Proposal for UAS/sUAS Phased Licensing/Registration Process

1. Provision for Initial Restricted User Registration designated by class. (See below)

2. Restricted Registration Permit would state that privacy laws and other local restrictions may 

apply.

3. Manufacturers would be required, by a set date, to send notification of new FAA Registration 

requirements, online registration URL and Operation 

4. Safety Practices form to all (known) previous and future purchasers.

The Process:

 FAA provides (ASAP) online registration process. Initial term for registrations restricted to 1 

year allowing FAA to phase in increased requirements. Registered operator may operate 

under specified class restrictions. Commercial operations under restricted registration are to 

be allowed only until 1 July 2015. After 1 July 2015 registered operator must pass class 

requirements to have restrictions removed (registration issued in online-generated PDF form 

with initial -R removed.) Full implementation of rules to be effective 01 July 2015.(?)

 Manufacturers must provide specifications for class acceptance determination by FAA.

 FAA creates initial rule proposals for input and approval process.

 Adopted rules put into effect 01 July 2015 (?)

****(By providing simple registration and then requiring registration through implementation of new 

rules, the FAA is thus provided with the means of regulation. Evidence of infractions of safety 

procedures, reported to or brought to the attention of the FAA through the regulating process, could 

then result in temporary suspension and/or revocation of registration after investigation and 

determination.

OPERATOR REGISTRATION NUMBERING SYSTEM:

UE - 000-000-000-000 - R (Example) 

[Unmanned Vehicle] [Classification] - [12-digit-registration-number] - [Restricted/Registration only]

CLASSIFICATION DESIGNATION STRUCTURE:
-O- Observer (-R restricted or certified)

Registered Observer: Must read and sign safety rules manual (printed or online) (Check box appears at 

end of online text scroll and at end of printed/signed version)

Certified Observer Rating requires Basic Safety(**) written test related to observation function 

(avoiding obstacles and hazards, watching for aircraft, etc. - (**See below)

- R- Restricted/Registered Operator (Temporary up to 1 year)

Restricted operational authority, including commercial uses, for LIMITED PERIOD subject to FUTURE 

requirements for certification and/or licensing (see below), Registration and signature acknowledging 

conditions of restriction, limited to 150 ft and below, Visual Line Of Sight (VLOS) only, no night flying 

(between local sunset and sunrise), observer (see -O- Observer below) and flight log required, 

observation of restricted spaces indicated on sectional charts for restricted space, and such other 

restrictions as deemed necessary by the FAA. Commercial AND hobby use allowed. This function would 

create a database of SUAS owners and provide a basis for communicating future rulings and 

requirements. Dealers selling UAVs should be requested to provide registration forms to future and 

all previous purchasers of UAV/UAS. Could be restricted by weight/class.

Operating Classes (E and above) may be certified(*) by a licensed pilot (Private or Commercial) or 

Certified Qualifier at recognized AMA or other R/C club facility. ("Recognized Club" means 10 or more 

members, affiliation with national group providing facility insurance coverage). 

EXCEPTION: Registration/certification NOT required for operations under 150 ft AGL at designated AMA 

or other R/C fields or functions where AMA member or other insurance coverage is provided. (This 

allows continued unrestricted hobby use under safety provisions of designated flying sites. "Home" 

hobby use under 50 ft AGL might also be allowed.)

 

-E- Experimental/Photographic (sUAS)

Under 5 lbs, VLOS only, operations under 400 ft AGL, no spectators within 50 ft. Registered Observer 

recommended. Airframe approval , logging. (No Autopilot or Flight Control at this level) Fixed wing and 

multi-copter. Must maintain current flight log. On-board digital logging is suggested. Operator must 

have current registration/certification available for inspection while flying.

Requirements:

Proof of Insurance (AMA/RCAPA or other). Approved airframe (manufacturer/model) or process for 

requirements and approval review of non-manufactured device. NO OPERATION ALLOWED OVER 400 ft 

or within restricted areas as designated on current local Sector Map.
Certification:(*)

Online or administered written Safety Test(**), Level B Proficiency (flight) test. Commercial/Private Pilot 

Rating accepted in lieu of written safety test. 

-D- Motion Picture/Corporate (UAS)

Under 20 lbs, VLOS only, limited to 400 ft AGL unless flight plan filed and approved by local ATC. 

Registered or Certified Observer required (subject to insurance carrier requirements), no spectators 

within 25 ft. Fixed wing and multi copter s. Fixed wing and multi-copter. Certified Observer required. 

Must maintain current flight log. On-board logging is recommended. NO OPERATION within restricted 

areas as designated on current local Sector Map. Operator must have current registration/certification 

available for inspection while flying.

Requirements:

Proof of Insurance. Approved airframe (manufacturer/model) or process for requirements and approval 

review of non-manufactured device, 

Certification:(*)

Online or administered written Safety Test(**), Level B Proficiency (flight) test Commercial/Private Pilot 

Rating accepted in lieu of written safety test. Autopilot or Flight Control is allowed in this classification.

FUTURE DATE REQUIREMENT:

Collision Avoidance System or equivalent (LIDAR?) and/or ADS-B and notice to local ATC for use over 400 

ft)

-C- Agricultural/Industrial (UAS)

Under 25 lbs, FPV supervision, limited to 400 ft above terrain (AGL) without Flight Plan or ATC 

Notification. Registered Observer required. Must maintain flight log., no spectators within 25 ft. 

(Includes utility, power line, pipeline and oil well monitoring operations) Fixed wing and multi-copter 

UAV. Certified Observer or radar tracking required. ATC notification or flight plan filing may be required 

for flights over 400ft or beyond VLOS range. Fixed wing and multi-copter. Certified Observer required. 

Must maintain current flight log. Must maintain flight log. Autopilot or Flight Control may allowed in this 

classification under certain specified conditions. NO OPERATION within restricted areas as designated 

on current local Sector Map. Operator must have current registration/certification available for 

inspection while flying.

Requirements:

Proof of Insurance. Approved airframe (manufacturer/model) or process for requirements and approval 
review of non-manufactured device, logging required, on-board logging may be required.

Certification:(*)

Online or administered written Safety Test(**), Level B Proficiency (flight) test Commercial/Private Pilot 

Rating accepted in lieu of written safety test. 

FUTURE DATE REQUIREMENT: Collision Avoidance System or equivalent (LIDAR?) and/or ADS-B and 

notice to local ATC for use over 400 ft)

-B- Public Safety/Utility (UAS)

Under 30 lbs, under 400 ft above (Fire, rescue, public terrain, limited to 400 ft above terrain (AGL) 

without Flight Plan or ATC Notification. Fixed wing and multi-copter. Certified Observer required. Must 

maintain current flight log. On-board logging may be required. NO OPERATION within restricted areas 

as designated on current local Sector Map. Operator must have current registration/certification 

available for inspection while flying.

Requirements:

Proof of Insurance. Approved airframe (manufacturer/model) or process for requirements and approval 

review of non-manufactured device. 

Certification:(*)

Online or administered written Safety Test(**), Level B Proficiency (flight) test Commercial/Private Pilot 

Rating accepted in lieu of written safety test. 

FUTURE DATE REQUIREMENT: Collision Avoidance System or equivalent (LIDAR?) and/or ADS-B and 

notice to local ATC for use over 400 ft)

-A- Heavy Class (UAS)

Over 30 lbs, FPV supervision, under 400 ft above (State, Municipal, Fed.)terrain. Fixed wing and multicopter. Certified Observer required. Must maintain current flight log. On-board logging may be 

required. NO OPERATION within restricted areas as designated on current local Sector Map. Operator 

must have current registration/certification available for inspection while flying.

Requirements:

Proof of Insurance. Approved airframe (manufacturer/model) or process for requirements and approval 

review of non-manufactured device, logging required, on-board logging may be required.
Certification:(*)

Online or administered written Safety Test(**), Level A Proficiency (flight) test Commercial/Private Pilot 

Rating accepted in lieu of written safety test. 

FUTURE REQUIREMENT: Collision Avoidance System or equivalent (LIDAR?) and/or ADS-B and/or 

operting aircraft communications monitor (scanner).

_____________________________________________________

(*)PROFICIENCY FLIGHT TEST could be administered by Designated Certification Instructor, licensed 

private or commercial pilot or flight instructor. Testing agent allowed to charge up to $100 for testing.

(**)SAFETY TEST comprised of questions relating to 400 ft AGL height limits, knowledge of 500 ft limits 

for manned aircraft, restrictions related to airports and heliports, spectator distance, VLOS 

requirement, observer requirement, minimum flight distance from utilities, highways, railroads and 

buildings, ability to recognize designations for restricted space and hazards on sectional charts, and 

other safety rules and other considerations. (Multiple choice format test from FAA contracted testing 

provider).

CERTIFICATION NUMBERING SYSTEM:

UE - 000-000-000-000 - R (Example)

[Unmanned Vehicle] [Classification] - [10 digit registration] - [Restricted/Registered]

Restricted use registration permit could be designated by class as in E/R or B/R and expiration date.

Restricted Registration Permit would state that privacy laws and other local restrictions may apply.

Under this proposal manufacturers and/or resellers of affected R/C devices would be required to send 

notification of FAA Registration requirement, online registration URL and Operation Safety Practices 

form to all (known) previous and future purchasers. It is assumed that most current owners are 

connected to manufacturers and resellers for warranty and marketing purposes, so the necessary 

communication structure already exists.

It is proposed that:

 The FAA provides (immediate) online registration process in place by 1 July 2014. Initial term 

for registrations (restricted) to 1 year. Registered operators may operate under restrictions. 

Commercial operations under restricted registration would be allowed only until 2015. After 
1 July 2015 registered operator must pass applicable class certification requirements to have 

the restriction designation removed (issued registration in PDF form with -R removed.) to 

continue operating after the preliminary registration expiration date. Operator would be 

required to cease operating until passing the required qualifications. Full implementation of 

rules would become effective 1 July, 2015

 Manufacturers provide specifications for class designation determination by FAA (Weight, GPS 

Return To Base and other safety capabilities, etc.).

 FAA creates initial rule proposals (based on above) for input and approval process.

 Adopted rules put into effect 01 July 2015.

 NO DIRECT LICENSING OF DEVICES (No "tail numbers") but designation of specific product 

being operated must appear on Operator Registration/Certification. Online process shall be 

provided for additional UAS devices within current class to be applied to existing Certification. 

Operation of higher class devices would require upgrade to that higher class Operator 

Certification.