RILA Comments on Registration and Marking Requirements

The Retail Industry Leaders Association (RILA) appreciates the opportunity to respond to the Federal Aviation Administration’s (FAA’s or Agency’s) Interim Final Rulemaking (IFR), “Registration and Marking Requirements for Small Unmanned Aircraft.” 80 Fed. Reg. 78594 (Dec. 16, 2015). Prior to the issuance of this IFR, RILA responded to the Department of Transportation’s and the FAA’s solicitation of public comment regarding the design and implementation of a new registration process for unmanned aircraft systems (UAS) operated by recreational and hobbyist users.1 While the IRF incorporated some of the recommendations RILA put forth within our previous comments, RILA believes a number of issues still need to be considered and addressed by the Agency prior to issuance of the Final Rule.