I'm not going to go asking the FSDO who it was that received them when I was there. However if you want the regulations on sUAS then you can read for hours
[here]
I know the regulations quite well - probably better than you. If the FSDO personnel were issuing the letters, they were most certainly not from the enforcement division.
This is likely what was being passed out. It is not an enforcement letter. It is carefully written to scare you into compliance with rules that don't exist. When the FAA Enforcement and Compliance division sends a civil penalty letter to a person charged with a violation, the civil penalty letter will contain a statement of the charges, the applicable law, rule, regulation, or order. No one has been able to tell me what law, rule, regulation or order would be indicated on the letter for commercial flight.
There is no law, rule, regulation or order on this letter, so, what is the violation?
Well, lets look at your link to the FAA. There are three regulations referred to in the link.
The first is Part 1, 'Definitions, Civil Aircraft, section 1.1'. OK, by regulation our small drones are aircraft.
Next are two sections of Part 21, 'Certification Procedures for Products and Parts'. OK, if you want to spend many tens of thousands of dollars to get your aircraft certified, go right ahead. But the FAA
has already determined that pursuant to the FAA Modernization and Reform Act of 2012, Section 333 (b)(2) "whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned
aircraft systems identified under paragraph (1)."
That's it. There are no other rules in the link.
The FAA interpretation of the “Special Rule for Model Aircraft", which the FAA tried to enforce as a rule without the normal NPRM and comment period as required for a federal agency by the Administrative Procedure Act was challenged by three groups with petitions for review of administrative action in the United States Court of Appeals for the D.C. Circuit. (The AMA, The UAS America Fund and the Council on Government Relations). In at least one case a court order of abeyance was obtained. [
link]
Nothing is illegal solely because a government agency claims that it’s illegal. The FAA cannot just make up regulations as it goes along, to enforce activities that it simply wishes to enforce. There must exist an actual statute or regulation for the FAA to enforce. Congress cannot create rules, notwithstanding the title of Section 336 of FAA Modernization and Reform Act of 2012. The FARs are the only federal regulations that exist pertaining to aviation, and are the only regulations that are legally enforceable.
So, I ask again.
What law, rule, regulation or order is the violation for operating your drone commercially?