Southern California Rotorcraft Association

UAS: Notice of Proposed Rulemaking (NPRM)

Dear PHPA Pilots and Helicopter Operators:

Please note that the deadline for comments for the Notice of Proposed Rulemaking (“NPRM”) for Unmanned Aircraft Systems (“UAS” – the generic or plural of Unmanned Aerial Vehicle or “UAV”), otherwise colloquially referred to as “drones”, is this coming Friday, April 24th.

Small UAS Notice of Proposed Rulemaking (NPRM) (FAA)

As perhaps you are aware, there are at least three matters that are of significant importance to the helicopter industry with the advent of relatively inexpensive UAS.

First, and by far the most significant issue is simply SAFETY ~ given size, altitude, general lack of airspace experience of most UAS operators or at least operators’ newness to airspace rules and considerations, all of which is information that you as local certificated pilots and helicopter operators know like the back of your hand. These devices are hard to see and generally fly at altitudes that may overlap with the altitudes we fly helicopters.

Of general interest to you are these considerations as this technology spreads:

Second, is that given capacities and costs of these devices, there will be some changes in traditional utilization of helicopters for various duties traditionally done by helicopters. Expect our industry revenue sources to change!

Third, at least during this period of COAs (“Certificates of Authorization” for commercial operation of UAS) there may be opportunities for experienced helicopter operators and pilots to take advantage of the approximately two year period before anticipated rules will take effect in order to develop new services or expand those of operators by adoption of UAS for certain activities.

We respectfully suggest that you consider taking action in one or both of the following two ways:

1. Address in your own words your concerns, suggestions, ideas ~ whatever ~ directly to the FAA in regards to the NPRM and do this in the next few days to meet the Friday, April 24th deadline.

2. Contact us with any of these concerns, suggestions, or ideas that you feel PHPA should or might wish to incorporate in a communication from the PHPA Board officially to the FAA on any or all of these matters. You can do this by copying us on whatever you send to the FAA if you wish, by sending us your suggestions whether or not you write the FAA, or by letting us know by phone message at the following number 323-929-PHPA (7472). If by phone, please leave your name and a return phone number. If by phone or by email, (please send email to please DO the call or send the email to us by Thursday morning, April 23rd, in order to give your Board time to consider pulling these thoughts together in a position statement to the FAA, should we determine to take a position as an organization, which, of course, we will share with you if we do.

RELATED LINK: AOPA asks FAA to close gaps in UAS rule (AOPA)