1. Regulatory Impact Analysis for Enabling Regulations: The Federal Aviation Administration's Small UAS Rule
Deborah Vaughn Aiken, Phd
Director of Regulatory Analysis
U.S. Department of Transportation

2. Background: What’s a Small UAS?
UAS = Unmanned Aircraft System (“drone”)
Small: <55 pounds
UAS are aircraft and are subject to Federal Aviation Administration (FAA) regulations

3. Highlights of the Small UAS Rule (Part 107)
First in a series of envisioned rules for routine operation of small UAS
Effective August 2016
Requires UAS operators to obtain a Remote Pilot Certificate
UAS operations must occur in pilot’s visual line-of-sight, in daylight conditions, and not directly over people
Flights at 400 feet or below in uncontrolled airspace; other airspace requires authorization
UAS must weigh less than 55 lbs. and be registered
Includes a waiver process to allow for deviations from many of the rule’s operational restrictions

4. Baseline: Prior to Part 107 Rule
Non-recreational, non-hobby, or commercial use of small UAS generally were not allowed (they were illegal)
However, the Secretary of Transportation has authority to grant exemptions from the law on a case-by-case basis, for certain UAS commercial operations
Through exemptions from the existing law, some operators had been able to enter the small UAS commercial market

5. Enabling Regulation
Regulatory action that expands production or consumption opportunities
Inherently deregulatory: imposes (net) negative costs
Relaxes existing standards and allows new industries to unfold
Part 107 small UAS rule was considered enabling since it reduced the cost of entry into the commercial market for UAS services
Formal analysis of economic impacts was required for the rulemaking

6. Part 107 Regulatory Impact Analysis
Existing exemption holders
Experience reduced costs, since the complying with rule was simpler and less costly than the exemption renewal process
Benefits are simply the reduction in costs
New Part 107 pilots
Rule enabled individuals to obtain a UAS pilot certificate without first obtaining a sport pilot license
Considerable reduction in the cost to entry, which will attract new pilots to the industry because the rule lowered entry costs
Benefits are expanded business opportunities
Some modest costs for obtaining pilot certificate

7. Forecasting the Number of “New Part 107 Pilots”: The Difficult Problem
We already knew the universe of 333 exemption owners, so calculating benefits for this market segment was straightforward
Projecting the number of new pilots who would enter due to the relaxation of the requirements was more challenging
Based on a marketing study that examined potential opportunities for UAS applications
Used a wide range: For example, the estimated range for 2017 was between 37,400 and 937,500 new pilots

8. Benefits of the Part 107 Rule