforcement 

and penalty philosophy that the FAA will pursue, including a schedule of penalties. 
November 21, 2015 Page 14

5. CONCLUSION 

These recommendations were agreed upon in a spirit of cooperation and compromise. Many Task 

Force members approached the proceeding with strong convictions, derived both from their 

personal experience and from knowledgeable input from their organizations and users. In such a 

time-limited tasking, many of these convictions were necessarily set aside in order to reach a general 

consensus among the group and to provide the FAA with a workable solution that met its safety and 

policy requirements while not unduly burdening the nascent UAS industry and its enthusiastic 

owners and users of all ages. 

Each of the recommendations for all the elements of this report required some level of compromise 

and mutual cooperation from various members of the Task Force. Therefore, the Task Force 

respectfully requests that the list of recommendations contained herein be viewed by the FAA as a 

holistic package, with elements of each recommendation closely interconnected with the others. 

Should the FAA find it necessary to significantly alter any element of its adopted registration system 

in a way that would contradict the findings and recommendations in this report, the members of the 

Task Force would respectfully request that the FAA reconvene the Task Force as soon as 

practicable. This would help to ensure complete industry and UAS community input into the 

registration system that is ultimately adopted by the agency. 
November 21, 2015 Page A- 1

6. APPENDIX Summary of Task Force Recommendations 

UAS Registration Task Force Aviation Rulemaking Committee 

Recommendations Summary

What category of UAS is covered 

by the registration requirement?

UAS that weigh under 55 pounds and above 250 grams 

maximum takeoff weight, and are operated outdoors in the 

NAS. 

Do owners need to register each 

individual UAS they own?

No. The registration system is owner-based, so each 

registrant will have a single registration number that covers 

any and all UAS that the registrant owns.

Is registration required at point-ofsale?No. Registration is mandatory prior to operation of a UAS 

in the NAS. 

What information is required for 

the registration process?

Name and street address of the registrant are required. 

Mailing address, email address, telephone number, and 

serial number of the aircraft are optional.

Is there a citizenship requirement? No.

Is there a minimum age 

requirement?

Yes. Persons must be 13 years of age to register. 

Is there a registration fee? No.

Is the registration system electronic 

or web-based?

The system for entry of information into the database is 

web-based and also allows for multiple entry points, 

powered by an API that will enable custom apps to provide 

registry information to the database and receive registration 

numbers and certificates back from the database. 

Registrants can also modify their information through the 

web or apps. 

How does a UAS owner prove 

registration?

A certificate of registration will be sent to the registrant at 

the time of registration. The certificate will be sent 

electronically, unless a paper copy is requested, or unless 

the traditional aircraft registration process is utilized. The 

registration certificate will contain the registrant’s name, 

FAA-issued registration number, and the FAA registration 

website that can be used by authorized users to confirm 

registration information. For registrants who elect to 

provide the serial number(s) of their aircraft to the FAA, 

the certificate will also contain those serial number(s). Any 

time a registered UAS is in operation, the operator of that 

UAS should be prepared to produce the certificate of 

registration for inspection. 
November 21, 2015 Page A- 2

Does the registration number have 

to be affixed to the aircraft?

Yes, unless the registrant chooses to provide the FAA with 

the aircraft’s serial number. Whether the owner chooses to 

rely on the serial number or affix the FAA-issued 

registration number to the aircraft, the marking must be 

readily accessible and maintained in a condition that is 

readable and legible upon close visual inspection. Markings 

enclosed in a compartment, such as a battery compartment, 

will be considered “readily accessible” if they can be 

accessed without the use of tools.