Proposed Solutions for the FAA: • Get Congress to pass an amendment to Section 336 so the regulations will not be in violation of it. • Go the notice and comment route with the regulations. Don’t skip this because it is inconvenient. • Publish a document that has everything a drone pilot needs to know in ONE place. There are multiple things being said in multiple places. Certain parts of the regulations apply and other parts do not. It needs to be listed in one place if individuals are going to be educated; otherwise, it is far easier to just fly than try and figure out what is actually required of you. See my blog post where I discuss further. I had to actually create a chart in my drone book, Drones: Their Many Civilian Uses and the U.S. Laws Surrounding Them , of all the do’s and do not’s because they are scattered all over. • Go through the drone reports and do your best to “clean up” the data. The data is lacking and because the whole flying near airports misconception has not been full clarified, the data is over inflated and inaccurate. Seek to implement quality controls on the data gathering and properly classify and represent it. • Allow flight instructors to start commercially flight instructing under Section 333’s so as to allow these highly skilled individuals to come in and educate the new drone pilots. This will go a long way on education as well as changing the culture from being one of “fun” to one of being “safe.” • Reach out to highly-viewed social media celebrities to collaborate with in educating the community. (i.e. That Drone Show, Roswell Flight Test Crew, Drone U) Why Am I Proposing These? My fear is this rule will “delegitimize” the FAA and DOT in the eyes of many drone flyers because instead of the FAA and DOT being seen as the authority, they will be seen as two government agencies not following what Congress told them to do in the APA and not do in Section 336. Final Thoughts: How will this get challenged? The group of people primarily being targeted are the model aircraft guys, mostly males ages 16-40, working full time, that are disorganized, and would most likely rather just chance getting caught than comply. There is also the AMA members which tend to be very law abiding but they are the minority. The Section 333 guys are not going to fight but love it because it makes their lives so much easier than the Part 47 process. The only 2 scenarios I see where someone would step in to challenge this rule would be: (1) the Academy of Model Aeronautics on behalf of its members or (2) someone receiving an enforcement action or criminal prosecution and is capitalized well enough to pay an attorney to fight this as opposed to settling for a lower amount than prosecution. Hope this helps guys. Fly safe. J Jonathan Rupprecht