My comment to the FAA

I am writing regarding docket number FAA-2015-0150, the proposed regulations on the operation and certification of small unmanned drones. I have taught journalism in a public high school in Maryland for 27 years. I am president of the MarylandDC Scholastic Press Association, hold two national certifications as an educator, and have written a technology column in the Dow Jones News Funds quarterly publication for journalism teachers, Adviser Update, for 19 years. In that role I have been following interest in the use of drones in high schools for several years. STEM classes have begun using drones to teach students about physics, aerodynamics, robotics and other concepts. At my own school, the United States Navy this year donated a quadcopter drone to the advanced engineering class (a Project Lead the Way class). The students assembled the drone from a kit and experimented with the crafts aerodynamic characteristics while operating the drone at an off-campus location. Across the country, science and math educators are finding innovative ways to use micro drones to teach important concepts and to get their students excited about learning. Communications classes and student newspapers, newsmagazines, yearbooks, websites and television broadcasts have begun employing micro UAS for newsgathering. Yearbooks have taken aerial photos of events on their campuses, newspapers and newsmagazines have used drones to photograph sporting events and to explore hard to reach corners of their schools, in-school television broadcasts and websites have used drones to film sporting events, homecoming parades and classes at work both inside and outside of their school buildings. Covering technology in education, I have encountered exciting uses of drones on high school campuses across the country. Educators have been mostly shocked to learn that up to now all of these activities have been illegal under current F.A.A. regulations. Teachers in the STEM and journalism fields have waited anxiously for promised new regulations for drones and micro UAS. Unfortunately, the regulations as presently drafted will disappoint them and will rob their students of the opportunity to use this exciting new teaching tool on campus. Commercially produced micro drones are now available at very reasonable prices and can serve as potent teaching tools in Americas schools. Some accommodation for this use must be included in the new regulations for small unmanned aircraft systems. It seems arbitrary that the minimum age for certification of micro drone operators should be set at 17. The FAA currently allows for piloting of balloons and gliders by students as young as 14, and of private planes by those as young as 16. Why, then, should piloting a micro UAS weighing just a few pounds and constructed of light, easily frangible materials require an operator be 17 years of age? Fourteen, the age at which young people are allowed to begin operating balloons and gliders, seems a much more sensible alternative. Beyond the issue of the age of the operator, an accommodation for the educational use of micro UAS needs to be included in any new regulation. There could be few safer places for students to learn to operate a small unmanned aircraft than on a high school campus under the guidance of a certified educator. The potential educational applications for micro drones in school are myriad, but they will become permanently unavailable to American educators if the regulations are put forward in their current form. The proposed rules for the Operation and Certification of Small Unmanned Aircraft Systems should be amended to allow for the certification of operators of micro unmanned aircraft systems as young as 14 years of age. Most importantly, they should include an educational exemption for the use of micro UAS systems on high school campuses for educational purposes and off campus as part of a school-sponsored educational activity. These additions to the new regulations are both sensible and can be put into practice with no risk to public safety. Sincerely, Gary Clites

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