Media Release: AMA JOINS DOT TASK FORCE ON UAS REGISTRATION

54 comments

1. I am a member of the AMA, and have been off and on over the past ten years as time and resources have allowed me to participate in this hobby.

   I first became interested in model flight back in the late 70’s while watching my dad build a control line, glow powered P51 Mustang. Over the years, I built many rubber band powered balsa and tissue free flight models, and as a kid with limited funds RC was always just our of reach.

   Now in my early 40’s, I am finally in a position to fund what is a pretty expensive hobby. And exciting new technology (autonomous, GPS equipped multirotors) has made flying safer and less crash prone than ever before.

   This exciting new technology is now readily available to anyone with the cash, and it is bringing more and more people into the realm of RC flight.

   However, this recent news of plans to register RC “drones”, and the AMA’s apparent cooperation with the federal government has me very concerned that multirotors will be thrown under the buss in favor of more traditional (less advanced) craft like fixed wing airplanes. Don’t get me wrong, I love fixed wing RC airplanes. But I have experienced the incredible fun that can be had with a model that can take off an land vertically, and can be used to carry a camera for some beautiful video and still images. The GPS “return to home” features of these new models save hobbyists thousands of dollars in prevented crashes.

   It is my sincerest hope that you will not throw these exciting new multirotor craft under the bus and will fight just as hard to make sure that the only distinction the DOT makes is weight. The hobby can work around weight restrictions, but making a technology distinction will utterly kill innovation in this hobby. The existing 55 pound weight limit for hobby aircraft is very generous, and could perhaps be scaled back. But much more less than 20 pounds would severely restrict our enjoyment of this hobby. Restrictions on the kind of technology a craft may include, such as GPS, cameras, or other sensors used for autonomous flight will absolutely decimate this new (and fastest growing) segment of our hobby.

   Please carefully weigh the potential for this new technology to bring vast numbers of new members into the hobby against the desire by some to protect more traditional hobby aircraft at their expense.

   And also, please exert any influence you can to make sure these registration requirements have exemptions for sparsely populated areas far from cities and airports, and apply only to actually flying the models, not mere possession of them.

   Possession of a room full of “drones” should not require any form of registration at all, until and unless the owner intends to actually fly them. I have models that I built and have no intention of flying, even though they are capable. Those should not require registration.

   In fact, refusal to register should not be a crime unless some other offense like injury or property damage has occurred in addition to lack of registration alone. As hobbyists, we should not have to be subjected to registration checks and be forced to land our models with police breathing down our necks so they can check for a sticker and run it through a computer.

   Thanks for taking the time to read this.

2. I am surprised that the AMA is accepting this new legislation, and burden on hobby flyers without any discussion with your members.
   quote
   “AMA looks forward to working with government and private sector stakeholders on a process for UAS registration.”
   What exactly is a UAS? Simple multirotors? Will I have to register my Xplorer 3.8 , Pulsar 3.2 or the other 8 sailplanes I own? How about the 3 or4 foamy warbirds I fly in a local field? Or my Trex 450 and 500 Helicopters?

   Lets see some leadership on this, AMA. Not just a blanket acceptance of “UAS registration”, before a UAS definition has even been proposed.

   Captain Ray
   retired Airline Captain
   AMA 955476

   1. Thumbs up!!

3. How is registration going to address the problem? So now we have to pay a registration fee ?
   Seems to me AMA hast just sold us out.

   That’s what I get for becoming a life member

4. Registration leads to confiscation. No other special interest group in America would tolerate it.

   Don’t fool yourselves: Amazon, etc. want drones off the market to avoid an Uber-esque scenario where the average man can deliver a pizza, or otherwise use RC to make an extra nickel on the side.

   The government realizes that RC empowers the common man, which the Feds absolutely hate.

   Remember that the NRA rank-and-file essentially fired its leadership, when leadership was going cave into any new regulation the government wanted. The renewed, activist NRA is now about 5-million members strong. Contrast that with ham radio (license, please, license), which is a stagnant hobby going the way of the dodo bird.

   I hope we will not have to seek an alternative to the AMA, or seek to replace AMA leadership. For more info: https://www.washingtonpost.com/politics/how-nras-true-believers-converted-a-marksmanship-group-into-a-mighty-gun-lobby/2013/01/12/51c62288-59b9-11e2-88d0-c4cf65c3ad15_story.html.

5. Christmas registration of Drones. What is a drone. Strictly quad plus copters or fixed wing RC also? I have well over 50 airplanes will I need to pay for all of these?

   Can the FAA be sued to prove the “emergency” need for registration?

   I just watched a you tube video of an explosive device being remotely triggered in a plane 2 yrs ago by a well respected RC manufacturing group. Does the AMA in some way impose a penalty on this type of activity? If our hobby’s manufacturers cannot abide by even the most basic rules, what hope does the hobby have of regulatory survival?
   AMA should post further details on this soon.

6. This is a tipping point for the AMA. I’m not a member, mostly because the local clubs are nearly hostile towards new members and new technologies, but this situation could either win over, or alienate a huge portion of the ‘new crowd’ of RC enthusiasts.

   This needs to be handled with a level head, and with the current news media environment, I’m skeptical such a thing is even attainable. I’d love to be proven wrong.

7. I am just going to point out that requiring hobbiests to register their craft is a violation of the 2012 FAA Modernization Act.

   Section 336 of that act expressly forbids any further rules or regulation for hobbyiest fliers.

   (a) IN GENERAL.—Notwithstanding any other provision of law
   relating to the incorporation of unmanned aircraft systems into Fed-
   eral Aviation Administration plans and policies, including this sub-
   title, the Administrator of the Federal Aviation Administration may
   not promulgate any rule or regulation regarding a model aircraft,
   or an aircraft being developed as a model aircraft, if—
   (1) the aircraft is flown strictly for hobby or recreational
   use;
   (2) the aircraft is operated in accordance with a commu-
   nity-based set of safety guidelines and within the programming
   of a nationwide community-based organization;
   (3) the aircraft is limited to not more than 55 pounds un-
   less otherwise certified through a design, construction, inspec-
   tion, flight test, and operational safety program administered
   by a community-based organization;
   (4) the aircraft is operated in a manner that does not inter-
   fere with and gives way to any manned aircraft; and
   (5) when flown within 5 miles of an airport, the operator
   of the aircraft provides the airport operator and the airport air
   traffic control tower (when an air traffic facility is located at
   the airport) with prior notice of the operation (model aircraft
   operators flying from a permanent location within 5 miles of an
   airport should establish a mutually-agreed upon operating pro-
   cedure with the airport operator and the airport air traffic con-
   trol tower (when an air traffic facility is located at the airport)).

   That laws is found on page 72 of the act in this link.

   https://www.gpo.gov/fdsys/pkg/CRPT-112hrpt381/pdf/CRPT-112hrpt381.pdf

   That section allows them to make new rules to punish people who violate the already standing safety rules and guidelines but it expressly forbids them from expanding regulation on hobby fliers.

   1. Mr. J. Thone makes a valid point about the 2012 FAA Modernization Act prohibiting the Federal government from making such requirements as the registration of model aircraft being used for recreational purposes. I worked for the Federal government for 30 years and we had to follow the law. I do not understand why FAA does not. I do understand why AMA would want to be on the committee so it (AMA) can provide input on behalf of its members. I do not agree that AMA should agree that everyone should register their aircraft for several reasons:

      1. Exactly how would such registration make flying remote controlled aircraft safer? I do not see how it would. The DOT and FAA claim there are hundreds of “close calls” with aircraft, but registration would not stop stop close calls. (Some of the reports are hard to believe about multi-rotor aircraft being at multiple thousands of feet of altitude. Most do not have the battery capacity to even reach that altitude, much less loiter around at thousands of feet.) So if there is a close call, are FAA inspectors going to go to the data base, pull up everyone who has a registered aircraft and go door-to-door questioning aircraft owners? That would take thousands of additional inspectors (and a substantial increase in the FAA budget) and would likely not yield any useful information any way. Local law enforcement does not have the people to do it either.

      2. As mentioned by other commenters, who is going to pay for developing and maintaining this database and what is its real usefulness?

      3. Will all of our aircraft be required to be registered? Most of us in the hobby have multiple aircraft. When someone retires an aircraft, or crashes it or sells it, will they have to contact FAA to change the registration and status of the aircraft. Also as another person mentioned, will aircraft built for display also be required to be registered? Will requiring an airworthiness certificate from FAA be next?

      4. What burden will be put on hobby shops and manufacturers to ensure that all aircraft they sell will be registered?

      5. Will DOT next decide to require registration of RC cars since they could be driven on a road and “threaten” full scale vehicles? Will RC boats also be included next? These may seem like silly questions, but if one follows the logic of registering all “drones” then registration of all RC devices might just follow the same logic.

      We have a wonderful hobby. It brings generations together, encourages innovation, supports local communities, advances education, teaches responsibility, and is just fun. The FAA has been dragging its feet for years to develop reasonable UAS rules. (By the way, they are not Unmanned aircraft systems, they are remotely controlled aircraft systems – there is a person involved in the operation.) Personally I have been tracing the rule making (or lack of rule making) for 5 years. In lieu of having small scale aircraft rules, they just said the full scale aircraft rules apply and one current has to get an exception from each individual rule to fly “commercially”. That is absurd. How hard is it to make some sensible rules for small remote controlled aircraft? They have been working on them for years and still do not have them in place, but they can suddenly put registration rules in place in a few months? Currently it is pretty much impossible to legally help out your community by donating your time and using your aircraft to even do something like a flight over a disaster area to help out local emergency response services. That might be considered “commercial use” and is prohibited with out getting cleared through a very intense and difficult process, including having a pilot’s license for full scale aircraft.

      If we are not careful, many people will drop out of the hobby or fail to enter because they do not want the hassle of registering their aircraft. I am an AMA member, and I strongly encourage AMA to fight this whole registration process.

8. If the AMA goes along with this crock of **** I will not be renewing my AMA membership next year. I am sure there are many more members who feel the same way.

9. And still for some reason you feel the need to continue lumping model aviation in with people who will buy a dji quad copter and will never join the ama. I really wish now that I had not renewed my membership, for the next 2 years. I feel let down by the AMA leadership. It seems that they are completely out of touch with reality. This I believe will be the end of our hobby for sure, it was already an uphill battle getting new people into our hobby. Now with the government so involved in the process the costs will surely rise as well as the headaches. I’m done with the AMA after 20 years of membership.

   1. That kind of attitude is what will kill the hobby. The AMA is trying to work with the Feds in finding a solution to this problem that we are seeing on TV on almost a weekly basis. You all will read it again you’ll see that they are already talking about a weight limit and no need to regulate the hobbyists. A more positive attitude will go along way in helping those involved find an agreeable solution to this problem. Heaven forbid a UAS should be involved in a midair with any kind kind of airplane!

      1. AMA already has the safety rules for model aviation in writing, and if they are to champion this hobby they need to fight excessive cumbersome regulation. That’s what we pay dues for. To knuckle under and offer no resistance is like when an eloquent speaker almost conquered the world, through mindless followers. (Hitler)

10. First the individual who is not causing the problem must be controlled and regulated.
    The beginning of the end of the hobby as we know and love.

11. I am at a loss here. Why has the AMA failed us in this aspect? So we will be registering all of our UAS’? Does that include every model airplane, helicopter, multi-rotor and so on? Wow that is a lot of paperwork. Who is going to pay for that? We the modelers will. At what expense? Well the hobby had a very dark day on 10/19/15, as it killed the fun and enjoyment for most.

    1. Safety is not impacted by ‘old timers’ who have been doing this for 20, 40, 60 years.

    2. This instantly hurts everyone, oldtimers most of all since there are guys with entire hangars worth of planes. Even if it is only 5$ ea it is still a bunch.

    3. BAd people dont register things. This is applying the horrible gun control mentality to rc. The RC you want to track running drugs for cartels, dropping contraband into prisons , and doing drug drops are not going to be registered. Only people who want to follow the rules will.

    4. If you want to track the ones doing bad things the id will need to survive a plane crash, for real.

    5. The safe pilots , who would listen to this have already been doing it with their AMA numbers because that is the AMA rule. If this who “have an id on your craft” rule was going to work and help things it would have already.

    6. Being interrupted while piloting a craft can potentially be deadly and they openly say they want to push enforcement. When all it really is to enforce is registration , it means getting pulled over and asked for it , it means detracting from safe operation of the craft as attention span is imperative. This IS the mandate , to enforce registration. It hurts saftey , which the idiots said they were “hyper focused” on.

    7. It is a funding nightmare , which means hefty fees to register , and hefty fines, which means cops are gonna be on little power trips (as we have proof of already without this) and out on revenue missions just harassing anyone they chose to that they see flying.

    8. dont have uas’s any more? , just lots of spare rc parts in a box. what are they gonna do about it? its not enforceable unless they start raiding peoples houses. Do we really want to authorize a drone gestapo to raid people’s houses for unregistered drone parts?

    9. Isnt there a law that they cannot pass more laws restricting rc modeling?

12. I expect that model registration would be a prohibitive burden for hobbyists who build and fly multi-copters especially if we have to register and re-register our models with the DOT (in triplicate carbon copies?) any time we tear them apart and put them back together using different frames, controllers, motors, camera/gimbal systems, or make any other significant modifications. I expect this would also limit the enjoyment of airplane model hobbyists who like to mix and match motor systems on foam board scratch constructed model airplane frames. Are these new regulations really going to make the airspace any safer?

13. Does this REGISTRATION apply only to gps controlled multirotors or all of modelers aircraft.
    Some modelers have collections of 50 plus models and would be a big task for them to do so.
    just would like to know some more info since its not specified.

14. Given that many of the sightings are small DJI Phantom sized sUAS, then the registration needs to apply to items at least that small, lest it fail to achieve DOT/FAA objectives. Furthermore, Secretary Foxx did not say “some” will be registered, he said “We are going to require all operators of drones to register their aircraft.” He said “ALL”. We should get with the program and realize the horse has left the barn on this…we need to be seen as partners. So if DOT/FAA says “all”, then we need to support that.

15. The first step in this process is to define what a “drone” or UAS is in the context of any proposed restrictions. Said definition should include the flight control system. For example, a long range UAS capable of being a hazard in shared airspace will typically include a flight control system, e.g., an Autonomous or First Person Video (FPV) system that enables operation beyond line of sight.

16. I hope the AMA can provide some sound advice and reasoning for this registration situation so it doesn’t become an unnecessary, bureaucratic burden for the typical R/C hobbyist. For example, clearly define what a “drone” is that will require registration or other such legal compliance. There should be clear weight requirements, among other considerations. For example, something as innocuous and light as a Horizon Hobby UMX, such as a Night Vapor or other, shouldn’t be included.

    Please, please provide some rationale to this situation. Thank you.

17. Is that really an ad for an FPV Glider at the top of the page?

18. I find this idea outrageous on several levels. First, how can some un-elected official arbitrarily demand the registration of so-called drones, including model aircraft flown for recreation when the US Congress has established LAWS prohibiting the restriction of such model aircraft? Second, as stated by Dave Mathewson, there are already guidelines in place requiring the proper labeling of model aircraft with owner information including AMA number, as well as when and where is appropriate to fly their aircraft. If there be some reckless individuals who balk at these guidelines already, why would they suddenly comply with a new mandate to “register” their drone? Third, while I believe the AMA had the right intention to be inclusive and maintain their relevance among what is arguably becoming the dominant form of radio control aviation, I believe there should be a distinction made between the “classical model aircraft”, and “modern drones”. There are several important differences, not the least of which is the ability of “drones” to fly beyond line of sight and/or using first person view, which has the potential to reduce a pilot’s situational awareness thus increasing the risk of unintentionally interfering with other aviation activities. Not to mention those who knowingly fly when, where, and how they please, such as those responsible for shutting down the firefighting efforts in California. If proper elected lawmakers are given the task of drafting laws which increase safety, while not violating the spirit of the law preventing restrictions on recreational model aircraft, then so be it. However, I am a responsible AMA member who flys “classical” (mostly scale) model aircraft at an established flying site in accordance with AMA guidelines and I’ll be damned if the government will register a single one of my planes. The AMA needs to take a firm stand and prevent this runaway train from derailing this great American past time.

19. I will be interested to see what they will classify as a drone when they want registration. I can see this getting completely out of hand do I have to register my 12 planes, 6 helicopters, and 4 multi rotors and whats it going to cost me to do this? Also wonder what is next they are going to require a 3-5 day waiting period before you can buy a drone? This is not going to fix anything people who do stupid things will do them I am for one disappointed that the AMA is going down this road with the FAA.

20. Are you Kidding!!!!!!!!!!!!!!!!!!!

    so you support R/C registration. Well, I can see a dues increase to
    “cover the cost of administering” the registration process.
    Not with my money. I will not renew my membership.

21. WHERE IS THE COPY OF THE BILL BEING CONSIDERED. ARE YOU SEPERATING PLANES FROM QUADS

22. Keep it simple! ‘LINE OF SIGHT’ takes care of everything. If you can’t see it, you need a permit or license.

    1. Amen!!!!!!!!!!

23. As you participate in the task force, don’t just look into size and capabilities but how multirotors are used. As with the new and growing racing multirotors hobby, they are full FPV and have photography (video) capabilities but not for landscape and surveying, but more for high speed view of the operator in flight (see what they see) so don’t forget about the racing community for FPV Muilticopters and FPV fixed wings.

24. I wonder if the “registration” process is going to require Make, Model and Serial Number – which would make my DJI-Framed, Aimdroix-Arms, Tiger-Motor U3’s, Hobby King ESC’s and DJI Naza – CUSTOM Homebuilt X-6 Hexacopter an interesting proposition to register – Also it probably weighs in at about 7-8 Pounds. The problem as I see it is that they want to catch all the novices with DJI Phantoms doing stupid things, which will end up encompassing ALL OF us Modellers – OR – Perhaps you could get an EXEMPTION for BONA-FIDE members of the AMA. That would be a win for us, and we would agree to PASTE out AMA Numbers on the Airframes to give the Govt the Tracability they require, and perhaps also ensure we carry our AMA Cards with us when we fly too…

25. Figures the AMA would just roll over on registering. This is just the first step. We need LESS government intrusion not more!

26. After watching the complete announcement from the US Dept of Transportation, the last question asked was not only, in my opinion, the most important, but was not answered. That question was, How will registration allow any help at all, unless the UAS crashed?
    Certainly no one believes that a UAS, especially a sUAS could possibly be identified in the air from a N number decal on it. I don’t get it. This would be like replacing auto license plates with a postage size stamp sticker on the inside of a windshield.

27. AMA #947161
    I mostly agree with AMA’s approach but must point out the gun registration only works for the ‘honest’ people. I don’t see any difference with ‘drones’ !!

28. The “know before you fly” link is pointing to your Exchange server’s OWA

    https://amablog.modelaircraft.org/amagov/2015/10/19/media-release-ama-joins-dot-task-force-on-uas-registration/

    1. Thanks! Updated.

29. at 21:30 the Airline Pilots Association once again perpetrates the falsehood that HUNDREDS of pilot/drone encounters have taken place, when a cursory glance at the data would tell us otherwise. The FAA deliberately and with forethought and planning LIED to the American Public, and was caught by the AMA. And yet here we go again, say it enough and it becomes true. It it time that SOMEBODY call them out on this.

30. This is a classic example of hurry up and wait, then cobble something together with no time for anybody to look at it. The FAA has had 8 or 10 YEARS to come up with regs and they have done nothing but stall, now they expect to write a registration scheme in 30 days under EMERGENCY Powers with safety being the driving force. But if they cant even tell a drone from a seagull at 300 knots and over 96 percent of the reported drone sightings being bogus, we are being fed a line here by all of them.

    Even the few drone “close call” (BTW there is no officail criteria for determining what one is) few if any required actual ACTION by the pilot out of prudence or actual conflict, and many of those were MILITARY Drones, not somebodies DJI Phantom.

    Just because a Pilot saw a light below him, he cant tell if it is below the 400′ recommended ceiling. Just because a pilot saw something does not make it a conflict. Flying an LED filled Night Combat foam aircraft at 200′ is legal, and just because the airline pilot at 3000′ or the police helicopter at 800′ looked down and saw it, does not mean there was a conflict. Sighting vs CONFLICT is not even well defined by the FAA. Again, your being sold a bill of goods here. I can build a drone in a couple hours without ever going anywhere near a hobby store or relying on a manufacturer.

    The other thing is they have to actually put their hands on the drone, to get any of this information because the registration number is not going to be big enough to read more than a 25 to 50 feet in the air. And god forbid a drone gets injested into an intake of a jet aircraft there is not going to be enough pieces left to identify them even if they search the area where the strike took place.

    If you want to be afraid of something, be afraid of birds! These people are afraid of up to a million drones being sold at Christmas, being flown by humans that are at least capable of rational thought and the ability to understand the issues, vs 200-400 BILLION birds out there. That is BILLION with a B.

    Even though it seems I would be against registration I am not, it is nessicary, but what I wont have is the FAA, an agency who holds the safety of every passenger and every person a plane flies over in their hands, playing fast and loose with the truth.

31. Government stupidity at it’s finest. This is like the DEA requiring stoners to register their bongs.

32. Once again the FAA and DOT have struck upon a great idea on how to spend millions of our tax payers money. Why not register the small drones your sons and daughters are now flying which this yeart alone is estoimated to sell over 750,000. The hobby of rc airplanes, helicopter and the new fledling small hobby drones is growing and has been ond of the safest hobbies in America. The large amount of people and record storingf will once again cost the federal government a hugh chunck of change and for what, so they know that the kid down from the block from me who flies his drone in the park near us is registered……..big brother has once again and reached out and touched the wrong group. Please tell me how this is going to stop those who fly these
    drones in a reckless and dangerous manner?

33. Hi,
    I was most likely flying RC aircraft before you were born. Fixed wing power to start, then gliders, then turbines, then Electric ducted fan, now mostly “drones” – love the forgiving ness and precise control of the craft. So much so that I’ve emased a veritable squadron. Maybe 35 under 2 lbs., and another dozen or so above that weight. The allure is FPV – your in the cockpit. Many members won’t admit it, but they’ve never flown or mastered FPV- it’s a blast ! Unfortunately, they won’t realize it until it’s too late. The homeland security folks are shutting us down – good bye to inocents, good by to freedom. The FeDs now own the sky’s. Illegal to fly at night ? Obviously have never flown a drown…

    1. Sorry, I know this is unsuitable to post – venting! If your looking for a 30 year plus AMA member to voice his opinion, let me know. I really want this to work for everyone. Example: “All RC pilots put their DL no. On craft it’s done ! So simple it’s almost comiclal.

34. I have recently gotten back into flying after decades away because of how easy [toy] quadcopters make it to fly and have fun. I have since moved up to more expensive 3D stunt quadcopter and 250 FPV racers, neither of which are flown in a manner that is menacing to commercial aircraft like photography platforms that are usually flown high and maneuver into places for pictures. I hope that these types of distinctions are considered as well, even within the “drone” category. I sometimes get the feeling that AMA only wants to draw distinctions between planes/helicopters and drones (God I hate that word!), and not consider that there are also subcategories within the drone community.

35. This to me is not going to do a bit of good. The guys that are breaking the law will not register their UAS. They will just make a new one. Instead of getting caught by law enforcement, they will just let it fly away, and make another one. Here we go again, punishing the people that do things legal, and not those who are the real outlaws. Its just like passing more gun laws, that dosent stop a crook from getting a gun. When are you going to wake up to the way things work in the real world. This isn’t the answer, it wont stop the bad guys.

36. As an AMA member and drone enthusiast I was happy to see the AMA represented in this gathering. And then I received your email outlining your position.

    While I am completely on board with limiting registration based on size and capability I cannot fathom how you can come conclude that “traditional” model aircraft should be exempt. These have just as much capability as any “drone” in terms of speed, height etc.

    If you are asking an exemption based on them only being flown at defined clubs and fields then surely drones that are only flown at clubs should likewise be exempt.

    I joined the AMA because I thought you would fight to protect our rights. Now I’m concerned that you will throw “drones” under the bus to protect your historic membership and sacrifice what is clearly the largest growth area of the hobby in the process.

37. There need to be some exemptions, such as airspace directly over a AMA field and lower than 400-ft. Or planes not capable of self-stabilization through onboard computers, gyroscope, compass, etc.

38. As expected, these proposed rules have *nothing* to do with National Air Space safety, but rather further government control and regulations. Someone please explain to me how ‘registration’ can even remotely affect ‘safety’.

39. This is a typical bureaucratic response which will not yield the desired result. The same level of identification can be had with a simple requirement to have the owner put their name and contact information (or AMA #) on any unmanned model. It provides the same level of traceability and effectiveness without the expense. This method will probably even increase the level of participation. Those who don’t want to put their name on their aircraft are also the people who are not going to flock to the registry.

40. After two years doing R&D in learning about RC Aircraft, then two years in the design, building, programming, testing, revising, modifying, improving, flying, testing some more of the RC Aircraft I built, I do not intend to be confined to flying around in circles in the space no bigger than a soccer field. Suffice to say I do not agree with the VLOS restriction that obviously is intended to regulate FPV technology out of existence for the citizen. Except of course that it doesn’t affect government and law enforcement “drone” pilots.

41. I would first like to comment that I started 25yrs ago flying RC heliclpters long before there were gyro stabilizers. My love for it led me to eventually open a helicopter flight school. Our operations at times fly within the parameters of RC airfields and we have never encountered issues with anyone flying the “model aircraft”. I believe the registration of any RC aircraft to be nothing more than a revenue generating operation for the government. Not that long ago any aircraft had a one time cost for registration . It has now become an every 5yr requirement (which I am sure will be dropped to 3hrs then 1yr) for registration. All of this under the guise of ” wanting to know how many aircraft are actually flying in the airspace”. Don’t let the government involve themselves in any part of what is considered a “hobby”. They will intentionally burden you with additional costs and as one of posts commented additional fines. The easiest people to attack are the people following the letter of the law. Criminals don’t know or care what the rules are.

42. Keep your friends close and your enemies closer.
    In the corporate world the best way to garner acceptance of someone who is against you is to invite them to be on your task force. For the AMA to enter the task force under the guise that there WILL be registration is wrong. The correct approach should be to determine if registration is needed, if so then decide how to accomplish the task. This proposed process is way to rushed.

43. I have over 50 fixed wing aircraft that I fly at least once a year. Do I have to register all 50? Will it cost to register? Why is AMA supporting this? This is not good for the hobby. The rule followers will register their aircraft where as the rule ignorers will not.

44. Waiting for the leadership to start communicating with the membership!

    Two questions:

    One: What exactly is traditional model aviation? The only acceptable answer for me is anything that is flown within the programming of the safety code.

    Two: How exactly did we come to be involved in this process? I will answer this one in the void of communication so far. The DOT/FAA came to us and gave us an ultimatum. “The boss wants registration so it IS going to happen. You can choose to be supportive and have a voice in the room and a chance to contribute your knowledge and experience to the process OR you can choose to fight this publically and be excluded completely. NOW CHOOSE” Knowing what little I do about the current federal administration I feel strongly this is likely what happened but in the face of radio silence from our elected leadership we are all left wondering?

45. I won’t like registering but will if I have too. It would be better to register pilots instead of planes. Maybe we could use our AMA number and the AMA could share that data with the FAA? I love flying gliders and my question to the AMA would be if during registration we have to review some rules and agree to them for example limiting our altitude to 400 feet. Will the AMA insurance become void if we exceed 400 feet? That rule will effectively kill RC glider flying. This will effect AMA membership in a negative way if there is are draconian rules that accompany registration.

46. I sent the following in reply to the FAA inquiry.

    The questions asked about the proposed regulation are largely irrelevant, because no purpose has been stated. Until the purpose is clear, there is no possibility of reasonable discussion about any regulation. The ostensible purpose is to do something about the danger to manned aircraft posed by UASs flying into space used by manned aircraft. Flying UASs into controlled airspace around airports is now prohibited; flying UASs into the space used by firefighting aircraft, which is wherever the fire occurs, is now being prohibited, as is flying into space from which popular events can be observed, and there is a general prohibition against flying more than 400 feet AGL. Presumably, the registration proposal can be seen as one means toward enforcement of these prohibitions. And, possibly, in the event of an air-to-air collision, to identify the owner of the UAS involved.

    It is obvious that whatever is proposed to aid in enforcement of these prohibitions has to be controlled by a ground-based pilot. A glider or a rubber-powered UAS caught in an updraft may fly for miles, but the launcher has no means of controlling it. Furthermore, the great majority of UASs (99.9%?) are controlled through the pilot’s line of sight. If one gets out of sight, and therefore is no longer controllable, it will soon crash, with almost no chance of entering controlled airspace.

    Therefore, any enforcement action regarding a UAS flying where prohibited needs to consider only the ground area from which it could have been seen and controlled. But how can that enforcement be performed? Registering the UAS will have no effect as long as the UAS is in the air. I fly fixed-wing model aircraft with spans of 2 to 6 feet, and I place my Academy of Model Aeronautics pilot number, in big letters, on the top surface of one wing (and my airline’s name [JOHNSAIR] on the other wing). But many planes do not have such identification, and on multi-rotor aircraft there’s no room for such.

    It is obvious that registration of any type is useless for identifying the owner of a UAS that is in flight. The only way to identify the owner of a UAS is to catch him (or her) on the ground with it. It is technically possible for a Police UAS of the multi-rotor type to be directed to a suspected airspace violator, detect it, and follow it to the ground, while coordinating with ground-based police to catch its owner with guilty ownership. While that is possible, registration takes no part in the process. Registration might have some effect in identifying the owner of a UAS that has been involved in an air-to-air collision (if the identification means survives and is found), or of a UAS that has been abandoned because of a guilty conscience, but these are sufficiently unlikely to justify the cost of a registration program.

    There are two means, today, of controlling small UASs outside the line of sight of the pilot. One is by GPS, the other is by First Person View. For example, the one model aircraft (out of five launched) that crossed the Atlantic was taken off under visual control, then flew by GPS to visual range of the target landing site, and then was landed visually. With FPV, the UAS carries a camera that transmits its “pilot’s” view, and other flight data, back to ground, where the ground-based pilot watches it and controls the small UAS. I understand that FPV requires at least an amateur radio license, and the transmissions may aid in identification. But the problem of identifying owners remains the same as with line-of-sight operation. The offending UAS must be traced to its base by air, coupled with arrest by ground-based police.

    I see no use for registration of sUASs that are used for non-commercial purposes. Without a use, no purpose will be served by having a registration program for such.

47. This will not address the issue.
    It will be just like another gun law on the books that will do nothing.

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