The FAA needs to strengthen its proposed equipment, maximum altitude and other operational requirements for small unmanned aerial systems (UAS) to ensure their safe integration into the National Airspace System, according to the General Aviation Manufacturers Association. In comments on the FAA’s proposed small UAS rule, GAMA expresses concern about “several key gaps in the FAA's proposal for how to start the broader integration of UAS.”

These include consideration of a proper buffer between UAS and low-flying aircraft such as crop dusters, light sport aircraft and helicopters. “GAMA questions whether the FAA has properly considered the expected interaction between small UAS and rotorcraft, as well as other low-flying aircraft such as agricultural aircraft,” the association said, suggesting a maximum altitude of 400 feet, the same limitation for model aircraft. GAMA also faults the proposal for remaining silent on how to determine the aircraft's altitude. “Does the FAA envision the operation ‘eyeball’ an altitude reference…or does the FAA assume the unmanned aircraft will be equipped with an altimeter?” 

The association further suggests that the agency require the grounding of UAS in the presence of other aircraft or around activities such as car accidents. GAMA notes that the proposed rule does not include equipment mandates, but suggests that since UAS are referred to as “aircraft” they appear to fall under equipment requirements. “The existing rules are sufficiently clear: small UAS aircraft must meet both the transponder and ADS-B equipage requirements to operate in specified airspace,” the association notes.