AMA Responds to the FAA’s sUAS NPRM

On February 23, 2015, the FAA published its proposed regulations for small unmanned aircraft systems (sUAS) as a notice of proposed rulemaking (NPRM). This began a 60-day period during which the public can comment on the proposed regulations. When finalized, the proposed rules would become the safety regulations for operating small, non-recreational, unmanned aircraft.

The NPRM references FAA’s June 2014 interpretation of the Special Rule. As indicated in detail in updates to our members last summer , the AMA has taken exception to several aspects of FAA’s interpretation. Aside from this, and one exception that may impact model aircraft manufacturers, the new proposed rule essentially takes the language in the 2012 Special Rule for Model Aircraft (the AMA amendment) and places it in the federal aviation regulations.

We encourage members to submit comments commending the FAA for appropriately separating model aviation from the new regulations and also encourage members to include in their comments the need to resolve the discrepancies stemming from the Interpretive Rule before finalizing the sUAS rule.

AMA has created a suggested template for comments, which we strongly encourage you to edit and personalize. Unless extended, the deadline for submitting comments is 11:59 p.m., Friday, April 24, 2015.

View template and comment


  1. The restriction of not being to fly over people should be deleted. There should be something about flying responsibly over people. If I am 400 feet up, the aircraft will not just drop suddenly and uncontrollably. It will drift.

    1. Planes do break in flight and come straight down with no control. Because things happen, it is best to not fly over people. Please keep it simple.

    2. David – not flying over people has been a part of the AMA safety code for a very long time, it is not a new proposal of the FAA.
      Reference: Academy of Model Aeronautics National Model Aircraft Safety Code
      All pilots shall avoid flying directly over unprotected people, vessels, vehicles or structures and shall avoid endangerment of life and property of others.

    3. Planes can fall straight down if the wing folds, and helis and multi-rotors are always going to fall straight down if they’re not moving too fast… even then, the best they’ll manage is a ballistic curve, since they don’t really generate lift without motors.

    4. An amendment or different wording to this restriction should be in place in order to allow flight over people in specific circumstances such as a special event film making. In this case the UAV fly over people. Totally restricting this is neglecting the fact that of payload objective i.e., filming an event. I understand the restriction yet it cannot be just as Keep it Simple. Safety is not a keep it simple thing but require careful planing and follows standard. Therefore flying over people should be authorized with condition of safety. These conditions must be spelled out clearly and simply to be effective.

  2. Being a pilot and RC pilot I understand both sides of the story. The FAA’S concern for safety. Pilots have a minimum flight altitude requirement which at the same time UAVS should have their maximum flight altitude that will not allow both parties to invade their airspace. That should not have anything to do as to where you fly or over what you fly over as long as the rules are respected. UAVS are safe to fly from my point of view if flown responsibly and safety pre flight checks are done their should not be any issues which to cause a safety concern. Real planes and Drones Do have incidents sometimes due to lack of safety inspections and or faulty parts. This is something that can not be avoided as accidents do happen. With proper training all UAV pilots should be safe to fly. The only way for the FAA and the AMA to be 100% incident free would be to ground all flying aircraft. And I love to fly its my life.

  3. I wanted to follow up here on my letter which was sent to support the AMA’s stance on this topic. For the past 42 years I have been flying model aircraft. I grew up in that era of Ambroid, Balsa, Silkspan and Nitro Engines. It was a big part of my childhood and I have many fond memories of those times with my Father and friends who flew. However, over the years I have seen a tendency to take Model Aircraft out of the backyard playfield and turn the hobby into a “Rich Man’s Sport” with rulings, control and movement into the realm of Model Private Planes. Personally I think this is short sighted for the continuance of this hobby and it cheats the youth of today out of a very interesting form of creativity. In fact, if you look at past history, you will see that many of the advancements in RC electronics came from Hams and experimenters that were allowed freedom to try new things. Same as the drones of today have created interest in a new developmental areas through open source programming and robotics. Over control and over regulation stifles this interest and puts development in the hands of those countries with which we compete economically.
    There are some sizes of models that do present a problem for larger aircraft if they are allowed to go uncontrolled. 1/4 scale and larger target drones (airplanes) do present a problem because of their sheer size in comparison to private planes. There is also some danger from errant gas powered Jet Aircraft that travel at speeds exceeding 100mph. Those dangers should be obvious. What I believe we see with the regulation of Multicopter Drones is mass hysteria fueled by followers of the 1984 novel and speculation on how these could be used to violate privacy or safety from attack. Let’s face it. Technology changes and with it so do the people who would abuse it or use it for devious reasons. Over regulation of “Toys” (which these models are)seems a little over the edge to me and people need to consider the path over regulation takes them down. Pretty soon those freedoms they enjoyed as children are gone and you are asking permission of your neighbor to walk your dog past his house.
    Society needs to take a reality check. Those of us who are now almost 60 survived pretty well being considerate of others. We took some nice whacks on the fingers from some pretty big planes, flew in open fields and survived pretty well with many fond memories. We didn’t need big government thinking for us because we used our heads. Just remember this: When you give control of what you are doing to someone else it is very hard to get it back. Think about it.

  4. I am 21 years old and have been an AMA member and flying since I was 17. I support the FAA rules regarding commercial drone use, however for recreational use of drones which includes fpv use as well. I believe all owners should be required to have an AMA membership and fly at an AMA field, just as people that fly r/c fixed wing and helicopters do. By having recreational drone users fly at an AMA field this ensures a safe and responsible flying environment by the following/enforcement of AMA rules. To require recreational drone users to have an AMA membership, it must be explained to them that the membership provides a million dollar insurance policy. As a result I believe many people would understand and agree with the AMA membership.The requirement of the AMA membership and flying at AMA fields would also provide significant revenue for the AMA and local AMA clubs.

    1. I am an AMA member and I obviously think the insurance and resources provided by the AMA to be worthwhile… for me. But to require someone to join and then always fly at an AMA field is way too restrictive. There are no AMA fields in convenient proximity to where I live, and it would limit my ability to use my multirotor in a variety of wonderful and completely safe locations as well. Flying responsibly is the key here and no one should be compelled to join any organization or be restricted to a crowded and limited location to enjoy their hobby.

    2. Nathan think out what you just wrote in this month old post. I first started flying (and driving) RC models in 1980 and now I live in a very rural area on a small lake and you don’t think I should fly here? The main reason I moved here was to get away from people living next door or the congestion of the towns and cities. I am 72 years old and follow the AMA suggestion on safe flying IN MY LARGE YARD and over the lake. There is no one here to bother. Even if I fly over the occasional home I make sure I’m over 100′ and they can’t even hear me much less see the craft unless they knew the approximate location. I also put bright white LED ‘headlights’ on the craft to make it easier to see and orient. There is absolutely no reason that I should have to go the non-existant AMA field to fly. Multirotor craft usually weigh under 3 maybe 5 pounds and the possibility of injuring someone on the ground is so remote that it’s much safer than being in a passenger car traveling on a public road. Please rethink your suggestion.

  5. I feel the FAA is just satisfying the fear mongers out there and should be concentrating their efforts on real world problems and not plastic models. I recently attended an event by DJI and was approached by an older women asking if i too own a “drone”. I quickly replied that i fly a multi-rotor copter? And that i do not work for the military. She asked “well what do you feel about these aircraft and the dangers they pose to people being struck by them?” I replied, i feel very little to that sort of event resulting in any significant injury and that the odds of it being something to be concerned about by the public once this wave of unfounded fear blows over were minimal.. The FAA as vastly more important things to be concerned about and the though of them concentrating their efforts on something that has essentially been around for decades is unsettling.

    1. I agree, The world has become a place where people are afraid of there own shadows!

      1. At the present time there are probably more multicopters flying than piloted airplanes by far. The odds are more on the side of a piloted aircraft flying at +100MPH causing someone personal damage or injury than these multirotor craft which weigh between 3-5 pounds and rarely fly over 35MPH.

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