Applications to Launch or Land an Unmanned Aircraft, Including a “Drone”

Online comments: 104

• Draymond Crawford

  As a commercial/professional UAS operator, I can only view this proposed rule/policy as a creation of unnecessary bureaucracy that only slows down operators ability to fulfill their assigned projects. As a Safety Officer of a City I only see confusion from citizens about the status of who’s drone is flying. I am familiar with the extended use of UAS’s by the FDNY and other first responders. By restricting “take off & landing” (key operational aspects of flying) you essentially are restricting all UAS operations within the city limits of New York City. The FAA has placed several control airspace limitations within the greater New York and New Jersey area to keep the majority of UAS flyers from taking to the skies. By putting these type of restriction or extra required step to gain authorization to conduct UAS operations. This and these type of requirements only hurt businesses and business opportunities to generate commerce within the city.

  Comment added June 8, 2023 6:33pm

• Audley Bullock

  I don’t understand why cities don’t adhere to the same rules that the FAA find suitable. They have these rules in place for a reason and they work. How can I run a small business when I have to apply for operation 30 days in advance? bad enough I have to consider the weather and countless other variables. If an opportunity arises next week I won’t be able to get the job done.

  Comment added June 9, 2023 9:14am

• Fran Lugo

  This proposed addition to already existing drone/UAV laws will no doubt affect small businesses that rely on UAV/drones for advertising purposes. Will this affect so called hobbyist drone operators, who do it for fun, not profit. I do hope you include dvice with citizens who have been droning for years, and have some insight in regards to drone operations in this city, both professional and hobbyists.

  Comment added June 9, 2023 11:04am

• Tyler Tippetts

  As a licensed Part 107 UAS operator I find air space regulation sometimes daunting. More and more different government agencies assert control over air space regulation making impossible for a person to comply with all the regulations made and enforced by multiply entities with sometime conflicting regulations. I believe air space regulations should be left to the Federal Aviation Administration and by doing so leaving one regulatory agency to comply with by both professional and recreational UAS pilots. It is also my further belief that too many regulatory agencies leads to non-compliance by a greater number of licensed and unlicensed UAS operators either for recreation or commercial purposes.

  Comment added June 9, 2023 3:51pm

• Tony Fazio

  The proposed rule is unjust and without warrant. There are established communities of drone pilots all over the world, and a huge number in the United States. While there are always a few that decide to do whatever they please, these folks will also not abide by your rules. The rest of us are friendly and abide by the regulations already set forth by the Federal Government Agency, the FAA. Please reconsider your proposed rule and talk to us, you will find that this is not needed and we can even help educate New York and other municipalities all throughout the US.

  Comment added June 9, 2023 9:26pm

• Phil

  Hi,

  The proposed bill does not take into account recreational use of drone. Recreational use of drone uses would not have insurance policy. This would create an unequal system.

  Phil

  Comment added June 9, 2023 10:18pm

• jack edgar

  The NYPD needs to start taking a step back. They don’t make FAA rules. The FAA should be the only ones with any sort of opinion on matters like this. The NYPD needs to start acting like law enforcement and not law makers.

  Comment added June 10, 2023 6:44pm

• Grebes Legions

  Why is the commercial drone industry even negotiating with the City? Aren’t the existing rules, and these proposed rules, superseded by the FAA? Just keep challenging the City and NYPD until the courts throw all of their rules out.

  As for recreational flyers, they already widely ignore the rules. Casey Neistat is back to posting drones shots on his YouTube channel with millions of views. Many others post to their Instagrams. The new rules will be ignored just like the old. Occasionally the NYPD will arrest someone and lie that a drone was interfering with their helicopter. And then camera footage will expose the lie.

  I’ll continue to fly and risk a $250 fine rather than pay a $150 non-refundable fee. Pro Tip: Fly from a private rooftop. Chances of getting caught are zero, provided you fly safe and don’t crash.

  Comment added June 10, 2023 10:07pm

• Lynn Caporale

  I strongly believe that the current ban on private drones in Manhattan airspace is wise.

  The only argument for changing the rules to create a public nuisance and potential danger of accident or terror attack is private profit. Each drone flight would profit someone while irritating many, and, opening a new source of serious risk,

  In spite of the vociferous opposition to the limits of the proposed change in the rules, the change seems very generous, designed to limit risk to the extent possible (although still having a camel nose under the tent” concern, enabling further changes.

  If there is any change in the rules, the new rule absolutely should be no less strict than the proposed rule,

  Again, for the overwhelming numbers of members of the public, at home and on the streets, there is no upside to changing the rule at all.

  Comment added June 11, 2023 7:04am

• Michael

  Hi I am a FAA Part 107 commercial Drone Pilot and have flown safely in NYC for 7 years without 1 incident and some of my drones have parachutes which allow me to fly over people . The current FAA Drone rules and license should continue to allow me and others to fly in NYC as long as every Drone Operator has a FAA part 107 license and a clean flying record and Insurance they should be allowed to fly . Asking people to submit a month in advance does not work for news or Architecture Photography and getting clearance from Community Boards and to post public notices is a wasted of everyones time , it would be like asking a Car Owner to do the same every time they drove – Please rethink and just make each Drone Pilot register with NYC like the FAA already does – Thanks – Michael

  Comment added June 11, 2023 9:19am

• David taft

  The new drone rules proposed by the New York City Police Department are overly restrictive and will stifle innovation and economic development. The rules require a permit to launch or land a drone within New York City, with limited exceptions. The application process for a permit is lengthy and burdensome, and the requirements for obtaining a permit are onerous. For example, applicants must provide information about their data privacy and cybersecurity policies, as well as proof of insurance.

  The new rules are also unnecessary. The Federal Aviation Administration (FAA) already regulates the use of drones in the United States. The FAA has a comprehensive set of rules that govern the operation of drones, including rules that address safety, privacy, and security. The new rules proposed by the NYPD would duplicate the FAA’s regulations and add an additional layer of bureaucracy.

  The new rules will have a negative impact on businesses and individuals who use drones for legitimate purposes. For example, businesses that use drones for photography, videography, and delivery will be subject to the new rules. Individuals who use drones for recreational purposes, such as flying them for fun or taking them on vacation, will also be subject to the new rules.

  The new rules are a clear example of government overreach. The NYPD should not be in the business of regulating the use of drones. The FAA is the appropriate agency to regulate the use of drones, and the FAA’s regulations are already comprehensive and effective. The NYPD should withdraw its proposal for new drone rules.

  In addition to the points above, here are some other concerns about the new drone rules:

  The rules are unclear and could be interpreted in a variety of ways, which could lead to confusion and enforcement problems.
  The rules are expensive and could make it difficult for small businesses and individuals to afford to use drones.
  The rules could stifle innovation and creativity, as people may be less likely to use drones if they are subject to so many restrictions.

  I urge the NYPD to withdraw its proposal for new drone rules. The rules are unnecessary, burdensome, and could have a negative impact on businesses and individuals who use drones for legitimate purposes.

  Comment added June 11, 2023 9:21am

• Greg Routt

  What if a drone is launched from outside the 5 boroughs (Westchester, NJ or Nassau County? Can it fly over the City? Who has jurisdiction over them? What notifications does the City receive? What notifications are the public given?

  The NYPD and FDNY have legitimate safety concerns. NYC is unlike any other city in terms of population density, skyscraper density and history of terrorist attacks. Even so, their proposal may be over-restrictive. On the other hand, many of the arguments given by drone operators are naive, simplistic and unrealistic.
  The city has legitimate concerns that drone operators need to acknowledge and that the rules need to address. I am all for creating business opportunities for legitimate commercial drone opportunities but it needs to be done in a responsible manner – taking all factors into account.

  Comment added June 14, 2023 11:57am

• Charles Haine, Chair, Brooklyn College CUNY Feirstein Graduate School of Cinema

  I am exceptionally excited that we will have more clarity about the rules around flying drones in the City of New York and how to do it properly.

  My largest worry is the 30 day requirement for a permit. With motion picture film production, it is often not possible to plan 30 days in advance in all scenarios, and it would be great to have a faster permitting process, even if that came with a fee for rapid processing.

  Very excited to see this development.

  Comment added June 17, 2023 4:50am

• Vic Moss

  Hello.

  First, I’d like to congratulate NYC for starting the process of amending your avigation law. Inclusion of sUAS into that law, while likely well intended, has completely closed off the entire city for drone use (with a very limited number of exceptions).

  But your proposed solution has basically the same outcome of keeping the airspace closed to all but those who are part of a large movie production.

  We as an industry understand the need for controls in NYC. NYC is a very congested area, both on the ground and in the air. And when it comes to drone, the urban canyons create a logistical nightmare with GPS signals. You and your citizens don’t need a bunch of people flying drones in NYC who aren’t experienced in this area. Either commercially or recreationally.

  But this isn’t the answer. First, a $150 non-refundable fee (with no guaranteed response time) with 30 day advance notice is unworkable. This industry doesn’t come with a 30 day advance notice for work. On a good day, it’s usually a week or two at best. So right off the bat, that’s an unworkable solution to the vast, vast majority of commercial sUAS operations. And the $150 fee would limit all but the large productions.

  And the notification process actually does what the avigation law already does, and that’s making it impossible to fly legally in NYC. Unless you are flying for, or part of a large production, there is no feasible way for someone to be able to notify all of the residents and community boards in the area of the shoot or data collections. And what about weather delays? There is no method of compliance for any last minute delays.

  And the information required for the notification of residents opens up the drone pilot to threat and possible robbery of equipment. These rules actually open up the drone operators to very real possible security issues.

  So what would work better?

  First, the pilot information needed for this will be taken care of on September 16 of this year. At that time, the FAA will require all registered drones to be broadcasting Remote Identification (RID). RID packets will be broadcasting much of the information required by this proposed ordinance. That includes drone and operator location. So if there is an issue, and responding LEO will simply have an app on their phone, and collect most of the data that would be required under the permit. Operator name and number won’t be available, but the RID serial number will be tied to the owner of the drone, and an LEO can get that information from the FAA as needed. And since operator location is also broadcast, that responding LEO can easily find them. Under the Standard RID regulations, the location of the operator also shows GPS based elevation. So the LEO can determine what balcony or rooftop that operators are operating from.

  Yes, not everyone should be flying drones in NYC, or other large congested cities for that matter. But there are plenty of instances where drones can be used safely and responsibly.

  I encourage this committee to shelve this proposal, and work closely with all stakeholders to come up with a much more workable solution for all involved.

  I’ve worked with a number of cities, as well as the FAA themselves when crafting new drone regulations. I am one of only two members of the FAA’s Advance Aviation Advisory Committee (AAAC) who actually fly drones for a living.

  I would be more than willing to be part of a new committee to craft new regulations for safe and responsible drone use in the boroughs of NYC if a remote option if available. I am not a resident of NYC, so I would not be available to attend those meetings.

  Thank you in advance for your work in this process, and please do go back to the drawing board, and gather input from those who would be so severely affected by these requirements if passed as proposed.

  Vic Moss
  Remote Pilot, AAAC Citizen UAS Operator, FAA Safety Team Drone Pro.

  Comment added June 18, 2023 9:19am

• Alex Potemkin

  Upon reviewing the proposal, I experienced a sense of familiarity. As a native of Belarus, I can discern that the regulations described in the proposal bear resemblance to those implemented in Belarus and Russia. The logical expectation, however, would be for such rules to be applied in those countries rather than the United States.

  This proposed regulation is virtually banning the utilization of drones, particularly for small businesses. The extensive bureaucratic requirements outlined in the proposal render it practically impossible for independent pilots to comply.

  The fundamental essence of drone usage lies in its ability to facilitate efficient and effortless operations. The proposed regulations put a heavy burden on the drones company and makes drone usage for business purposes uneffective. Furthermore, drone operators heavily rely on weather conditions, which adds further complexity, especially in the context of aerial photography and videography where optimal lighting and specific weather conditions are crucial. Predicting such conditions in advance proves to be an impossible task.

  The purported “privacy” concern appears to be contrived. Should we not also consider the multitude of tourists and New Yorkers who possess smartphones capable of capturing images? Would a facade cleaner who have direct close view into offices and apartments be subjected to similar procedures and pixelation requirements as a drone pilot? Shall we scrutinize the smartphones of every tourist to ascertain the absence of unauthorized images of individuals? What about the bus, truck, and taxi drivers who poses danger on the roads and may be possibly use their vehicles for terracts – would they be threaded as drone pilots?

  We are addressing the matter from a business perspective, and businesses naturally strive to maintain their operations, avoid lawsuits, prevent accidents, and address legal complaints. Such government oversight, as proposed, only serves to create unnecessary problems and involves individuals who have no legitimate role in this process.

  Safety concerns are understandable, given that New York City is a bustling metropolis. However, a potential resolution could be to conduct annual background checks for pilots intending to fly in NYC. While I believe this to be unnecessary since we possess federal licenses, I am willing to undergo such checks if required. Once my license and criminal records are verified, I kindly request the freedom to perform my job without undue hindrance. I implore the authorities to prioritize the protection of drone operators rather than impeding their activities. We already adhere to regulations established by the Federal Aviation Administration (FAA), and soon all drones operating under Part 107 will be required to comply with Remote Identification (RID), enabling law enforcement to identify pilots and their locations and verify their background checks. This concern should therefore be confined to the city level. Additionally, I propose the establishment of an on-demand registration service similar to LAANC for NYC, enabling pilots to register their flights in real-time. Such a system would automatically resolve conflicts such as simultaneous drone flights or interference with police and first responders. This proactive approach would provide law enforcement with real-time information about drone operations.

  Should a licensed pilot fail to adhere to federal regulations, they would face consequences from the FAA, including license revocation and potential lawsuits, outcomes that no one desires. Additional regulations will not add anything to this responsibility we are already have.

  In its current state, this proposal is untenable and should not be enacted. The law should be intended to follow, not to avoid. This proposed regulations will only push pilots to violate it acting as criminals. I don’t believe it is something the NYPD really want to achieve.

  Comment added June 18, 2023 10:15am

• Marc Leadbetter

  The notification requirements are onerous and would basically create the same “drone ban” they have now, except put it in actual ordinance instead of relying on an interpretation of a law from the 1940s.
  RID will be required on 9.16.23, and it will have much of what you want to know anyway.

  Comment added June 18, 2023 11:28am

• June

  While I am glad NYC authorities are taking steps to change the current – and draconian – laws that prohibit the take off and landing of UAS, the proposed are not the way to go.
  As they stand, with the exceedingly strict requirements, these new regulations would not actually change the current state of the law in any practical way. The permits, notifications, and exorbitant fee would effectively create a blanket drone ban for anyone who is not a large production company with large budgets and time to spend with all of this bureaucracy. Much of the benefit of allowing drones to be used in the city are effected by small companies and individual commercial pilots who provide those services.
  Additionally, many of these proposed requirements would be addressed by the upcoming RID regulations put forth by the FAA that will take effect in September 2023. So not only is NYC’s proposed path forward onerous and limiting, it is also redundant.
  I strongly urge the city to scrap this plan and start from scratch, this time actually taking into account the needs of the people will benefit from the changes in the law. Listen to UAS pilots, include them in the process in order to come up with a solution that is actually beneficial instead of creating new laws that are a ban by another name.

  Comment added June 18, 2023 12:15pm

• Brad Copley

  An aspect to consider in this rule change may be a reduced interest in visitation by tourists. With the list of requirements being purposed, visitors with the intent of capturing some unique pictures and or videos that a UAS can provide, may well consider spending their time(and money)elsewhere.
  With these types of imposed restrictive measures, my consideration would be to not participate in providing any revenue for any reason in the New York City boundary.

  Comment added June 18, 2023 12:17pm

• Bridger Hawkinson

  Subject: Support for Proposal Allowing Drone Flights in NYC Area – Respecting Federal Aviation Regulations

  Dear Decision-Making Body,

  I am writing to express my strong support for the proposal to allow drone flights in the New York City (NYC) area. As the owner of Hawkinson Aerial Photography, LLC, a drone business based in NYC, I am excited about the opportunities this initiative presents, not only for my company but also for other drone businesses in the region. It is crucial, however, that any changes to local legislation fully respect and align with the guidelines outlined in 49 USC §40103 to ensure compliance with federal aviation regulations.

  Allowing drone flights in NYC would bring numerous benefits to the local economy, foster innovation, and provide valuable services to various industries. As drone professionals, we have witnessed the positive impact that drones have had in fields such as photography, videography, inspections, and surveying. By embracing this technology responsibly, NYC can become a hub for drone businesses, attracting investment, talent, and spurring economic growth.

  It is essential to emphasize that any proposed changes to local drone regulations must adhere to the guidelines set forth in 49 USC §40103. This federal statute establishes the authority of the Federal Aviation Administration (FAA) to regulate and oversee the national airspace system. While I wholeheartedly support granting greater flexibility for drone operations in NYC, it is imperative to ensure that local legislation is harmonized with federal regulations to maintain the integrity and safety of our national airspace.

  As a responsible drone business owner, I fully recognize the need for regulations to ensure the safe and responsible operation of drones. Compliance with federal aviation regulations, such as registration requirements, airspace restrictions, and pilot licensing, is crucial to maintaining the highest standards of safety and security. By aligning local legislation with 49 USC §40103, we can strike a balance between enabling drone operations in NYC and upholding the necessary safeguards set forth by federal authorities.

  Furthermore, I appreciate the acknowledgment that the proposed changes to the law should not infringe with 49 USC §40103. Respecting federal aviation regulations demonstrates our commitment to a cooperative approach, ensuring that local and federal authorities work together harmoniously to foster a thriving and compliant drone industry in NYC.

  In conclusion, I strongly support the proposal to allow drone flights in the NYC area. By aligning any changes to local legislation with the guidelines outlined in 49 USC §40103, we can achieve a balanced and responsible approach to drone operations while capitalizing on the immense opportunities this technology offers for businesses like mine and the broader community. I urge the decision-making body to carefully consider federal aviation regulations and ensure that any proposed changes respect and align with them.

  Thank you for your attention and consideration.

  Sincerely,

  Bridger Hawkinson
  Owner
  Hawkinson Aerial Photography, LLC
  [email protected]

  Comment added June 18, 2023 12:22pm

• Barry Houldsworth

  First, thank you for starting the process of amending your avigation law.

  Inclusion of sUAS into a law created so long ago has resulted in a practical ban for drone use in NYC and, while well intended, has meant that the significant benefits that could be obtained from the use of drones has been unavailable to NYC residents and businesses.

  It is nice to see that this is being looked at but, unfortunately, the proposed solution will, IMHO, create a similar ban for all operations other than large film crews and big businesses that can afford the fees.

  I do understand the need for controls in NYC.

  NYC is a very congested area, both on the ground and in the air. And drone flights in between large buildings can be very difficult, particularly for people that are used to flying with the aid of GPS. GPS signals become unreliable in such locations and so additional expertise or equipment is required to do so safely. As such, some additional restrictions is warranted.

  However, the plan as laid out is so onerous that the most likely effect is that the professional drone operators will not accept work in NYC, while operators with less experience and safety focus will simply ignore the rules and fly. Note that this happens already today.

  Here are areas that are problematic.

  1. A $150 non-refundable fee (with no guarantee of acceptance) is significantly higher than many jobs pay in total (see example below).
  The most well known drone service provider in the US, Dronebase, often lists jobs in the NYC area with pay rates around $75. We can argue that those rates are too low, and I would agree, but the fact is that people are taking these jobs today and ignoring the avigation law. Implementing fees this large is likely to lead to those regulations to continue to be ignored.

  2. A 30 day notification period does not work for most drone jobs. Often only a few days notice is provided. Two weeks is rare. A month is practically unheard of, other than for regularly scheduled work.
  Given that most drones cannot fly in bad weather (high winds and/or rain) there is a strong likelihood of reschedule which, presumably, means another fee and another 30 day wait.

  3. The requirement to notify all residents in the area is completely unworkable. Aside from the logistical difficulties, this also basically announces that someone with some very expensive drone equipment will be in this location on this date – it is an invitation for harassment by ill informed public at best and, at worse, an invitation to be robbed.

  It also duplicates what will be put in place with the introduction of Remote ID (RID) in September this year. RID will require the drone and the operator to broadcast their location in real time and, as such, anyone with a concern can easily find the operator to engage.

  So how can we improve this?

  a. Rework the proposal to come up with a more realistic fee structure. Failure to do this will result in non-compliance and, therefore, less safety for people in NYC. This will likely increase as drones become more commonplace in the NYC airspace and being able to tell which ones have filed the right paperwork will be nearly impossible.

  b. Rework the proposal to incorporate the FAA’s Remote ID systems into the process to remove the notification requirements

  c. Change the notice period. Ideally this should be automated, similar to what the FAA has done with their Low Altitude Authorization and Notification Capability (LAANC) system to allow people to obtain authorizations in low risk areas immediately, and higher risk areas in a timeframe of a few days.

  Given the above, I would ask that this committee shelve this proposal, and work closely with all stakeholders to come up with a much more workable solution for all involved.

  Thank you for your consideration of this. If I can help, please feel free to reach out.

  Comment added June 18, 2023 12:26pm

• coal kolivas

  What is needed is a drone friendly state, because those flying a drone have a pilots licenese and soon to be RID in just a few months, what that means is each drone will carry a license plate. Drones allow a sense of freedom, a hobby and for many a way to help the Police, Fire and Rescue.

  The best thing about Drones is when there seen in the sky, it will be difficult for those to know if there a poilce drone and curb crime , and provide police with a more direct path to those who need to go to Jail

  The Public wants to know that the Police are being creative and really wanting to lower crime so stop making things so difficult and ugly for drone pilots instead recruit them make them work for you as eyes in the sky.

  Comment added June 18, 2023 12:28pm

• Loretta Alkalay

  Dear NYPD – the proposed permitting process is a welcome change that would allow some drone operations to take off and land within NYC.

  However, the proposed requirements are unduly restrictive for all but the wealthiest operators, including the insurance, community notice and 30 day notice requirements.

  The proposed rules would also effectively prevent NYC college and high schools from, for example, testing school- built models outdoors, except to the extent they were able to access the handful of recreational fields. This puts NYC students at a continuing disadvantage, as compared to, say, suburban or upstate students.

  While some parts of NYC have unique density issues and terrorism concerns, a permitting process that would allow access to drone work opportunities to small businesses – including disadvantaged businesses -and schools/universities would be a fairer and more equitable process, while still protecting important NYPD concerns.

  I would recommend forming a small task force, with affected stakeholders, to propose an ordinance that is fair for all drone operators and not just the wealthiest among them.
  Loretta Alkalay

  Comment added June 18, 2023 4:59pm

• Chuck Peters

  How great to to see NYC looking to amend it’s rules on drone launch and landings, there by opening up commercial operations for so many types of industry. I know small video production companies such as my own, along with real estate photographers, construction surveyors, inspection companies, education and organizational agency’s, all of which are very excited for this opportunity.

  As the proposal points out, there is certainly a need to monitor and control launch and landings and provide the utmost safety and privacy to the citizens of the city. There are already federal regulations in place that would require commercial operations to be certified by the FAA and certainly a city permit would be a prudent requirement, but requiring a per flight permit with such a burdensome fee structure is going to limit these new opportunities to only large production companies or institutions. The proposed permit costs will encourage small operations to make unlawful flights to avoid the financial burden. I’m sure this is not what the city is trying to accomplish.

  A one time permitting process that would assure the operator is part 107 certified with the FAA, and that the pilot is aware of the unique safety requirements of working in a metropolitan area would certainly be a better approach for encouraging safe drone operations within the city. This could be an online process requiring completion of a training course, submission of insurance certificates along with any other requirements for streamlining the issuance of a permit.

  Another concerning part of the proposal are the advance scheduling requirements, 30 days notice prior to an operation from a small business standpoint is not at all reasonable. As a professional photographer/videographer I’m lucky if I get a weeks advance notice of an upcoming job, photography is all about lighting and there is no way I could plan a production schedule with a 30 day advanced notice and have to reschedule if the environmental conditions at the time of the scheduled shoot were not ideal. This advance notice was a problem when the FAA first started requiring pilots to obtain permission to launch commercial drones into the national air space. They approached the problem by initiating a network data system called LAANC which is a collaboration between the FAA and private industry. It provides close to real time access to controlled airspace, awareness of where pilots can and can not fly, along with providing visibility to air traffic professionals into where and when drones will be operating. This same type system along with the up coming federal requirement for the remote identification (RID) of drones could be used to provide NYC law enforcement and public safety officials with all the specifics the proposal suggests with a much simpler flight approval process.

  The requirement to post notices in the area of operations creates a very real safety concern for drone operators and crew. Your basically requiring a operator to broadcast when and where they will be operating expensive equipment opening themselves up to criminal activity.

  Privacy is certainly a concern for citizens in the area of operations, but citizens don’t have a reasonable expectation of privacy in a public place. In today’s society just about everyone has a phone camera and no one is expected to obtain a permit to take pictures in a public place. I’m sure there are peeping tom laws in place in the city and with the new remote id requirements, it would be easy to identify and locate any pilot in the area of a privacy complaint.

  Again, it’s great to see the New York City Police Department (“NYPD”) proposing to amend its rules to create a procedure by which members of the public may submit applications to launch or land an unmanned aircraft, including a “drone,” within New York City, but it would seem that they have not taken into consideration all stakeholders in their proposal. I strongly suggest the committee shelve this draft proposal of rule change and instead start the process over, involving all those impacted by these changes. There are many professionals in the drone industry that would be more than willing to work with the NYPD to come up with a solution for implementing rule changes for the benefit and safety of all concerned.

  Sincerely,
  Chuck Peters

  Comment added June 19, 2023 12:10pm

• Peter Burke

  I oppose this ruling. It is a de facto ban on UAV use.
  The city clearly did not consult UAV users.
  It does nothing to add to public safety.
  The FAA already has detailed, extensive regulations for UAV use to make them safe in the USA.
  And even the federal government, known for being slow moving, is super fast compared to the 30 day advance requirement in this proposed regulation.
  In short, I urge NYC to shelf this, rely on the FAA regulations instead for safety.
  This rule is bad for the citizens of NYC, bad for the economy of NYC, and does nothing to improve safety.

  Comment added June 19, 2023 1:47pm

• Zachary Riter

  Good afternoon,
  As the owner of Showtime Photography LLC we are requesting you re-address this completely in its entirety and actually pull in all of the Key Stake holders involved. Starting with your 107 Pilots, Small businesses, etc. Everyone’s voice matters with this current situation, not just residents and Government officials.

  I would also like to point out. RID goes into effect in September of this year. Your going to know where each pilot will be, and the contact info in case you need to make a point of contact. The business your loosing by requiring all of this lingo is totally ridiculous. NYC, is just like any other city in the U.S. It shouldn’t be considered anymore special than any other location.

  In conclusion, as a pilot & small business owner I have flown many locations, and 99.9% of these locations have “loved” the outcome. A drone is a very useful device when used properly and efficiently. I lobby to allow any pilot that’s certified take off and land on any NYC public property. Thank you.

  Showtime Photography LLC

  Comment added June 19, 2023 2:16pm

• Bill C.

  I am an FAA Certified Remote Pilot from an NYPD family. I fully recognize and appreciate the safety concerns that the city has regarding the flying of drones within the city limits, and which the FAA regulations alone do not address. With those concerns in mind, I would like to suggest a simpler, less bureaucratic, more efficient, and more reasonable approach for allowing a growing number of professional businesses to utilize drone technology within the city limits. I would like to see established different application tiers that would better fit the different flying needs and situations for a more fair and reasonable approach to new legislation.

  The following is my suggestion for a 4-tier NYC drone application system:

  TIER 1 – RECREATIONAL
  Applicants may apply for and purchase an annual/seasonal pass to be able to take off and land within certain designated city parks and areas. In return for being granted these take-off and landing rights, the operator agrees in signing the application to limit their flying to within the park/area boundaries, to adhere to all FAA recreational regulations, and to always keep the drone within operator unaided visual sight.

  TIER 2 – SMALL BUSINESSE (SHORT SCHEDULE)
  Permission to fly is limited to a 1-week period to accommodate a business deadline while having weather condition flexibility. Once the day of intended flight is determined, the local NYPD Precinct command must be notified 24 to 48 hours prior to the actual flight. The drone operator must have proof of FAA permission to fly in any restricted airspace, be in possession of a current FAA Remote Pilot Certificate, and have $1M liability insurance coverage. Application would specify the take-off time, area, duration, and altitude of the flight.

  TIER 3 – SMALL BUSINESSE (RECURRING SCHEDULE)
  Drone operations for Construction projects would fall under this tier. The application process would be a bit more detailed with added safety and OSHA requirements. The construction company hiring/assigning the drone operator would have a role in the application process. A working relationship with the local NYPD Precinct command and drone operator would be established. The drone operator must have proof of FAA permission to fly in any restricted airspace, be in possession of a current FAA Remote Pilot Certificate, and have $1M liability insurance coverage.

  TIER 4 – PRODUCTION (ON-GOING SCHEDULE)
  Film productions would fall under this tier. The application process would be very detailed with added safety and OSHA requirements – more in line with what you are currently proposing. A working relationship between the Precinct commander and production company would be established. The drone operator must have proof of FAA permission to fly in any restricted airspace, be in possession of a current FAA Remote Pilot Certificate, and have $2M liability insurance coverage.

  As others have mentioned, bad actors will simply ignore any new laws. The key is to establish reasonable laws that generally good people and professional drone operators can abide by.

  I thank you for this opportunity to provide comments.

  Comment added June 19, 2023 3:23pm

• Dale G.Davis,M.D.

  Attention: NYPD

  I am an amateur drone enthusiast, and I enjoy flying my drone for photography, and as a hobby. I do not do commercial photography. I am simply a hobbyist. I follow all of the standardized rules for recreational flying, such as not flying over traffic, people, emergencies, over 400 feet, near airports of no fly zones. I have my FAA Trust certificate. The proposal of the New York Police Department would set an unacceptable rule by creating a procedure by which members of the public need to submit an application to launch or land a drone within New York City.

  Many, more than adequate rules by the FAA already exist. This proposal would severely create an almost insurmountable barrier to recreational flying. We already have appropriate smart phone apps which allow us to safe permission to fly in zones at safe altitudes and gain LAANC approvals. This proposal would require an undue hardship on recreational drone flying. The proposal for notifications is an onerous hardship on this drone community. It would create the same ban as already exisits by the FAA.

  I would suggest that the committee set aside these rule changes and re-start the process in order to include stakeholders, in order to achieve a workable solution for all.

  It should also be noted that radio identification of all drones will soon be coming to us on September 16, 2023, and this proposal would merely be a duplication.

  Dale G. Davis,M.D.

  Comment added June 19, 2023 8:00pm

• AB Kohn

  Hello, i’m a pilot with a recreational permit. i think this is very unfair and that this is another one of the city’s many other new ways to grab your money. i fly safely and i believe the majority of other pilots do to. this law is unfair and interferes with private pilots who legally make money off of taking pictures.

  Comment added June 19, 2023 10:15pm

• Michael Casey

  Hi
  I am a RC Airplane flyer at Floyd Bennett Field Brooklyn New York 11235 Our Club name is PARCS “Pennsylvania Avenue Remote Control Society” We fly fixed wing Aircraft which are mostly replicas of existing scale Airplanes and we fly by line of sight flying. NO First person viewer or computer or auto landing or take off there is human intervention at all times. We are not flying Drones as you know them. You as the Pilot in command have full control of model airplane from takeoff to landing. We should not fall into the category of a “DRONE”.
  I am a Retired NYPD Police Officer and did 27 years as such and worked 13 years at Floyd Bennett Field and was also President and Vice President of this Club and we as a club never had a issue with our flying.
  Given the Fact that we fly in Class B Airspace we have a working agreement with NYPD Aviation Unit, FAA and ATC. On a daily basis we call NYPD Aviation when we open up to fly who intern notify FAA that we are up and running. We have been doing this for over 60 years as a RC Model Club. We have insurance through the AMA ” American Model Avation Association” we have a Permit from the US PARKS DEPT and our RC Aircraft have FAA number that are assigned to each Pilot visible on each aircraft.
  I understand the rule of law as I am retired NYPD and understand your need to put the clamps on the amount of Drones that are flow in NYC but I also belive this new law you are looking to put into effect should have a separate line that if you have been a existing Club for many decades with rules and regulations for safe flying in the busiest airspace in the country without incident we should be able to continue flying as this is a Hobby and introduction for young children to have a career in the Aviation industry as well.

  For Your Consideration

  Retired NYPD Officer
  Michael Casey

  Comment added June 20, 2023 8:16am

• Michael Dirac

  Related to clause: § 24-02 Unmanned Aircraft Permit Requirement:

  1. Will there be an exception for the approval process “if related to design & construction project on City “managed Property” for purposes related to an NYC Design and Construction project (which could be subject to a separate procedure)?

  Noted reference: NYS Office of General Services (OGS) has an approval procedure for Unmanned Aircraft Systems (UAS) which applies to any individual or organization which seeks to launch, land or otherwise operate an UAS on OGS managed property, other than for purposes related to an OGS Design and Construction project (which is subject to a separate procedure).
  https://ogs.ny.gov/nys-office-general-services-application-use-unmanned-aircraft-systems-uas

  2. For flights performed within a NYC Authority/Agency’s property limits, will there be an exception or waiver if the Agency/Authority implements the NYPD requirements for insurance, security ( & privacy) and the agency monitors/tracks the credentials of UAS operators?

  3. Will there be a streamlined the review process (<10 days) for NYC Authority/Agency drone flights for agencies with a large number of building assets requiring facades inspections on an annual basis related to design & construction projects?

  4. Will there be a portal for UAS operators to sign-in and register (with certificates of insurance, Part 107 credentials & security requirements), either on an annual or bi-annual basis ? (Similar to NYC DoT street permits contractor registrations)

  5. Will third-party operators (UAS Providers) working under the direction of a NYC Authority/Agency meet the exception for permits?

  Comment attachment
  NYPD-Drone-Take-off-Public-Comments.pdf

  Comment added June 21, 2023 9:31am

• Vincent Garrison

  I have been in business for 10 years in the NYC area. In that time, the money I have earned has been enough to make a life that is better for me and my family. The rules you want in place would make it virtually impossible to fly drones in the 5 Burroughs. We live in a very densely populated area and the opportunities to fly commercially to make a living is real.
  I really hope you take a look at the law now and create something that can actually work for professionals like me.

  Comment added June 21, 2023 12:39pm

• John

  This is an unnecessary over reach that will impact remote pilots in a very negative way. The current regulations in place combined with the substantial and effective FAA regulations that are currently adhered to by certified pilots has resulted in an effective use of the airspace that has provided safe use of the affected area. This is a solution to a problem that doesn’t exist!

  Comment added June 21, 2023 1:19pm

• Felix Fernandez

  This will only closed off the entire city for general drone use.

  Only exception would probably be large production companies who won’t be affected by the $150 non-refundable application fee. It is extremely hard to schedule a job with a month or even more time in advance when the weather is always changing, and to make it even harder, you have no guarantee for a response time or approval.

  One more thing to keep in mind is that operator needs to notify community boards about the possible flight plan, which poses a risk for our own safety and equipment.

  I do believe that this proposal can be fixed and updated to a more workable way. Hopefully the advice and input from fellow and more knowledgeable pilots will be taken into consideration for the matter.

  Felix Fernandez
  Remote Pilot and drone enthusiast

  Comment added June 21, 2023 8:09pm

• Matt Lekawa

  Clearly the new proposed “permit” application process is designed in such way making it almost impossible to obtain, not to mention very discouraging to begin with. Why not compromise and allow FAA Part 107 remote pilots access to some of the city’s airspace? These are knowledgeable and FAA certified individuals that put laws, regulations and most importantly, safety first. Furthermore, create a comprehensive online training course/certification specific to any NYC restrictions, regulations, do’s and dont’s, etc. that may be different or outside of what’s currently covered by FAA’s Part 107, and require (and charge $$) Part 107 remote pilots to be certified prior to flight. Overwhelming majority of Part 107 remote pilots are very talented photographers and/or videographers. We don’t fly our drones just to fly, but rather position our aerial cameras to create beautiful content and share it with the rest of the world. The world already knows what a beautiful and magical place NYC is, but they haven’t seen what we can show them from above. Think about it, there is so much potential here for New York City…

  BTW, I live in Denver CO and show the world through my aerial photography what a beautiful place my city is. I could never live in NYC knowing that I couldn’t do the same.

  Comment added June 22, 2023 10:13am

• Charles Di Bartolo

  Please reconsider this UAS proposal in NYC the requirements are cumbersome and impractical for business. This will only allow the mega companies to proceed while hindering the local business community from competing. The fees, time frames and notices are not reasonable. Thank you for considering my comments.

  Comment added June 22, 2023 10:20am

• John C Brown

  More and more restrictions have been put on this wonderful hobby of mine, which is making it harder and harder to enjoy it! In addition, it’s also restricting new members from becoming active in this wonderful hobby. This hobby has been around for over 80 years with the Academy of model aeronautics, many many young men have grown up to become very active in both the model airplanes, as well as full-size airplanes, whether they be pilots or mechanics, or in some cases, working with NASA! So to restrict us now, would put you in harms way any new brilliant minds that might become associated with aeronautics . I would hope that anybody involved in this and see that they need to promote a hobby such as flying model airplanes and get the right people involved with it while not suppressing it.

  Comment added June 22, 2023 10:58am

• Jeff Noreman

  Thank you NYPD for proposing to amend your rules and to create a procedure by which members of the public may submit applications to launch and land an unmanned aircraft like drones within New York City.


  I applaud that the City realizes it must balance the safety and privacy concerns of the public with the significant financial benefit to local businesses (and to the City itself, through additional tax revenue) that will result from modifying the rules for the use of drones. However, the proposal does not show insight into the actual work situations where drones are used.

  First, the use of radio-controlled, flying consumer devices is hardly new technology. In fact, as early as the 1960’s, the radio controlled scale aeromodeling craze swept the country. And in the last decade, drones as both a hobby and a business tool have far surpassed that acceptance. Drones are business tools that provide aerial photography, fire monitoring, waterway monitoring, environmental monitoring, infrastructure inspections, precision agriculture, and entertainment in the form of illuminated sky shows – and all of these areas are expanding exponentially.

  Are there potential hazards when flying a drone? Sure. But a two-pound consumer drone can certainly do far less harm when compared to a 5,000 lb car, based on its mass and speed. Still, people who have never driven in NYC traffic are allowed to drive in the Five Boroughs, simply with a valid driver’s license from anywhere in the United States.

  When people hurt or harass others (with or without a device), there are plenty of existing laws that protect the public that NYPD officers can enforce. Let them do that as needed. Patrol officers have enough to do, and already handle a mind-boggling variety of situations. There is no need to give them more to interpret.

  This proposed rule has several additional problems. First of all, $150 per request, whether approved or not? Sorry, that’s just a money grab, and that’s not going to change anyone’s behavior. Next, although you would require 30 days advance notice to request these paid permits, you make no guarantee of when you’d address such a request – could be one day before, or not at all That’s just unreasonable. Most of the businesses mentioned above require a crew who are likely working on several projects that overlap time-wise. Professionals need to assemble their crew, and that involves coordination on a day-to-day basis. And of course, safe drone flights are dependent on weather and wind. Therefore, 30 day advance requests are entirely impractical.

  Posting notices with people’s names and phone numbers publicly? Do you guys even live in New York? Do you want your names and phone numbers posted anywhere publicly? That’s just creating a dangerous situation for drone operators.

  As far as having data privacy and cybersecurity policies, this is far beyond the scope of work of a professional aerial photographer or videographer shooting for a real estate agent, a roofing inspection job, or an aerial shot for a marketing video. You want us to report something strange that happened during our drone flights? Sure, give us a website or a phone number – that’s a reasonable request.

  Contacting every member of the City Council and each local community board where we fly? Why? This is just a waste of time. They will not be the law enforcement agency ensuring legal and proper behavior. If you feel you must inform these parties, that can be done automatically by NYC.

  In summary, if you actually want a reasonable set of policies that will encourage safe behavior, allow a variety of NYC tax paying businesses to thrive, give you oversight without unreasonable financial requests, have a meeting with some working drone professionals. I, for one, would be glad to help, and I know many here would as well.

  Thank you for your attention.

  Comment added June 22, 2023 5:37pm

• Jon Pufahl

  NYC is filled with historical sites and views. Allowing the pictures and videos using drones will add to the public Information of people 100 years into the future. I think it will be of interest. We have seen trolley videos of NYC 100 years ago to get a feel of those times. Drone picture and video should be allowed. It is only a flying camera with very little risk. I am a recreational UAV flyer. Using my equipment safety and responsibility and should not be restricted.

  Comment added June 23, 2023 9:12am

• Jacques Millett

  I am writing to strongly oppose the recently announced rules by the New York City Police Department (NYPD) regarding the procedure for launching and landing unmanned aircraft, including drones, within New York City. These rules negatively impact the drone services industry, overlap with existing federal laws regulated by the Federal Aviation Administration (FAA), and create unnecessary confusion and burdensome requirements.

  Drones have revolutionized various sectors, providing valuable aerial imagery and data. However, the NYPD’s rules hinder the growth and innovation of the drone services business in NYC. The added restrictions and requirements create unnecessary bureaucratic hurdles, deterring individuals and businesses from operating drones within the city or forcing them to seek more drone-friendly jurisdictions.

  Furthermore, the new rules conflict with the established FAA regulations, which are responsible for ensuring safety and compliance nationwide. Deviating from federal guidelines creates inconsistency and undermines the FAA’s authority. It imposes an unnecessary burden on drone operators who are already complying with federal regulations.

  I urge the NYPD to revise the rules and align them with existing federal laws. Collaboration between local and federal authorities is essential for striking a balance between safety and innovation in the drone industry. Focus on public education and awareness campaigns about existing regulations and best practices would be more effective in promoting responsible drone use.
  In conclusion, I strongly protest against the new rules for launching and landing unmanned aircraft in NYC. These rules hinder the drone services industry, conflict with federal laws, and undermine growth and innovation. I urge the NYPD to reconsider and collaborate with the FAA for a unified and consistent regulatory environment for drones.

  Thank you for your consideration. I am available for further discussion and to provide additional information.

  Comment added June 23, 2023 1:58pm

• Josh

  As a certified part 107 remote pilot and videographer for a non-profit of 23,000 people, I take extreme caution when using my UAS. Future applications for ground use substantially hinder my ability to create quality images. When I am doing a project often things have to move quickly. I got my FAA certification so that I could operate efficiently and safely while understanding the suitability of an environment. Often times, weather, wind, light or clouds make or break a quality shot and most of that is unpredictable. With extra red tape, the time window of application often come and pass without a suitable environment to fly. When I have freedom to conduct operations in a professional way when the environment is suitable I can make quality images that directly impact the outcome of my organization’s vision.

  Comment added June 24, 2023 11:05am

• Stephen

  For those of us who fly sUAS recreationally are for the most part safe about it. As tech evolves faster than some can absorb it some see another capitol gain. With all the filming going on in NYC I don’t see why? Now those who have businesses using sUAS it would hurt them more so. I fly recreationally and love aerial photos which could be a benefit to city agencies like tourism so to impose these rules would kill that and I’m sure you would want more tourism than less. I truly hope this hours nowhere fast because I want to film my city without being caught up in bureaucracy.

  Comment added June 24, 2023 1:15pm

• Arnold LeVine

  The 30 days effectively makes this unuseable.
  Why not set up an automated system such as the FAA LAANC system for flying in the Class B-C-D airspace around airports. this would make the rule tenable and save NYC countless hours of manpower in reviewing applications.
  Also, starting 9-16-23, the RID (remote ID) requirement means live transmission of date that law enforcement can read.

  Comment added June 24, 2023 2:16pm

• Paul Widmayer

  As I feel it is important to know who is flying in the National Air Space I believe a rule such as the proposed rule would put undue stress on those providing this service. Drone service providers have begun a revolution in many industries including real estate, infrastructure inspection, and public safety. I think the requirements are cumbersome and not needed. With the deployment of Remote ID in July. The required information of who is flying will be available to those who need to know. Additional regulation will provide a burden to mostly small business owners. I am a professional drone operator and an emergency service provider with over 30 years of service to the public. I am very safety oriented.

  Comment added June 25, 2023 11:12am

• Justin Melanson

  I strongly oppose the proposed restrictions/regulations on drones in New York City. Drones have become increasingly popular for commercial use, and they offer numerous benefits such as aerial photography, search and rescue missions, and infrastructure inspections. These proposed changes on drones would limit their potential and hinder innovation in the drone industry.

  Instead of a (ban), there should be regulations in place to ensure that drones are used responsibly and safely. Drone operators should be required to obtain 107 licenses and demonstrate that they understand the regulations and how to operate drones safely in the NYC air space. With the Remote ID being required this September it will be easy for law-enforcement to identify reckless individuals and deal with them accordingly. There are many safety benefits to having Drones in the NYC airspace. The NYC Facade Inspection Safety Program (FISP), also known as Local Law 11, requires NYC buildings taller than six stories to have their facades inspected and repaired every five years. These inspections are hazardous without the use of drones and it would be irresponsible to deny or make it almost impossible to obtain a permit for these valuable tools. The proposed $150 permit fee is quite hefty and with no guarantee that you will even get a response it is obvious that this was not completely thought out.
  Furthermore, a ban on drones would have a negative impact on businesses that rely on drones for their operations. It would limit their ability to operate efficiently and effectively, which could lead to job losses and economic setbacks. Instead of these new regulations and restrictions NYC should work with stakeholders and investigate all options and research the models of other states to develop guidelines and regulations that ensure safe and responsible drone use in these challenging environments.

  In conclusion, these new regulations that are being proposed on drones is not the answer. Instead, we should work towards responsible and safe drone use by implementing regulations that promote innovation and protect public safety.

  Justin Melanson
  Cofounder at Aeras Drone Technology

  Chair of the Economic Development Committee at PennDOT UAS Integration Taskforce

  Comment added June 25, 2023 11:07pm

• Donald Laird

  These proposed regulations will completely end recreational (and most small commercial) drone activity. They are ridiculously onerous. Please reconsider. Reasonable regulations are fine – these are nowhere near reasonable.

  Comment added June 27, 2023 12:02am

• Anthony Machado

  The NYPD does not have the authority to control or regulate drone operators who operate under an FAA Part 107 Federal license. Federal guidelines regarding both commercial and recreational drones pertaining to local governments are here: https://www.faa.gov/uas/public_safety_gov/sightings_reports
  https://www.faa.gov/uas/public_safety_gov
  https://www.faa.gov/uas/recreational_flyers
  https://www.faa.gov/uas/public_safety_gov/public_safety_toolkit
  The federal law governing part 107 operations is here: https://www.faa.gov/uas/commercial_operators

  The NYPD cannot simply assume the role of the FAA because it feels like it. It cannot govern commercial drone operations in the same way it cannot govern commercial flight operations at JFK or LGA airports.

  Additionally, as a small business operating drones under Federal law for my livelihood – I will follow all FAA laws/regulations, but I am NOT subject to subjective, impulsive local lawmaking. I’m a federally (not state, not city) certified operator.

  Lastly, a 30 day approval rule would destroy my business. As any time we plan a flight for a client, it is subject to last minute weather rescheduling/delays. Sometimes a client needs a job done tomorrow. As a small business/freelancer, I take whatever jobs come. I take them when they come.

  Bottom line is NYC/NYPD does not have the authority for this type of governance. If for some reason the NYPD proceeds along these lines EVERY part 107 certified commercial drone pilot will have absolutely no reason to comply with such irresponsible, ridiculous “lawmaking”.

  I won’t sink my own business to appease the NYPD’s idiocy. I don’t think others will either. There you have it. File this.

  Comment added June 27, 2023 8:45am

• Lance Threewitt

  From the perspective of a surveyor who is required to do topographic surveys in relatively low traffic areas withing the 5 boroughs, drone lidar solutions could allow us to collect topographic information in safer way with less impact on the environment. We often have to inform clients and agencies that unfortunately there are some areas that are impossibly to safely collect data as well as some areas where it is prohibitively expensive. This proposed rule seems to cater only to the film industry and exclude pilots in my industry from doing important work that would be of great benefited to the community and infrastructure in the great city of New York. Please consider lower monetary/insurance requirements and streamline the notification and approval process. I believe it would be more beneficial to lower the requirements to fly and instead create more accountability for those who may cause problems for the community and city, this will allow professional and responsible pilots who are making a contribution to the city to do their work safely and efficiently.

  Comment added June 28, 2023 3:19pm

• David H. Aretsky

  Dear New York City Police Department,
  I am writing to express my concerns regarding the proposed rules for UAV (drone) flight within New York City. While I support the idea of allowing drone flight in the city, I believe that the proposed rules are overly burdensome and would essentially result in a de facto “drone ban” for all except wealthy commercial enterprises, essentially maintaining the status quo that has been in place in NYC since the 1940s.
  It would be beneficial if the NYPD could consider implementing less stringent rules that would allow small UAV operators like myself to utilize the airspace. I believe there are numerous commercial applications within the city that could contribute to its economic growth, create job opportunities, and benefit its residents.
  I strongly object to the proposed non-refundable fee of $150, as it is unaffordable for many individuals, including myself. Especially considering the fact that the fee would not be refunded if the operator’s flight request is not approved.
  Requiring a 30-day advance application is also problematic, as many operators receive job requests with short notice and are dependent on weather conditions to ensure safe flights. Considering that a mission could be canceled due to weather or safety concerns, resulting in the operator losing the $150 fee, this requirement is burdensome.
  Starting September 16, 2023, the FAA will be implementing Remote Identification (RID). Much of the information requested by the NYPD in the proposed rules, such as the operator’s name, contact information, flight purpose, time, date, location, aircraft information, and FAA authorization, will already be broadcast by law-abiding drone operators through this system. Therefore, it seems redundant to require operators to provide this information separately.
  Regarding data privacy and cybersecurity practices, as a photographer/videographer, I adhere to common privacy and photography guidelines. There are already existing laws that regulate the collection of images, and my privacy policy is publicly available on my website.
  While I understand the NYPD’s interest in requiring insurance (although it is not mandated by the FAA), I am currently utilizing on-demand insurance through an app since my previous insurance company went out of business. Providing proof of insurance to the NYPD 30 days in advance would be a significant challenge.
  In conclusion, I would recommend that the City of New York avoid imposing overly burdensome rules on UAV operators and instead rely on the FAA’s RID and LAANC systems, which will provide comprehensive coverage for the entire United States, ensuring a secure and safe flying environment for all.
  Thank you for your attention to this matter.
  Sincerely,
  David H. Aretsky

  Comment added June 28, 2023 6:48pm

• Lorey Miller

  Would the rules include protection for avian populations, so that when drones are launched or are flying they are designed to emit a sound from their rotors or their drone bodies which would scare away birds? If this could be designed and implemented, avian populations would be protected from collisions and premature death.

  Comment added June 29, 2023 11:07am

• Sharon DeVivo, President/CEO, Vaughn College of Aeronautics and Technology

  NYPD Legal Bureau
  c/o Agency Attorney Melanie Braverman
  One Police Plaza, Room 1406
  New York, NY 10038

  Dear Ms. Braverman,
  I write in response to the proposed rules for drone operations in New York City. As the president of Vaughn College of Aeronautics and Technology, I am thrilled to serve a population of students who represent the diversity of our city and who pursue high-paying positions in aviation and aerospace including the drone industry.

  Since 1932, Vaughn College has offered certifications and degrees in all aspects of aviation, engineering, management and technology. Our founders were early aviation pioneers, and our current students are achieving positions with airlines, manufacturers, airports, public utilities and the NYPD as pilots, aviation maintenance technicians and officers. Many of our students are also working in New York City for drone manufacturers such as DJI and Easy Aerial. More than 80 percent of our students come from underrepresented and under resourced backgrounds.

  Vaughn is currently working with high schools in Brooklyn and Queens to offer five courses that lead to Part 107 certification as drone pilots. This grant is being funded by the Federal Aviation Administration. The great difficulty is where to allow these students to practice their training within the confines of New York City. Incredibly small pockets of land are available, and the current proposed rules are untenable for students to meet in order to pursue their potential career goals.

  I would like to suggest that the new proposed rules also include an exception for students and be structured like the NYC rule for student filmmakers. Students would still need a permit but would be granted permission based on the institution they attend, and provided that the institution also ensures permission. In the case of Vaughn College, we understand the safety issues surrounding safe drone flying and would work with our students to confirm that they are following all applicable rules and guidelines.

  By not having an exception for students who are piloting drones, New York City will continue to limit an incredible career path for students in the flight, manufacturing and managing of safe drone operations. Underrepresented and underserved students deserve the opportunity to share in this sector which is forecast to grow commercially from about $43 billion in revenue in 2023 to $584 billion by 2030 according to Grand View Research (https://www.grandviewresearch.com/industry-analysis/global-commercial-drones-market). “That growth is directly tied to favorable government initiatives regarding the advancement in drone technology coupled with the growing demand from businesses for drone-acquired data,” also according to Grand View Research.

  I appreciate New York City’s willingness to look at the rules governing drones and respectfully request that we provide an exception that will allow ALL students—not just those in surrounding regions where restrictions are limited—to share in the prosperity and opportunity that exists in this exciting and growing industry.

  Comment attachment
  NYC-Rules-for-Drone-Operations-Vaughn-College-Response.pdf

  Comment added June 29, 2023 2:44pm

• Rebekah Morris

  I live in East Flatbush and despite living in a less safe area, i am STRONGLY opposed to the allowance of drones in NYC. As an urban planner, I see how slow the city is at doing the most routine of activities such as permitting buildings for construction or responding to an abandoned car for towing. There is absolutely no way that even if a policy had the best set intentions (which i do not believe this drone program would have – beyond spying and making war against New Yorkers) that it would be effectively monitored. You can bet in two minutes, foreign enemies, stalkers, youtubers trying to build their following by doing stupid actions for clout, – all would be there trying their hardest to get around whatever rules NYPD creates. And how is NYPD going to regulate tiny little ships in the air? The whole thing is ill-conceived, dangerous and stupid. Vote no on allowing drones.

  Comment added July 1, 2023 9:41am

• hopster

  Hell No! Technology is ages ahead of regulations and you want these flying all over, spying in windows, forcing more ADVERTISING on us? Making people look up as they run you over on a bike? And thugs will be trying to shoot them down, killing more kids looking out windows. How about thugs using drones to watch for PD and lying on the application? Drug deliveries? Drones hitting windows, knocking down bird nests, and worse? You think every jerk that has one is good using it?
  This is terrible, invasive and just plain ignorant.
  If you want to raise money, make bicycles have license plates and pass a test and pay a fee. Like they did in Wisconisn in 1976!!! Take a test to show you know the rules, since every bike in the city runs red lights. Have a fee and a license plate on the back of the seat for reporting!
  Drones should be for looking for sharks in FL, emergency use (viewing fires, etc) and possible police crime fighting use. NOTHING else. Not to mention how they will disturb birds and the environment.
  What genius thought this was a good you-know-what idea???

  Comment added July 1, 2023 8:54pm

• Fredrico jacobs

  As a member of the Bronx Blue Angels club we fly remote control r/c airplanes flying line of sight we already fly in a class B airspace which we have permits with parks department and FAA . We have fully covered insurance by the A.M.A . All of our aircraft’s have FAA numbers visible and we abide by the rules and regulations. The BronxBlue Angels have been flying for over 50years and we have been teaching young kids how to fly and leading them into opportunities into aviation .

  Comment added July 2, 2023 2:06pm

• Herman Green

  I am writing this comment, because it is necessary. I started flying drones about seven years now. It started as a hobby for me. Satisfying the love for RC, and photography. I have taken the love for the two, to YouTube. Where we do a Livestream, that talks about everything in the unmanned world. From commercial to consumer, and advanced Air mobility. And over the years, I have seen many of changes come from the FAA. I have always felt that I have followed the rules. I have obtained my FAA part 107 certificate. The same one that is obtained by the NYPD drone pilots. And I have registered every one of my drones. As the years have gone by without any fatalities in the industry. Yes it is safer than manned Aviation. You could check the numbers with the FAA. I am now the owner of Those Guys Aerial LLC. We are a small UAS service provider. We specialize in aerial video and photography. We have work with construction companies. This brings me to the proposal that is on the table. There are many of things that are scheduled in construction. But just like flying a drone many things on a construction site are dictated by the weather. And Sometimes deadlines can’t be met for many reasons. Something moving things to another day, and dates change. This proposal seems as if it is a back door to controlling airspace. Something that the FAA does a great job of already. This proposal for a 30-day application process to take off and land, will definitely damage commerce. Your proposal asked about data. Most of the work done in filming with drones, the data belongs to the customer. As a small company your proposal makes it difficult or even impossible for me to take on any immediate work that is time sensitive. As a 30 day application process that, isn’t guaranteed is needed. In the areas where I am operating, I have gone to the local police department and identified myself. Letting them know that I will be in the area working for a construction site, or for whoever I’m flying for. In another there is a juvenile detention center, which happens to be geofenced. The drone can’t even come in to close to the facility. And I identified myself with them as well. And they both seem to appreciate the heads up. Something like that would have been great to propose. The FAA has implemented Remote ID. And it is going to go into effect on September 16th of this year. I am quite sure that you are well aware of that. And I’m quite sure you are well aware of all of the things the FAA has implemented to keep the airspace safe. Your proposal is a passive aggressive way of keeping all drones out of the sky. Or at least that is what it seems at first glance. or is it a way of selling airspace? What I know is it will severely impact a small companies like mine. This proposal creates hurdles that are impossible for a small company to make. As I said before with 30-day applications, and not being able to operate on the date proposed in the application due to weather or any other circumstance. Companies will not deal with that. And they just won’t hire companies like ours. So I asked you is there some other way of making it possible that companies like my own can continue to operate within New York? Like I said before the FAA has implemented Remote ID. We are all part 107 pilots operating within the rules of part 107. I understand the need for rules. But something like this it’s only going to be implemented to control or stop the law-abiding citizens that use this technology for their livelihood. There has never been a law implemented yet, that has been implemented to stop criminals. Criminals will not follow the rules of Remote ID. Nor anything else you implement on top of the FAA’s laws. And I feel that we should go after lawbreakers as they break the law. Not implement things to stop law abiding citizens from conducting their business. At Those Guys Aerial LLC we are a fairly a new company, based here in New York City. I started this company due to being injured on a construction site. Finding myself out of work after six surgeries. And not able to work on a construction site to perform my tasks safely. I could not see myself at my age on social security. So I started this company to earn a living and to help my family. And what you are proposing will definitely directly interfere with that. So I asked you again is there anything anyway that you can come up with anything else that would make it possible for companies to be able to operate? Your proposal talks about safety. Allow me to walk you through a takeoff as a part 107 pilot and remote pilot in command. First you need to obtain airspace clearance through LAANC. Then double check your weather to be sure it is safe to fly. Then the area must be checked to make sure it is safe to take off from your location. Then the aircraft must be inspected with a pre-flight check list. After that you may then put the battery into the drone. And now you are ready to start the drone. Once you are locked into satellites it is safe to take off. All flights are conducted with a visual observer, and some with a crew resource manager. All flights have to have a contingency plan in case of an emergency. To bring the drone down safely. And these are just some the things that are required by the FAA. It Is a standard to have a million dollar liability policy to fly for anyone. So when I look at the proposal for a 30-day application process that does not necessarily qualify me to get approval. I see this as a direct way of interfering with my livelihood, severely harming economic growth. Yes, This Will destroy commerce. I’ll say it once again this proposal makes it impossible for companies to contract out work to companies like mine. I propose to you that maybe you could come up with another step similar to the airspace clearance process. I asked you to reconsider this proposal and try to take steps to influence commerce. As opposed to harming it. I thank you for hearing or reading my comment. Respectfully Herman Green Those Guys Aerial LLC

  Comment added July 3, 2023 1:07am

• Lawrence Clark

  I am a Part 107 pilot and with these new laws: “The New York City Police Department (“NYPD”) is proposing to amend its rules to create a procedure by which members of the public may submit applications to launch or land an unmanned aircraft, including a “drone,” within New York City”. this law is trying to kill commerce within New York City. It is almost impossible to work in Construction with these new proposed laws. By asking to apply 30 days in advance is within reason but. What happens if weather is bad on the day of the waiver and we only applied for that day. That would be commerce lost for that Part 107 pilot that would have been made under other conditions. There has to be a better way for New York City and its Part 107 pilots can still make a living.

  Comment added July 3, 2023 4:32pm

• Paul

  Any rules or regulations created should take into account those directly involved. This will negatively impact so many unfairly.

  Comment added July 3, 2023 4:41pm

• Richard Rizza

  It is ridiculous to lump model aviation hobbyists with operators of commercial UAS. It is NOT a crime to fly model airplanes and it never should be.

  Comment added July 3, 2023 6:32pm

• Rafat Abdelrehim

  Do you guys realize how much commercial revenue you’re getting in the way of? At least Just allow it for commercial use. This city is always behind because of dumb bans that eventually get approved.

  Comment added July 4, 2023 12:40am

• Deneen Pagan

  The proposed rule is unjust and without warrant.
  I feel this new proposal will only hurt the drone community. As a pilot, weather isn’t always on your side plus there’s always that last minute job offer. Having to request a 30 day in advance will completely wipe out any chance we have to complete that job. Paying 150. & up per job is absolutely unfair plus too costly. There’s been more accidents on the road than the air. A better salutation must be thought of. This will hurt any job offering & crush any small business.

  Comment added July 4, 2023 11:25am

• Mo

  I am excited to see the city take proactive steps towards sUAS usage within the city and am glad to read the comments from the community here. I do have some comments and questions regarding the proposed amendments:

  SS 24-03 (a): “An application for permit to take off or land an unmanned aircraft … must be submitted to the Department at least 30 days prior … ”
  – Will a full flight plan be required to be part of this submission? Flight plans would normally include weather conditions at time of flight which does not seem reasonable to include at even 7 days out, 30 days is not feasible. Will weather need to be included as part of the flight details?

  SS 24-03 (b)(11): “A copy of the applicant’s data privacy policy…”
  SS 24-05 (d): “…in the event of a cybersecurity incident…”
  – These sections need further expansion as it is not atypical for recreational/commercial operators to use existing cloud-based services (some of which the City of New York actively uses itself) such as Dropbox, OneDrive/O360, iCloud, etc. As part of this application process are we to provide the data protection and privacy policy of the storage provider? Furthermore, this section should clearly stipulate what is the minimum acceptable criteria for data privacy otherwise approval becomes subjective.

  SS 24-03 (d): “A non-refundable fee of $150 shall accompany the application.”
  – An application fee in general is not an unreasonable ask considering most other cities and jurisdictions carry their own fees for sUAS operation especially for commercial operations. What makes the fee unreasonable is aforementioned subjective / unclear guidelines for what constitutes an acceptable application, especially since it requires a minimum 30 day review period.

  SS 24-05 (e)(1): “Notify each community board for the community district or districts where the unmanned aircraft is anticipated…”
  – I believe this statement is necessary given the population density of the city and the FAAs guidelines around flights over uninvolved persons. However, this step should be included automatically as part of the application review and approval process, not at the end when activity is actively or about to take place. Furthermore, this section would benefit from expansion for clarity including a clear division of responsibilities and authority. As written, hypothetically; if an application is submitted, reviewed, and approved by the Department, does the local community board or representative suddenly have the authority at what is effectively hour zero to stop all operations? Or are they to be informed for informational purposes only.

  Empirically, while I am not against providing the NYPD and City Agencies details required for situational awareness and safety, it seems much more feasible to not double-down on the guidelines that the FAA has already set forth as part of TRUST and Part-107. Why not automate the approval process similar to LAANC approval, and stiffen the penalties for non-compliance?

  As an example, why not have the city provide a portal to submit an application for automatic approval/rejection; include it as part of the existing NYC311 app. Automatic approval could be granted for small scale flights, but manual review and approval would be required for flights involving larger geographical areas or complex flights. Approved flights are granted a QR code to be provided to law enforcement on request indicating all application and flight details including equipment being used, RPICs, FAA Compliance items, etc. Furthermore, the city could institute a mandatory training and credentialling program requiring operators to undergo annual or bi-annual training to stay up to date on NYC’s regulatory guidelines surrounding sUAS usage.

  Comment added July 5, 2023 10:40am

• Daniel Feighery

  The Supremacy Clause of the Constitution of the United States establishes that the Constitution, federal laws made pursuant to it, and treaties made under its authority, constitute the “supreme Law of the Land”, and thus take priority over any conflicting state or city laws.

  The NYPD does not have the supremacy over federal regulations. It’s in the Constitution.

  The overly burdensome actions of the NYPD have destroyed the NYC filmmaking drone business over the last 15 years. Countless business opportunities have been lost. The West Coast filmmaking community of drone pilots has grown exponentially while businesses incorporated in New York have suffered due to NYPD actions.

  Federal regulations are clear: licensed pilots are allowed to fly drones anywhere in the United States within federal guidelines, and the only exceptions in NYC are those dictated by the FAA. NYPD cannot supersede FAA.

  This is why NYC had to settle their lawsuit, and they will lose a court challenge to these proposed regulations in the future.

  Licensed pilots can receive authorization to fly in FAA regulated airspace like Class B airport zones in a matter of minutes. The proposed NYPD regulations are overly burdensome and restrictive to business, with both an unnecessary fee to apply and unnecessary advanced warning time.

  The proposed notification for city council members is well outside the NYPD’s or NYC’s jurisdictional authority encroaching into a federally regulated matter.

  Film companies operate on tight timelines, and these regulations would make regular drone work impossible.

  NYC drone regulations have stunted the growth of federally licensed NYC filmmakers, allowing West Coast filmmaking companies to surpass us. There should be some protection for NYC licensed companies to do the work of filming in this wonderful city. In states that offer tax credits, it is required for local companies to be hired to obtain that benefit.

  Please focus on protecting NYC companies and business, and require NY companies to film in NY, instead of creating onerous and burdensome regulations. Please don’t allow the big West Coast drone companies to swoop in and steal our business after 15 years of harming legitimate NY companies that provide services that benefit New York City. There’s a reason everyone in the world loves filming in NY–don’t make it impossible for the beauty of drone video and photography to show off this amazing city.

  Comment added July 5, 2023 11:39am

• Michael Candelori

  I am a cinematographer and visual journalist. With years of flight experience and FAA licensing I am permitted to my small UAV almost everywhere across the nation, safely, as thousands of professionals do every day. The extra requirements proposed for permitted flight in NYC are onerous and will stifle both news gathering and creative endeavors by all but the largest operations.

  Comment added July 5, 2023 3:34pm

• Luke Rohde

  Drones are an incredible public nuisance, a privacy nightmare, and will quickly become a menace to NYC. Beyond a “wow” factor, they have few legitimate uses that outweigh the disruption they will cause to everyday life.

  Comment added July 5, 2023 3:52pm

• Stefan T Jeremiah

  Would be nice if the NYPD would focus on applying existing laws equally and not creating laws. *cough* parking! *Cough!* everyone gets a placard *cough*

  The FAA is the appropriate body for this matter, not the NYPD.

  That being said…
  30 day permit application is overly draconian for two very transparent reasons.

  1. To deliberately interfere with news gathering. To maintain the ability to shut down photographers at breaking news events/crimes scenes. For the sole purpose of controlling information, and deciding what people get to see. Even patrol officers like to make editorial judgments on what’s newsworthy. Tape mostly goes up, rooftops only get cleared and entire blocks get shut down, only when media professionals arrive. The public are totally fine to film on their phones.

  2. Account for their own inefficiency. It’s a window big enough to allow them to take their sweet time. They don’t hustle when it comes to servicing your requests. 30 days will allow them to keep you waiting on tender hooks for 28 days, most like to only to deny your request on the day of.

  The rest of the proposal is all nonsense, designed to make the process as convoluted and bureaucratic as possible. Most likely in the hopes of putting people off from even bothering, while simultaneously trying to look like they’ve made some kind of effort/accommodation.

  Chances are, even if these rule changes are adopted, the NYPD won’t bother telling its rank and file. And so when you do finally launch a drone 30 days after submitting an application begging to fly. You’ll get shut down by a random beat cop, responding to a call about a drone flying pervert, who’ll then confiscate your drone while you’re left crying “but I haz permit officer”. To no avail.

  Comment added July 5, 2023 4:13pm

• Matthew W Bagwell

  I truly feel that these purposes rules with definitely impact the ability of profession UAS operators to perform their commercial jobs as well as it is an excessive over reach to requires a 30 day notice in order to schedule a job that far in advance. This will significantly reduce the ability of texting pilots as well by restring their ability to reboot this hobby. I ask that you consider restructuring this proposal significantly to not burden UAS PILOTS. Thank you

  Comment added July 5, 2023 5:14pm

• Drew Nash

  Truly an unworkable situation for photojournalists to cover important issues within city limits. Please reconsider the policy.

  Comment added July 5, 2023 5:24pm

• Patrick Klein; Assistant Chief Gerrittsen Beach Fire Department

  The attached PDF Comment is submitted on the behalf of the Gerrittsen Beach Fire Department and Volunteer Firefighter’s Association of NYC to request to the final rule be amended to accommodate drone use by emergency service organizations.

  Comment attachment
  7.5.23-GBFD-Drone-Comment-PK2.pdf

  Comment added July 5, 2023 5:33pm

• Yosbel Sarduy Herrera

  I’m glad that the city finally allows UAS but the bureaucracy of the new rule is excessive and is overruling the FAA laws and norms. Also I don’t heard any mention about the recreational UAS that are very limited in certain spaces made imposible fly on it. Usually safety, privacy are used to justify the old law and the most controversial point of the proposed rules. But the new rules looks like that is intended for keep the same restrictions and for made it only for tue elite that can afford the payment fees. Second should be the city council with the support of the FAA, and UAS operators and specialists who made the rule this is not the NYPD.

  Comment added July 5, 2023 5:56pm

• Eric Williams, Academy of Model Aeronautics Board of Directors, Vice President for New York/New Jersey and Europe

  The Academy of Model Aeronautics (AMA) is both encouraged by the NYPDs attention to safety and security, and we are also understanding of the interests of both commercial and recreational remote control aircraft operators. AMA believes the proposed rules, “to create a procedure by which members of the public may submit applications to launch or land an unmanned aircraft,” require some modification.

  New York City based model aircraft clubs have been highly involved in the educational, family oriented, and community-based activity of model aviation for over a century! The first model aircraft club in the United States was established by Emma Lilian Todd, who started the Junior Aero Club in her New York City apartment in 1908, to foster the education of future aviators. Fast forward through the decades and model aviation has always been an important educational activity for New York City residents.

  There are few activities that capture the imagination of a young person and combine both creativity of the mind with dexterity of the hands, as does building and flying model aircraft. With a society focused on portable devices and fewer hands-on learning experiences, education through model aviation provides a unique and highly rewarding educational platform for youth and adults. A high percentage of our country’s pilots and aviation professionals got their start in hands-on model aviation activities in their youth.

  While the proposed rules procedure provides an exemption for model aircraft flown at areas designated by the NYC Department of Parks and Recreation, the proposal overlooks recreational flying activity at other city locations where the activity occurs with permitting from other governmental agencies.

  One of NYCs model aircraft clubs, The Pennsylvania Avenue Radio Control Society (PARKS) has operated at Floyd Bennit Field in the Gateway National Recreation Area in Brooklyn for many decades. PARKS follows a rigid set of safety protocols, known as the AMA – National Model Aircraft Safety Code, and like other AMA clubs, PARKS and its members are insured by AMA. The PARKS club also has ongoing agreements with the NYPD Aviation Unit (also located at Floyd Bennit Field), local air traffic control, and other FAA representatives in the area. PARKS has a permit from the National Park Service to operate at their designated area. In view of the unique location of the PARKS club, located in a national park that lies within the New York City limits, and to remove future ambiguities, language must be added to the final rule that excludes from any of the NYPD permitting requirements or rules within the proposal: “…take-off or landing that occurs in an area designated by the NYC Department of Parks and Recreation, The New York State Office of Parks, Recreation and Historic Preservation, or the National Park Service…”

  In addition to AMA’s concerns to maintain model aircraft operations for the benefit of New York City and its residents, AMA suggests that the proposed rule include language that recognizes existing federal law. As others have commented, NYPD regulations should not run contrary to federal law. To do so not only create contrary laws and regulations it also creates confusion among law abiding citizens. To this end, AMA would suggest additional language in the regulation that provided an exception to the required permit and other provisions of the regulation: “when unmanned aircraft are operating within the programing of an FAA recognized community-based organization and within the provisions of U.S.C.44809. “

  While we thank the NYPD for their attention to the city’s safety, it is important to reflect on recent history. The specter of unregulated, carless drone flying has dwindled. Reports of sightings and incidents are a fraction of what they were five years ago. For the most part, clueless or careless operators have learned their lesson. The general public gets it! And as we know, criminals do not abide by laws or regulations. AMA would suggest a greater emphasis on education before regulation, and any regulation should be focused on the nefarious operator.

  Established in 1937, AMA is the nation’s first federally recognized community-based organization for model aircraft, representing nearly 200,000 members. AMA has worked with hundreds of federal, state, and local public officials in numerous capacities as both subject matter experts and in representing the recreational model aircraft community. AMA remains ready to assist the NYPD in any way.

  AMA, its clubs and its members thank Acting Commissioner Caban and the NYPD for the opportunity to comment.

  Comment attachment
  AMA-District-2-NYPD-Proposed-Rules-Comments.pdf

  Comment added July 5, 2023 6:40pm

• Sam Cornwall

  As a FAA Part 107 drone pilot who has had to turn down jobs in NYC due to the current ban and rules on UAS operations, I applaud NYPD and the City Council for updating the current ban with a permit system. For the safety and quality-of-life of city residents a permit system for commercial operators is needed. Recreational flyers should stick to specific drone zones in the parks. However, the current proposal does not reflect the realities of commercial UAS operations in multiple ways.

  The 30-day permit application is too far out in advance for most drone operations, especially with no weather window. There needs to be a much shorter time period to apply. Many jobs are arranged less than 10 days in advance. One permit should cover a 48 or 72 hour period to accommodate for changes in weather. This will encourage drone operators to be as safe as possible and not take risks in unfriendly weather conditions.

  The neighborhood notice is currently unworkable and will attract unwanted attention to a permitted UAS operation, encouraging criminals and would-be harassers to descend on the operation. This current requirement should be replaced with the FAA RID system that will be available to first responders in the field and in the office, as well as city offices, community organizers and the public. This will save everyone time and money, while making the information available faster (the FAA RID will report live drone activity) and easier to get. The FAA will be requiring all drones to update their location with the RID system making unregistered and unpermitted drones stand out from the operators who are following all rules and regulations.

  The FAA LAANC system could be integrated with an NYPD system. Much of NYC is already under specific FAA airspace restrictions and requires using the LAANC system to fly a drone.

  The NYC Film Office already handles permitting for the commercial video and photo productions. As many drone operations are for these productions, it would be easier and smoother for productions to go through one agency, the NYC Film Office, instead of two. Permitting through the NYPD sounds like it will create a bureaucratic and expensive process for the applicants and for the NYPD staff and NYPD budget.

  I am excited for the NYPD and City Council to streamline and open the city for drone operations. Approved and safe UAS operations will be a benefit to the city in many ways from streamlining construction and inspections to showcasing New York City to the world. However, the current proposal should be more closely integrated with the FAA systems and take into account the needs of those in the UAS industry.

  Comment added July 5, 2023 7:25pm

• Norbert Norton

  Dear NYPD,

  A drone is a fraction of the size of a bicycle or scooters. Drones have fewer accidents than either of those and do not congest traffic, pose dangers to pedestrians, and do not require infrastructure (bike racks, locks, etc.). And yet the proposal you have to extend permits to drones for their use in the city is an astronomical cost that is multiples above and beyond what you demand for a bicycle permit or scooter license. What you are proposing isn’t a viable solution. Rather you are creating a shadow ban. You’re in the wrong on this. Do better.

  Comment added July 5, 2023 7:45pm

• Simon Gruzmark

  The proposed rule is cumbersome and cost prohibitive. Especially for hobby drone operators. There are other major cities in the US who are very drone friendly. Philadelphia is one of them.

  Comment added July 5, 2023 8:36pm

• Ryan

  How to best evaluate your newly proposed UAS permit rule? Replace “unmanned aircraft” with bicycle and see if it is ridiculous.

  Can you imagine the outrage if NYC put forward a bicycle permit that required a 30 day lead time, carried a $150 non-refundable fee, required insurance, had to provide a “flight” plan describing a starting location and direction of travel, demanded photo ID, and needed to list the make, model, and year of manufacture of the bicycle?

  Did that just sound utterly over the top ridiculous to you? It should, because it is. And that is disgusting.

  Comment added July 6, 2023 7:44am

• Xavier Arthur

  Thank you NYPD for proposing to amend your rules and to create a procedure by which members of the public may submit applications to launch and land an unmanned aircraft like drones within New York City.


  I applaud that the City realizes it must balance the safety and privacy concerns of the public with the significant financial benefit to local businesses (and to the City itself, through additional tax revenue) that will result from modifying the rules for the use of drones. However, the proposal does not show insight into the actual work situations where drones are used.

  First, the use of radio-controlled, flying consumer devices is hardly new technology. In fact, as early as the 1960’s, the radio controlled scale aeromodeling craze swept the country. And in the last decade, drones as both a hobby and a business tool have far surpassed that acceptance. Drones are business tools that provide aerial photography, fire monitoring, waterway monitoring, environmental monitoring, infrastructure inspections, precision agriculture, and entertainment in the form of illuminated sky shows – and all of these areas are expanding exponentially.

  Are there potential hazards when flying a drone? Sure. But a two-pound consumer drone can certainly do far less harm when compared to a 5,000 lb car, based on its mass and speed. Still, people who have never driven in NYC traffic are allowed to drive in the Five Boroughs, simply with a valid driver’s license from anywhere in the United States.

  When people hurt or harass others (with or without a device), there are plenty of existing laws that protect the public that NYPD officers can enforce. Let them do that as needed. Patrol officers have enough to do, and already handle a mind-boggling variety of situations. There is no need to give them more to interpret.

  This proposed rule has several additional problems. First of all, $150 per request, whether approved or not? Sorry, that’s just a money grab, and that’s not going to change anyone’s behavior. Next, although you would require 30 days advance notice to request these paid permits, you make no guarantee of when you’d address such a request – could be one day before, or not at all That’s just unreasonable. Most of the businesses mentioned above require a crew who are likely working on several projects that overlap time-wise. Professionals need to assemble their crew, and that involves coordination on a day-to-day basis. And of course, safe drone flights are dependent on weather and wind. Therefore, 30 day advance requests are entirely impractical.

  Posting notices with people’s names and phone numbers publicly? Do you guys even live in New York? Do you want your names and phone numbers posted anywhere publicly? That’s just creating a dangerous situation for drone operators.

  As far as having data privacy and cybersecurity policies, this is far beyond the scope of work of a professional aerial photographer or videographer shooting for a real estate agent, a roofing inspection job, or an aerial shot for a marketing video. You want us to report something strange that happened during our drone flights? Sure, give us a website or a phone number – that’s a reasonable request.

  Contacting every member of the City Council and each local community board where we fly? Why? This is just a waste of time. They will not be the law enforcement agency ensuring legal and proper behavior. If you feel you must inform these parties, that can be done automatically by NYC.

  In summary, if you actually want a reasonable set of policies that will encourage safe behavior, allow a variety of NYC tax paying businesses to thrive, give you oversight without unreasonable financial requests, have a meeting with some working drone professionals. I, for one, would be glad to help, and I know many here would as well.

  Thank you for your attention.

  Comment added July 6, 2023 3:27pm

• American Council of Engineering Companies of New York (ACEC New York)

  The American Council of Engineering Companies of New York (ACEC New York) is an association representing nearly 300 engineering and affiliate firms with 30,000 employees across New York, with a concentrated presence in New York City. We thank the NYPD for this opportunity to submit comments on the proposed rule.

  About ACEC New York: Founded in New York City in 1921, our association is one of the oldest continuing organizations of professional consulting engineers in the United States. Our members are the professionals who plan and design the structural, mechanical, electrical, plumbing, civil, environmental, fire protection, and technology systems for buildings and infrastructure across New York and the world.

  ACEC New York, and many of our members, have a proud history of providing technical expertise to city agencies and officials as needed in order to update, advance and amend city laws and codes to address modern needs. For example, during the city’s last comprehensive Construction Code revision cycle (2017 – 2021), over 100 of our members supported the city’s work by volunteering their time and expertise through serving on the DOB’s Technical Committees convened to update the code.

  Specific comments to the rule: Our Public Policy Committee reviewed the NYPD’s proposed rule to create a permitting process that will allow lawful take-off and landing of unmanned aircraft, including drones, in the city. In general, we are in favor of this proposal as it is better to have this rule in place rather than the absence of a rule. Our main constructive comments are as follows:

  1. The 30-day notice before each flight is not practical. It is not possible to predict the exact flight details such as date, time, and the drone model a whole month ahead. A more reasonable request would be to reduce this notice period to 10 business days.
  2. The rule in Paragraph 24-05(e) that says operators must inform the local community board and City Council members at least 48 hours before taking any photos. Since operators take photos during every flight, this requirement seems excessive. The purpose of this notification isn’t clear either. Furthermore, physically posting notices around the flight area seems unnecessary and impractical. Also, it is currently unclear whether operators can apply for flight permission online. There is also a risk of confusion if there is more than one flight in a day from different operators It would be far more convenient and efficient if operators could submit an online application, and if the NYPD could maintain a publicly accessible online database showing all upcoming drone flights, so anyone concerned about flights in their area can check who is conducting them.

  The drone industry generally thinks it is best to follow Federal CFR Part 107 – a set of national rules that cover all the important aspects of flying drones. More about these guidelines are available here: https://www.droneprepared.org/
  Some aspects of the proposed rules, mentioned above, are excessive and impractical. We have offered recommendations to keep the rules’ original intent intact while making them more practical and easier to follow.

  If ACEC New York and our members’ professional engineering expertise can be of assistance, please contact us at any time.

  Comment attachment
  ACEC-NY-comments-to-NYPD-re-permitting-process-for-Drone-use-in-NYC.pdf

  Comment added July 6, 2023 4:20pm

• TO

  I’m a commercial helicopter pilot regularly operating in NYC airspace primarily in the aerial filming industry It is agreed that there is a need for drones in the commercial sector in NYC, but there are significant risks associated with manned aircraft, specifically helicopters, if proper precautions are not put in place. NYC has the highest population density and one of the most complex airspace in the country. A few years ago, a drone hit a military helicopter over the water, just south of the Verrazano Bridge. If that drone hit a civilian helicopter over a busy part of Brooklyn or Manhattan the results could have been fatal for us in the air and for the people on the ground.

  Obtaining a commercial drone license is relatively easy. If you wake up on your 16th birthday and have $150 to spare, and can pass a 60-question multiple choice exam with anything over a 70, you legally join the ranks of the commercial drone industry. In other words, since there’s no practical exam, you can call yourself a commercial drone pilot having never actually flown an unmanned aircraft. The idea of that is frightening to pilots who spend a lot of their days and nights in the sky over NYC.

  There is no doubt that drones are a great tool for a number of different industries here in New York City, but safety needs to be paramount.

  In that interest, New York City should require commercial drone pilots to have a private pilot’s license in order to obtain a permit to work here. There is no way a new commercial drone pilot will understand the complicated airspace of this city, hence creating risk. Drone pilots who have a private pilots license, by nature, would take more precautions because of their flight training, ground training, and experience knowing what it would be like to have a drone in the windscreen of their aircraft.

  When the FAA first rolled out the drone program, they required all UAV operators to have some type of manned aircraft certification, which was known as the 333 exemption.

  This requirement was held for 2 years before Part 107 (commercial drone certification) was launched. Mimicking this same type of guideline for the initial 2 years of this proposed permitting process, the city could have the ability to reduce that requirement, if the data supported it.

  At the end of the day, ensuring the safety of all people coexisting in the same airspace is paramount.

  Comment added July 6, 2023 5:07pm

• James Earl

  This is unfair and nothing more than yet another poor attempt at money grabbing.
  What isn’t understood is that NYC Stands to loose (through rule implication) the ability to utilize the unrealized “one of a kind” works of “ART” generated by every single done that captures a photo while within the skies over NYC of its skyline.
  With ours – (NYCs) skyline being the absolute most popular on the planet, I wonder how this consideration hasn’t crossed the mind of anyone on the panel of consideration in reference to the proposed rule[s].
  This or these rules would be counterproductive to the City, public, part 107 operators & hobbyist alike. There will be an “INFRINGEMENT” of free expression should said “rules” pass – we are over taxes & regulated as it is……….ENOUGH…

  Comment added July 6, 2023 5:14pm

• Adam Roberts

  July 7, 2023

  Community Housing Improvement Program Testimony
  on Proposed NYPD Drone Rules

  Thank you for holding this hearing today. I am Adam Roberts, Policy Director for the Community Housing Improvement Program, also known as CHIP. We represent New York’s housing providers, including apartment building workers and owners. We are here to support legalizing the use of drones.

  Drones can significantly improve the safety of New York’s apartment buildings. Most critically, they will enable building facade inspections to occur more efficiently, as operating a drone is less time consuming and expensive than building and maintaining scaffolding. The use of drones is also likely to produce more accurate facade inspection reports for Local Law 11, when compared with in-person visual inspections through scopes and cameras from the ground level.

  Regular facade inspections with drones could reduce the time and expense of Local Law 11 work. If drone use enables Local Law 11 inspections to become easier and less costly to perform, these efficiencies could allow for more frequent inspections, allowing facade issues to be caught sooner. This would lead to less time-consuming facade work, ultimately reducing the length of time scaffolding remains up.

  Outside of facade inspections, drones can also assist with marketing apartment buildings and even individual units. Throughout the country, drones are regularly used for taking pictures for marketing materials in real estate transactions. The inability to do so in New York makes buildings and apartments more difficult to market.

  Drone use must be properly regulated to ensure the safety of the general public. The compliance scheme adopted for our industry should consider the professional qualifications of applicants. This is particularly critical for facade inspections, as those operating drones should be the same professionals who are already legally allowed to perform Local Law 11 inspections. This will ensure that those hired to use drones to inspect facades have the expertise to determine a facade’s state of repair.

  Drones offer enormous potential for our industry and the city as a whole. They can make our buildings safer, reduce the burden of scaffolding on our streets, and improve access to New York’s apartments for rent. Therefore, we strongly support the legalization of drones. Thank you.

  Comment attachment
  7.7.2023-NYPD-Drones-Hearing-Testimony.pdf

  Comment added July 6, 2023 6:06pm

• Fred Guenther

  Let’s make no bones about it. This is an anti-business law, and will hamper small firms’ ability to conduct business within the NYC limits. As a professional land surveyor, I use drones to collect data for mapping of land. I am US 107 certified and know full well the FAA regulatory process regarding drone flight which works well in the rest of America. It is my professional opinion that that FAA regulatory umbrella is sufficient for regulating flight in the New York City area. The NYC permit process outlined is ungainly and impractical for anyone flying a drone for business. 30 days is a ridiculous application time when compared with the FAA instantaneous approval via a smart phone. It’s also ridiculous because after 30 days, the weather could shift and conditions could be unfriendly for flight for that day. Then what? Is there a back up process? Or does the permit simply expire and someone has to apply again? I don’t know any businessman who can operate under those limits. It’s hard enough to make money nowadays without business-throttling regulations added to our backs.

  I urge the City of New York to jettison this ill-conceived proposal and develop one that encourages business and serves all New Yorkers, providing for safety, prosperity and well-being.

  The recreational flyer is also unfairly encumbered by this new regulation, as flying is stifled in the New York City limits. Videographers and photographers are silenced as another freedom is taken away for no other reason than instituting some kind of performance theater, so that it looks like somebody is doing something about something. In the early 2000’s, in the days after 9/11, the NYPD strove to ban photography of the New York subway system. It was a similarly foolhardy effort as a form of security theater instead of solid, common sense regulation and public policy.

  This proposal of permitting and regulation of drones is so bad it needs to be fought on all legal levels.

  Thank you for your time.

  Comment added July 6, 2023 8:39pm

• Stan Khlevner, COO @ Remote Optix

  In an age characterized by rapid technological advancement and innovation, regulations play an important role in maintaining a balance between technological adoption and public safety. Recently, the City of New York has proposed a new permitting process for commercial drone flights within the city limits. However, an in-depth analysis reveals that certain aspects of these regulations, particularly the application fee and notification window, could unintentionally hinder the industry’s growth and foster illicit and reckless drone usage.

  The proposed drone permit process involves a non-refundable $150 application fee, a figure significantly higher than many small businesses and independent operators might be able to afford. This prohibitive cost does more harm than good; it disincentivizes legal compliance, potentially leading to a surge in unauthorized and potentially unsafe drone operations. A more reasonable and accessible fee, suggested in the range of $20 to $40, would ensure affordability without compromising the objective of maintaining order and safety in drone operations. More importantly, it would encourage wider adoption and compliance, fostering a thriving drone ecosystem that includes not just large corporations, but also small businesses and independent operators.

  The second major, and quite honestly more pressing concern revolves around the proposed 30-day notification window, which seems excessive and operationally challenging. Such a lengthy notice period can create significant obstacles for businesses and operators that need to react quickly to client needs & requirements, unpredictable weather and other circumstances that don’t allow for long lead times. It’s critical to strike a balance between ensuring safety and allowing businesses to operate efficiently. Reducing this period to a more practical timeframe, perhaps 7 to 10 days, would still adequately serve public safety interests without imposing undue burdens on drone operators. In today’s age, there should be no reason adequate resources can’t process 100’s of requests a day.

  Importantly, the proposed regulations must consider the safety record of drone operations. According to current data, drones represent the safest form of aviation in the United States. Excessive regulation is not only unnecessary but could also inadvertently compromise this safety record by encouraging illegal drone usage.

  Lastly, it’s crucial to note that several industries, particularly construction and engineering, stand to benefit enormously from a more flexible drone policy. Drones offer incredible value to these industries, from conducting aerial mapping and monitoring job sites to improving operational efficiencies and reducing human risk. By imposing prohibitive fees and unnecessary bureaucratic hurdles, we risk stifling these benefits, ultimately hindering industrial growth and innovation.

  My company, Remote Optix, conducts routine, safe commercial drone flights at multiple sites throughout the United States. Sometimes logistical delays and other construction-related setbacks change our flight schedule within a very short timeframe. How will this proposed regulation help get our customers the valuable data they need to ensure their projects can stay on schedule and aim to be on-budget? If the permit process can account for long-term engagements at a particular site, that would also be ideal. If it rains on Monday and we have to fly on Tuesday, there should be a simple notification mechanism of communicating this change if the city feels the impending Remote ID requirement doesn’t provide enough notification and flight documentation.

  While the safety and privacy concerns associated with drone operations should not be overlooked, it’s equally important to avoid overregulating an industry that has demonstrated significant potential. A balanced and fair permitting process that fosters innovation and growth while ensuring public safety is of paramount importance. The City of New York has an opportunity to set a precedent for other cities, but to do so, it must reconsider the currently proposed drone permitting regulations. In doing so, it would encourage compliance, enhance safety, and allow sectors such as construction and engineering to harness the benefits of drone technology. Our industry has unlocked value for a number of other, very important industries in favorable operating environments; please don’t hamper our ability to add tremendous value to the companies and organizations that call New York City home.

  Comment added July 6, 2023 9:07pm

• Jonathan Atkin

  Kindly see PDF attachment

  Comment attachment
  2023_07_07-NYPD-Drone-Hearing.pdf

  Comment added July 6, 2023 9:31pm

• Charles Di Bartolo

  You are making a good first step towards allowing business drone flights to happen in NYC, but please make the requirements achievable. Filing a permit 30 days in advance for something that requires good weather is impossible and then having to refile if it’s refused for any reason with another fee is ridiculous. It feels like you would rather not allow drone flight in NYC. This is one reason why New Yorkers are moving out in droves. Please make a reasonable effort to allow commercial Drone Flight by qualified professionals to be attainable by small businesses in NY. I am a commercially licensed drone pilot, with insurance and the same BPERP certifications that police and firemen take. I am looking to be a responsible contributor to NYC Drone flight for commercial use. NYC needs this. Thank you for listening.

  Comment added July 6, 2023 10:19pm

• Calvin Jose

  I have a drone that I only use when traveling because I live in Manhattan and I can’t fly in the city. I even do freelance projects for small businesses and real estate companies but having a big no fly zone in NYC causes issues for my longtime hobby and secondary source of income.

  Comment added July 6, 2023 11:13pm

• Mickey H. Osterreicher & Alicia Calzada

  See attached Comments of the National Press Photographers Association (NPPA) (corrected version) joined by ten (10) other organizations. Thank you.

  Comment attachment
  NPPA-NYPD-Comment-Avigation-Rules-07-07-23-1.pdf

  Comment added July 7, 2023 7:34am

• Scott Shtofman

  The Association for Uncrewed Vehicle Systems International (AUVSI) thanks the City of New York for the opportunity to collaborate on safely expanding drone operations in New York. Please find our comprehensive comment attached.

  Comment attachment
  AUVSI-NYC-Drone-Permitting-Comment-Final-07-06-23.pdf

  Comment added July 7, 2023 8:07am

• Michael Wiggins

  Good morning I’m glad to have an opportunity to comment. I’ve been a hobbyist player for about seven years. I’m building a business for Drones services. I hope that you guys will allow a small businesses to flourish in New York City for allowing us to takeoff and land. please do not make the rules so strange with that make it virtually impossible for small businesses start I think that Drones will bring a needed value to the workflow. Please help the little guy like me who follow the rules and do everything according by the book.

  Comment added July 7, 2023 8:20am

• John G. Cohan

  As the president of the Empire State chapter of AUVSI, I support the comment submitted today by AUVSI and look forward to the opportunity to collaborate with the City of New York to enable the expansion of safe drone operations. You can reach me @ 516-567-1874. I will be glad to assist in any possible. Thank you.

  Comment added July 7, 2023 8:48am

• Brendan Cochrane

  As a production company owner who has lived and worked in New York City for over 40 years I have watched and seen numerous changes to the City and policy.
  I think having a starting point for framework is great, but I would like to see safety training, implementation of emergency plans in the event of an emergency. A modelled protocol and much like the Mayor’s Office has a list of vendors who work with the MOFTB – a list of drone companies and or operators with both NYPD and MOFTB. This would and could expedite any 30-day window as they would be on file. We have a lengthy permit history so when our applications get submitted, they know we have done numerous jobs safely and efficiently. The other aspect of this is that much like any community, preference should be given to New York businesses and companies who know, understand, and appreciate New York. The converse is that out of state operators and companies come to New York take a leave often with no desire to contribute to the city other than taking images away. I would suggest much like other career paths require references that lone wolf and out of state businesses require references from New York Businesses and or production companies with a physical presence in New York. I own the production company Digital Seven http://www.digitalseven.nyc and started a safety company called Safesets.nyc I would welcome a discussion on any pilot program in conjunction with experienced operators to find a balance to all this that can work for everyone to find a safe and manageable balance for law enforcement and civilian and commercial drone pilots. Thank you. Brendan Cochrane

  Comment added July 7, 2023 9:16am

• Lionel Delevingne

  I love drones but it is my opinion that unless they are highly regulated, drones to be operated in a city environment represent an added public threat to privacy and safety.
  I see these NYPD recommendations as wise for the rest of us.
  Thank you for allowing comments.

  Comment added July 7, 2023 9:23am

• Joe Fazioli

  Honestly, I’m glad to see some progress, but it is simultaneously too much and not enough.

  NYC is the only major metro in the US to say “no drones” without a clear, simple permitting process. If a commercial drone pilot can use an app to get clearance for controlled airspace, instantly, and for free, why should NYC be any different? The FAA has put extensive research into integrating sUAS into the national airspace, so this is redundant and unnecessary; it’s a waste of city time and resources to even write these documents.

  Meanwhile, infrastructure is crumbling, and buildings are years behind on inspection schedules.

  Simplify this process, or eliminate it altogether. The national airspace is well regulated by the FAA, and, like national parks, is a resource for all Americans, not a select few who can waste time and money fighting their way through an intentionally onerous permitting process.

  Comment added July 7, 2023 11:05am

• Josh Levin

  To: New York City Police Department
  From: Josh Levin, Vice President, Northeast Region, Motion Picture Association
  Date: July 7, 2023
  RE: Motion Picture Association Comments to NYPD Proposed Rules on Drone Use

  The Motion Picture Association (MPA), on behalf of its member companies, is submitting comments to the New York Police Department (NYPD) on their proposed rules on the use of Unmanned Aircraft Systems (UAS)/drones in the city. MPA is the trade association for the leading producers and distributors of movies and television and streaming series. MPA’s members include Walt Disney Studios Motion Pictures; Netflix Studios, LLC; Paramount Pictures Corporation; Sony Pictures Entertainment Inc.; Universal City Studios LLC; and Warner Bros. Entertainment Inc.

  The use of UAS is helping moviemakers push creative boundaries and producing the kinds of scenes and shots we could only imagine just a decade ago. Beginning in 2014, the Federal Aviation Administration (FAA) began approving exemptions to the federal prohibition on the use of UAS for commercial purposes. Among the first exemptions granted were those for closed-set filming. These exemptions, issued under Section 333, provided for nearly 30 safety and operational limitations. The Operations Over People rule took effect on April 21, 2021. Drone pilots operating under Part 107 may fly at night, over people and moving vehicles without a waiver if they meet the requirements defined in the rule.

  We look forward to the use of UAS in New York City. While UAS are not a complete substitute for manned helicopters in filmmaking, they are safer, more sustainable and cost effective, produce little effect and noise, and are a more flexible alternative in many cases. In order to use this alternative, we have outlined questions and concerns regarding the proposed rules.

  Application Process:

  For the use of film, television, and streaming production this permit period of 30 days is inconsistent with other jurisdictions who have a thriving production community and would be overly restrictive for our productions. In the State of California, those jurisdictions within the domain of the California Film Commission allow up to seven business days for the film commission to process requests for the use of drones. In Los Angeles City, the use of drones is tied to the FilmLA’s permit process and the permit approval period is 96 hours. The City of Chicago, which has similar building height and density, requires five business days for permit requests using a drone. These, and other jurisdictions, understand the uniqueness of our industry and have offered a permit period that works for our industry and allows sufficient time for the appropriate departmental review. This timeframe is also inconsistent with the NYC Film Office film permit filing period of two business days and the NYPD Movie and TV Unit’s three-to-four-day approval of stunts and driving scenes.

  Permit Conditions

  Currently, when a film permit is obtained, the Film Office issues the appropriate street activity and parking notification to the community about when/where filming activities will occur through the Citywide Event Coordination and Management flash notification system. This includes automated notifications to the local state senator, assembly member, borough president, city council member, and community board. Additionally, productions are required to post no parking signage on lampposts, sign poles, and trees for the impacted blocks that include the time and date of the shoot along with the project name, locations department contact name, and a phone number. In the proposed rules, it would require a production to notify each community board for the community district or districts, and each member of the City Council for the council district or districts where a drone is anticipated to capture or transmit still images, audio, or video as well as place signage in the impacted area. Currently, those notification rules do not apply to helicopter scenes that follow an actor or vehicle on the ground making the proposed NYPD drone posting rules redundant and excessive for film productions. We request similar notifications for helicopters, by way of the Notify NYC service, which is New York City’s official source for information about emergency alerts and important city service, overseen by Emergency Management.

  The proposed rules do not address the issue of delays once an application has been approved. For example, if a production has a permit for a particular day and there are weather conditions or other delays that prevent use of a UAS on the stated permit day, what is the process for rescheduling? Would the production have the flexibility to quickly submit another time/day within the parameter of the current drone permit? Would the production need to reschedule and pay an additional $150 permitting fee to restart the application process on top of the proposed non-refundable $150 permitting cost? We seek clarification since production schedules are very tight and, in some cases, could result in an entire project being scrapped because a quick turnaround to reschedule or appeal a rejection are not granted quickly costing productions and studios millions of dollars as well as opportunities for further economic benefits to the city and community.

  Take-off and Landing Site

  The proposed rules state that take-off and landing mean the locations designated by the Department of Transportation (DOT) pursuant to section 10-126 of the Administrative Code. Does this mean that take-off and landing would only be permitted in locations already deemed for aircraft use by DOT such as heliports and other similar locations? Or does the NYPD mean that other locations will be designated by DOT for the use of UAS? Our productions would need the flexibility to take off and land near where filming activities would be taking place and would contain the flight path for a smaller area. We are also aware that other agencies could be part of the application approval process such as NYC Parks or the Port Authority of New York and New Jersey, which could cause further jurisdictional permitting issues.

  We look forward to working with the NYPD on these rules and welcome a meeting to discuss these issues further since we have initial concerns that there will be application processing constraints that would have an impact on productions utilizing this much needed tool. We hope to remedy these issues so drone use can help New York City productions soar to new heights while bringing in additional permit fees and tax revenue for New York City. Thank you for your time and consideration.

  Sincerely,

  Josh Levin
  Vice President, State Government Affairs
  Northeast Region
  Motion Picture Association

  Comment attachment
  MPA-Testimony-NYPD-Proposed-Rules-on-Drone-Use-07.7.23.pdf

  Comment added July 7, 2023 11:07am

• Katherine O'Sullivan

  We do not need any more manned or unmanned flying machines in NYC air space. Please do not amend the rules to allow more.
  Our privacy is already under attack on so many fronts. This is another privacy invasion.

  Comment added July 7, 2023 11:29am

• Patrick Klein; Assistant Chief Gerrittsen Beach Fire Department

  Thank You for the opportunity to comment in person today. The GBFD and VFA wish to submit one supplemental comment. As mentioned at the meeting: because our organizations are non for profits 501(c)3’s, and not part of a local government or political subdivision, we cannot operate under an FAA Certificate of Authorization as specified in the proposed Rule § 24-02.
  We would also note that under the NYC avigation law, Administrative Code of the City of New York § 10-26(c): the NYPD’s rules cannot contravene a city statute allowing for avigation of “an aircraft to takeoff or land … in an emergency.” Such emergency operations are the core of our organizations operations.

  Thank you for consideration of our previous comments.

  Comment added July 7, 2023 11:46am

• W WHITE

  This proposed rule will essentially destroy the hobby of so many law abiding citizens of this city. These restrictions will NOT eliminate the threat posed by bad actors because we all know that they don’t play by the rules. The implementation of a system to locally register drones in the city and issue term permits would be more appropriate – similar automobiles. Aeroscope and/or remote ID could detect drones with permits and drones without.

  Comment added July 7, 2023 12:44pm

• The Commercial Drone Alliance

  Please see attached comment of the The Commercial Drone Alliance.

  Comment attachment
  CDA-Comment-to-NYCs-proposed-drone-ordinance-7.7.2023.pdf

  Comment added July 7, 2023 12:51pm

• Richard Bogart

  To Whom It May Concern,

  I am Richard Bogart, a professional videographer specializing in capturing breaking news events, and a certified Part 107 drone pilot. I am writing in response to the proposed drone regulations by the New York Police Department (NYPD). I want to express my concerns and offer constructive feedback on several aspects of these proposed rules.

  1) The first area of concern pertains to the redundancy of the proposed rules in light of the comprehensive regulations already instituted by the Federal Aviation Administration (FAA). The FAA’s rules, particularly with the advent of Remote ID in September, offer robust and detailed regulations that govern drone usage effectively. The Remote ID system provides necessary transparency and gives both the authorities and the public crucial information about drone activities in their vicinity. I believe this federal system, paired with existing tools and devices that NYPD could utilize to track and mitigate bad actors, should suffice in maintaining safety and order in our city’s airspace. Adding another layer of city-level regulations seems unnecessary and could potentially complicate the operations of drone users like me who already meticulously adhere to the FAA’s stringent rules.

  2) The nature of my work as a breaking news videographer is unpredictable and time-sensitive. The proposed requirement for days-in-advance notice for drone flights is impractical for my field of work and potentially impinges on my First Amendment rights to free press and free speech. Any delay or hindrance to my ability to document and report news events could undermine the core principles of my profession.

  3) The proposed requirements for a cybersecurity policy, notifications to community boards, and the blurring of individuals in footage appear excessive and inconsistent. For example, the footage produced by NYPD’s own units, such as the Aviation Unit or the body-worn camera unit, doesn’t seem to adhere to these requirements. I respectfully suggest that what can be viewed from a public vantage point should be fair game for filming without additional restrictions.

  4) The proposed rules focus primarily on the NYPD and FDNY Public Aircraft COA as the only first responders, overlooking the numerous law enforcement agencies, fire departments, and approximately 60 EMS agencies operating within New York City. As it stands, these regulations could potentially render existing drone programs illegal and discourage the establishment of new ones, negatively affecting public safety efforts where drones have proven invaluable.

  To strike a balance between facilitating responsible drone use and ensuring public safety, I propose a simpler permitting process:

  Proposed Permitting Process

  1. Application Submission: Drone operators submit an application including their contact information, FAA Remote Pilot Certificate number, drone details, purpose, and basic operational area.

  2. Permit Review: NYPD verifies the applicant’s information, checks FAA compliance, and for emergency services applicants, confirms their status.

  3. Permit Issuance: If approved, NYPD issues a permit allowing drone operations in the specified areas for the specified purposes.

  4. Emergency Drone Use: Permit holders can operate drones immediately in emergency situations, reporting their usage to NYPD as soon as possible afterward.

  5. Non-Emergency Drone Use: For non-emergency drone flights, permit holders are required to provide a 24-hour notice including flight time, location, and purpose. The NYPD may temporarily restrict flight plans in the interest of public safety, security concerns, major events, or during emergency situations. All restrictions should be aligned with FAA guidance, reasonable, clearly communicated, and based on predefined criteria. Denied flight plans will be accompanied by a clear explanation, and a fair system to address grievances or appeal will be in place.

  6. Data Privacy Compliance: Operators follow FAA guidelines and local laws regarding data privacy. No additional data privacy requirements are imposed at the city level.

  7. Penalties: Violations may result in fines and permit revocation.

  I respectfully suggest a balanced approach that allows for responsible drone operations without undue infringement on operators’ rights. I trust my feedback will be taken into account when refining the proposed regulations.

  Sincerely,

  Richard Bogart
  Part 107 Certified Pilot and Breaking News Videographer

  Comment added July 7, 2023 1:01pm

• Jay Mulakala

  Drone technology today is far safer, more reliable, and more compliant than it has been in years past. While I can understand the security and safety concerns people have had over flying drones in NYC, at the same time there are 100s of thousands of operators world-wide safely flying drones for commercial purposes that help us maintain our buildings, put construction workers out of harms way, and ultimately protect the public.

  NYC is behind in this regard, and I really hope we open up the possibility for companies and the government to fly drones responsibly in NYC. Drones can benefit NYC greatly as many other cities have over the past several years.

  Comment added July 7, 2023 1:09pm

• Paul Rose

  I commend NYC for the proposed amendment to the avigation law. However, these new rules are overly restrictive.

  While I understand the need for controls in a congested area like NYC, the proposed solution of a $150 non-refundable fee with a 30-day advance notice is impractical for most commercial sUAS operations. This industry typically operates on shorter notice, often a week or two at best.

  Additionally, the notification process outlined in the proposal presents a similar problem to the existing avigation law, making it nearly impossible for drone operators to legally operate in NYC unless they are part of a large production. It is unfeasible for drone operators to notify all residents and community boards in the area of their planned activities, and last-minute weather delays are not accounted for in the process.

  A more practical approach would be to leverage the upcoming implementation of Remote Identification (RID) by the FAA on September 16th this year. Under RID, all registered drones will be required to broadcast relevant information, including the location of the drone and operator. Responding law enforcement officers can utilize a mobile app to access this information quickly and efficiently. While operator name and number may not be available, the RID serial number can be linked to the drone owner, and law enforcement agencies can obtain that information from the FAA when necessary. The GPS-based elevation data provided by RID also enables officers to identify the specific location from which operators are flying, such as rooftops.

  It is essential to acknowledge that not everyone should be flying drones in NYC or other densely populated cities. However, there are numerous instances where drones can be used safely and responsibly.

  I strongly encourage the committee to reconsider the proposed ordinance and collaborate closely with all stakeholders to develop a more viable solution that addresses the concerns of all parties involved.

  Sincerely
  Paul Rose
  Multivista

  Comment added July 7, 2023 1:15pm

• kenneth stewart

  To Whom It May Concern,

  Please find attached NUAIR’s comments in response to New York City Police Department’s (NYPD) request for comment on its proposed rule to establish a permitting framework for uncrewed aircraft (UA or drone) launch and landing operations in New York City.

  Regards,
  Ken Stewart

  Comment attachment
  NUAIR-Comment-to-New-York-Citys-Proposed-Rule-for-Permitting-UAS-Launch-and-Landing-final-07072023.pdf

  Comment added July 7, 2023 1:54pm

• Eaton Bryce

  If these rules changes take effect please hold learning institutions harmless and exempt. Schools such as Vaughn College, NY Tech and some City schools as others that are involved in drone technology and development should have the absolute right to continue their coursework without hindrance.

  Comment added July 7, 2023 2:33pm

• Barrett Doherty

  The FAA has already established clear rules, licenses, and protocols regarding the operation of drones in the National Air Space(NAS). The proposed rules are only adding extra layers of bureaucracy and unrealistic timelines (30 day requirement to file for a permit) to licensed professional pilots. By FAA regulations are pilots who receive any kind of compensation for their work must be Pt 107 license holders. The FAA has provided a working authorization system for drones to access restricted airspace through the LAANC system. FAA authorization should be enough to safely operate a drone within NYC. Community Boards and Council members are not authorities on NAS rules and regulations. And I fail to understand why they should have any thing to do with a flight that the FAA has already approved. As a commercial pilot, most of my commissions are hired a week or two before the flight. Thirty days is an unrealistic timeline to conduct business. Drones are a useful innovation for society. NYC should be supporting that, not creating layers of bureaucracy.

  Comment added July 7, 2023 3:12pm

• Consumer Technology Association (CTA)

  Attached.

  Comment attachment
  CTA-comments-regarding-NYPD-proposal-7-7-23.pdf

  Comment added July 7, 2023 3:22pm

• Todd Maisel, contributing editor, AMNewYork, NYPPA

  As a member of the NY Press Photographers Association and 40 year member of the media, I feel that the proposed rules as offered are overly restrictive and make it impossible for members of the media to use drones as a tool in news gathering.

  The media has sought to eliminate the need for helicopters in their news gathering to cut the massive costs and to make it safer for the public as crashes have occurred from time to time. Also, it would eliminate the excessive noise created by helicopters in news gathering.

  A 30 day delay or even a single day delay for a news operations is tantamount to a life-time. The rules also override FAA rules for those certified by federal regulation and would not stand up in court and therefore should be eliminated from the proposal.

  Comment added July 7, 2023 3:57pm

• Israel kochin

  The previous definition of an aircraft included “captive balloons.” Without an alteration of that provision would a kid holding a helium balloon still be at risk of being cited with a misdemeanor?

  Comment added July 7, 2023 4:53pm