Comments in Support of Uber Elevate’s Petition for Exemption to FAA to Enable Advanced UAS Operations

Re: Uber Elevate, Inc. Petition for Exemption (Docket No.: FAA-2019-0346)

To Whom It May Concern:

The U.S. Chamber of Commerce’s Technology Engagement Center (“C_TEC”) appreciates the opportunity to provide comments to the Federal Aviation Administration (“FAA”) in response to the above-referenced proceeding.

We write in support of the underlying petition for exemption, which would help enable the petitioner’s Part 135 commercial Unmanned Aircraft Systems (“UAS”) operations. C_TEC recognizes that the petitioner has been actively engaged in the U.S. Department of Transportation’s Unmanned Aircraft Systems UAS Integration Pilot Program (“IPP”), working collaboratively with partner organizations to help ensure a safe, efficient, and effective regulatory structure for commercial UAS operations in the United States.

The petition for exemption represents a pragmatic approach to enabling unmanned commercial operations in the United States. It prioritizes safety by carefully building off the existing regulatory structure for Part 135 operations, while identifying and seeking exemption only from those provisions that are impractical or impossible to achieve for small UAS. We support this collaborative approach, which built off work with the FAA and partner organizations through the IPP to identify a feasible and appropriate path to commercial drone delivery.

In order to enable more advanced UAS operations, we urge the FAA to strongly consider the petition. Thoughtful approaches like this one will spur innovation in the commercial UAS industry while ensuring the safety of the national airspace.

We appreciate your consideration and strongly encourage your expeditious review and approval of the underlying petition. Please do not hesitate to reach out to me with any questions you might have.