Who knows its early for those questions. My point was the comments are important part of the record and often important part of subsequent legal challenge. The FAA has legal duty to explain themselves in detail and the public should make them do it. Court challenges are time consuming and costly sure. But, be careful about scoffing too soon. Remember that all it took was one person, John A. Taylor, to prove in court that the FAA had no right to require registration of hobby drones under former law. Yes, the FAA was subsequently bailed out of their mess by Congress which amended the law but still all it took was one guy to prove the FAA overstepped its authority and enacted a bogus regulation.
In an opinion May 19, a three-judge panel of the U.S. Court of Appeals for the D.C. circuit said that although drone-related safety incidents have been increasing and registration as a policy may help “to some degree,” the letter of the law was clear. “In short, the 2012 FAA Modernization and Reform Act provides that the FAA ‘may not promulgate any rule or regulation regarding a model aircraft,’ yet the FAA’s 2015 Registration Rule is a ‘rule or regulation regarding a model aircraft.’ Statutory interpretation does not get much simpler,” the opinion reads. And so the requirement was vacated.