As noted on our Home page, Kelly Law UAS has more than more than three decades of experience practicing before federal agencies like the FAA. Specifically, with respect to drone law, Kelly has
• Filed timely Comments in the FAA’s Notice of Proposed Rulemaking in Docket No. FAA-2015-0150, 80 Fed. Reg. 9,544 (February 23, 2015) on behalf of NetMoby, Inc., on April 24, 2015, ID No. FAA-2015-0150-4054. See the link to the Comments at Regulations.Gov here http://www.regulations.gov/#!documentDetail;D=FAA-2015-0150-4054
• Filed a Section 333 petition for exemption to allow commercial operations of unmanned aircraft systems (UAS) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Public Law 112-95 (P.L. 112-95), Special Rules for Certain Unmanned Aircraft Systems. This Section 333 waiver petition was filed on October 5, 2015, and was accepted for comment by the FAA on Regulations.gov on December 3, 2015, here. http://www.regulations.gov/#!documentDetail;D=FAA-2015-7428-0001
• Filed timely Comments in Docket No. FAA-2015-4378 entitled “Clarification of Applicability of Aircraft Registration Requirements for Unmanned Aircraft Systems and Request for Information Regarding Electronic Registration”(“Clarification”) on November 6, 2015. The FAA proposes new registration rules for all UAS including model aircraft. The FAA’s stated purpose of the new rules is both to educate new operators about airspace rules so they can use their UAS safely and to allow the FAA to more easily identify and take enforcement action against people who intentionally violate the rules or operate unsafely.
This will be a radical departure from prior regulation and enforcement of existing FAA rules. For a detailed suggestion as to the proper method of UAS registration , see the Kelly Law UAS Clarification Comments filed on behalf of NetMoby, Inc., which can be viewed here.
Please call with any questions you might have concerning Kelly Law UAS’s FAA filings to date.
Robert E. Kelly,
founder and principal
I have several decades of experience in the area of administrative law representing clients before Federal agencies like the Federal Aviation Administration (“FAA”) in Washington, D.C., as well as state regulatory agencies across the United States. I have filed numerous comments with the FAA concerning the development of Unmanned Aircraft Systems (“UAS”) regulation. (UAS are otherwise referred to as drones.
For many years I have represented broadcast and telecommunications clients in administrative procedures before Federal regulatory agencies, primarily involving licensing and other authorization proceedings before the Federal Communications Commission in Washington, D.C. I have also practiced before the United States Department of Commerce, the Federal Trade Commission, the Federal Aviation Administration, and other Federal regulatory agencies. As in-house counsel for a NASDAQ-listed Competitive Local Exchange Carrier that provided local exchange telecommunications and Internet services in 36 major markets nationwide, I have practiced before state regulatory commissions in more than a dozen states, including California, New York and Virginia.
I formerly sat on the Board of Directors of the North American Numbering Plan Billing and Collection, Inc., an entity authorized by the Federal Communications Commission which reviews Federal regulatory policies and issues concerning billing and collection practices by telecommunications companies throughout the United States and abroad.
I currently sit on the Public Policy Committee of the Greater Reston Chamber of Commerce, whose areas of concern include Dulles Airport. The GRCC regularly addresses economic policies to foster business development in Northern Virginia and the entire State of Virginia, including the aviation industry.
For more than fifteen years I have proudly served U.S. military service veterans through a federal appellate practice representing veterans in disability claims appeals before the U.S. Department of Veterans Affairs and the United States Court of Appeals for Veterans Claims. I also have served as first-chair counsel for appeals before the U.S. Court of Appeals for the District of Columbia Circuit.
I am a graduate of Colgate University, and Fordham University School of Law. I was formerly admitted to practice in the State of New York and am a current member of the Virginia, Maryland & District of Columbia Bars.