Letter to FAA-Expedite the Rulemaking Process for UAS Operations

 

AMA and AUVSI lead 33 organizations in calling on FAA to expedite rulemaking for Unmanned Aircraft Systems

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The Academy of Model Aeronautics (AMA) and the Association for Unmanned Vehicle Systems International (AUVSI) joined 31 other organizations today to send a letter to the Federal Aviation Administration (FAA) encouraging the agency to expedite the rulemaking process for unmanned aircraft systems (UAS) operations in the U.S. airspace. The letter also calls on the FAA to allow the limited use of small UAS for commercial purposes before the final rulemaking is completed.

While Congress authorized the integration of UAS in 2012 and the FAA has recently implemented key steps in the integration process, the rulemaking for small UAS has been delayed for almost four years. Last month’s FAA v. Pirker decision underscores the immediate need for a safety structure and regulatory framework for small UAS, according to the co-signees.

“The time for resolution has come, and we cannot afford any further delays. The technology is advancing faster than the regulations to govern it,” the letter states. “While the FAA has indicated its intention to appeal the Pirker decision to the full National Transportation Safety Board, we strongly encourage the FAA to simultaneously expedite its small UAS rulemaking and issue notice and public comment as soon as possible.”

The co-signees include a broad array of organizations and industries, from agriculture to real estate to photography, that recognize the benefits of UAS. Meanwhile, the effort represents the first time stakeholders from both the manned and unmanned aviation communities are coming together to press for a regulatory framework for UAS. The Aircraft Owners and Pilots Association (AOPA), the General Aviation Manufacturers Association (GAMA) and the Helicopters Association International are among the letter’s co-signees.

In addition to expediting the UAS rulemaking, the organizations urged the FAA to use its congressional authority to allow some limited UAS operations right away.

“We recommend the FAA use all available means, including Section 333 of the FAA Modernization and Reform Act of 2012, to allow for some limited UAS operations, subject to the Secretary of Transportation’s safety determination, before the small UAS rule is finalized,” the letter states.

“The current regulatory void has left American entrepreneurs and others either sitting on the sidelines or operating in the absence of appropriate safety guidelines. The recreational community has proven that community-based safety programming is effective in managing this level of activity, and we highly encourage the FAA to allow similar programming to be used to allow the small UAS industry to establish appropriate standards for safe operation. Doing so will allow a portion of the promising commercial sector to begin operating safely and responsibly in the national airspace.”

“Community-based programming has a proven track record,” said AMA President Bob Brown. “The members of the Academy of Model Aeronautics have operated unmanned aircraft (model aircraft) in the national airspace for decades and have set the example for operating small unmanned aircraft systems in a safe and harmonious fashion. The Academy stands ready to lend its expertise and to assist the FAA in developing a safety structure that will enable and allow all small UAS to operate safely and responsibly in the national airspace”

According to AUVSI’s economic impact study, the integration of UAS will create more than 100,000 new jobs and $82 billion in economic impact in the first decade following integration. AUVSI President and CEO Michael Toscano noted the many societal benefits of UAS and the economic costs of any further delays.

“UAS have enormous potential to benefit our lives,” Toscano said. ”This technology has the ability to transform that way many industries operate, whether helping farmers better survey their fields, assisting search and rescue missions or providing real estate agents with new vantage points. Delays in the rulemaking process have slowed the integration process, keeping these industries on the sidelines. Every year that integration is delayed, the United States loses more than $10 billion in potential economic impact. This translates to a loss of $27.6 million per day that UAS are not integrated.”

Read Full Letter to FAA

The Academy of Model Aeronautics has been the nation’s collective voice for approximately 164,000 modelers in 2,400 clubs in every state and Puerto Rico since 1936. A nonprofit association headquartered in Muncie IN, AMA sanctions more than 2,000 events and competitions each year under the auspices of the National Aeronautic Association.

The Association for Unmanned Vehicle Systems International (AUVSI) – the world’s largest non-profit organization dedicated to the advancement of unmanned systems – represents more than 7,000 members from 60 allied countries involved in the fields of government, industry and academia.

5 comments

  1. The AMA is an insurance company. In doing it’s risk management business, it must be committed to safety as I would hope all my fellow hobbyists are. However, I do not wish AMA to assume to be my spokesperson as we may have different opinions. This whole matter of regulating further the aircraft we have been operating in harmony for decades is political horseplay. The radicals have pushed for ridiculous legislation which will over-tax a policing system by using child predators, terrorism and any scare tactic they can to make a public worry about something else. The numbers show that the hobby is declining as is. I expect this push to merely quicken the process. Be careful what you wish for. Beer deliveries by multirotor? Amazon delivering a heavy package for miles? Google can image you from space but I can’t do an innocent landscape shot from above 8 feet? Please forward on my behalf to the FAA.

  2. The AMA’s GOVERNMENT RELATIONS BLOG begins with:
    “As the FAA looks to regulate the hobby, sport and educational pursuit of model aviation, this site will keep you informed…”

    The AMA starts by apparently approving of new FAA “regulation” for this Hobby-Sport.
    What happened to defending the decades old Circular Advisory for the hobby ?

    Tell me. Tell all of us… What is the AMA’s current official position working with the FAA adding regulations to this hobby/sport ?

    Does the AMA seek to expand into “commercial” profit-making aspect and dis its Hobby-Sport herritage ?

    1. Gary, There seems to be a misunderstanding in regards to the proposed small UAS rule and its applicability to recreational unmanned aircraft (model aircraft). AMA has advocated on behalf of the recreational/hobby enthusiasts for decades, and for the past six years has worked to protect the aeromodeling community from onerous regulation in regards to FAA’s intent to regulate small unmanned aircraft.

      This issue was resolved two years ago with the passage of the FAA Modernization and Reform Act of 2012, in which Congress established the “Special Rule for Model Aircraft”. This rule provides that the FAA Administrator “may not promulgate any rule or regulation regarding a model aircraft, or an aircraft being developed as a model aircraft, if… the aircraft is operated in accordance with a community-based set of safety guidelines and within the programming of a nationwide community-based organization”.

      With this in mind, it is past time to create regulation to enable the UAS industry and establish a safety structure for an activity that is already at play in our communities. In the absence of appropriate standards and operating procedures this activity is creating a melee of bad publicity and diminishing public sentiment, much of which has the unfortunate consequence of diminishing the goodwill and positive community relations established by the aeromodeling community.

      As stated in the letter to the FAA, AMA believes the proven success of community-based programming can and should be used to provide a safety structure for the small-small UAS operations (under 20 lbs).

      Rich Hanson
      AMA Government and Regulatory Affairs

  3. I see no representation of those just interested in UMV as a hobby. Further, if you review what Britain has done, like it or not, there are many fine points in their process involving education and certification. Why not build on what has worked. As a supporter of this organization, “community-based programming” means what?

    1. Tim, The UK has an excellent unmanned aircraft program and I think there is much there we can draw from. The AMA is looking at Britain’s program as well as others such as Australia and Canada in the development of its small UAS program.

      Community-based programming means that those operating within the program have input in the development process (i.e. AMA’s representative structure of elected Executive Council members), and program participants agree to abide by the consensus based guidelines as a condition of being part of the program/organization.

      Rich Hanson
      AMA Government and Regulatory Affairs

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