airman certification requirements to allow online testing to satisfy knowledge requirements, and to
work to eliminate in-person visits and background checks.
It should be noted that representatives of ALPA, NAAA, HAI, and PAPA did not agree that online
testing and the elimination of background checks were properly informed or appropriate
recommendations for the ARC. The organizations all strongly maintain the position that an
individual intending to exercise the privileges permitted under proposed part 107, which include
commercial small UAS operations, should fully comply with the necessary training and certification
as currently described in part 107, no matter the size or complexity of the aircraft. Their concerns
were centered on the lack of data submitted during the ARC indicating this UAS category is not a
proven security risk, or that testing will not enhance safety. In addition, data was not provided to the
ARC indicating that security and testing requirements for this category would discourage
compliance. The dissenting groups also stated that training, experience, and evaluation of skills and
knowledge for initial certification and a revalidation of those skills periodically, such as is required
for other airman certificates, should be required for these UAS and that proposals waiving such
requirements were outside of the charter for this ARC.
April 1, 2016
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