Understanding the FAA’s Interpretation of the Rule and How to Comment.

AMA would like to thank the thousands of AMA members and aeromodeling enthusiasts who have responded and made comment to FAA’s interpretation of the Special Rule for Model Aircraft. To date we’ve had over 25,000 comments made and we know many more are developing comments and will be submitting them shortly. new deadline for comments as September 23, 2014.

When deciding if the rule will affect you personally and whether or not you should make comment, consider asking yourself the following:

•   Are you a modeling enthusiast?
•   Do you enjoy flying First Person View?
•   Are you a sponsored pilot, fly in competitive events, or enjoy watching companies
demonstrate product?
•   Do you fly within 5 miles of one of the more than 17,000 airports in the US?
•   Does your club manage its own flying site in a safe and responsible manner?
•   Do you or your club fly in “controlled airspace”?
•   Do you know every rule and regulation pertaining to the National Airspace System?

This is a complex issue and many of our members have asked that we provide a simplified explanation, and suggested comments to the Interpretive Rule. Click the link below to find a simplified explanation as to just what this rule means to the average modeler. Also included are AMA’s viewpoints and an explanation of the commenting process.


What can I do to help?

The administrative rulemaking notice and comment process is the means by which the FAA can address these concerns and make any definitive changes to the rule. Your comments need to be detailed, meaningful and constructive.

We are asking all of our members and everyone who has an interest in the future of model aviation to participate in this process.Go here to read the simplified explanation of the Interpretive Rule and to follow the guide to submitting your comments.

Support AMA


  1. Since when did our government care about model aviation? Not all of us are a threat to the national security. All we want to do is fly our model planes, both for recreation and commercial purposes, within the guidelines and safety code of the AMA. But then do you really think the FAA and the rest of the government give a rats-behind?

  2. https://www.regulations.gov/#!docketDetail;D=FAA-2014-0396.

    I am an AMA Member and I believe the safety rules for this sport should not be governed by the FAA except to oversee the AMA safety rules which all of us know are sound and are made with commonsense. The trouble with the FAA is that it will be impossible for that organization to keep up with the sport and it will fail to enforce the rules unless they hire thousands of new agents to watch everyone and that sounds like Communism or Nazism. I would like to see a team effort to this problem as the AMA has done with the FCC and other organizations like local government. The AMA has teamed up with many organizations in order to make fair rules. I am proposing that the FAA use the AMA to help regulate, which otherwise would be an impossible task for the FAA, it should only mandate that anyone who is a member of the AMA, follows the AMA safety rules, has the provided liability insurance when joining the AMA, and is in good standing with a (photo) ID from the AMA is legal to fly in the US. If this is not done then the FAA will have to spend millions on enforcement because no one will do it for them and no one will have liability insurance when the AMA is gone. I know the FAA has many other things to worry about than a sport that has been regulating it’s self for many years. I know there will be some rouge people out in society but there always is. Thank you!

  3. Yeah model aircraft is been operated for many years safely by millions of people, but then soon its been ruled out by some organization/government. I don’t want to belong to any organization just to fly a model aircraft. Well it looks like soon we will just practice rules and no more model aircraft.

  4. I feel the AMA needs to get more involved with the Faa. We have people flying here in Northwest Montana that fly at County owned Airports with no Charter, No club recognition. And some with no AMA affiliation. This is an accident waiting to happen. This law will prevent people like this from operating and ruining the sport that we all love.

  5. Hello AMA team…you may need to update some of your site content updating the comment submission date to the FAA from today 7/25/2014 to the new September date. The video notation still has today date.



    1. Thank you!
      I have updated the text – AMA would like to thank the thousands of AMA members and aeromodeling enthusiasts who have responded and made comment to FAA’s interpretation of the Special Rule for Model Aircraft. To date we’ve had over 25,000 comments made and we know many more are developing comments and will be submitting them shortly. new deadline for comments as September 23, 2014.

  6. When I checked the total comments received on the FAA Interpretive Rule at regulations.com yesterday the count was 29,702. Today it shows 23,216. Can anyone explain the discrepancy?

  7. This Hobby is and has been very well maintained by all flying fields and the AMA to maintain a safe environment for the public and RC pilots. I just think the FAA and the news media have been giving RC a lot bad publicity. the sport is so much safer then ever. The rules are getting out of control and just pushing so many out of the sport with all the red tape.

  8. Someone help me out here… exactly how is a flawed “administrative interpretation” going to help the FAA with enforcement of non existent law. In this situation they are interpreting the words of congress, not a FAR that has become law through the Administrative Procedures Act. In litigation, it would seem reasonable that a judge would give a higher consideration to the actual word of Congress. In Pearl v. Bd. of Prof’l Discipline of the Idaho State Bd. of Med., 137 Idaho 107, 113 (Idaho 2002). The Supreme Court of Idaho held that courts will give considerable weight to agency’s interpretation of a statute only if it satisfies the following four conditions:

    1. Legislature must have delegated the agency with the responsibility to administer the concerned statute
    2. The interpretation must be a reasonable one;
    3. The specific issue cannot be determined from the plain statutory language
    4. Presence of rationales underlying the rule of deference.

    The rationale that must be present includes[iv]:

    1. Confidence of the public on the agency’s interpretation;
    2. Interpretation of agency is a “practical” interpretation of that statute;
    3. If, after knowing that the statutes are interpreted in a particular manner, the legislature does not alter that interpretation, then it is presumed that it sanctions the agency interpretation.
    4. If the statute is interpreted “contemporaneously” with the passage of the statute at issue.

    Here is why I feel the FAA Interpretation as written would not be given weight in court.

    1. The interpretation is not reasonable.
    2. The issue has already been determined twice in court from the plain statutory language of Congress.
    3. Based on comments to the interpretation that I have read, the public has no confidence of the FAAs interpretation.
    4. The interpretation was not introduced “contemporaneously”, but only after the FAA lost two court decisions.

  9. I’m an old foggy who has come to the end of my flying years, but I still build and design aircraft for my own pleasure. I have heard and read about all the problems with people flying model aircraft near full scale aircraft manned with pilots and crews. I have not seen nor heard of any people being tracked down and caught who are making these dangerous flights and therefore do not know if any are AMA pilots.
    There is nothing to stop anyone from going into a store be it a model shop or some other type store and buying a model that is ready to fly. There are no rules, regulations or laws that prohibit them from buying models that are ready to fly. I have seen every type of aircraft flying in my own small town by those who I doubt are members of any flying organization.
    With the quality of aircraft that are now on the market anyone can buy are aircraft that can be flown into the airspace of full scale aircraft. These same aircraft are capable of carrying an explosive object and take pictures. They only thing that keeps them from doing anything the pilot wants them to do is his expertise and dollars to fiancé them.
    AMA cannot regulate all the models in the USA. It can only regulate its members. In the past there have been organizations that have been formed that may or may not still be active that provided services for modelers. I do not know if there are any of them remaining.
    I believe that AMA should continue to negotiate with the FAA to establish a rule that members of AMA with a valid AMA card and a picture ID such as a driver’s license would be exempt from the FAA rules so long as the AMA member is operating his/her aircraft in accordance with AMA rules. All other persons operating an aircraft would be subject to the rules of the FAA and every model, RTF, ARF, kit, etc be labeled with readable rules.
    Clyde Brothers
    AMA 2533

  10. Your argument is very convincing and I whole heartily agree, however we are asking a government court to rule against another government agency, in favor of a bunch of citizens. The reality is they will always protect themselves by voting in favor of themselves, because they need each other, and don’t need us.

  11. I feel that AMA becomes an extention of the FAA, since the regs propose that a local organization be joined by anyone who wants to fly even a $15 battery operated “helicopter”. Too mzny regulations. I cannot get the PALM SPRINGS International airport to keep full sized helicopters from flying over my home at 1:00 AM! My kids are frightened to death with the windows being battered by downdraft and engine noise. Almost every other commercial planes flies over the golf courses and follow the main highway. Now we hobbyists will be loaded with draconian regulations from the FAA overstepping its “rule making” authority

  12. Personally, as an AMA member, model builder, and flyer for over sixty years, I believe it is important to know and understand the following:

    Drones should be banned from private use, says Google’s Eric Schmidt

    Google executive chairman says in Guardian interview that technology has potential to ‘democratise the ability to fight war’


    Google chief urges action to regulate mini-drones

    The influential head of Google, Eric Schmidt, has called for civilian drone technology to be regulated, warning about privacy and security concerns.


    Google Political Donations: Where Company Execs Put Their Cash

    With the news last week that Google Chairman Eric Schmidt has finally agreed to testify before a Senate subcommittee on antitrust issues in September, we thought it would be interesting to look at which politicians have benefited the most from campaign contributions by Schmidt — and Google as a whole.


  13. We are just seeing our government expanding it power to control the lives of the American People. Model aircraft is just that, model aircraft. Drones are just that, Drones. I see the Government attaching a fee for an FCC license, like in the past. We will have to pay a fee and give our personal information to the Government in order to do what we love, fly model aircraft for the fun of it! Not for business or to get photos of people we are not suppose to take. More personnel will be hired to oversee we who is flying models and where. Or Government has MORE important things to worry about than people fling model aircraft for fun.

  14. It is my understanding Congress already ruled in 2012? that the FAA cannot make ANY rules or regulations against R/C model aircraft. I believe its important to remember that there was someone out there not long ago flying a Quad taking photographs and the FAA fined the person $10,000. To make a long story short, the Quad pilot sued the FAA and a Federal judge told the FAA that they can NOT fine ANYONE for this practice as there is no law on the books and this was protected by what Congress passed in 2012? In essence, what the judge was saying was the FAA couldn\’t fine someone for a regulation that they made themselves without due process of making it a law. Since it was an intended regulation of the FAA, it is just that, a self imposed regulation, it is NOT a law. Therefore, the judge dismissed the $10,000 fine and the Quad pilot continued doing what he has been doing FLYING and taking pictures. In summary, personally I don\’t believe the FAA has a leg to stand on. They can interpret Congress\’ law on this all they want. It doesn\’t change the fact what the law says and that means \”there shall be no rules or regulations of ANY sort by the FAA to impose on its own regarding R/C aircraft. If the FAA can interpret the LAW on how they \”feel\” it should be, then shouldn\’t everyone else be able to interpret the law according to their liking as well if they don\’t think it should be a certain way? Its clearly written into law by Congress. What is there to interpret? The FAA needs to respect the LAWS Congress passed. Congress represents the people, at least that\’s the way its suppose to work. If the FAA doesn\’t want to acknowledge the will of the people that Congress represents, then maybe the FAA along with the IRS and any other gestapo, radical, self serving government entity should be dismantled and done away with because it is no longer SERVING its citizens. It is now dictating to them what they are going to do and is no longer \”We The People\”…….

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