Guidance on Submitting Comments to the FAA’s Interim Rule on UAS Registration

AMA is  fully considering all possible legal and political options for alleviating this unnecessary regulatory burden on our members.

In the meantime, you can help by making your voice heard with the FAA. Specifically we are asking all AMA members to submit comments on the FAA’s interim rule on registration. The deadline to submit comments is January 15, 2016. All comments can be submitted at https://1.usa.gov/1Jegj0C.

Below are recommended messages to convey in your comments:

• Express your disappointment with the registration rule. As a member of the Academy of Model Aeronautics (AMA), I am disappointed with the new rule for UAS registration. I am a long time model aircraft flyer, who has operated under the guidance of the largest community-based organization (CBO) in the world for many years.

• Highlight AMA’s history and safety record. Since 1936, AMA has published safety standards and offered training programs for our members – more than 20 years before the FAA was created. Our National Model Aircraft Safety Code has been recognized by Congress as well as by state legislatures as a safe and effective means of managing model aircraft enthusiasts like me.

• Note that you already register with AMA. Additionally, AMA’s safety program already instructs me to place my AMA number or name and address on or within my model aircraft, effectively accomplishing the safety and accountability objectives of the interim rule.

• Make it clear this rule is contrary to the intent of Congress. The new rule is contrary to the intent of Congress in Section 336 of the 2012 FAA Modernization and Reform Act. Section 336, also referred to as the “Special Rule for Model Aircraft,” clearly prohibits the FAA from promulgating any new rules for recreational users operating within the safety guidelines of a community based organization. In addition, the FAA’s contention that model aircraft should be considered aircraft and are subject to existing regulation is currently the subject of pending litigation.

• Affirm that as an AMA member you should be exempt from federal registration. The registration process is an unnecessary burden for me and the more than 185,000 other AMA members. AMA’s membership program should be deemed an acceptable means of compliance and AMA members should be exempt from registering with the FAA.

187 comments

  1. As a member of the Academy of Model Aeronautics (AMA), I am disappointed with the new rule for UAS registration. I am a long time model aircraft flyer, who has operated under the guidance of the largest community-based organization (CBO) in the world for many years.
    Since 1936, AMA has published safety standards and offered training programs for our members – more than 20 years before the FAA was created.
    The new rule is contrary to the intent of Congress in Section 336 of the 2012 FAA Modernization and Reform Act. Section 336, also referred to as the “Special Rule for Model Aircraft,” clearly prohibits the FAA from promulgating any new rules for recreational users operating within the safety guidelines of a CBO. In addition, the FAA’s contention that model aircraft should be considered aircraft is currently the subject of pending litigation.
    I am already an AMA registered member. As such, the AMA already recommends that I put my AMA registration number or name and address on or inside my model aircraft.
    Furthermore, the registration process is an unnecessary burden for me and the more than 185,000 other AMA members. AMA members should not be required to register with the FAA.

    1. As a member of the Academy of Model Aeronautics (AMA), I am disappointed with the new rule for UAS registration. I am a long time model aircraft flyer, who has operated under the guidance of the largest community-based organization (CBO) in the world for many years.
      Since 1936, AMA has published safety standards and offered training programs for our members – more than 20 years before the FAA was created.
      The new rule is contrary to the intent of Congress in Section 336 of the 2012 FAA Modernization and Reform Act. Section 336, also referred to as the “Special Rule for Model Aircraft,” clearly prohibits the FAA from promulgating any new rules for recreational users operating within the safety guidelines of a CBO. In addition, the FAA’s contention that model aircraft should be considered aircraft is currently the subject of pending litigation.
      I am already an AMA registered member. As such, the AMA already recommends that I put my AMA registration number or name and address on or inside my model aircraft.
      Furthermore, the registration process is an unnecessary burden for me and the more than 185,000 other AMA members. AMA members should not be required to register with the FAA.

    2. I AGREE COMPLETELYY WITH THIS, I FLY FIXED WING AIRCRAFT. I DO NOT OWN NOR WISH TO OWN AND OR OPERATE A DRONE. IF There is a problem with drones then let drone owners register them. Ifthe rest of us have to register, then let us do so with our AMA numbers and the rule should be name, address tel #,and AMA # IN, OR ON THE AIRCRAFT. I CANNOT UNDERSTAND WHY THIS CANNOT BE DONE WITH DRONES. PROBLEM OVER. FOR THOSE NOT AMA members ,maybe they should have to become AMA members or if they choose not to join AMA, they would be flying drones illegally. Lastly, the drones I have seen are very small compaired to a 40 size aircraft and it is hard to believe that drones are readily visible above 400 feet, let alone 1000ft.

      1. For anyone interested in asking the FAA about these rules for themselves, the direct phone number is (202) 267-8306.

        Or Contact: Les Dorr or Alison Duquette
        Phone: (202) 267-3883

        I called and they actually called me back. This is the office that the FAA says is in charge of the “new” registration, and where I was told on Dec 16th while on a phone call with them, that if I am flying at a designated model flying field, under the current AMA guidelines that I did not have to register for anything. If that is true, it means it exempts most of us community flying field flyers and not the over my/your house video spy-ers.

        Give them a call.

        1. I just called the number to ask if I had to register before the 19th if I already own a model but will NOT be using it until April 2016. If not being used, does it need to be registered still by Feb 19th.
          My stated reason is that things are evolving and changing, not being sure where this will all end up feel it is a good idea to wait till I intend to use a model.
          No answer, sorry sir, I will not and cannot answer the question.
          Will

      2. Be careful what you support! Multi rotor pilots are part of the RC community. The FAA will not likely differentiate between what kind of craft is being flown. “Drones” are not the problem. Irresponsible operators are the problem. It isn’t likely that they will find registration numbers on downed craft that cause damage. However, if they show up to an AMA field, the majority of craft, if not all, will have appropriate markings and being operated by qualified operators. So what good is all the time and money spent on this legislation? Absolutely zero…

      3. Greg

        just so you know alot of us Multirotor/Drone flyers are already AMA members. And I have to say as a fellow AMA member thank you for your support. As members we should be together on this issue not divided.
        “IF There is a problem with drones then let drone owners register them.”

    3. I belong to fort smith flight masters no one in this club flyes drones’s that I know of I fly airplanes and helies for fun been doing it for 30 years just don’t thank its fair that you are picking me or us. to whome it may concern

    4. As a member of the Academy of Model Aeronautics (AMA), I am disappointed with the new rule for UAS registration. I am a long time model aircraft flyer, who has operated under the guidance of the largest community-based organization (CBO) in the world for many years.
      Since 1936, AMA has published safety standards and offered training programs for our members – more than 20 years before the FAA was created.
      The new rule is contrary to the intent of Congress in Section 336 of the 2012 FAA Modernization and Reform Act. Section 336, also referred to as the “Special Rule for Model Aircraft,” clearly prohibits the FAA from promulgating any new rules for recreational users operating within the safety guidelines of a CBO. In addition, the FAA’s contention that model aircraft should be considered aircraft is currently the subject of pending litigation.
      I am already an AMA registered member. As such, the AMA already recommends that I put my AMA registration number or name and address on or inside my model aircraft.
      Furthermore, the registration process is an unnecessary burden for me and the more than 185,000 other AMA members. AMA members should not be required to register with the FAA.
      While I am not at all please with this I have registered to avoid the $5 fee because I do not expect common sense to prevail in this matter. As stated above, members with planes previously identified are already being directed to sign-up with the FAA site and pay the registration fee for a membership number they will not use for anything but a piece of paper they will be required to print out and carry with them to the airfield. Why? So they will have it for the inspector the FAA will now hire to go to airfields and inspect for the piece of paper to inspect for. Does not make sense, does it? Nor does it make sense to completely ignore the lawmakers’ stipulation not to impose on the hobbyist, but you have done just that! And what do you hope to accomplish? Tracing the individual that runs their UAV into an airplane? Do you really think someone is going to mark their UAV with identifiable information themselves then proceed to fly it into an airplane? This is one of the most asinine moves I have ever seen by a Government entity, and I spent 22 years in the Navy. Find someone who can think and let them process this. You will find you have really missed the target on this one. You have induced a lot of expense, a lot of burden, with small chance of any return on your investment. Really, re-think this one!

      1. Typical democrat left wing control freaks. Keep voting democrat and soon you won’t be able to spit on the sidewalk without a jail term. All you pathological altruistic left wingers and the democratic welfare slaves (leaches)that lick your boot straps will destroy this country. God help us if the communist/socialist Clinton or Sanders get in office then we’ll be another broke ass Russia with drug heads and alcoholics slithering all over the place. You think this registration of RC planes is bad, you haven’t seen anything yet. I hate to get up on my soapbox but it’s time for the American people to wake up and retake control of this country.

    5. The idea that the government is overreaching its authority into a hobby just goes to show how misdirected the leaders of this country truly are. This is a great example of how a government agency is looking to justify their existence by looking for a new revenue stream to maintain and expand their jobs and make it look like the bloated FAA is truly important.
      We have larger problems flying in our air space such as drug smuggling, terrorist, over crowned commercial air planes, near hits on runways. But the regulation of a weekend hobby is at the top of the FAA list?

  2. OK, my toes are getting stepped on, now it is time to fight back. With enough e-mail and votes, at least we can try to do something. Otherwise, take what you get!

    1. From what I see, no one is pleased with this. I’m an RC flyer and recently an AMA member. I already have my AMA number in my planes. I follow the AMA code. I learned to fly at a local club where everyone teaches safe, responsible flying. This process does nothing for me nor any of the responsible flyers like me. The rules clearly should have stated “either join an approved organization and follow its rules or register with the FAA”. You should be pushing people toward joining community groups where they can learn to fly safely and be monitored by their piers. You do not have the resources to enforce or monitor this system but local RC clubs have been doing just that for almost 100 years. You are wasting time and resources pretending your action is adding accountability when it is not. I suggest you change the rule to prefer people join a group like the AMA and participate in a local club. I started about a year ago. As invalid my argument may be, I still make my point. Registering quads makes sense. But this is just too much. As a thirteen year old, money is not a steady thing. It’s hard enough to get gas to fly. So please respect the opinions of the Ute R/C Club and any others.

      Thanks.

    2. That is right! You can sit back and watch them take our rights
      away or you can do something about it! Dont expect the AMA to do
      it all! Call your congressmen, senators ect. Call the FAA!
      raise H*ll with them!

  3. VAs a member of the Academy of Model Aeronautics (AMA), I am disappointed with the new rule for UAS registration. I am a long time model aircraft flyer, who has operated under the guidance of the largest community-based organization (CBO) in the world for many years.

    The new rule is contrary to the intent of Congress in Section 336 of the 2012 FAA Modernization and Reform Act. Section 336, also referred to as the “Special Rule for Model Aircraft,” clearly prohibits the FAA from promulgating any new rules for recreational users operating within the safety guidelines of a community based organization. In addition, the FAA’s contention that model aircraft should be considered aircraft and are subject to existing regulation is currently the subject of pending litigation.

    • Affirm that as an AMA member you should be exempt from federal registration. The registration process is an unnecessary burden for me and the more than 185,000 other AMA members. AMA’s membership program should be deemed an acceptable means of compliance and AMA members should be exempt from registering with the FAA.

    Respectfully

    Charles Lukes

  4. Here’s text of letter I sent my congressional reps. Leverage and CONTACT your Reps TODAY!

    Honorable US Congressman MR Firstname Lastname,
    I am writing to express my opposition to the FAA’s decision to require registration for all privately owned and operated radio controlled aircraft. I respectfully request your representation of my position on this issue to Congress and the FAA, and am requesting your support of the efforts of the Academy of Model Aeronautics (AMA) as related to this issue. Ultimately, I am requesting that model aircraft operated according to the rules of the AMA be exempt from any FAA registration. The FAA is requiring registration between December 21, 2015 and February 19, 2016. I am requesting your assistance in establishing an immediate hold of any required registration until full vetting of the FAA’s intent and rules can occur and aircraft operated according to AMA rules can be exempted from FAA registration.
    The AMA has successfully self-governed fixed-wing and rotor model aircraft since 1936. Members of the AMA agree to uphold and abide by a strict set of rules to assure safe flying. Most AMA members belong to a local flying club which typically maintains a dedicated flying field and model-sized runway (AMA club facility). Each of these clubs — and there are hundreds across the U.S. — closely monitor and instruct their members to fly safely and under control in designated AMA club facilities that are approved by local governments. The AMA has prescribed clear and specific rules by which these AMA club facilities are governed. No one is permitted to operate an aircraft at AMA club facilities without following AMA rules. Aeromodelers follow AMA rules to ensure their personal safety as well as the safe return of the model aircraft itself, which is often the result of significant investments of time, care and money. Also, formal AMA membership provides liability insurance coverage for flight activities at the AMA club facility. Suffice to say, safe flight operation is paramount for AMA modelers.
    Congress recognized the safe and sensible approach to self-governance which the AMA has practiced for years by passing in 2012 a special rule called the “Special Rule for Model Aircraft”. The Special Rule for Model Aircraft in the FAA Modernization and Reform Act of 2012 clearly states that the FAA is prohibited from promulgating any new rules for recreational users operating within the safety guidelines of a community-based organization (CBO) such as the AMA. In spite of this special rule, the FAA now states all model aircraft are required to be registered. Meanwhile, the FAA’s contention that model aircraft should be considered aircraft is currently the subject of pending litigation. Congress by no means intended to grant a free pass to flyers within this system. Instead, it left risk mitigation and the development of appropriate safety guidelines to organizations like AMA.
    I understand and appreciate the FAA’s concerns about the proliferation of multi-rotor aircraft, or “drones” that occasionally are in fact operated in a risky fashion. The operators of drones often consider these flying machines as toys rather than piloted aircraft and are unaware of what constitutes “safe and appropriate flying”. Recent news accounts report of “incursions” where drones have inappropriately entered certain protected airspace or have been operated too close to full-size aircraft. These infractions do not occur when AMA member pilots are involved. If this were not true we would be hearing about radio controlled airplanes and helicopters constantly infringing upon restricted airspace or causing continual risk to full sized aircraft. I cannot recall one instance of such an issue. The FAA should focus its efforts towards non AMA situations.
    I find the FAA’s required registration to be a gross infringement upon my freedom to practice model aviation. It is also yet another example of unnecessary government intervention upon my activities. I challenge the FAA to show evidence where forced registration will eliminate inappropriate operation of model aircraft and drones. As with other required registration situations, those that cause trouble will be the ones not registered. Law abiding, or in this case AMA rule abiding, pilots will be infringed upon by unnecessary FAA regulation.
    In summary, I am requesting your assistance and representation in order to;
    1) Obtain an immediate hold of any required registration until full vetting of the FAA’s intent and rules can occur and aircraft operated according to AMA rules can be exempted from FAA registration.
    2) Partner with and support the AMA in order to change the FAA’s stance to that as I have explained in this letter.
    For your reference, here are web links from the AMA web site with information about this issue:
    Director of AMA Governmental and Regulatory Affairs: Mr. Rich Hanson amagov@modelaircraft.org
    http://www.modelaircraft.org/aboutama/organization/hqstaff.aspx
    amablog.modelaircraft.org/amagov/2015/12/14/ama-reacts-to-dot-uas-registration-rule/
    amablog.modelaircraft.org/amagov/2015/12/14/ama-and-the-faa-registration-process/
    amablog.modelaircraft.org/amagov/2015/12/16/amas-voice-gains-national-exposure/
    This is the “Know before you fly” effort of AMA to educate drone owners of AMA safety guidelines:
    amablog.modelaircraft.org/mediaroom/2015/12/17/amazon-among-more-than-20-organizations-joining-know-before-you-fly/

    I would welcome an opportunity to speak with you personally about this issue. Please let me know if you would like to have a conversation. I would also appreciate a response to this letter and continued updates of your progress on this issue.
    Respectfully yours,

    1. Brian, great letter, I will probably be using some of your comments in mine.
      However I agree with Bob below.

      I think it is imperative the our senator and congressmen realize that the Model Aircraft is not being registered, nor is the pilot being licensed or trained in any form or fashion. All the FAA is doing is a PEOPLE registration for the sole purpose of ENFORCMENT.

      I believe this requirement is in direct violation of 336 as their are no FAR’s dealing with people registration and therefore this IS a new rule.

      This rule dose nothing to improve the safety of the NAS nor does it integrate sUAS in the NAS, which the FAA was tasked with by Congress. The FAA failed miserably and this rule is merely a last ditched effort to save face in the general public and media’s eye.

      I would suggest that in our letters we emphasize the words “Model Aircraft” and make a clear separation with words sUAV’s and Drones because that is at the root of the problem and confusing the issue and the general public, feeding the media and the FAA is taking advantage of it.

      While we must continue to support the AMA (even if I feel they underestimated the FAA, IMO) and their efforts to save our hobby from Federal Legislation, we, the Model Aircraft Comunity must step up to the plate as individuals as well and write our senators, congressmen, other elected official and the FAA and let our voices be heard.

    2. Mr Beulow, I think your letter to your congressional reps was fantastic. As for the modernization act of 2012, I think Congress trumps the FAA! The FAA can blow it out their backsides. This is yet another example of big government trying to regulate the life activities of it’s citizens. Last time I checked, we put them in the positions they hold and we darn sure can take that away from them. In case the sarcasm wasn’t apparent enough, I’m a little hot under the collar and I will NOT register with the FAA; now or ever….

      1. And the US Constitution trumps Congress. Neither Congress nor the FAA has any constitutional authority whatsoever to tell anyone what they can or cannot do with their own private property if it is not being utilized in interstate commerce. That is strictly state and local jurisdiction. Start organizing a class action lawsuit NOW.

  5. I appreciate your efforts, but your blog contains a serious misstatement. There is no requirement that we register our aircraft. The requirement is that we register ourselves individually. This is an important distinction, because the FAA is saying that since it was always a requirement that we register aircraft, this is not a new rule that would violate Section 336. Since it applies to individuals, it IS a new rule, and therefore DOES violate the 2012 Act.

    Thank you again for your efforts. Next up…getting the DC SFRA lifted!

    1. Hi Bob,

      The rule states in section VII(F)(4) para. 14:

      “As previously noted, for owners of small unmanned aircraft used exclusively as model aircraft, this registration constitutes registration for all small unmanned aircraft of a single owner, provided those aircraft are all used exclusively as model aircraft.”

      The language used is for registering the entire fleet – not the individual. I’m not saying I agree with the ruling as it does violate 112-95 Sec. 336, but this is the language the FAA is using to get around it.

    2. Bob, the DC SFRA has been in existence since 9/11. I assume you mean getting it lifted as pertains to sUASs. I feel like that is a losing battle, but wish you luck. We pilots would love to have the DC SFRA lifted. It is a permanent “TFR”.

  6. As a member of the Academy of Model Aeronautics (AMA), I am disappointed with the new rule for UAS registration. I am a long time model aircraft flyer, who has operated under the guidance of the largest community-based organization (CBO) in the world for many years. Since 1936, AMA has published safety standards and offered training programs for our members – more than 20 years before the FAA was created. Our National Model Aircraft Safety Code has been recognized by Congress as well as by state legislatures as a safe and effective means of managing model aircraft enthusiasts like me. Additionally, AMA’s safety program already instructs me to place my AMA number or name and address on or within my model aircraft, effectively accomplishing the safety and accountability objectives of the interim rule. The new rule is contrary to the intent of Congress in Section 336 of the 2012 FAA Modernization and Reform Act. Section 336, also referred to as the “Special Rule for Model Aircraft,” clearly prohibits the FAA from promulgating any new rules for recreational users operating within the safety guidelines of a community based organization. In addition, the FAA’s contention that model aircraft should be considered aircraft and are subject to existing regulation is currently the subject of pending litigation. The registration process is an unnecessary burden for me and the more than 185,000 other AMA members. AMA’s membership program should be deemed an acceptable means of compliance and AMA members should be exempt from registering with the FAA. Thank you for your attention.

  7. As a member of the Academy of Model Aeronautics (AMA), I am disappointed with the new rule for UAS registration. I am a long time model aircraft flyer, who has operated under the guidance of the largest community-based organization (CBO) in the world for many years. I am 70 years old and have been flying fixed wing models for almost 35 years. I believe that this will just add another burden onto the modelers of the future also.

  8. AMA members are conscientious flyers that follow existing FAA and AMA regulations, safety practices, and local club guidelines. We all take pride in our hobby. Those flyers that are flying in restricted zones are not AMA members. They are most likely hobbyists that are new to the sport and are not familiar with AMA or FAA regulations. They are spoiling this great hobby for respectable AMA members and giving drone flyers a bad name. I would suggest AMA member IDs stay in place without no additional government registration for aircraft. The AMA has a good system that is working for us – no need for additional government intrusion that will not solve drone problems that are occurring.

    With respect to the commercial or flying a drone for business, i see no need for a full scale pilots license or full scale recreational pilots license. This requirement is a big overkill and flying a drone is not at all like flying a full scale plane or aircraft. Sure there are similarities. This requirement would be daunting for commercial drone flyers and this requirement would hamper the development of the commercial drone business. The money required to complete pilot training would be out of reach for most small business people. This requirement needs some rethinking prior to going forward. The drone flyers operating in restricted space and near airports are not licensed pilots – lisenced pilots would never do that. So you will not gain anything by requiring drone pilots to have license. I would also note that foreign countries are ahead of the US in terms of this technology.

    Thank you, Shane Craig

  9. Do I take this to mean that you (AMA) are un willing to do a mass 185,000 strong letter to the FAA ? Why are you so unreasonable with this suggestion ? There must be a reason for this unwillingness. I have suggested this line of attack for 2 years now and you are only able to take an attack that is doomed to fail.
    Please tell the membership why you don’t want to succeed with your dealings with this rougue agency.
    I submit that where there is smoke there is fire.
    Your method will fail as it has before,what is to be gained by meeting the enemy full force in a frontal attack?

    1. Appreciate your suggestions. We have conducted similar campaigns, as you suggested, in the past with success. At this stage though, we need to submit as many comments as possible through the registrar before January 15, 2016. This is not necessarily our last call to action.

      1. I would be helpful to have a break down of AMA members by state. That way members can address their state elected officials with total membership numbers as well as state numbers.

        1. The only thing our writing to the FAA will do is give them our names. Isn’t that their agenda?

  10. CORRECTION—–LAST SENTENCE SHOULD READ:

    Your method will fail as it has before,what is to be gained by* not* meeting the enemy full force in a frontal attack?

  11. I am bewildered by this registration requirement. I see no purpose in it rather than another government inclusion into our lives based on very questionable reports and fear. I am a member of the Academy of Model Aeronautics (AMA). I fly within the guidelines and rules of the AMA and my local RC Flying club.

    The FAA does not even have the authority to impose this regulation. It’s contradictory to the intent of Congress as per Section 336 of the 2012 FAA Modernization and Reform Act. Section 336, also referred to as the “Special Rule for Model Aircraft,” clearly prohibits the FAA from promulgating any new rules for recreational users operating within the safety guidelines of a community based organization. It can’t be much clearer than that.

    Please rescind this inappropriate regulation.

  12. A few things…First, the public comment period is well over. Second, you got us about the best you could given the requests of other organizations. Third, although some people know of the AMA requirement to have your name, address, and AMA number inside airplanes, it is seldom followed (especially on smaller planes, helis, and UAVs, and I have never heard of it being enforced. For the FAA to think that AMA national and local groups will suddenly enforce that rule seems a bit disingenuous.
    I’m sure you don’t see things this way, but I am on both sides as a member of AMA, EAA, and AOPA – both an R/C flyer and a full scale pilot. I don’t see the burden of this.
    If you feel that it violates congressional mandates you can sue, but you run the risk of it becoming an issue in the next congress. Especially if there were an event that makes the media.

    Thanks for listening,
    Doug Grant
    P.S. If it is not obvious, I have already registered.

    1. I registered because I feared administrative action on my pilot’s certificate if somehow I were to be found in violation of the registration requirement.

    2. It’s interesting to me that so few people out there have this view. I agree with Douglas 100%. It takes about as much time to register as it does to place an Amazon order. And the FAA wants LESS information!

      Over the years, I’ve seen less people put their AMA info in/on aircraft than do. You show me one RC aircraft WITH AMA info in it, bet I can show you three WITHOUT it. I’ve seen AMA members do VERY stupid things while flying RC aircraft. Statements like “AMA members are conscientious and safe” or “AMA members already adhere to similar safety rules” is at minimum inaccurate. Preface these statements with “Some AMA members” and I would tend to agree.

      The public is no more inherently safe because RC aircraft flyers pay attention to AMA safety rules versus FAA safety rules. The only real issue I have with the FAA policy is the 400ft ceiling. The language seems to mandate a 400ft ceiling at all times, everywhere. That’s troubling.

      The complaint I hear in almost every argument is “Big bad government is trying to manage another part of my life.” That may be true. But the functional aspect of the FAA ruling doesn’t really mean much to RC aircraft flying in general. Anyone arguing the politics of this issue can do so all day long. I’d probably agree it’s bad, meaningless policy. But you site there and try to tell me this is going to keep you from flying an RC airplane this weekend and I’ll call BS everytime!

      If someone plans to fly an RC aircraft into a full size aircraft or building or group of people, I’m pretty sure they’re not going to include identifying information on the RC aircraft. FAA or AMA information. It’s my opinion, AMA is wasting it’s breath and money trying to get AMA members excluded from the FAA registration. AMA members are not necessarily more safe just because they’re AMA members.

  13. I have been a RC sailplane hobbyist for 40 years. I have also earned a Private Pilots license. In my personal experience I have never seen a “near miss” with a full sized aircraft. Flying a sailplane without noise enables me to determine when an aircraft is approaching and take appropriate action. I have line of sight of my model at all times. A nation wide 400 ft. ceiling is not required based on flying under AMA’s safety rules, including having my AMA number 20538 on all of my models. Please do not catagorize RC sailplanes with FPV aircraft which do not have the same level of situational awareness. Such a limitation ruling in all US airspace would be in direct contradiction, in my opinion, to the intent of Congress under section 336. Therefore based on actual data RC sailplanes should be excluded from a nation wide ceiling of 400 ft unless a model is operating within 5 miles of an airport.

  14. I understand, and largely concur, with your position on this subject. And I recognize that many of the new people with drones have little training nor understanding of their responsibilities. However, I do believe you could/should make an excepting re: the registration of model aircraft flown by AMA members at AMA fields. These men and women, are fully cognizant of their responsibilities. They do not pose a hazard to aviation not to national security.

  15. I think pilots should be allowed to use their AMA number for their registration number.
    The AMA has all the information required by the FAA as it is.
    Adding yet another number to the process will do nothing to make any thing better for anyone.

  16. Please reconsider our line of sight flown radio controlled airplanes and helicopters, we have always flown with-in the rules of the AMA and our club rules. And now we are all thrown into one group with the UAS that are causing the problems, they (UAS) are gps guided or flown fpv. My self, with RC helicopters, will always fly line of sight, under 300′ be a member of the AMA. It takes considerable time and money to enjoy and become a decent pilot, and I am sure not going to do anything to take away my ability to enjoy this hobby.
    Please come up with a better description to describe UAS, possibly less on weight and based more on its guidance control and its ability to fly autonomous, or through a fpv camara system.

    A 700 class helicopter can cost up words of several thousand dollars and take years to master. These you don not just go buy and fly.

    Thank you for your time and consideration.

    Jack Brechbill
    AMA # 1011869

  17. The AMA has a better track record on safety than you do !! We have not lost our systems
    while aircraft are in the air carrying passengers and thousands of gallons of Jet A-1.
    We have not let helicopters fly with defective gas tanks for over 30 years, which have
    caused crashes and fires. The helicopters belong to police depts., emergency rescue and
    private pilots. You were told about these defects and did nothing, only approving new
    designs in new built helicopters. Your safety record compared to AMA SUCKS. Clean up
    your own house before telling someone else to clean up theirs !

  18. 20 minutes and 10% battery life and the page still will not load up! Is this how our government bureaucrats buffer people from adding their
    voice.

  19. The problem is people that fly drones are generally not AMA members. They purchase quad
    copters or planes that have or can be modified to carry cameras and GPS systems. These
    units can not be seen from the ground for control ( LOS )line of sight. They are flying
    at altitudes that can not be controlled from the ground by sight. These people do not
    represent the majority of AMA members and has brought this hobby a bad name.
    If you to rectify this problem, prohibit or ban the use of FPV (first person view) equipment such as GPS and down link to laptops, Iphones and Ipads. Make the fine big
    enough that would scare these people off from the purchase of these units, not a slap
    on the wrist. They can purchase the units to fly but not at altitudes that would hinder commercial or private pilots. The commercial use of drones could be left as is
    by having them registered, trained in the use of the units and a license issued after
    completion of their training. There are always bad apples in every bunch. Don’t through out the basket because of the one or two bad apples.

    1. Oh, ok, so just throw FPV enthusiasts under the bus?! Forget about the gross infringement upon my freedom to practice model aviation in the way I see fit, i.e. via FPV flying?

      Many other people, including many young people are finding the joys of aviation through FPV technology which they may not have through the traditional model aircraft route which can be an expensive and timely aspect of the hobby.

      Its hypocritical to say don’t infringe upon my rights but its ok to infringe on other people’s rights.

      In America, you have the freedom to believe what you want until those beliefs turn into campaign platforms, legislation and law, then you’ve overstepped our constitutional boundaries that protects otherwise free people from Fascist or Communist tyranny.

    2. I understand there is a lot of fuss about drone registration. I don’t have a problem withama not registering their model aircraft. The problem I have is that there are a few rogue pilots with their precious little drones making it hard on the rest of us. I should have my exemption 333 approved by the middle of next month. I say that if you are not going to use your drone for commercial purposes you should not have to register the drone, but the few dumb stupid pilots with their dumb drones have caused all the problems. With that said the FAA has now had to step in and put all these regulations that everyone has to abide by. As everyone knows that everyday life is full of regulations. At your work there are regulations, and when you drive there are regulations. With that said you could pose this scenerio I don’t drive my car recklessly or I don’t break the rules so why should I have to get a drivers license. Same thing. Nobody likes the federal government regulating our lives but we all have to abide by these regulations. I don’t want to upset anyone but If I were going to do anything about rogue drone poerators or rc airplane pilots that make it hard on everyone I would make the penalty so stiff that it would put an end or almost stop the stupidness. When you fly around airports and one of the drones gets injested into the engine of an airliner it puts lives in jeopardy. I could preach on and on but this is my views. Why don’t all the ama members gang up on the rogue operators.

  20. AOPA does not register aircraft, EAA does not register aircraft, AAA does not register cars, BoatUS does not register watercraft…registration is inherently governmental. So I predict that’s a non-starter from FAA’s perspective.

    Secondly, we’re actually going to try and say that giving FAA less information than we give AMA is burdensome? Putting less information on our sUAS under FAA regulation than info AMA “recommends” is burdensome? And paying $225 to AMA for three years vs. $5 for three years to FAA is burdensome? I really don’t see that argument gaining much traction either.

    Lastly, we’re going to try and say that this runs contrary to section 336. How did that work out the first time we were asked to make that argument? It didn’t.

    FAA has a fundamental authority to regulate in the name of safety. While model aircraft have not been required to participate in that process in the past, we’re not living in the past anymore. The rapid growth in the number of sUAS means we can no longer do things the way we’ve always done them. Administrative controls like registration is a part of FAA’s authority and part of a comprehensive approach to safety. Next will be operational controls necessary to segregate unmanned aircraft from manned aircraft. I’m no rocket scientist, but altitude blocks sure seem like a good way to do that. But we’ll wait and see.

    And yes, I registered the first day.

    1. There are already laws in place protecting our airspace space. What is requiring everyone to register their toy planes going to do for the “safety” of our airspace?

      There is not one shred of tangible evidence to support that this measure will make our airspace any safer.

      However, if you can find evidence, it’s not too late to improve your post.

      1. Registration is an important administrative control to ensure that tools are in place for enforcement should it ever be needed. Remember, FAA doesn’t have luxury of looking backward, they have to figure out what needs to be in place for the future.

        1. Registration is always the first step a government takes to strip freedoms. How about stiff penalties and fines if you do something stupid with a model aircraft? Criminal intent is never stopped with regulations. The law abiding always pay the price. $5 now, $500 later.
          “Registration is an important administrative control”….Mao, Stalin and Hitler were firm believers in that!

  21. How true it is that a lot of these non AMA-FAA registered members are out there. 4 days ago i went to one of those Christmas light houses that compete for the holidays in Christmas decorations. I went with my kids we were there for a bit. As i was there is saw and heard a Bell ranger police helicopter fly right above the house, i though nothing of it and continued with the festivities, And would you not know it, out of the blue 5 feet above me was a phantom hovering with the stock cam. And this place had literally 100 people in the front lawn not including the cars up and down the block. No one did anything. I looked and scanned all over the place until in the back i spotted the pilot, a young kid. almost my sons age a bit older, i came up to him and i said i am an AMA member please do not fly the quad over peoples head and land. I asked him if he knows the rules of flying and being registered, He said yes but apparently i know he did not know even if he was registered. He landed and went into the house that had the people around it, his dad came out and proceeded to supervise him and asked him not to fly over the people. He did it over a spot were he can operate safely at a distance. I stepped over and handed him the AMA website to register, he said thanks you saved me a world of trouble.

    I am glad i stepped in, either wise it would been on the news as another lawsuit and a headache for us AMA pilots. As AMA members we also have to keep an eye out to protect our hobby and do what is necessary.

  22. I would suggest AMA members, like myself also point out these facts (mandatory registration, possible 400 foot ceiling for all Model Aircraft) to our Senators and Members of Congress as a violation of the spirit and law in Section 336 of the 2012 FAA Modernization and Reform Act. .
    Constantly harping how we are AMA members, Community Based Organization, etc with a strong safety record doesn’t seem to matter to the FAA against lobbyists from the likes of Walmart, Amazon and the sUAS industry that want more latitude with their drones.

    So write your elected representatives in Washington. I have kind of given up on letter writing to the FAA. The last round of letters to the FAA didn’t do much for us.

  23. Our AMA number is all the FAA needs from an AMA member. We have all the rules in place and a safety record to back up our willingness to follow safety protocols. Another number puts an unfair burden on the AMA member in that now we have put two numbers on our aircraft. Besides a registration number will not deter a pilot with malicious intent. He will not bother to register his aircraft or join the AMA.

  24. I am not a member of the Academy of Model Aeronautics (AMA), but still I’m disappointed with the new rule for UAS registration. I am a long time RC hobbyist, who has operated under the guidance of the largest community-based organization (CBO) in the world for many years.
    Since 1936, AMA has published safety standards and offered training programs for their members – more than 20 years before the FAA was created. The National Model Aircraft Safety Code has been recognized by Congress as well as by state legislatures as a safe and effective means of managing model aircraft enthusiasts like me.
    Additionally, I already place my name, address and phone number on or within my model aircraft, effectively accomplishing the safety and accountability objectives of the interim rule.
    The new rule is contrary to the intent of Congress in Section 336 of the 2012 FAA Modernization and Reform Act. Section 336, also referred to as the “Special Rule for Model Aircraft,” clearly prohibits the FAA from promulgating any new rules for recreational users operating within the safety guidelines of a community based organization. In addition, the FAA’s contention that model aircraft should be considered aircraft and are subject to existing regulation is currently the subject of pending litigation.
    Just because I am not an AMA member does not mean I don’t follow AMA rules. To the contrary, I believe these rules are for the safety and good of everyone. I have not joined AMA because I don’t use their sanctioned flying sites. I fly over private property but adhere their (AMA) rules.
    There are people who do as they please and will ignore this regulation. I believe the industry must inform buyers of the safety rules when the model is purchased.
    Why not have on line instruction and quiz? We do this annually for our OSHA safety compliance at work. Offer a proof of attendance and a certificate number. This could be attached to the model along with contact information.
    As I see it now, one only has to pay, get a number and go fly. Have they learned anything, probably not? Will they continue to break the rules, more than likely?

    Anyone with evil intentions will just ignore this regulation anyways.

  25. I have not seen the following question answered by the AMA or the Far Above Authority group. WTF do you expect to accomplish by registration. just an honest straight forward answer without excess verbiage from either will do. You may use my email address or answer in any of the forums.
    TOM EWING. AMA8855

    1. There are a lot of new pilots out there who need to be educated to fly safely and responsibly. We at the AMA do not believe requiring our members to register will address that issue.

  26. I’ve been working on formulating a productive comment to the UAS Registration rule based on the provided tips (https://www.regulations.gov/docs/Tips_For_Submitting_Effective_Comments.pdf) rather than a blanket copy/paste of the AMA suggested comments. My two reasons are because I care deeply about this issue (my future activity in this hobby is dependent on the ultimate outcome) and because the AMA form letters won’t carry much weight since comments are not votes (per page 3 of the linked tips PDF).

    So, here is what I’ve come up with and have submitted (of course there’s more I could write, but this uses up the 5000 character limit). You are free to use all or some of it for your own comment, but please do submit a thoughtful comment on the rule (https://www.regulations.gov/#!submitComment;D=FAA-2015-7396-0001) using the provided tips before January 15, 2016.

    Cheers.

    —————————————————–

    As a member of the Academy of Model Aeronautics (AMA), I am disappointed with the new rule for sUAS registration for the following reasons:

    1. The sUAS registration is a rule or regulation regarding a model aircraft promulgated by the FAA which is in direct violation of Public Law 112-95 Section 336 which states “…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…” and thereby further defines a model aircraft (336(a)). The FAA rule also states its authority for rule-making is based on “…the statutory definition set forth in 49 U.S.C 40102(a)(6)…” (Sec. V para. 2 and VI(A) para. 2), but that definition was not recognized in Administrator v. Pirker, as being “…applicable to, or include a model aircraft within their respective definitions” (Docket CP-217 p. 7).

    Moreover, Section VII(M)(1) para. 7 states “…section 336 bars the FAA from promulgating new rules or regulations that apply only to model aircraft…” however that statement does not hold true to Section 336 as stated above. The FAA misinterprets it as “new rules” and “apply only to model aircraft” and yet Section 336(a) clearly states “…any rule…regarding a model aircraft…” Ergo, since this UAS registration rule applies to model aircraft, it cannot be accepted and should be dismissed altogether in violation of Section 336.

    2. The FAA registration website requires the following be agreed to in order to complete registration:

    
“I will fly below 400 feet”

    “I have read, understand, and intend to follow the safety guidance”



    As a RC pilot who flies safely in accordance with the law and AMA safety guidelines, I cannot agree to these terms as it violates Public Law 112-95 Sec. 336(a) which states “…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 community-based set of safety guidelines and within the programming of a nationwide community-based organization; …” According to the AMA Model Aircraft Safety Code (A)(2), model aircraft pilots will “(c) Not fly higher than approximately 400 feet above ground level within three (3) miles of an airport without notifying the airport operator.” Per Congress, there is no law against model aircraft from flying above 400 feet and that modelers are to follow the safety guidelines of a community-based organization and not of the FAA. Imposing new operating rules via subversive contractual language through the FAA online registration process violates Public Law 112-95 Sec. 336.

    With sUAS registration, an alternative means of compliance is needed which allows model aircraft registration for models operated in accordance with Section 336 and under the rules of a community-based organization. The FAA could accept the community-based organization’s procedures in lieu of registration with the FAA or the FAA online registration tool can be altered so that registrants are not required to contractually waive one’s ability to perform legal activities.

    3. Section VII(K) states “…all information in the database will be available to law enforcement…” (para. 24) and “…the general public will be able to search the part 48 registry database by the unique identifier…” (para. 25) revealing the associated name and address. While this information is only available by querying with the unique identifier, I disagree that my privacy is being protected and I am not being afforded the respect I have earned and deserve as a responsible aero-modeler. I now have the burden to protect my unique identifier from somebody who covets my model aircrafts as they potentially would be able to read the number, query the database for my address, and target my home for robbery – something I’ve previously never had to worry about.

    An alternative solution is for AMA members not to register with the FAA as we already have been registered with the AMA and do list our AMA number on our model aircrafts. While this number is publicly visible, only the AMA has access to the name and address of the owner, thus protecting the privacy of its members. Pilots that do not belong to a community-based organization (such as the AMA) could require registration with the FAA and their information (name, address, etc.) be kept private within the FAA and not publicly searchable.

    Since 1936, AMA has published successful safety standards and offered training programs for our members – more than 20 years before the FAA was created. Our National Model Aircraft Safety Code has been recognized by Congress as well as by state legislatures as a safe and effective means of managing model aircraft enthusiasts like me. Education works better than regulation.

    1. I find it odd that when I tried to respond to you comments I was spam blocked. I’ll try again. Registration should be the responsibility of the sellers and should take place at time of purchase. ie. Point of sale. As far as errant pilots who need training the comment would be simple, train them to fly by the rules BEFORE they take to the air, just like the big boys.

  27. This public comment is directed to the AMA executive leadership. I hope someone from the leadership is reading these comments.

    My prediction is that the AMA will have to ‘bite the bullet’ so to speak and decide to either challenge the FAA via the courts or ‘throw in the towel’ to use another tired but understandable phrase. I would like the executive leadership to make it clear what the estimated costs of that legal challenge will be and what is the probability of success. This and the terms of what the success will be should be published in the AMA magazine. Invite membership comment before embarking on what may be a case of ’tilting at windmills’ to complete this comment with another well known phrase.

    Thank you for reading this comment.

  28. Does the current AMA insurance policy/underwriter demand all policy holders comply with all applicable Federal, state and local laws as a condition of coverage? Can’t find the policy on the AMA website.

  29. With all due respect, what good is going to do complain to the FAA about how we feel, what are standing is with the AMA, and of course the blatant fact that they have violated Congressional law? The FAA sounds like they are going to do what ever they damn well please despite our efforts.

    Have you been to any retail stores in the last few days? The retail stores are pushing very hard for registration. Practically every multirotor being sold today off the shelf is advising the consumer that they must register. I can’t tell if this because of pure ignorance on the retailer’s part of not being aware of Congressional law, or the fact that the FAA has threatened the retail industry with who knows what punishment for not informing the public that they must (blindly) register without knowing anything about the law.

    I hate to say it, but the way this looks right now, it looks like the FAA will have its way, despite this being an overstepping of Congressional law on their part. The FAA has shown they do not care about what we, or the AMA, has to say about any of this. The FAA already has disregarded the AMA’s input, and I’m sure our efforts will be just as easily ignored.

    It is impossible to stop this mess now, with every retailer putting up registration warnings. Even my small town’s newspaper today (Pop. 9445) has a front page headline that reads: “Register drone or pay big”.

    Really?

    Why can’t someone of authority contact Congress, or a Supreme Judge in this matter and halt this unlawful and illegal operation in its tracks?

    In my opinion, the AMA needs to file an injunction, and, at the least get the attention of Congress. I am a paying member of the AMA. I appreciate what the AMA has done so far, but this is a very serious problem that is going to shape the future of the AMA, and its members. The effort of one person is not enough. It’s going to take an organization (AMA) to stop this.

    AMA: Please consider stronger legal options.

    1. The AMA should file a suit in Federal Court. This is just another example of a federal agency doing what they feel is right when in fact it is wrong. Our current President as well as a few before him have used their Executive orders to by-pass congress, why would the FAA be any different.

  30. The FAA has been less than clear on the fact that they do not register recreational drones. They only register the people who intend to fly them.

    For reference, see: https://www.faa.gov/uas/registration/faqs/ under Frequently Asked Questions.

    Question and Answer #44 in the FAQ’s is in direct conflict with many of the other questions and answers, in that it allows one to transfer the registration number (and responsibility) to another person.

    I am disappointed, but not surprised that, for as long as the FAA has had to work on this, they have not been more diligent.

    AMA Member 11803 since 1953.

  31. Michael, I am in complete agreement with you but are we really dealing
    with The FAA? It seems more like the KGB.

  32. Rich Chambless:
    Hear Hear. Compare General aviation safety recrd to AMA’s.

    Just sayin’

  33. These FAA rules are another example of “big brother” asserting its power upon law abiding citizens of the United States and I’m getting damn tired of it! The blatant disregard for law perpetrated by the current administration is disgusting and scary. Who would have thought that these “agencies” of the government would be allowed to walk all over the rights of the Citizens – whatever is this Country coming to? Another rules which will be totally un-enforceable is not what we need. Certainly the problem posed by irresponsible fliers is a serious one, but the new FAA rules aren’t going to have any positive effect on irresponsible acts of a few idiots or untrained children. I agree that the AMA should be seeking an injunction to STOP THESE RULES FROM BEING ENACTED. Anything else is simply going to amount to “giving in” to “big brother” yet again and more citizens rights will fall by the wayside!

  34. I might remind our leadership that if you read the FAA’s new (illegal) law, almost all the comments here have missed the point; to wit: since when has the FAA been in the business of registering people? Other than licensing qualified pilots? The way I see it, this new rule is nothing more than a beaurocracy’s attempt to create a bulk database of people, and make a whole bunch of money doing it. Please keep up the fight to make the FAA cease and desist with this illegal act. AMA 120623

    1. I have been working actively with our 3 federal elected officials that represent the residents of Indiana. To date I have received help from Rep Marlin Stutzman and Senator Joe Donnelly. Senator Dan coats and his staff dont have clue and after carefully explaining the situation on the FAA ruling, I was absolutely stunned to receive the following reply.
      He basically tells me the rule number and how to comply with it and also the “know before you fly” website. What a waste of my time and effort. I spent a lot of time with emails and phone calls and gave the office very specific details such as the exemption 336 in public law 112-95. Then in the letter he recites it back to me! Pretty much verbatim including the dates etc.
      Thank goodness his term is up in 2016. He doesn’t have a clue!!!! My reply to the letter wass not very complimentary!!!!!

      Senator coats letter is below, read it for yourself, I feel my intelligence has been insulted and wanted to share the ineptitude of Senator Dan Coats (R) Indiana and his staff.

      Dear Roger:

      Thank you for taking the time to contact me about the regulation of small unmanned aircraft systems (UAS). I appreciate the opportunity to respond.

      I understand your concerns regarding the regulations related to small unmanned aircraft systems. The FAA released final regulatory rules for small UAS on December 16, 2015, as required by the FAA Modernization and Reform Act of 2012 (Public Law No. 112-95). These new regulations require users to register their small UAS and pay a minimal fee to the FAA. I encourage you to visit http://www.knowbeforeyoufly.org and http://www.faa.gov/uas/registration/faqs to learn more about the new rules now in place.

      In the meantime, I will be sure to consider your concerns as this evolving issue is discussed in the 114th Congress. Rest assured, balancing convenience and freedom with safety and responsibility is important to me. Thank you again for contacting me, and please do not hesitate to do so regarding other issues of concern to you.

      Sincerely,

      Dan Coats
      United States Senator

  35. Stop this new FAA model aircraft registration program, right now!!!
    It is wrong headed overreach of government into our hobby activities and should be discontinued immediately.
    I have flown full scale aircraft, as well as model aircraft, for many years and do not think this new rule makes the skies safer for me or my fellow pilots.
    It certainly will not prevent anyone with bad intent from doing what they want.

    Also the 400 foot altitude limit is totally unacceptable to RC glider fliers and would ruin a perfectly safe and fun activity.
    The 400ft limit will make criminals of people flying gliders in an otherwise safe manner. That is a really bad thing to do!

    This is Government overreach and should stop immediately!
    There are already enough laws on the books to punish people who cause harm to others.

    This new rule is contrary to the intent of Congress in Section 336 of the 2012 FAA Modernization and Reform Act. Section 336, also referred to as the “Special Rule for Model Aircraft,” clearly prohibits the FAA from promulgating any new rules for recreational users operating within the safety guidelines of a community based organization. In addition, the FAA’s contention that model aircraft should be considered aircraft and are subject to existing regulation is currently the subject of pending litigation.

    If you will not stop this rule, at least raise the weight requirement to 500 grams.
    Get rid of, or change the 400 ft height limit to what is controlled airspace.

    The FAA has gone to far with this new rule for our hobby.
    Hope you will do the right thing and reverse this bad new rule asap.

  36. AMA Leadership:

    This issue with UAS registration is ludicrous on all accounts. As the leaders of this organization you are failing to address this with any type of temperance that truly represents the members of your organization. Working with the FAA is great; however the volley has been launched and its time to defend what is a principle right for the AMA members under the current laws. While I can appreciate your need and desire to maintain cool heads and promote relationship building I can also appreciate you standing up and taking action of a much more aggressive approach.

    To date and by not taking legal actions to stop this issue at hand you in effect are creating a vacuum for others to fill thereby ignoring your leadership responsibilities. This is not the “good old days” and its not a friendly environment that we face with our lawmakers. Frankly, this is a world where every one will be vying to take away rights and freedoms because they can somehow claim they are offended or its somehow safer with more regulations put on the books.

    This is where it gets tough to be a leader and I would encourage you to think about why you were elected to these positions and begin to truly represent the desires of your membership with actions that prevent this infringement from occurring. While its easy to sit far away and judge you for minor differences in opinions and internal rules that not everyone will agree with, its very simple to judge your efforts through the results at hand. By seeing no formidable legal offense occurring on this issue one can only surmise that you are taking a disastrously passive role.

    It is time to stop sending social media updates, news letters and communicating the status of whats happening to us and begin filling a suit to block and reverse any and all actions that propagate the FAA rhetoric. Simply put, its time to do the job you were elected for and truly lead. Anything else is failure to represent the majority.

    Best Regards,
    Tim Maxson

  37. I’ll be quick to my point – If I as an AMA member will be required to register to be covered under AMA and/or “legal” in the eyes of the Federal FAA/DOT agencies I will just quit the sport. This hobby/sport at the level I fly and the models I fly should not have any additional requirement or Federal oversight other than what the AMA requires.

  38. These rules should only apply to drones and FPV.
    Standard RC flight requires skills and local proximity, thus does not add to the problem the FAA is trying to address.
    The issue is unskilled/malicious pilots with drone+fpv technology that want to look at the airport from their apartment, not actual recreational RC flyers.
    Since you are already supposed to have some ID on your RC flying models, there is no need for an additional registry.
    I say push back and solve the problem another way.

  39. Dear FAA,

    If you want to step in and do something, I suggest you require all model pilots to be registered with the AMA instead of this non-sense. I suggest you have the AMA serialize each craft so the responsibility is held to the right person. We already pay, and pay quite a lot for the lower class like me. We are NOT the problem. The problem is the stray, unlicensed pilots that don’t know the rules, haven’t had any guidance, haven’t had any safety exams, and get into trouble because they don’t know how to fly a craft that could possibly cause harm or damage. Right now you are very intrusive.

    The AMA is here for a reason. A reason that is already covered. We don’t need to raise hatred towards some fools looking to charge us for something we are already charged for.

    -Joel

  40. Does the AMA recommended that wee fly new model aircraft (e.g. planes bought and/or not first flown until after 12/21/2015) before registering with the FAA?

  41. Well I’m not surprised that the FAA would do something like this. That you would try to redirect your own rule or regulation. In SEC 336 it clearly states that you the FAA cannot 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 community- 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 unless otherwise certified through a design, construction, inspection, flight test, and operational safety program administered by a community-based organization;
    (4) the aircraft is operated in a manner that does not interfere 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 procedure with the airport operator and the airport air traffic control tower (when an air traffic facility is located at the
    airport)).
    And I can say with assurity that we, the members of the AMA follow our safety rules to the letter. You have stepped over the line with your regulation change.

  42. I have been in the sport of model aviation for more than 40 years now.. AMA#33908.
    My opinion is all of this is being taking out of context and missing the big point.. Registering is the FAA’s way of catching “who did it”. Was the Secret Service guy who flew the drone while drunk and landed on the White House lawn registered? NO… He admitted to his screw up before being caught.. Is putting out a no fly zone for UAS doing anyone any good right now for a 30NM radius from DCA.. NO… Did the guy flying his Quad to close to the presidential motorcade know the presidential motorcade was even there on the island last week. NO… (should have been flying at a proper field).
    It is causing more risk and harm… Some guys are flying in parks and schools and where ever just to fly versus being at a club field and flying in a controlled environment. With people who are enforcing the AMA rules…
    Club fields should be on the FAA list for air traffic control that are in the TCA so the risk can be reduced by keeping the full scale aware and away from the fields. Plus it is the AMA club members who are the eyes and ears out their to provide the “see something say something” information as the policy wishes. If a qualified club member sees suspicious activity or notices suspicious characters who want to do harm than they would be the first to recognize and filter out this bad behavior or threat to our well being.
    It is my thought that this needs to be going the other way… Creating more hobbyist not deterring from the sport being the extra set of eyes and voices to culture safe activity within the sport… We need more fields to keep the activity in a controlled environment.

    The AMA rules are the backbone to keep this sport safe and responsible. Those who want to really do harm won’t register, won’t leave their name and contact info on a note in the UAS… But more responsible pilots can deter and identify the ones that want to do the harm… The registration process will have no value in the long run and will most likely not help in an investigation if something does go horribly wrong…

    Honestly hearing the label Drones makes my skin crawl… I fly Model Aircraft not a flying target to be shot at…

    Has there ever been a mid-air collision from a model aircraft and a full scale aircraft? Especially a commercial aircraft.

  43. Since the FAA is going after every owner of every kind of rc aircraft, whether you fly in some obscure field in the middle of nowhere, the Bonneville Salt Flats, an AMA approved field, or not at all, I can’t help but see this as anything other than a tax grab, an act of yet another attack on our freedom and a Government’s illegal over-reach to control the actions of free, responsible citizens.

    I’m a member of the AMA. I fly my sailplanes in an AMA approved field ONLY. I follow AMA rules and guildelines. I fly responsibly yet I’m being lumped with irresponsible kids who are flying drones recklessly and dangerously. I’m being burdened with restrictions, registration, fees and threats of enormous penalties for non compliance, all under the guise of ‘safety’.

    If safety is the FAA’s real concern then I would suggest the FAA go after the people who are causing the problem and leave the responsible flyers to our sport. And everyone knows that registration will do nothing to stop irresponsible operators of drones from flying irresponsibly.

  44. the fines are so big that they seem like they are designed to absolutely and permanently destroy a citizen for just one infraction. The rules have changed several times in recent years and unfortunately, you are guilty until proven innocent. Even if accused– the way an attorney will “bill” or “charge money” to defend is not going to based on your innocence or not– its going to be based on the size of the fine that they are helping you to avoid– so no matter what– you can easily be destroyed. Unfortunately, if this rule isn’t alleviated by February 19th, I am going to destroy all of my planes and throw them away. That is bad for the economy, I was a frequent spender which helped fund the technology which everyone benefited from including the FAA. I just can’t afford to take even a very remote risk at one of those fines. You never know when they will suddenly declare a new no-fly zone and for whatever reason– you didn’t hear about it– bam– huge problem: financial destruction. Hint: I’m already in financial ruins.

  45. The FAA’s registration requirement is another example of bad UAV regulations. The way registration is designed eliminates any usefulness other than in the relatively few cases where a UAV is recovered without the operator being identified. It does nothing at all to further airspace safety. If there had been mandatory air safety education associated with registration then it would actually be in the public’s interest to require registration. Instead of focusing on the important part, the FAA decided it needed to rush SOMETHING into place so they picked the absolutely least useful thing to do. Another example of the FAA “doing something” instead of doing something logical and useful, is the 333 exception requirement that to operate a UAV commercially you must be licensed to fly a plane. There is no intersection between operating a quadcopter and flying an airplane. I think once again the issue is education. A licensed pilot knows the rules of the sky so the FAA took the simplest route again – this time 180 degrees from the uselessness of the registration process to a process that is overkill for the objective. It is absurd to say that you have to invest the same time, money, and flight training to operate a UAV commercially that is required to operate an airplane. The FAA needs to stop “doing something” and instead invest the time and resources to come up with an education/certification program for UAV operators that lies somewhere in the middle of the two current extremes that would actually apply to the skill/knowledge set a UAV operator would need to operate safely. All the FAA has really done so far is create a couple of new classes of criminals. The whole distinction between recreational and commercial use OF EXACTLY THE SAME UAV is pretty artifical to begin with. The FAA is not the Commerce Department. Their concern should be safety only. Consider that the exact same flight of the exact same UAV taking exactly the same videos and photos of the exact same subject now has two wildly different FAA requirements depending ONLY on whether or not those videos and photos will – after the flight is over – be viewed by friends and family or a customer. FAA, please stop making rules until you’ve given a lot more thought – and consultation with interested knowledgeable parties such as the AMA – to what it is you should really be focused on accomplishing.

  46. As rules go this seems completely redundant if the AMA has already agreed to turn over to the FAA membership lists as a good starting point in solving a problem. The real problem is similar to gun control, the people who create the problems are not those of us who play by the rules and register with organizations such as the AMA. This new process will not stop those who chronically disregard authority and rules just because they can. It is true the new legislation puts teeth in the form of steep fines for those who violate the registration process and create a problem. But one has to then ask, how many times will such offenders be caught? You can still have am appropriate punishment on the books without penalizing everyone else. Requiring vendors to register non-AMA members at the time of purchase would be a far better solution. If you don’t register at the time of sale there simple is no sale. The amateur radio vendors do good work following these guidelines. They ask consumers for a call sign before they sell them a radio. I know this to be true as I am also a licensed amateur radio operator. I wish the FAA would reconsider the AMA’s point of view and the membership that they represent. I would go as far as saying that AMA member are far better trained pilots that those who are not.

  47. Here’s what I am sending:

    1/5/16

    To:

    https://www.murphy.senate.gov/contact
    https://www.blumenthal.senate.gov/contact/
    https://himes.house.gov/contact-me/email-me

    Dear Sirs,

    The FAA has ignored Congress’s clear statement that model aircraft are not to be subject to rules of the FAA in Special Rule 336 of the FAA modernization Act of 2012.

    Making hundreds of thousands of people register themselves so they can fly a drone or a 12 inch B52 replica 40 feet in the air in their backyard does not make our skies safer, and yet the FAA admits this new system will cost hundreds of millions at the Federal level, and untold millions at the state and local level to enforce without funds.

    The FAA is promulgating a rule that asks children under 13 to get at least a 13-year old to register for them, using the email address of anyone they know and anyone’s credit card (even using anonymous gift cards), and yet thinks that is making the skies safer.

    The FAA jumped past its own statements that it would get from flyers of Small Unmanned Aircraft systems (“sUAS”) an “acknowledgment” various simple safety rules. Instead, the registration process requires from owners a positive affirmation that the person registering as an owner “will” do such and such. To make it worse for the average 13-year old to understand, these rules are unspecific and contradict at least three other simultaneously existing FAA lists of ‘simple rules’ that model aircraft flyers should follow.

    The FAA commented that the decision to require credit card payment was to enable further “vetting”

    Also the FAA site wording wanders aimlessly around between “registering your drone” and “registering as a drone owner.”

    And the FAA took the new rulemaking event to re-assert is claim to total jurisdiction over airspace at any altitude, even 1 inch over your head, preventing states, cities, counties and towns from having ANYTHING to do with controlling who’s peeking into our bedroom windows.

    The FAA site does not let me register now. It happens that when I registered for my daughter, I used my email address for confirmation, because I was the one doing the registration. Now the FAA won’t let me register because the email address is “already in use”. So now I am stuck in the middle, wondering what I should do, and get response from the FAA to my inquiry.

    Since the system was pre-announced Dec 14th, the FAA always published statements, and made clear in its own ruling, one could register by paper. Today, I see they amended all previous promises and said that the paper system is not for model aircraft or recreational drones. Then later in the same FAQ, the FAA reverses itself and says you can register by paper. That process means I have to drive to Hartford from New Canaan to pick up an original paper form. The FAA does not accept any other paper form.

    By not allowing paper it means you cannot use U.S. coins or currency for paying (sort of) a $5 fee to the U.S. but instead you must have access to a credit card, even if you do not need, use or qualify for one (e.g. owners aged 19).

    The FAA, in its FAQs, says “The credit card transaction helps authenticate the user.”
    But
    1. if anyone can use an anonymously-purchased card, or anyone’s card, the above statement is simply false.
    2. The FAA site is very UNclear but it seems to say a few times that registration is not off a drone, or a user, but instead an “owner”.
    3. Keeping and using credit card information beyond the transaction is not allowed by the credit card companies.
    4. The logic for the credit card business is weak at best.

    The FAA rushed out a site where you can’t cancel a registration. Because the FAA suddenly on 12/25, and without time for public comment or consideration, banned model aircraft within 30 miles of the FAA’s HQ (D.C.), a friend in Virginia decided he wouldn’t buy a drone after all, and tried to “cancel” his registration. No can do. You can’t cancel an existing registration. How badly can you manage a registration roll-out?

    The FAA sites says that if I sell my drone, I should update “my profile” on its site. But there is no place in the “profile” to do this.

    Three weeks after I had permanently marked my daughter’s aircraft with the number, the FAA came out with an obscure reference as to how it should be written, with dashes in certain places that were not there when they gave me the number. This certainly could have been planned and described in advance.

    For me, the FAA’s apparent rush to exclude other registrars, and roll-out their flawed system pell-mell became apparent the day I first tried to write to the FAA to make a comment. Instead of accepting my comment, the web page came back saying I had failed something or other and proceeded to show me someone else’s comment on my screen, with name, comment and email address. It persisted for a few days like this. I wrote to let one of the victims of this privacy breach know their comment had not gone forward, and also wrote to let the privacy person at the FAA know of the breach.

    And what is it about to charge $5 “to register” (whatever that means) and then rebate it right away? No wonder the FAA is losing money on this program; paying for two transaction fees to the credit card companies and processing banks and yet making no money? Is it even legal to ask someone to use a credit card for no actual transaction just to capture the cc information? And it tells the FAA nothing about the person who “owns” the drone. How could this have been dreamed this up? And I used a gift CC with no name on it, where there is no way to repost the credit. What happens there?

    In one place on the FAA site it says I need to “mark the aircraft with the number” and in another it says I can include in on a piece of paper on the inside of the aircraft as long as it does not require special tools to get at it, and in another says it has to be “permanent”.

    Because the number is that of the owner and not the operator, when the operator loses control of the aircraft and it crashes on to a freeway, does the FAA intend to arrest/fine the 8-year old owner or the 13-year old registering person, or the 25-year old who decided to take it for a spin?

    Getting back to examining the very basic presumption is always good:
    What is the point of asking an owner of one recreational drone or toy plane to put
    1. His/her name and address
    2. into a FAA website
    3. charging them $5
    4. to then get a number spit out from the FAA computers,
    5. then rebate the $5 fee back to them,
    6. then make the owner put the tiny number on the model aircraft
    7. just so that if the drone is lost,
    8. a local policeman can look up the number on the FAA site, and get
    9. His/her name and address

    Why not just rule thus:
    “Everyone has to put their name and address on their model aircraft”
    (which the AMA has been saying already for 20+ years)
    o No big losses of money at the FAA
    o No big administrative nightmare
    o No loss in safety (bad guys will ignore the FAA anyway)

    Here’s the embedded conspiracy theory (and not unlikely in one way or another) in all this:
    It seems as if the BIG boys – FAA, Amazon, FedEx, UPS, Media and Google among others — have gotten together behind closed doors and conspired to reserve the “dronosphere” airspace (anything under 400 feet) for themselves. They want to be able to fly their commercial drones at 100 mph unhindered by citizens flying around and getting in the way. Amazon and all the rest of the BIG boys will be willing to put transponders on their drones, file flight plans, and all the rest. With more fear-mongering by the FAA that a few model aircraft “incidents” far outweigh the proven dangers and crashes caused by birds, the public will become “educated” that all this is necessary for safety and security.

    On the other hand, towns and cities, if left alone, would probably require commercial drones to fly down the center of streets, at specific heights, not fly over buildings and sidewalks, stop at red lights, etc., seriously inconveniencing and slowing down the BIG boys.

    It seems logical extension of this ruling, and within their self-declared jurisdiction, that the FAA will eventually say that buildings cannot rise without their permission, because they control the National Air Space and such new buildings may require coordination with Amazon’s flight patterns (filed with and approved by the FAA).

    Let us just face it: The FAA is not designed for, has no experience in and does not know how to handle “retail” flying by responsible kids and adults.

    This is a local issue, except for major airports and threats to national security.

    Getting to the heart of my personal problem with the registration system, I believed the FAA would accept the logical and consensual advice of its 25-member Task Force from a broad spectrum of parties in the area of how to make registration at the level deserved, make it easy and widespread as soon as possible and make it competitive for the most value for all stakeholders. That group recommended that other registration sites and avenues could exist as long as they could exchange data with the FAA computers. This is more or less they way the Internet managed its explosive growth. My brother and I invested substantial time and money developing a just such a site that would provide a better service at a lower price, and now we are shut out of the process as the FAA tries to “go this alone” for no apparent good reasons.

    Please consider talking some sense into the FAA.

    Yours Truly,

    /Peter W. Farnsworth/

  48. It is a waste of taxpayers money to not utilize the database and administrative system in place of the age old AMA organization to save on registration time and efficiency!
    This is an organization which prides itself to the education and practice of safe flying, which can help teach others to fly responsibly
    Let’s make the AMA nrs the drone registration nrs, simple as that!

  49. Disappointed in the AMA’s response and work on this. It all seems like a money grab to me. Both by the FAA and the AMA. Why are you fighting for members of the AMA not having register? So you can gain more money and increase membership numbers by everyone who flies having to be a member of the AMA?

    You shouldn’t have to register with the FAA or with the AMA!

  50. I can see it now…. federal background checks for purchasing radio controlled aircraft or land based vehicles.
    How is someone getting an ID # going to make the skies safer?
    Classic example of a few bad apples ruining it for the whole bunch.
    If you really want to make a difference, start regulating the quality and safety of the cheap Chinese imported electronic knock-offs.
    Government should be regulating the manufacturers of drones. One model may have an issue with GPS or motor issues… I would bet this causes more incidents regarding safety than operator error..
    Just my 2 cents… I have more but if I really thought it was going to make a difference I’d give more.

  51. I have been flying RC model airplanes for 35 years and have also been a commercial airline pilot for the last 22 years. What I can’t figure out is what problem, exactly, is registration of RC airplanes supposed to solve? Realistically, how many cases have been recorded of RC model airplanes that are being flown within the line-of-sight of the RC pilot interfering with manned aircraft? I can’t speak to the potential hazards of “drones” flown at high altitudes out of the visual range of the operator but, to my knowledge, RC model airplanes have never been a problem. What we have here is additional government regulation being proposed as a solution to something that is not and has never been a problem; what sense does this make? This is just a waste of taxpayer money and government resources; where is the cost/benefit analysis to justify this? All this is going to do is hurt a great hobby and make young people less likely to get involved in RC model aircraft flying. We are not hurting or endangering anybody, please stay out of our hobby.

  52. I guess I don’t like that on the form you have to check I will not fly over 400 feet period!

    In flying Jets and Gliders and Big Imac Planes we do get over 400 feet and if I can be fined or loss my right to fly or lose our club because of this I make me worried what is the FAA Up to it is not in compliance with our AMA Rules!

  53. All this means: Guilty until proven innocent! Another government overreach. Contrary to Government’s opinion: You cannot legislate safety! I am a retired military and professional pilot as well as a US citizen since 1971(legal immigrant). What I am leading up to is that the US government has failed miserably doing it’s constitutional duty. E.G.: It does not protect our borders and sovereignty. It infringes on the citizens rights with abandon. The absolute percentge of the US population consists of responsible citizens. Registering our drones is a money grab for starters and a future gateway for frivolous litigation. Why is a 2 pound drone in the hand of a responsible operator a safety risk more so than millions of bicycles roaming the streets and byways with plenty of victims to show for. I feel already a little bit like living in a socialist country which has changed drastically from when I discovered the USA 58 years ago. Citizens, push back and push back hard. DC, got out of my bedroom, my front- and backyards, my kitchen and my hobbies. More laws will not safe a single life. By the way, my little drone cannot make an airliner land in the Hudson River but the same birds can render my quadcopter a useless collection of plastic pieces. Ban the Birds? Surely NOT!

  54. As a Lifetime AMA Member I must admit that I am disappointed at the AMA is as vehemently objecting to the Drone registration proposed by the FAA. I have not studied the particulars of the proposal and I would not be surprised to learn that the” DEVIL IS IN THE DETAILS”

    I see a strong resemblance between A.M.A and the N.R.A whenever a government body attempts to rule either organization. It would appear that the AMA did have representation in the steering committee that formulated the present proposed rule, but, according to the AMA , all their recommendations were rejected. ALL THEIR RECOMENDATIONS WERE REJECTETD ….. Really ? I need to see if that is true ! I, for one find that hard to believe.

    I am surprised to see the same feeling of despair presented by AMA members who seem to feel that they will be disenfranchised by the FAA if they allow even one good idea to be incorporated into any rules the FAA proposes. this is in spite of the FAA agreeing to the Light sport aircraft designation as well as ” Sport Pilot medical requirements.

    I ask that each of you take the time to truly read and study this proposal and determine if any of the parts make sense. If so you might consider supporting those portions as I suggest the board of the AMA do also.

    I’m sorry if I am the Only one that feels this way, but I cannot see being arbitrary just because I don’t TOTALLY TRUST our government!

  55. I feel that if you fly airplanes in the line of sight why do you have to register them

  56. Seems to be clearly in violation of the statute. Maybe the court will follow the law, although there is no guarantee. This is nothing but another illegal power grab by a government out of control.

  57. Right or wrong, legal or illegal it just makes sense to me to use an already established database with a proven track record. Even the Government should recognize the cost savings of using data that is already compiled. They could easily incorporate the data by using an alpha numeric registration system. Example: AMA12345 for those in the AMA or FAA12345 for those registering through the FAA.

  58. The FAA needs to have a unified data base for all UAS. This is important in incident investigation, as well as their continuing quest to learn from each incident and promote safety. The AMA has successfully worked with the FAA in the past to promote safe operation of model aircraft. The intent of Congress is to continue this working relationship. As a nonprofit charitable organization, this is just one more thing we have to do.

  59. The FAA may just need our help so they can do their job keeping our airspace safe. We should go ahead and place a label with their registration number on all our greater than one half pound model aircraft. As a charitable organization we should continue to work with them and do our part. I have been a AMA member since 2007.

  60. I agree strongly with Michael,

    The AMA needs to file for an injunction with the courts RIGHT NOW!!
    Just like all the other special interest groups do to stop something in its tracts until a judge decides the issue.
    It’s done all the time. for example when tree huggers don’t want the lumber company to cut down tress etc they get an injunction to stop the logging right away until the matter is decided in court.
    I am tired of the AMA asking ME to write letters. I want the AMA headquarters to get this done on our behalf. Get a temporary injunction and wait for the courts decision on how the FAA has no legal right to regulate or legislate laws controlling MY hobby!

    Congressional law was passed and that is that.
    My vote and Order to the AMA is to get our lawyers to file for a temporary injunction NOW!

  61. After reading Federal Register Vol 80 #241 December 16, 2015 Part VI Department of Transportation Federal Aviation (FAA) Division 14CFR parts 1, 45, 47 et al Registration and marking requirements for small unmanned aircraft; final rule and other documents available on the FAA website for Unmanned Aircraft Systems (UAS) registration. It is plainly obvious the FAA adopted within their regulation requirements, the flight parameters stated in congresses special rule for model aircraft (further defined in the aforementioned document by the FAA as sUAS) in section 336 of the FAA modernization act of 2012 (P.L. 112-95). This special rule contains the very same flight parameters and similar identification requirements as nationwide community based organizations (NCBO) such as the Academy of Model Aeronautics (AMA) requires of its members (hobbyist) for safe and responsible voluntary model fight operations.

    While commercial operations of sUAS by definition are different and generally not covered by NCBO’s such as the AMA and registration with the FAA seems appropriate. It appears the FAA confused the direction of congress to not promulgate (make) any rules regarding sUAS for the hobbyist. The FAA used their mandated requirement to protect the National Air Space (NAS) to mean they could/should still require registration of all sUAS and/or the operators regardless of the use of such aircraft for the purpose of enforcement with penalties of around $27,000.00 fine and/or imprisonment.

    In creating the new regulation FAA rejected notification of a hobbyist having a registration with a NCBO such as the AMA, and created a registration requirement thereby forcing all hobbyists to register with the FAA that was not intended for hobbyists by congress. Effectively circumventing the intent of congresses requirement for hobbyists to register with, and conform to a NCBO’s such as the AMA which have consistently maintained the highest level of voluntary compliance.

    The apparent basis of FAA’s ruling was to create a database for use during enforcement of the NAS security. Because the sUAS marking requirements and information required and maintained by NCBO’s such as the AMA is nearly identical. It can be reasonably assumed that same information for a specific sUAS (i.e. hobbyist model aircraft) could and/or would be available either voluntarily, or without undue restraint by court order in the event of an incident requiring FAA and/or law enforcement investigation. After which the FAA and/or law enforcement may determine the appropriate and/or necessary enforcement action and/or penalties.

    It appears the failure of the FAA to recognize and/or accept registration notification with an NCBO such as the AMA by an individual showing they are already in compliance with congresses flight parameters, is nothing more than the FAA’s intent to force duplicate and unnecessary regulation, enforcement and possible penalties upon the modeling public, thereby punishing them.

    If the FAA adopted information and/or notification of registration to/from an NCBO such as the AMA as recommended by congress, it would reduce the impact on the agency’s funding, workload and maintenance of such an unnecessary and duplicate database. It is also reasonable to believe that accepting information/assistance from such a program could/would not hinder in any way the FAA’s ability to enforce their mandated requirement to protect the NAS. FAA should reconsider their position and accept information and/or notification of registration by a hobbyist with an NCBO such as the AMA as proof of voluntary compliance as set forth by congress in section 336 of the FAA modernization act of 2012.

    Respectfully
    Ronald Grasmick
    AMA#RG846992

  62. What is the big deal? I have done the registration. I am not afraid that someone is going to look me up on the list so that they can steal my planes and equipment. Maybe what we should be asking for is that someone should have to show cause why the FAA would release your information. If the FAA would keep your information private, then I see no harm in them asking that people piloting aircraft, register that they do so, and that their aircraft be labeled for tracing it back to an owner if it were to be involved in an accident.

    The real problem is that drones are so easy to fly. That people can learn to do this sport without the need for a mentor.

    I learned to fly back in the late 70’s (the dark ages). We flew only at the local club field, and for the most part, there would only be one plane flying at a time. Of course, the prime rule back then was “Safety First”.

    We should be supporting the FAA in knowing who is flying, but hey should also be required to keep our information private. Those of us flying by LOS (line of sight) are not the problem. It is people that are flying strictly by first person view or GPS that are creating problems. Make no mistake, pilots are reporting near misses in and around airports.

    We should be backing the FAA and working with them to craft sensible rules that will actually protect air traffic. We know that it is not AMA members that are creating these problems, but if all we do is stand in opposition to any attempt to get things under control; they will not work with us to craft rules that will not hinder our sport in the future.

    The FAA is trying to address a real problem. Let’s be a part of the solution.

  63. Dear Mr. FAA,
    I have been an AMA member for a little over 3 years and have belonged to a local AMA club. I have been taught and practiced all the AMA rules and follow them in a safe way.
    For thous reasons alone we as AMA members should not have to be a part of your process.
    We have our numbers in our RC – hobby wooden planes and if there would ever be any problem the info we place in our plane will provide all info necessary to show where to go for any liability issues.
    How ever, Our AMA number could be sent to you for your information or data base as to show your need as a registration number from the AMA, as they have us on there files.
    I for one fill If you are unwilling to work this out with the AMA will result in less AMA members just will not register at all or drop out of the AMA all together in disappointment for things not coming together in a fair way for all of us. It is going to be hard to point the finger when some thing happens with no way to identify who the air craft belongs to.
    The other problem also exists of those who are not part of the AMA, do not have any understanding of the air rules, common sense, or just do not care, what will you do about them? Working with the people who care, follow the rules and have common sense seems to me to be a better solution to work this out.

    Thanks for your time and hope for all of us that care about this hobby that you will get this worked out so we all can help police the sky’s.

  64. I believe that drone flying should be regulated. A drone is a mecanical device subject to failures. AMA members are all regulated and certified flyiers with the clubs they belong to. To be further regulated is unnessisary and a duplication. We fly in designated areas which are in most part remote locations. Each club has its own rules and regulations.

  65. I agree with most of the other comments posted here. Not sure why we’re being penalized for being a responsible organization 🙁

  66. The AMA should be doing there job better and the FFA wants us molders to pay MONEY so the can make a rule, Partly because some DUMB ASS is flying around a airport THAT JUST PLAIN STUPID. The law all ready says we can fly and we have flew safely for years with NO POLBEM. We SHOULD be able to fly on our property or at our club as long as it is SAFE.

  67. What I want to know is,(its been on our local news) as to why a person that live about 10
    miles north of me HE SAID HE IS EXEMPT FROM REGISTRATION because he gets paid for his video work !!

  68. The new rule is nothing more than a beaurocracy’s attempt to create a bulk database of people, and make a whole bunch of money doing it. Please stop with this (IllegaL Act).
    Sincerely,
    William E. Burrows Jr.
    AMA Member

  69. So I’ve left my comment for this terrible rule on regulations.gov. However, I am disappointed in the AMA efforts so far. Recently an individual filed a lawsuit against the FAA and this new rule.

    WHY HAS THE AMA NOT ALSO FILED A LAWSUIT FIGHTING THIS RULE????

    I am sure the AMA answer is that ‘we are working behind the scenes with the FAA…. ‘ As members we read this a lot. But the FAA keeps ignoring us/AMA, and most other industry ‘advisors’ on a regular basis. When is the AMA going to realize: if it walks like a duck, and quacks like a duck…. its a duck!

    The FAA actions indicate it really has no intention of working with anybody but itself. As far as model aircraft goes, the AMA IS our representative organization. Please stop dithering and make a real stand against these ridiculous FAA rules!

  70. This is the real problem.

    Q6. Does the FAA have the authority to require registration of UAS used by modelers and hobbyists?
    A. Yes. By statute all aircraft are required to register. Congress has defined “aircraft” to include UAS, regardless of whether they are operated by modelers and hobbyists.

    A poor definition by congress that allows the FAA to lawyer their way around the the intent of the law. We should be writing to our Representatives asking them to modify the definition in the law so there is no way the FAA can be yet another agency that thumbs its nose at the Congress.

    For us to be talking to the FAA at this time is a wasted effort that should be directed to our Congressman.

  71. I have read most of these comments, and bar a few ridiculous comments they are all very valid. The problem with all of this is that the FAA knows that it is an attempt at control and not based on any hope for making our national airspace safer, This is an exercise in empire building.

    The people that FAA are supposedly attempting to protect us against will not register their aircraft nor themselves, but the FAA will have increased control and an increase of budget and manpower. This all feeds into the power grab of overblown government agencies which is a sign of the times.

    The big negative of this action may be with the novice entering to the model aircraft hobby registering with the FAA because it is mandatory and passing up the AMA with the loss of education they provide. This may make in fact make the airspace less safe. Then the FAA will propose mandatory training by governmental or commercial agencies providing nothing but regulation. [This has already happened with legislated boating education provided by private organizations such as US Power and Squadron.] This will afford an increase of their sphere of influence. Perfect, more control, manpower and budget.

    I will provide additional comments both to the FAA and to the legislators of my state, but i have little hope of us winning this battle. We are fighting an organization ignorant of the problem [if there really is one beyond that invented by them] with nothing to loose and everything to gain in this battle.

  72. I am a member of the 185,000 member national model flying association, the AMA. Belong to this, and a local club, cost me about $150 a year. This provides us with over a million dollars of bodily and property damage. My name, address, and membership number is attached to any model aircraft I fly. I would report any safety violations that I see. I have been a member for 15 years, and flown hundreds of times. Our AMA membership is responsible, and has a very good record.

    Please allow that our total membership be registered through the FAA as a group. It will be easier to monitor our flying activities than with the general public, and the new pilots operating their drones.

    Thank you, Ralph Todd, AMA member # 692035

  73. I’m very disappointed this has gone this far. As a longtime AMA member, I expect our governing body to represent us well. The AMAis the “NRA” of model aircraft! We are 180000 strong! Legal action needs to be taken immediately. We don’t need government intervention into our beloved hobby, especially since we already have rules and our track record is exemplary.

  74. Firstly I’m disappointed with the way the AMA has handled the whole dealing with the FAA. First of all instead of going along to help the FAA with this chink in our liberties the AMA should have been going on the defensive with people who know the law and know what it is to be subjugated. Yes you can still fly as we all have done, but now as a group your agreeing to a new form of rule by signing up. This “data base” and its intent, will do nothing for NAS safety, it might stop someone studid enough to register after already being watch by the NSA. History has shown that a criminal is a criminal, not even the death penalty stops a murderer. So don’t kid yourselves, one day you will walk into a hobby shop, or attempt to make an online purchase only to find you have to have a background check to purchase that new “model airplane, helicopter or quad copter and radio and then wait five days to pick it up or have it shipped to your nearest hobby shop, like gun shops do. This is already the case for guns… But if your already vetted, and the feds know your a good boy, without jihadist intent, then you can walk out with it the same day. So, where does it go from here? For all you out there that think trading your liberties in for safety is where its at, you surely don’t know this countries history. Ben Franklin once said, “those that would trade their liberty for security deserve neither liberty or security”. It really makes me steamed that so few people understand this countries founding documents and the men that wrote them. Enforce the existing laws against those that are fowling up our HOBBY! One more note, by its very nature Law Enforcement is after the fact. If it becomes proactive, as it is in small doses, just watch the news channels and all the idiots,”ya I said it”, wanting more rules on social interaction, in case you purposely offended somebody. Have I offended anyone yet, GOD HELP US ALL. That should do it.

  75. I am in agreement with you but are we really dealing with The FAA? What does the AMA really do??????? It seems more like the current administration in Washington.
    GET YOUR FREEKIN HAND OUT OF MY POCKET. MAKE THE OWNERS OF THE DRONES AND QUADS RESPONSIBLE FOR BEING STUPID. I’M TIRED OF PAYING FOR OTHER PEOPLES BAD HABITS.
    WAKE UP.

  76. The FAA is in violation of Section 336 and the RC community/AMA should argue this issue further. We should take this blatant disregard for the law very seriously as it set a very bad precedent.
    I will not renew my membership until this is resolved. AMA698605

  77. Two thoughts:

    First:
    Article I, Section 1, US Constitution reads, “All legislative Powers herein granted shall be vested in a Congress of the United States, which shall consist of a Senate and House of Representatives.”

    That’s all! Simple, clear words; the first words in the Constitution.

    Public Law 112-95 is a Constitutionally proposed, debated and passed Law, with the President’s signature accepting and agreeing to enforce it.

    There is NO Constitutional authority to surrender or delegate legislative (lawmaking) powers to any other entity, whether part of the National Government or not! A departmental regulation or rule does not have authority to revoke Art. I, Sec. 1, USC, or any other part of the US Constitution.

    Second:
    Information in FAA’s FAQ released to or by AMA is confused, confusing and self-contradictory.

    Paraphrased-
    Each model aircraft need not be registered, but must display the model flier’s registration number.

    A model aircraft acquired or flown after December 21, 2015 must be registered to be allowed to fly.

    Flying an unregistered model aircraft after that date is punishable by fines and/or imprisonment as a civil or criminal offense.

    Several other phrasings in the FAQs blur the distinction between registering EACH model, and registering ONLY the flier. The implication is that an unregistered model, which is not to be individually registered, cannot be flown (period!)

    Happy New Year 2016…

  78. I have not seen mention of the fact that the 400′ altitude restriction will practically kill RC Sailplane and ALES modeling (maybe I just missed it). Ales models shut off above 400′ then go higher in thermals and a winch launched glider can easily approach 300′ on launch depending on the size of the field. Then they go higher in thermals. I’ve only seen this in soaring blogs, but have not seen it mentioned by the AMA reps. Additionally Free Flight models can exceed 400′. But I guess according to the logic applied by the FAA they aren’t a problem because they lack guidance. Full sized airplanes are not supposed to go below 500′ in unpopulated areas & 1,000′ over populated, so I think I see the FAA’s logic for the 400′. They try to absolve the full sized pilot’s responsibility of collision avoidance & dump it all on the modeler. I say this as a pilot with military background and an ATP rating. Wee just need to get all of the birds to register with the FAA to really solve this. Another example why we need to shrink government. Too many people trying to justify their paycheck by ruining other people’s lives (who are extorted to pay for the paycheck). Pass the Tylenol.

  79. I am an AMA member: 1046011 and I just downloaded the FAA’s B4UFly app on my iPhone.

    I live in the Air Captial.

    So many airports and helipads, I had to send a comment to the application developers, requesting they add all the phone numbers to the application. I want to make sure I am in compliance with the law.

    My concern is, it looks like the local flying field is also covered by one of the many airports and helipads in my area.

    I thought the local club field was exempt?

    How will this impact our AMA liability insurance if we don’t call all the local helipads and airports before we fly?

    How often do these locations want us to report? Each day before we intend to fly? Or before each battery?

    I’m still holding off on registering my Blade 230 S helicopter, since it is over .55lbs.

    While I hope our AMA membership excludes our need to register, I also hope we can address the ATC issue as well. Though I can see one upside to that requirement. I need more practice to improve my helicopter skills. Maybe calling every time I fly will encourage me to practice more?

    I also recommend everyone check out the FAA’s B4UFly application. Send them comments on the application. Especially if adding phone numbers to the application makes sense for your area!

    Good Luck to us all!

  80. I am far more concerned about the extent of the regulation than the registration. Registration is just to keep lawyers fed with business — people suing people. But part of the registration is an assertion that we’ll follow the FAA’s rules and the rules include a 5′ radius cylindrical flight restriction vis-à-vis… not major airports, but anyplace that there might be aircraft activity. Now, install the B4UFLY app and there’s a huge hint of the real agenda suggested there… select an area and it will draw a 5-mile circle around everything… private airstrips, lakes where seaplanes are based, hospitals, minor airports, major airports. When you overlap these circles, there might be a small part of some farmer’s field in Iowa where it’s OK to fly, but nowhere else in the US. This is insidious… if that’s how they plan to interpret it, they’re grounding all of us.

    Incidentally, I checked and every AMA field in my neighborhood is within 5 miles of something.

    AMA, you will do us a service to address a rational approach to managing this with the FAA:
    * Standardization of regulations regarding airspace (no local municipalities, cities, states, counties, neighborhoods imposing regulations or laws on the use of airspace) — the maze of laws is already difficult. If we have one set of clear regulations, it will be much easier to comply than dealing with the confusion of many.
    * Recognizing conical airspace restrictions: airplanes have to climb out of their takeoff to get to altitude quickly… they don’t fly at ground level for 5 miles then shoot straight up. Our restrictions for flying model aircraft should reflect a 3D conical space and not a 5-mile circumference cylinder. Additionally, airplanes do not fly below tree line, roof line, etc… they fly well above it… the space below their safe flying altitude should be available for us. Also, helipads don’t need 5-mile radius — helicopters fly up. Likewise private airfields — their climb rate is fast.
    * the restriction of flying in national parks is absurd — OK, one idiot crashed his quad in a geyser. How many idiots have also dropped canteens, jackets, backpacks, cameras in geysers? Why pick on UAS’s except to pander to Luddites with irrational fears of the technology? The national parks are for everyone… and the airspace above the national park is regulated by the FAA, not the park service.
    * If the FAA’s job is to regulate safe airspaces, why do commercial restrictions make sense on UAS’s? They’re likely a carryover from regulation trying to control airlines, but when applied to a flying camera…? It is not more or less safe to take a picture for commercial use than for personal use.

    AMA, please help us guide the regulatory bodies to make this a realistic, rational environment. No one wants to have any risk of interfering with a manned aircraft, but the rules they appear to be on course for will ground the entire industry. Thank you.

  81. Hello, I recently purchase a $1200 drone and am all for registering it and following the rules. After downloading your new app, I discovered that there isn’t anywhere close to me that I am allowed to fly it. These rules seem extreme. For example, I should be able to go to my neighborhood park and fly my drone at a low altitude. There’s cell phone towers and power lines that go much further in the air, planes aren’t flying 50 feet over rooftops, heck I could throw a football higher in the air that I can fly my drone. It doesn’t make any sense and it is very disappointing that the FAA has taken a great new hobby & made it illegal by technicality. I encourage you to reconsider or make some exceptions to these rules.

  82. We have all expressed our displeasure with the FAA and the present administration, what they are doing is violating the law and our very Constitutional rights- and although it gives our AMA leadership the general attitude of its membership, now we need to express that same displeasure to our congress and senate. Im pretty sure Mr Foxx and Mr Huerta dont care to read these blogs. Althogh ive found that most Congressmen and Senators seem to be following lockstep with the present administration, we need to keep pressure on them also. We need to be the “squeeky wheel” this time.

  83. I have been a AMA member#530364 since I was 15 years old I’m 36 now I’ve flown in a safe manner away from people and places your aren’t allowed to be flying at I started flying drones(which I always hated calling it that I actually like calling them Multi Rotors instead) since 2013 L.O.S(Line of Sight) then later that year I got into FPV which is a lot of fun also since I was 15 still til this day I’ve been flying airplanes too dough not in FPV just L.O.S. I don’t feel I should to answer for something I didn’t do I understand there has been a tons of reports of people flying in a area or location that have no business flying at all now the FAA feels that by getting everybody to register is going to help solve this problem ok that’s what they think
    but as for me and my uncle and are long time friends and all you follow modelers out there why should we have go through all that if we all members of the AMA why don’t just use are own AMA numbers on are models instead? Or I just hope that AMA would once puts the FAA at bay and that everything just back to normal I really hate that the government wants to make this hobby which is loved by me and so many other people a big BUMMER by having alot of us hard working folks be paying another bill it isn’t that pricey now but who says it will stay that way knowing every year how everything is get more pricey IMHO. Thank You and Once Again I hope all this gets worked out?

  84. I think the FAA has a concern just like the rest of America, with the people operating drones in a reckless manor. However, i don’t believe that the way the FAA is going about it is right. The AMA has a large modeling community, that does a really good job with self policing itself. If, at my club i ever saw someone flying a drone in a reckless manor, they would be asked to come down immediately and the rules be explained to them. If they continued in this reckless behavior, they would be asked to leave the field and they would be suspended from the club. We all have a vested interest in keeping our skies safe and the AMA and it’s members believe very strongly in this. What i would propose is if you belong to a community organization like the AMA, you already have to have all of your planes with your registration number, so there is no need for that from the FAA. The folks that you should be concerned about, are the ones who buy the drones, and do not belong to a community organization and have no intention to register with the FAA. I understand that the FAA is almost in a no win situation, but please understand that the AMA is not the enemy, and we will, if we see something, say something about pilots who fly in a reckless manor. I hope that you reconsider your registration with respect to the AMA and allow us to continue to operate as a community orginzation using our own registration.

  85. Seems to me what put all this intense focus on out hobby was the advent of FPV (first person view). Then couple that with the advent of multi rotors at the same time and vulah! (DRONES). Timing was everything! Without this technology surely very few people would unload their airplanes/ rotorcraft and fly at the end of the runway at their local airport, or over fly a crowded event. This new equipment coupled with flight stabilization electronics has allowed people to do these activities from afar and so they do. Why I ask, am I being regulated for flying my equipment as I have for the last 30 yrs? Don’t get me wrong I’m not opposed to FPV/ multi rotors in fact I have purchased the equipment. Seems the technology exploded and got out ahead of everyone. Just give some guidance, rules, and then if necessary some regulations for the new kid on the block (FPV’ers) leave the rest of hobby alone, it wasn’t broke so don’t try to fix it. I am a licensed aircraft mechanic and work according to the FAR’s. I deal with the feds regularly. I have no doubt the FAA’s intent is to promote safety, but the means to which they are trying to achieve this; I fear, is going to be never ending.

  86. Do any or all of these rules/ regulations/ laws, whatever you wana call them.. only apply to those who are required to register? for example… under 250g flying with fpv goggles with no spotter and not an AMA member.

  87. LIFETIME AMA MEMBER. Once again only the honest, tax paying citizens will be penalized by our overreaching government.

  88. I am an AMA member for over 68 year’.Ben flying all types of Model Airplanes.A charter member of RCCD model ClubWe always co operated with the AMA on aii rules that Govern Model Aviation.I think that allowing us to use hour AMA number on our Model’s should be
    enough to satify this ruling.My AMA # is 4125.

  89. As a member of the Academy of Model Aeronautics (AMA), I am disappointed with the new rule for UAS registration. I am a long time model aircraft flyer, who has operated under the guidance of the largest community-based organization (CBO) in the world for many years.
    Since 1936, AMA has published safety standards and offered training programs for our members – more than 20 years before the FAA was created.
    The new rule is contrary to the intent of Congress in Section 336 of the 2012 FAA Modernization and Reform Act. Section 336, also referred to as the “Special Rule for Model Aircraft,” clearly prohibits the FAA from promulgating any new rules for recreational users operating within the safety guidelines of a CBO. In addition, the FAA’s contention that model aircraft should be considered aircraft is currently the subject of pending litigation.
    I am already an AMA registered member. As such, the AMA already recommends that I put my AMA registration number or name and address on or inside my model aircraft.
    Furthermore, the registration process is an unnecessary burden for me and the more than 185,000 other AMA members. AMA members should not be required to register with the FAA as our members of the AMA to include myself are not the ones you need to worry about.
    Interfering by regulating the hobby aircraft or drones is completely wrong. As an Amateur Radio operator my information would be on the transmitter as well as the aircraft/drone. Efforts should be made to punish the individual abusers of these aircraft to fullest extent of the law, not to create laws that interfere with law abiding citizens in the love of our hobby. The FCC and FAA don’t need to be doing double duty.

    1. Robert,
      My reply references the FCC abdication of enforcement and offloading of licensing as burdensome. I also referenced the ATF offloading for Instant Check to the States, for the most part.

      What we have here is a bunch more laws by which the law abiding may be criminalized at whim. I read the proposed “statute” carefully to see if any right to inspection was granted. It was not, however, that may not prohibit such inferred authority given the numerous references to other documents.

      Bottom line: No nefarious or accidental tragedies will be prevented by any of this before the fact. Sad.
      Mark S.

  90. The rules are for UAS’s if you read the rules the said Unmanned Aircraft System (UAS’s) Registration Service (FAA web page) a fixed wing plane if is not a person INSIDE the plane is a UAS, so you have to registered too.
    Everybody is talking about “DRONES” and FAA about “UAS’s”
    I fly planes and I fly Quadcopters and I have my name and AMA# on it since the beginning in this hobby, never an accident, never a problem, and I fly FPV and never a problem.
    The problem is not the aircraft, the problem is whoever is behind the controller.
    If you check statistics, how many fatal accident since 1936 with remote control planes and/or quadcopters?
    Why don’t stop Walmart for selling knifes, there are people staving people and is not a registration for a knife!!

  91. Your new regulation to require folks flying Model aircraft to register with the FAA is simply silly. It will in no way improve the safety of anyone, especially the modeling community. Most non-serious modelers who buy commercial UAVs but are not members of the AMA will never register. I have talked to many who bought these FPV and photo capable UAVs and they unanimously state that the FAA can go to hell. So one again, federal regulations target responsible citizens with no consequences to those who flaunt your silly regulation and no impact on safety. Besides, you don’t have enough personnel to monitor the full scale commercial and civilian aircraft operators. Based on my experience with the FAA, the only time I saw anyone of you idiots was when I took a written or flight check ride. Keep up your good work, as far as I am concerned, all you’ve done is diminish my already low opinion of the FAA, or any federal rule making organization for that matter.

  92. enough of the BS. the ONLY way that this will get resolved is for OUR organization – the AMA – to protect our interests. we have joined this organization as a means to protect ourselves from undue interference. the AMA leadership should be our ONLY voice in this matter.

    AMA # 793111

  93. My question is this: what is the reason for us to register in the first place? If someone wants to blow up, bomb or otherwise cause destruction, I’m sure they will register first with the FAA before the do their dirty deed ha ha ha. And also put the directions to their house + phone #. Another smoke screen to control everything.

  94. Dear FAA,

    Please explain how is it I can go out and fly a full scale glider with NO registration whatsoever yet if I had a r/c model of that same glider I’d have to register it.
    Explain your logic please, if you can..

  95. AMA should never had lumped scale aircraft in with quads and “drones”, Period.
    But AMA got greedy and they are no longer acting as a member driven organization, they want you to be required by the FAA to register with them for $75 a year instead of 3 years for $5. They want the commercial drone business and dam the r/c fliers.

    AMA 1527

  96. We had no problems until drones or quads came along. Pick on them and leave fixed wing planes and pilots alone. Its not us doing wrong. Pick on them. not us rule abiding pilots.

  97. Why is it FAA can not do anything right? You want to register something how about your IQ most have to be around 60. 45 years of RC and your desire to get your sticky fingers into something you have no real understanding of. If Drones are the problem then register them. Bad enough you change flight patterns to bring noise to our area now you want to know what my hobbies are. Forget it I am not registering and the word f**k you goes along with it!!!!!!!!!!!!!!

  98. Do we really need government meddling in every facet of our lives? Come on, these are toys we are talking about here not full sized aircraft and definitely not “DRONES”.

    Yes, “Drones” should be regulated but only for safety and privacy reasons. But, they should be regulated by rules written by an organization that understands the difference between quad copters and fixed wing aircraft. II lost all confidence in the FAA being that organization when I saw they only featured quad copters and not fixed wing aircraft on their website. It appears they don’t know the difference.

    I believe this is a small example of bureaucratic incompetence at it’s finest. I feel the FAA is simply using this whole issue to make money and clear the airspace for future industry.

  99. You ( FAA) have no clue what how silly this new rule is. The government now can’t control gun laws and immigration laws how do you think you will control model airplanes.
    Keep up the good work another great move.idiots!

  100. I think there is still work to be done, and I am willing to forego my $5 to see it come to fruition. Here are the concerns that I am watching and wondered if anyone can respond.

    1 – AMA has successfully won the argument that an RC Operator does not need to register each UAS! However, there is a concern with this approach. If each RC Operator registers and receives their ‘permit’ or ‘license’ to pilot a UAS in any airspace, the requirement states that that Operator must put their FAA assigned number on the UAS making it accessible without tools. This sounds simple enough, however if I put it in plain site, and I am friendly and want to help educate others about AMA, RC, and UAS my number is right there in plain view as the inquisitive spectator snaps off some pictures. A week later FAA pounds down my door because they find a multi-rotor UAS in the front lawn of the White House with…. MY FAA assigned number! How does the FAA plan to protect this information? It get even worse if the AMA club records my FAA number and post the club roster with phone numbers, addresses, AMA number and the FAA number.

    2 – AMA clubs should not change their bi-laws, nor should AMA change their bi-laws until the above protection of private information (and now I am including the FAA permit or license number), which I would suspect will at the very least take us to the 2nd half of 2016.

  101. As a ‘Control Line’ modeler and long time AMA member, I fail to understand how our niche activities have ANY effect national security .We are tethered to our planes at all times for God’s sake !!! The fact that the FAA completely sidestepped congress is ludicrous. The SFRA effectively shut down about 19 clubs in the Washington/DC area. This madness has to come to an end. Place whatever restrictions are needed on the multi-rotor ‘drones’ and leave the rest of the modeling community alone !!!!!!!!!!

  102. I agree with most of the above, it is not right making us register again. Have been with AMA a long time and they have the best RC flying safety record you can get. It’s just not right collecting more money, for a person to put into a hobby flying RC, where they safety records speak for themselves. This will not impact safety or who flies them … at all !

  103. I have been flying model airplanes since 1973 and a AMA member. I am very disappointed with all of the rules and regulations the FAA is trying to force upon our hobby. AMA and its members have an excellent safety record and do not need someone else watching over us. I am already registered with AMA with a membership number that I put in all of my aircraft, and I sure do not need another one. I hope AMA and FAA can get this issue resolved soon so we can concentrate on building and flying and enjoying our hobby again.

  104. Oh good, you should now feel safe ! Thanks to a new government mandate, I’m now required to register my 5.5 pound stick and tissue paper model airplane, with a new government office (bureau), complete with a salaried officer who will collect my registration fees. Of course should I fail to do so and continue to fly as I have, I will be fined. All this is to insure I comply with rules such as staying below 400 feet and always keeping my craft in my line of sight at all times, and outside of full scale aircraft control zones. The trouble is, these rules are no different from those which I have dutifully followed since I joined the Academy of Model Aeronautics. My membership in this flying organization provides me with registration, flight instructors, a safely officer, an insurance policy, and a staff of experienced pilots who can conduct a thorough check out of my craft at any time. This guarantees its air worthy status. In addition we each spot for each other, and instructors are available who certify each pilot is fully cleared before solo. Lastly, we offer constructive critique to each other. So, not much has changed except, a new fee and the threat of a fine has been added, if we fail to comply. Clearly, the addition of a New Government bureau makes you now feel safe from those nasty drones, right ?
    On the contrary, what we now have is more Government overreach. We are punishing those who comply with organized membership rules. Unregulated pilots, are still free to buy and fly their dime store quads under the flight paths of airliners on final approach, and will continue to do so until THEY are caught and punished. In the meantime the good guys pay the price for the out of control idiots. Alas, we punish the law abiding for the bad behavior of the fools.
    I am, Michael Vivian, a Sun Valley Flyer, and AMA member in good standing.

  105. Whole thing is a money-grab by AMA. How do you come up with a fee of $5 if you have to pay AMA dues as well? AMA failed its membership and now appears obvious why. AMA is an overpriced insurance company now trying to leverage membership to avoid FAA oversight.

  106. The intent of the FAA to registered Model Aircraft is a knee jerk solution to solving absolutely nothing. Drone manufacturers can easily program Drones to remain under 400 feet, and to shut down and land whenever close to a full size aircraft.

    I have remained below the 400 foot requirement with my Model Aircraft since 1972. I taught RC flying for many years and following the AMA rules has always been standard protocol. Model Aircraft must remain in sight of the operator, so to go outside of those boundaries is just not done.

    For those individuals who choose to go outside the AMA limits, there needs to be a responsible action from the FAA and that is NOT being done.

    Thank-You

  107. It seems in this day an age, that the politicians (FAA etc.) that are clamoring to fix problems are just trying to do something, right or wrong, to appease their constituents. Not trying to solve the real problem. Enforcing the existing law would be a start, not setting up a system that will not solve any issues. This will place a burden on law biding citizens and not the people who are causing the problems. I became a registered member of the AMA to learn about what I can do and current recommended practices while flying because I knew I needed to learn. Do you really think that a person or persons would register their UAV if they are planning to use the UAVs for criminal intents? Common sense should come into play.

  108. For a Long time member of the AMA and with flying Model Aircraft for over 35 years. I don’t think this will solve anything. The folks that are flying near airports and breaking the rules more often then not are not members of the AMA. Don’t follow the rules and most likely don’t know what AMA stand for. We protect our rights to fly. I have seen several airfields go the away to building homes and Safety concerns. This is not helping anything. Sure we can put our names on our planes, AMA Reg. Numbers, yet how will that prevent anyone from flying a Quad Copter near an airport, fire fighting aircraft, or police helos. DO you really believe those folks care about what the FAA or AMA do? If they don’t care about the lives they are putting in danger why do the care about the rest of us? Sure I will be a good soldier and follow your rules and Register my AMA number with the FAA. Now lets see how many of these folks that don’t follow the rules sign up. V/R MADD

  109. I hope everyone will read this carefully.
    I am a registered RC Pilot with both the AMA & FAA as required by both. I display the two numbers on all my aircraft and it is not a burden. The AMA is a business and the FAA is a government agency and both have their own agendas.

    I am an AMA member primarily for insurance. This covers me only at a sanctioned AMA field, if my aircraft is sound, if I fly responsibly, and if I paid my annual dues. I understand that part of the reason for such rules is to hopefully reduce liabilities and claims. The rest is common sense safety. I am also a member to promote a common hobby of model aviation with members who share that same interest. I am a proud AMA member.

    I am registered with the FAA because it is the current law and I am a law abiding citizen. FAA’s agenda is about keeping all things that fly in the airspace coordinated. That way, hobbyist can fly without flying into a commercial aircraft (and vice versa). It’s the same logic as not having all aircraft landing on the same runway. For now, the FAA is asking for registration so that it has a direct line of communication to ALL RC pilots alerting them of some basic guidelines. It is a start and only part of the answer.

    I see no reason for all the conflict. We should all be wanting the same things. I will not use the “D” word as this is a military term and suggest you not become part of the herd. There is no reason to become divided by separating multirotors, FPV, or red airplanes (joke) from the rest of “us”. I am concerned that the AMA didn’t call for a majority vote before representing it’s members, but that will be a discussion for later. And I can’t imagine people griping about $5 when my other dues are so much higher. Regardless, for now, I suggest we all follow the rules, enjoy your hobby and friends, and don’t put your fields into jeopardy. If the debate becomes too heavy and litigations too numerous, those who own the fields may just decide to take an easy way out and develop a new dog park. I like dogs. If dogs could fly, I like ’em even better.

  110. I a have been a member of the aircraft modeling community since the 1950’s and a member of the general aviation community since the 1960’s. I remain active in both. Over the years, I have learned dear lessons from the FAA. The FAA is a procedure, compliance and penalty organization. While there are some examples of the FAA trying to be a helpful citizen, these cases are the rare exception. We all need to recognize this and form appropriate strategies.

    The FAA wants to have drone registration in order to be able to provide training to reduce incidents. The FAA alleges a plethora of near misses of with aircraft. I have over 4,800 hours of flying, most in the mid-Atlantic corridor, known for its high density of aircraft. ATC is excellent in pointing out air traffic to me, typically one to five miles in distance. I would guess that I will typically be able to see 10% of the called traffic. And yes, I pass the eye exams required annually required by the FAA. I really don’t think that I am likely to see a drone. I imagine an airliner at 180 knots and the difficulty a pilot will have in seeing a drone go by that is 100 feet away. The requirement is that the observer must be looking at the exact spot at the right time as there will probably be less than a second to see the drone. That should not be interpreted to mean there isn’t a problem, just that some caution must be exhibited.

    The answer is simple. Provide the option to allow AMA membership to meet the registration requirements. Second, enter into a contractual agreement between the FAA and perhaps the AMA and AOPA to put together a training program with a focus on model safety and operation. We will get a program that has an opportunity to add value. Unfortunately, the FAA training programs are lacking in effectiveness. I have attended FAA training on operations in controlled airspace and on ground control requirements. The material was presented in a less than interesting manner and at time, the material presented was of questionable accuracy. On the other side, there have been some highly effective computer training based modules on runway incursions which are presented in an interesting and informative manner and clarify the requirements. This is an example of what could be done but it is not coming from the FAA environment. It is not their specialty and it will be a distraction to the FAA to attempt this task. This is a specialized area of training and should be performed by the specialist.

    Finally, the FAA is in its usual delaying mode. They were able to throw together a less than well thought out registration program in a matter of months. Inserting the AMA as an option is no big deal, other than the FAA’s and governments’ hidden agenda which is simply their insatiable appetite to regulate.

    Hopefully all responses on this less than thought out regulation will bring some cures. However, be prepared for the legislative option.

  111. I am through with AMA and will NOT register anything. Tired of the government anal exam into every aspect of my life. I fly control line only.

    Mike

  112. Me being new to the hobby starting this past summer was told from the beginning to join the AMA. It is needed to cover your butt. All of the fly-ins I’ve attended require you to be a AMA member. Enough said about that. My point is that those of us that are AMA members abide by the rules and know the rules which really is just plain common senses.
    Those don’t know anything about the rules and don’t care about anything around them or there aircraft. The rule should stand as everyone join the AMA and learn more and alert of there surroundings. Let the government stay away from this and do what they do best which is nothing. AMA all the way now FAA.

  113. New registration process appears to be a political sideshow. Ok so I register ….

    1- Any one could copy a registration number from a valid RC plane or Quad
    Copter and place it on another device. Should that device cause some
    future damage, the person who caused the damage would never be known.

    2- You think a person who is out to destroy or cause damage is going to
    register ? That is like saying gun control is going to stop violent crimes.
    Should anyone believe otherwise, time for a reality check.

    3- I would encourage the FAA to listen to the AMA recommendations.
    The private sector usually has better results.

    4 – I would also think the FAA has better things to do than chase quad
    copters with tax payer money.

    5 – Who is going to provide oversite of this program on a local basis?
    Local government does not enforce Federal law. Besides how many
    small pastures and rural areas are there to be policed ? Have a better
    chance winning the Lottery.

    Someone has jumped to political pressure and forgot to think thru the various situations.

  114. I think the FAA should target only r/c aircrafts that fly beyond the human eye can see from a fixed position. Personally, pilots careless enough to fly over large crowds at concerts, expressways, airports, peoples yards and chasing vehicles at high speeds with their remote head gear. I think the average person should not be allowed to purchase any r/c aircraft that can be programed to fly beyond the human eye can see.
    Inexperienced, spoiled, stupid pilots flew their drones carelessly IS the whole root of this new FAA ruling. And never in the past was this such an issue till these past ten months. Its always a DRONE flying at an air port, the White House Lawn, over live concerts, I seen them my self and new this would happen eventually.
    Todays technology put us all in the position. These sophisticated r/c crafts should have never gone on the market for the average person off the street.

    1. I am an AMA MEMBER, for years I wanted a way to ride in my models and see what it was like to really do approaches and touch and go,s from a pilots perspective,it’s not new technology it’s just gotten more compact and affordable,I can now way afford to fly full scale aircraft so have been grounded my intire life except for a few short rides,,never mind ever taking any aerial photos or videos,the drones as everyone calls them and the micro cameras and transmitters have made this possible for me and many others,have you seen 3D robotics slogan? after gravity? and all the crying about video cameras invading privacy? common people every man woman and child is running around with cell phone cameras,,,should we ban phones as well?

  115. I think pilots should be allowed to use their AMA number for their registration number.
    The AMA has all the information required by the FAA as it is.
    Adding yet another number to the process will do nothing to make any thing better for anyone.
    Should I have to register all my Uav and someone down the street don,t register and he has damage or a Fatal accident
    The FAA would come to my address and I would have to prove that it was not mine. The FAA has no way of knowing who it
    Really belong to. I really don’t think that this is going to solve anything. THINK ABOUT IT!!! IF SOMEONE WANTED TO DAMAGE SOMETHING WOULD HE REAL REGISTER IT. I think not

  116. I would think that people are paying the AMA to keep Government out of our hobby, and protect our freedom, perhaps by suing the FAA, not telling us to write letters to the FAA.

    Looks to me that someone at the top of the AMA is getting paid off to look the other way as government grabs control of our sport for absolutely no reason but on a false premises of safety.

    Personally, I have given up model airplane building and am selling everything off.

  117. I am an Airline Transport Pilot with multiple jet type ratings and hold a life time membership in the Academy of Model Aeronautics. Since I have been involved heavily in both full scale and model aviation for over 40 yrs. I feel qualified to enter a measured response to the proposed registration and marking requirements for sUAS. I realize there is a real possibility of a “drone” interfering with a full scale aircraft and wholly support the registration requirement. However, I feel the proposed rules have got too far. The AMA’s National Model Aircraft Safety Code has been around longer than the FAA. All of our members are already registered with the same information the new requirement mandates. The AMA’s current safety code instructs me to place my name and address or AMA number on or inside my aircraft. The registration burden on 185,000 members of the AMA and a huge cumbersome obligation for FAA can be eliminated if current AMA members were allowed to use their membership in lieu of the FAA registration requirement. Additionally, please be aware that the new rule is contrary to the intent of Congress in Section 336 of the 2012 FAA Modernization and Reform Act. Section 336, also referred to as the “Special Rule for Model Aircraft,” clearly prohibits the FAA from promulgating any new rules for recreational users operating within the safety guidelines of a Community Based Organization (CBO).

  118. Remember, this is an AMA blog- i doubt the folks at the FAA go out of their way to read our comments here. Keep bending your congressmen and senators ears! Write your newspaper op-ed.
    The AMA was and is the governing body for model aviation in the US and for international aeromodeling competitions. Our membership and the hobby industry need to publicly denounce this ” interm mandate” until a better/ more streamlined registration is developed that will be inclusive to our membership.( myself, i would not object to a small dues increase to offset the cost of a “dual” registration process through the AMA) our AMA# should be sufficient and our personal info would NOT go into a publicly searchable database.

  119. It’s clear that the driving force behind the reclassification of All Model Aircraft into the category of UAS is the profit potential for commercial drone operations that is being pushed by the industry’s Congressional Representatives (and Lobbyists).

    For several decades the FAA and AMA enjoyed a mutually beneficial and respectful relationship. Now, many AMA members feel abandoned (or betrayed) by the FAA. There is no doubt that rouge Drone operators have helped to create support for more regulations (coincidentally at the same time the FAA is being pressured by Congress for regulatory guidance to allow commercial FPV Drone operations within the NAS).

    I am an AMA member, but my area of interest is AMA’s Park Pilot Program for those who have very lightweight foam aircraft. It’s actually the Liability Insurance coverage offered by AMA that makes membership beneficial to those who have small foam airplanes (however many people who routinely fly these foam aircraft in parks and soccer fields seem to have no such concerns). So, even for these small foam plane owners AMA Membership already covers the need to address any damage that can be caused by small lightweight aircraft (which supposedly is the need addressed by the newly proposed .55 pound weight restriction. Considering provisions afforded by AMA Membership, there should be no need for a separate registration with the FAA.

    The key issue that has caused a crimp in the longstanding positive relationship between the AMA and FAA, leading to a call for more regulations on our hobby is the lack of transparency inherent with FPV Technology – Those who operate their aircraft within line of sight are transparent (easy to locate should an incident occur), while FPV aircraft operators are not transparent.

    Make no Mistake, the train is not being driven by the FAA, it’s the corporate interests seeking profit making opportunities, and AMA Hobbyists are collateral damage!

    1. I provided a comment that was tagged at the top “Your comment is awaiting moderation”. Just curious why the tag??

      1. Hi Gene, like many other blogs and forums, we are hit with a lot of spam and do not want spam filtering into these posts.

        In addition moderating requires someone from the AMA to read every comment. We gain a lot of feedback insight reading these comments.

  120. One item that I have not seen discussed anywhere is the point that IF anything that flies is an aircraft, as stated by the FAA, then it would follow that anytime there is an “aircraft” accident, the FAA would be required (by existing law) to investigate the accident – along with the NTSB. I’m sure the number of models that crash annually would totally overwhelm the FAA’s resources! If the FAA responds to a call for an investigation by saying it isn’t a “real” airplane crash, then they would be negating their position concerning model aircraft.

  121. Come and get me.No way can this Reg. be policed. I’m in compliance have been on and off for 65 yrs. We had a Deputy out at the field 1 day last year and told us he didn’t know the field was there. Nine foot airplanes were flown there often. Cops have to much on there plate to worry about if we have a number in or on our acft.Feds don’t care either. It is a power grab, and opens the door to have a license,and what quilifications on how large of aircraft,and then who signs off on such a license? Is there going to be some kind of test? People drive cars with out a license, no one going to ck us. What if a suit shows up and I’m flying a brand new acft. slic,no number,I have to see a Judge? Gov. is a big Joke any more. All about big man on top of little man, guys. Well running out of space,hmmm,must be 400 inch law here. Fly on guys God Bless the Boots on the ground pilots watch out for Crop Dusters flying under the 400′ rule thats ok flying in our airspace. Nothing like the smell of Nitro. AMA # 1055850

  122. I have been building and safely flying fixed wing model airplanes for 75 years,and a member of the AMA, also a licensed pilot. I think that this registration process is a Government over reach and will do nothing but cost more money. The AMA has an excellent record for the safe operation of its members models, and a well established model registration system and a well designed safety code of operation for our models. The Government would do well to accept AMA membership as sufficient requirement for model airplanes. It is these new Multi motor Drones that is the problem, and it is only their they should concentrate on registration on the sale and use of them.

  123. Comment:
    Dear Sirs;

    I find it amazing that items, referred to as toys, must now be identified with federal markings to identify ownership.

    Yes, there are some errant individuals who have the stupidity and ignorance to take a quad helicopter and use it in an unsafe and hazardous manner. I doubt seriously that these persons will even be knowledgable or ameanable to self registration with the FAA.

    I am a member of the Academy of Model Aeronautics and consequently subscribe and abide by the guidance and rules set forth by them. I know of the FAA requirement to self register with the FAA by means of communications from the AMA on this matter. Numerous individuals that fly these “toy RC aircraft”, do not belong to AMA, nor are they aware of any FAA requirement to self register.

    Just like the Citizen’s Band Radio of the 70,s when you were suppose to have license to use one, how long did that remain in effect after the CB radio craze took off?

    So now I have to join two organizations of national prominence, the AMA and FAA. Why can’t the FAA recognize the status of AMA, work with them to ensure a cohesive partnership to minimize the intrusion of what is being perceived by the RC community who are required to now post two pieces of information on their RC aircraft in order to fly.

    I can’t wait until the FAA trys to tell some kid that his 3/4 pound toy that he flew in his backyard, just caused a huge financial levy because the online store that sold it to him never mentioned the FAA requirement? ACLU will surely jump on this.

    I support the need to eliminate the unsafe behavior of flying UAS in and around airports and into the airspace of manned aircraft. And, that registration with FAA offers a chance of education surrounding such behavior, but it only works if the general population is aware, and most importantly, they feel it applies to them. Register your toys? What is next, background checks for owning RC aircraft? Oh, and what about laser pointers, shouldn’t those be registered as well?

    Work with the AMA, they have years of experience in developing a safe and sane activity, not to mention a very important economic engine for the economy.

    Respectfully yours,

  124. Sent this to the FAA TODAY;
    I am a leader member in the AMA . It is and has been a requirement according to our rules, that every aircraft we fly must be marked with name, address , and AMA number. Each member agrees to abide by this rule. In my 33 years as a member, I have never seen an issue with this. The FAA directive is redundant and not needed for AMA members. How you intend to enforce the ruling is also mind boggling. With every retail store selling quad copters as toys, are you going to require Wal-Mart to inform their customers about registration requirements? And all the other retail stores selling craft that weigh more than .5 lbs? I believe the directive serves no purpose as it pertains to AMA members. And enforcement on John Q. Public who has no idea about the requirement, or the AMA is going to burden our judicial system that is better served dealing with real crime, instead of prosecuting someone who didn’t register their toy aircraft.

  125. My FAA Comment:

    As both a licensed private pilot and a long-time member of the Academy of Model Aeronautics (AMA) I understand both sides of this difficult issue. Although I dislike government regulation in general, living in a civilized society requires that all parties understand the ‘rules of the road’, or in this case of the air. As a private pilot I have never encountered an issue with model aircraft operation in the past. I believe this is because, in the past, most model aircraft required some degree of skill to build and operate and their operators belonged to national safety organizations such as the AMA.

    For better or worse, we are now entering an age where unmanned aircraft (UAVs) can be bought fully assembled at reasonable cost, and can be flown by individuals with little skill and, unfortunately, minimal knowledge of safe operation in the airspace. There is even the potential for UAVs to operate autonomously, both for hobby and commercial use. For these reasons I consider the identification and registration of UAV operators a good idea. However, the chief goal of this registration should not be to limit or restrict the operation of UAVs or other model aircraft, but to encourage the knowledge of and safe operation of these small aircraft in the airspace system. For that reason I would like to see the FAA work with the AMA to 1) acknowledge that the operation of model aircraft by operators flying within the safety guidelines of the AMA do not pose a threat, and 2) to encourage the recreational operators of UAVs and other such aircraft to join the AMA or other similar organizations, where they can receive instruction on the safe operation and rules for operating such aircraft.

    To encourage UAV operators to join organizations such as the AMA, I believe the FAA should allow AMA membership to be used in lieu of registration with the FAA. I would also have no problem with the AMA sending the pertinent registration information of its membership to the FAA. If AMA (or similar) membership could be used in this way, it would encourage UAV operators to register with these organizations for the additional benefits they provide, and the organizations would then be able to provide the necessary safety training that many of the UAV operators are currently lacking. By itself, registration does nothing but allow pursuit of miscreant operators after the fact, presuming that they registered at all. If we presume that the vast majority of UAV operators are not malicious but just unaware–which I believe to be the case–then anything the government can do to encourage the education of these operators in the safe use of their small aircraft is a desirable goal.

  126. I keep hearing the term DRONE attached to MULTIROTOR aircraft,,why is this? when most all full scale DRONES are fixed wing,,HELLO have you seen the videos of fixed wing (model airplanes) flying near cloud level MILES away from a ground based operator? I am an AMA member flying both, lets understand one thing,,copters don’t glide and ride thermals to 5,000 ft in full scale airspace,flight times are limited by battery capacity,every minute spent assending requires additional power to get back down,so please all you that think multirotors are the intire problem, wake up,they are catching the heat because unlike fixed wing nearly anyone can take one out and fly it without years of practice,which has caused a surge in sales and attention to all modelers,I am not happy about the FAA getting involved here,yet another data base to collect our personal info but what can you do,I have full scale aircraft overfly my private flying site DAILY and quite often well under1,500 ft. I live over 10 miles from any airstrip,if I want to take my 3 meter sailplane to cloud base a full scale pilot will never see it,like it or not modelers are going to have to be held accountable for thier actions in some manner,how that will happen is very unclear to me,anyone can cheat with the wrong number on thier craft,can the government afford to enforce such a thing?Being an AMA member I am insured,how is the FAA registration going to provide insurance? fellow AMA members this is our advantage towards AMA number recognition in the FAAs new requirement, we are RESPONSIBLE AND INSURED,,,even when flying my DRONE,,,,,

  127. The FAA has made all of these rules the people that belong to AMA knows what safety procedures the need to take before and while flying quad otters.Also I registered with the FAA the day it started.The charged me $25.00 Free my foot.

  128. The argument that AMA members should not be inconvenienced by registering with the FAA is ludicrous! Just because I subscribe to one RC magazine doesn’t mean I get every other RC magazine for free. Just because I pay DMV fees on one of my cars doesn’t mean the others are free. If you join one RC club, are all the others supposed to let you join theirs for free?

    Argue whether the FAA has the right to include all radio control aircraft into one category.
    Even contest the FAA’s authority to create this new rule.
    Point out how nonsensical, impractical, and unenforceable the rule is.

    But please stop whining about how AMA members should be exempt “just because they are AMA members” and no other reason. That just sounds like a child throwing a tantrum because he doesn’t get what he wants.

    Mark P.

  129. In the Interim rule, the FAA includes a lot of words to rationalize their duty to register all “aircraft”:

    “This rule is also promulgated pursuant to 49 U.S.C. 44101-44106 and 44110-44113 which require aircraft to be registered as a condition of operation and establish the requirements for registration and registration processes.”

    And then proceed to explain the reasoning behind including all UAS, including recreational models, in their definition of “aircraft”:

    “VI. Background
    A. Statutory Requirements Related to Aircraft Registration

    For purposes of the statutory provisions in part A (Air Commerce and Safety) of subtitle VII (Aviation Programs) of title 49 of the United States Code (49 U.S.C.), title 49 defines “aircraft” as “any contrivance invented, used, or designed to navigate or fly in the air.” 49 U.S.C. 40102(a)(6). Since a small unmanned aircraft is a contrivance that is invented, used, and designed to fly in the air, a small unmanned aircraft is an aircraft under title 49.”

    Yet in the case of Part 103 ultralights, which arguably also meet the definition of “invented, used, and designed to fly in the air” as in the description above, the FAR states:

    “103.7 Certification and registration.

    (a) Notwithstanding any other section pertaining to certification of aircraft or their parts or equipment, ultralight vehicles and their component parts and equipment are not required to meet the airworthiness certification standards specified for aircraft or to have certificates of airworthiness.

    (b) Notwithstanding any other section pertaining to airman certification, operators of ultralight vehicles are not required to meet any aeronautical knowledge, age, or experience requirements to operate those vehicles or to have airman or medical certificates.

    (c) Notwithstanding any other section pertaining to registration and marking of aircraft, ultralight vehicles are not required to be registered or to bear markings of any type.”

    There are a number of documented “near miss” and even some midair collisions between ultralight “vehicles” (FAA-speak), yet the training and education of ultralight pilots was (and is still) left to the existing ultralight organizations.

    My question being, why should there be a difference in treatment?

  130. I believe that one of the main reasons that the FAA is pushing this registration of model flyers is the money that it will bring in to the FAA every 3 years, just like the FAA’s past requirement several years back that requires real aircraft owners to “re-register their aircraft” every 3 years at $5.00 a pop,(including every airliner that an airline owns) or the title (registration certificate) of the aircraft gets cancelled and their registration number (“N” number) goes back in the pot of available registration numbers for anyone else to take for their aircraft. So – if you multiply the 185,000 AMA members by $5.00, that amounts to $925,000.00 every 3 years out of the pockets of model flyers and into the Feds kitty, and this goes on for every 3 years that a modeler continues to fly. It’s mostly about money. This rule will not prevent any model aircraft from colliding with a real aircraft.

  131. I am chagrined that FAA has redirected their efforts from generating effective and well thought out regulations for integrating UAS into our national airspace and instead focused on a hastily implemented and poorly planned registration fiasco. FAA chose to ignore the extensive input and guidance provided by the AMA and others which cost significant time and money to provide. The one goal that is plainly revealed by the FAA’s program and actions is retribution for anyone whose UAS is found to have violated common sense flying safety considerations. And these are the individuals that are least likely to register. While myself and others who have responsibly flown RC models for decades as members of the AMA are now subject to extensive criminal penalties for continuing to do so, should we not register in time or miss a renewal every 3 years.
    It is hard to imagine how registration of UAS, including virtually all RC models, will result in increased safety. The registration is also in direct conflict with Congress’ Section 336 of the 2012 FAA Modernization and Reform Act. Registration does not equate to responsible use and is completely out of proportion to the risks posed by UAS. The registration requirements for automobiles and firearms are extensive, yet more than 45,000 US citizens were killed during 2015 by irresponsible use of these (www.gunviolencearchive.org and http://www.nhtsa.gov ). How many people were killed or injured by UAS in this same period?
    The AMA’s 80 year safety record and active participation in training programs warrants substitution for the single faceted registration under the FAA. I (and 185,000 other members of AMA) should be exempt from FAA registration, as we are subject to AMA’s more extensive standards for safe operation and identification of our models.

  132. As a modeler having continually built and flown model airplanes since 1937, without having any problems with flying in controlled airspace, (I am also a licensed instrument flying instructor) I take with contempt the attempt of congress and the FAA to impose restrictions on one of the greatest hobbies in the world. How far has the govt. gotten with restricting gun controls that kill thousands of our citizens each year visavis problems caused by the modeling community.

  133. Your suggestions for writing to your senators and congressman are good but
    for some members letter writing is an obstacle . Here is a template they can use.

    Dear Senator /Congressman,

    I am a model aviation enthusiast and member of the Academy of Model Aeronautics (“AMA”), recognized as a national community-based organization.

    I am very distraught with the recent announcement by the Federal Aviation Administration that as of December 21, 2015, AMA flyers will have to register with the FAA.

    This new requirement appears to be a contradiction of the FAA Modernization and Reform Act of 2012 which was passed by Congress and the Senate. By promulgating new restrictions and requirements for AMA members, the FAA appears to be overriding the existing Congressional directives, and imprudently interpreting the guidelines set forth in Congress.
    The new registration and identification requirement is a complete redundancy of our registration with the AMA. Combine this with the recent closure of 36 AMA chartered fields it appears that the FAA is imposing needless hardships on our membership.
    We have established an 80 year record of impeccable safety, and in fact have set the standard for safe operation of our model aircraft in our national air space. AMA requirements demand that all pilots follow the AMA safety code, and we utilize training programs to ensure our members fly safely and responsibly.
    I would welcome you or any member of your staff to visit our local flying site to witness first hand how we are good stewards of our land and airspace.
    I’d be happy to discuss these issues with you or your staff if you have any further questions or concerns.
    On behalf of all AMA members I hope that you will look into the legality and the fairness of their actions.
    Thank you very much for your attention to this matter,

  134. I believe everything composed was very logical. However, what
    about this? suppose you were to write a killer headline?
    I mean, I don’t want to tell you how to run your website, however suppose you added something that grabbed people’s attention? I mean Guidance on Submitting Comments to the
    FAA’s Interim Rule on UAS Registration | AMA Government Relations
    Blog is kinda plain. You could glance at Yahoo’s front
    page and note how they create article titles to grab viewers interested.
    You might try adding a video or a picture or two to get readers interested about everything’ve
    got to say. Just my opinion, it could make your blog a little livelier.

  135. so stupid this is a lot of crap ,,,first should be free yes is only $5 but they are interested in get everybody under this registration ,second,Is hard already to make to a decent field to fly 4 times a year now on top of that ,we have to get screen by the faa ,and we have to mark the planes with a number!!! ,so lets say you spend years reproducing and building an rc replica we have to f!@#t it all up with the registration faa numbers?and if we don’t register you can be
    I have a better idea why they don’t put somebody from the faa in the model fields to inspect the rc planes.I wonder what is next? let me guess we are only goin allowed to fly in specific flying fields set up by the faa right?.
    just to ask we still live in a free country?Is this the land of the free?

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