The sUAS Guide 2016 Q1 Update | Page 25

airman certification requirements to allow online testing to satisfy knowledge requirements, and to work to eliminate in-person visits and background checks. It should be noted that representatives of ALPA, NAAA, HAI, and PAPA did not agree that online testing and the elimination of background checks were properly informed or appropriate recommendations for the ARC. The organizations all strongly maintain the position that an individual intending to exercise the privileges permitted under proposed part 107, which include commercial small UAS operations, should fully comply with the necessary training and certification as currently described in part 107, no matter the size or complexity of the aircraft. Their concerns were centered on the lack of data submitted during the ARC indicating this UAS category is not a proven security risk, or that testing will not enhance safety. In addition, data was not provided to the ARC indicating that security and testing requirements for this category would discourage compliance. The dissenting groups also stated that training, experience, and evaluation of skills and knowledge for initial certification and a revalidation of those skills periodically, such as is required for other airman certificates, should be required for these UAS and that proposals waiving such requirements were outside of the charter for this ARC. April 1, 2016 Page 13