AMA Member Communications to FAA Interpretive Rule.

On Monday, June 23rd, the Federal Aviation Administration (FAA) released an Interpretive Rule in which it presented FAA’s interpretation of the “Special Rule for Model Aircraft” established by Congress in the FAA modernization and Reform Act of 2012. The Academy has reviewed the rule and is extremely disappointed and troubled by the approach the FAA has chosen to take in regards to this issue

In its Press Release the FAA stated it was, “issuing the notice to provide clear guidance to model operators on the “do’s and don’ts” of flying safely in accordance with the Act and to answer many of the questions it has received regarding the scope and application of the rules.” It also stated, “(this) guidance comes after recent incidents involving the reckless use of unmanned model aircraft near airports and involving large crowds of people.” It’s important to note that very few of these cases have been factually documented and not a single incident was shown to involve a member of the AMA or to be connected in any way to modeling operations conducted under the auspices of the special rule.

In AMA’s response to the rule it was pointed out that, “The FAA interpretive rule effectively negates Congress’ intentions, and is contrary to the law. Section 336(a) of the Public Law states that, ‘the Federal Aviation Administration may not promulgate any rule or regulation regarding a model aircraft…’, this interpretive rule specifically addresses model aircraft, effectively establishes rules that model aircraft were not previously subject to and is in direct violation of the congressional mandate in the 2012 FAA reauthorization bill.”

AMA has voiced its opposition to FAA’s action and will pursue all available recourse to dissuade enactment of this rule. It’s important that every AMA member becomes involved in the effort.

The first step is to respond to the public comment period established in the notice. Look for a follow-up email from AMA with information on how to respond to the FAA notice. This is your opportunity to express your views and to comment on various aspects of the Interpretive Rule. It’s important for the Administration to know that this rule significantly impacts the entire aeromodeling community and that this community is resolute and committed to protecting the hobby. In this case silence IS NOT golden.

Please alert your friends, family members and fellow modelers regarding this issue.


  1. Can AMA please post how we should comment to FAA regarding this policy? I see this as a big issue in terms of over-regulation that can be very detrimental to the hobby. We need to tell people how to express their views so common sense prevails.

    Example of over-regulation that I see:
    No use of FPV equipment even with a spotter?
    Flying model aircraft over your own farm is prohibited if you ever sell your crops?
    Notification (permission) from airport to fly ANY model aircraft within 5 miles of airport, what if I am flying inside my home or something 10ft off the ground in the community park? Does paper airplanes count?

    1. Yes, we are developing a follow-up communication that will go out soon detailing how to submit comments as well as providing a number of talking points for consideration.That way our members can be seen as a unified front.

  2. My response to the flying Government goons.

    I have been a member of the AMA since I started flying several years ago. I have followed the law and have been a responsible citizen in regards to my model aircraft.
    I am not an avid FPV flyer and have no vested interest in it. I am in favor of sensible regulations on their use and in particular their commercial applications.
    I do have a vested interest in the RC Hobby in general. I have invested a lot of time, energy, money and friendships in the entire hobby.
    It has been a big part of me an my family\’s life. However, your special interpretation does not propose any sensible regulations and is meant to hurt and attack everyone
    involved in the Hobby. Its thumbing your nose in the face of the law enacted in 2012 and ignoring the voices who had a say in the orginal act of 2012. Aside from the imposed
    regulations on FPV, the other regulations on regular model aircraft is an incredible stretch of the law and without a doubt a far reaching attempt to claim jurisdiction in an airspace
    that you otherwise don\’t have jurisdiction over. You broke the laws in the Modernization and Reformation Act of 2012 by making suppositions and far reaching claims about
    safety and srediculous claims about financial compensation made in regards to regular model aircraft. If a Hobby company shows up at a field and pays pilots to demo new products,
    you have essentially killed that with your regulations. It is an attack on Commerce and an attack on the hobby industry and those who enjoy this hobby. The hobby
    provides numerous educational and social opportunities for people of all ages. I have several friends who have moved on to getting their commercial pilots licenses or
    enrolled in some sort of engineering program in college because of their involvement with RC. Your overreaching, overbearing regulations threaten to hurt all of it. Your ill-concieved, retaliatory interpretation
    would have it be illegal for me to fly a paper airplane in the parking lot.

  3. As a pilot and rc flyer, it’s time to counter the FAA with perminate TFR’s for all registered model flying fields. Radius of two miles and altitude of 500′. This would keep all full size aircraft out of the rc flying airspace and would be up to the full scale pilot to keep track of them. For FPVs who wonder out the faa would have the right for violations. A simple form with the faa to register your flying field would put the burden on them.

    1. James,

      I am a private pilot and an RC flyer as well and have been an AMA member for many years. your suggestion would require everybody to fly at a club field, and I do not agree with that. If I choose to fly my own RC aircraft in my own back yard, including FPV and don’t bother anybody else and remain safely below altitudes that could interfere with full-scale aircraft, I should be allowed to do so, unmolested and left alone by the FAA or any other government agency.

  4. James,
    Although well intentioned, you recommendations would be detrimental to our hobby. We must NOT propose limitations on ourselves. How are we to abide by an arbitrary altitude limit? Will we be required to install telemetry to determine altitude? Not thanks …this hobby is expensive enough. Additionally, most Giant scale aircraft exceed 500 ft. during aerobatics as they require more airspace due to their size. Your altitude suggestion would limit the size of aircraft currently in use. Furthermore, it is in our best interest NOT to register our airfields. Once registered with the gov\\\’t, they will assume control of it. We don\\\’t want that. Let\\\’s not shoot ourselves in the foot.

  5. Where is there a link to the FAA ‘s Interpretation of Special Rule?

  6. The FAA has essentially made it a federal crime to fly a model airplane via FPV, and the agency has narrowed the definition of a model aircraft to make it easier for the FAA to regulate unlicensed drone operations.

    Here are the pertinent government documents at the heart of this crisis, in chronological order:

    1) FAA Advisory Circular AC 91-57 (09 June 1981). “Voluntary” guidelines for model airplane operations. Establishes 400 feet as the ceiling for model aircraft, and “suggests” notification of airport operators or air traffic control if flying within 3 miles of an airport. See$FILE/ATTBJMAC/ac91-57.pdf

    2) 72 FR 6689 – Unmanned Aircraft Operations in the National Airspace System (13 February 2007). References FAA Advisory Circular AC91-57 in a “Rules and Regulations” policy statement, thus elevating the content of the “Advisory Circular” one step toward the status of a set of regulations. Establishes the clear division of unmanned aircraft into three categories (public, civil and model). Reiterates that a model aircraft “should” be flown no higher than 400 feet. See

    3) FAA Modernization and Reform Act of 2012 (14 Feb 2012). Elevated the suggestions contained in the FAA Advisory Circular AC 91-57 to law. Establishes into law the FAA policy that “a model aircraft is an aircraft.” Extends the “permission zone” around airports from 3 miles to 5 miles. Establishes a requirement that a model aircraft must be flown “within the visual line of sight” of the operator, which sets the stage for prohibiting flying model aircraft via FPV. Also, interestingly, establishes a requirement that a model aircraft must be flown “within the programming” of a national organization such as the AMA, which would imply that all model aircraft pilots must be a member in good standing of such an organization. What does this mean for park flyers? See

    4) FAA Interpretation of the Special Rule for Model Aircraft (18 June 2014). Flatly states that it is the FAA’s position that the Act precludes the operation of a model aircraft via the use of “vision-enhancing devices, such as binoculars, night vision goggles, powered vision magnifying devices, and goggles designed to provide a “first-person view” from the model.” Also makes it clear that the FAA can enforce a number of regulations in any case in which the FAA deems the operation of a model aircraft to be unsafe, regardless of whether or not the aircraft otherwise meets the requirements of the definition of a model aircraft, and furthermore, establishes the FAA’s authority to regulate model aircraft if a regulation concerning aircraft in general happens to include them. See

  7. Thanks Rob Wood for that post. I have sent two e-mails to asking for clarification on this 400′ restriction inserted into the “Interpretation of the Special Rule for Model Aircraft” Still no answer from the AMA regarding this question.
    Am I legal to fly my sailplanes above 400′ or not?
    ps.I also hold an FAA Commercial Pilots Certificate, so I don’t want to be subject to enforcement action , by flying a Model Airplane.

    1. There is no restriction to flying model aircraft above 400′ in law or regulation. AMA’s Safety Program (Safety Code) requires AMA members to remain below 400′ when within 3 miles of an airport unless otherwise agreed upon by the airport or air traffic control (ATC) if a control tower exists at the airport.

      In addition, AMA’s safety guidelines require AMA members to not interfere with manned aircraft operations, to notify the airport and/or ATC when operating within 5 miles of an airport and to See & Avoid other aircraft in accordance with AMA’s See & Avoid guidelines in Document #540-D.

      Needless to say, pilots conducting thermal soaring operations should use could judgment and avoid operating in proximity to airports or in areas were there is a concentration of manned aircraft activity.

      Rich Hanson
      AMA Government and Regulatory Affairs

      1. Thank you Rich for that response. I am flying my sailplanes far from any airports.
        I was concerned that the restriction in Advisory Circular 91-57 (no model aircraft to be flown above 400′)had somehow been integrated into the new Interpretation of the Special Rule for Model Aircraft

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