Tell the FAA They Need to Protect Birds and Ecosystems from Drones Now

  • by: Will Anderson
  • target: The Honorable Michael P. Huerta, Administrator Federal Aviation Administration

The Federal Aviation Administration (FAA) has begun to update regulations on the operation of drones. What they do now will set the stage on how much or how little birds, wildlife, people, and ecosystems will be protected from the hundreds of thousands to over a million drones that will fill the air in the coming years.

However, the FAA has excused itself from any environmental reviews but is taking comments on its proposed rulemaking.

Drones/UAS will provide substantial benefits and advantages for protecting ecosystems and human well-being. Nevertheless, they must be used as tools appropriately and in numbers that will not erase birds from the sky nor create social and environmental harms to the humans below. Their new and unique presence and characteristics are precedent-setting. What must stop is the increasing numbers of UAS—public, civil, and model drones—being allowed to fly without appropriate NEPA examination and social approval.

The FAA thinks it can get away with ignoring the National Environmental Policy Act (NEPA) because it is addressing one class of drones and not the others until later. However, NEPA requires federal agencies to look at cumulative environmental impacts. Our goal is to get the FAA to conduct an Environmental Assessment and then an Environmental Impact Statement about the impacts of drones befoe allowing an unlimited number of these machines to fly.

Formally stated, our response to the Notice of Proposed Rulemaking (NPRM) for the Operation and Certification of Small Unmanned Aircraft Systems (UAS), docket number FAA-2015-0150 is that the FAA must conduct an Environmental Impact Statement (EIS) under NEPA before proceeding further.

According to Unmanned Aircraft Systems (UAS) Service Demand 2015 - 2035 Literature Review & Projections of Future Usage, “… the following are projections of UAS fleet size by user in 2035: Department of Defense ~14,000, with additional ~5,000 having optional pilot augmentation (Air Force ~3,500; Navy + Marines ~2,500; Army ~10,000); Public Agencies (Federal, State, & Local) ~70,000. Total UAS vehicles will approach ~250,000 by 2035, of which ~175,000 will be in the commercial marketplace.” Significant is the fact that these figures do not include the far larger number of users in the model/hobby UAS category. Amazon.com is reportedly selling ten thousand drones per month.

Find detailed information at Green Vegans, a nonprofit human ecology advocacy organization.

Administrator Huerta, stop this rulemaking process and implement NEPA today.

The Honorable Michael P. Huerta, Administrator
Federal Aviation Administration
800 Independence Avenue, SW
Washington, DC 20591


Dear Administrator Huerta,
We urge you to implement the National Environmental Policy Act (NEPA) before proceeding further with the FAA Notice of Proposed Rulemaking (NPRM) for the Operation and Certification of Small Unmanned Aircraft Systems (UAS), docket number FAA-2015-0150.  


We understand the consequences of human behavior and agency decisions that destroy ecosystems and accelerate the loss of biodiversity. The NPRM unwisely limits its concerns to safety in the national airspace (NAS), public safety on the ground, and costs to drone owner – operators for compliance with the FAA Rule. Not until page 161 of the NPRM does the FAA mention the environmental impacts of its far-reaching actions, and then only to deny there are any. 


The FAA decision to categorically exclude NPRM FAA-2015-0150 from the NEPA statutory requirements is arbitrary and capricious. Privacy and fear of government overreach is a constant concern (social impacts on the human community). Yet, there is no examination of the issue in the rulemaking. The FAA is committing to actions before obtaining the clarity, data, and broadened public examination of the environmental impacts from drones. Only an Environmental Impact Statement can accomplish that open process.


Drones/UAS will provide substantial benefits and advantages for protecting ecosystems and human well-being. Nevertheless, they must be used as tools appropriately and in numbers that will not erase birds from the sky nor create social and environmental harms to the humans below. What must stop is the increasing numbers of drones being allowed to fly without appropriate NEPA examination and social approval.


We petition you, Administrator Huerta, to intervene follow the law. Start the NEPA process today.

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