Comment Now on FAA DOT Proposed UAS Registration

By now, nearly everyone should be aware that the FAA and DOT are considering requiring registration of some sUAS and have created a task force to help develop that process.

As part of these efforts, the DOT and FAA have asked for public input on the issue and have identified 10 questions in the document titled “Clarification of the Applicability of Aircraft Registration Requirements for Unmanned Aircraft Systems (UAS) and Request for Information Regarding Electronic Registration for UAS” that can be found at!docketDetail;D=FAA-2015-4378.

AMA asks that its members review the questions and offer comments. The government website for this project is cumbersome and only allows a person to either type comments into a text box or to upload a file. To help, however, we are offering suggested comments to the questions we feel would impact our membership the most. Feel free to provide your own comments on the registration of model aircraft. We want the DOT to know your thoughts on registration, whether you think its beneficial and necessary to ensure for safe operation in the National Airspace System (NAS) or state any objections or limits you would have to a registration process. Discuss any concerns you might have or suggestions with establishing thresholds of who or what should be exempted from registration and what method of registration would you favor.

If you prefer, you can paste these comments directly into the response box. It’s important that you submit your comments by November 6, 2015. Comments offered after this date will still be accepted, but might not carry as much weight as those submitted by the deadline.

Q: Consistent with past practice of discretion, should certain UAS be excluded from registration based on performance capabilities or other characteristics?

A threshold must be established under which sUAS/model aircraft are exempt from registration. Model aviation, operated within the safety programming of the Academy of Model Aeronautics (AMA), has an impeccable 80-year track record of operating safely and simply requiring AMA members to now register their aircraft would have no impact on that record.

The sUAS that lack the capability to fly beyond line of site by using either first-person view, or those sUAS that lack onboard navigational systems that allow the aircraft to fly missions beyond visual line of site, should likewise be exempt because they pose little or no threat to other users of the airspace. This would include all sUAS that fall into the toy category.

Q: How should a registration process be designed to minimize burdens and best protect innovation and encourage growth in the UAS industry?

Registration should involve only those platforms whose technological capabilities exceed a certain level. That threshold needs to be identified by using substantive, relevant data and not merely be a subjective point selected with nothing to support it. The process should be as automated as possible and minimally intrusive so as to only collect the data needed to identify the platform, if necessary.

AMA members have used a system of aircraft identification for decades where members place their names and addresses or AMA numbers on their models. This should be acceptable for AMA members as an alternative means of complying with the registration process.

Q: What type of information should be collected during the registration process to positively identify the aircraft owner and aircraft?

The only necessary data would be an identifying number/algorithm that connects through a database the name and address of the owner. Other information could be selected as appropriate such as an email address or telephone number.

Q: Are there additional means beyond aircraft registration to encourage accountability and responsible use of UAS?

Although registration of some platforms might have a minimal impact on the small number of users flying irresponsibly, most enthusiasts are accountable and want to fly safely. This is why it is so important that the DOT and FAA focus more of their efforts on education and training and increase their support of AMA’s and AUVSI’s efforts with the Know Before You Fly program.

Finally, the most important thing the FAA can do is to step up its efforts in taking enforcement action against anyone doing something that rises to the level of causing an eminent threat to others in the airspace; however, the real solution lies with education and enforcement.



  1. Require all RC aircraft operators to register with AMA. Let the AMA membership rolls serve as the registration database.

    Sellers of RC aircraft are not permitted to sell RC aircraft products to individuals without AMA membership/registration or face steep fines.

    Users are not permitted to fly RC aircraft without AMA membership/registration or face steep fines.

    All RC aircraft should be in kit form. No more ready to fly (RTF) models.

    Any GPS enabled systems that lets the users fly out of their line sight would require special licenses and additional insurance coverage.

    This should weed out all the offenders and irresponsible flyers.

    1. Most quadcopters on the market today that have a camera on them also have GPS, but it’s not for the purpose of flying out of Line of Sight. Most of the 2.4 Ghz radios don’t even have that ability, unless aftermarket signal boosters are used. The GPS simply allows the quadcopter to return to the last known location of the transmitter and safely land itself, in the event of a lost transmitter signal. It improves safety by prevent fly-offs.
      If only all of our models could share that ability!

    2. My ‘RTF’ required almost complete assembly. How do you find that a problem? Even a first time flyer would have to be able to assemble it, set up the controls, and be able to operate the transmitter. Not like buying a 4 wheeler and just pushing a button to go…

    3. Registering 1 cell 3.7v toy aircraft is laughable. With ranges of less than 100 meters they pose no threat.

    4. Kit form only? As if being able to build a kit makes you a good flier? Wow, I guess you’ve never been to an AMA field.

    5. Requiring sellers to verify AMA membership does little when a significant number of sellers are someplace else, and there is a reciprocal in as much as there are out of country purchasers buying from US sellers.

      Even a serial number or other track-able solution likely won’t be enough when some stupid puts one into a jet engine. Common sense trumps legislation.

    6. Drones are outnumber the closed minded xenophobes that constitute the AMA. I look forward to the tears shed when the AMA finally lays down in the grave they have dug over the past few years.

  2. We modelers who belong to the AMA and fly airplanes and helicopters have been operating since 1936 as an organization, without government intervention or registering our models with the government. We have a clean record, police ourselves, and we don’t need any government intervention now.On the other hand, these drones coming on the scene are a big problem for everybody, including us. We don’t consider them part of our modeling community. Many of them fly wrecklessly and without regard for others. They don’t belong to the AMA and we don’t claim them as modelers and they’ve been causing us grief by their actions. They don’t join the AMA and we shouldn’t be included with them if any government regulations come down the road.

  3. I join the multitude if recreational – i.e. – hobby radio control ( R/C) fliers in condemning the irresponsible action of rogue drone fliers endangering property, inviting accidents and invading privacy. The racent emergence of readily available drones,not requiring any experience,skill or discipline put us responsible R/C fliers in a very bad position. We are a totally different group of hobbyists. – we fly only on sactioned airfields, are licenced by our national organisation, the AAA. We are insured and are mentored and taught by experienced fliers when we enter the hobby. We stay below the 400ft altitude guideline, when appropriate, have a spotter to look out for interference with fellow flyer’s landing or full scale aircraft. To lump us together with the irresponsible, untrained individuals who exploit the current developement if drones, is unfair. I request that you design regulations that will not impact on our persuit of R/C flying – be it model airplanes,helicopters or drones.. The regulations should restrict drone flying to AAA sanctioned fields, AAA insured membership, never flying over anyone elses property, buildings or public structures (houses, bridges, dams, etc) or events/occurances like fires, sporting events, human gatherings of any sort.

    1. I am a member of AMA and have been in the hobby for many years. I do not agree that drones should be restricted to sanctioned fields. Some drone flier’s do not live near a sanctioned field. I think the manufacture of drones should only sale drones that meet the FAA regulations for height and distance and if the aircraft is to be used out side this requirement for commercial use then the owner would have to send drone back to manufacture with written proof of registration, insurance and any other requirements that FAA establishes to have these limitations removed. Lets put some of the requirements back on the manufacture and not all on the hobbyist. You have to remember that drones are used for many types of activities other than casual flying.

    2. I disagree with requiring flyers to use only AMA fields. I have visited many AMA fields looking to fly my small electrics and I get admonished by members not wanting me to waste their flying space with such small aircraft, that I should consider upgrading to larger gas powered models. I am often asked why I don’t just go to the local park, which I end up doing.

      Responsibility is at the user level, and the majority of AMA and non-AMA members are responsible and safe flyers. Forcing memberships to use limited and often unfriendly fields is draconian at best.

  4. Q1: What methods are available for identifying individual products? Does every UAS sold have an individual serial number? Is there another method for identifying individual products sold without serial numbers or those built from kits?
    Model aircraft range from scratch built models made from parts manufactured by the individual to fully ready to fly models manufactured and sold by large manufacturers. In addition, during testing and flying individual models, it is likely that major components will be changed throughout its use. It is unreasonable to expect all these models to have a serial number that will carry from one variation of the model to the next. It is our opinion that there is fundamentally no way to define any major component on a model aircraft that could reasonably be registered. Would a user be expected to serialize every single prototype created during the creative process of making a new model aircraft?
    Q2: At what point should registration occur (e.g. point-of-sale or prior-to-operation)? How should transfers of ownership be addressed in registration?
    Model aircraft and components are sold by vendors around the world, and international vendors have shown that they have no intention of following US regulations that currently exist. It will place an unreasonable burden on US vendors to expect them to offer any sort of point-of-sale registration for the buyers. Also, relating to the reply of question 1, as major components on a model aircraft are damaged and/or changed, what defines a specific model aircraft will be impossible to determine.
    Q3: If registration occurs at point-of-sale, who should be responsible for submission of the data? What burdens would be placed on vendors of UAS if DOT required registration to occur at point-of-sale? What are the advantages of a point-of-sale approach relative to a prior-to-operation approach?
    The reply for question 2 applies to this question as well. There is no advantage to asking vendors to have any responsibility for the registration of model aircraft, and any attempt to do so would have an immediate and drastic negative financial impact on all US vendors which have to adhere to any rules created as such.
    Q4: Consistent with past practice of discretion, should certain UAS be excluded from registration based on performance capabilities or other characteristics that could be associated with safety risk, such as weight, speed, altitude operating limitations, duration of flight? If so, please submit information or data to help support the suggestions, and whether any other criteria should be considered.

    According to the rules already set in place, the Academy of Model Aeronautics (AMA) has procedures in place for various model aircraft sizes and capabilities. Following the FAA Modernization and Reform Act of 2012, only model aircraft not being used or designed for amateur/hobby use and those model aircraft that do not fit into the existing rules set forth by the AMA should be considered for any possible registration requirements, including special provisions for model aircraft over specific weights. Outside if the existing AMA rules, the only other recommendation we have is that model aircraft should be over five pounds to institute any sort of labeling requirement.
    Q5: How should a registration process be designed to minimize burdens and best protect innovation and encourage growth in the UAS industry?
    It is our opinion that any registration requirements for model aircraft that are included in the current AMA rules and guidelines will violate the FAA Modernization and Reform Act of 2012, add unnecessary burden to the growing US industry surrounding model aircraft, and stifle innovation in the US relating to model aircraft and the sciences related to them. The AMA already has recommendations to place the AMA number on model aircraft. This requirement, which is consistent with the 2012 law, seems adequate.
    Q6: Should the registration be electronic or web-based? Are there existing tools that could support an electronic registration process?
    It is difficult to imagine any other method of registration given the technology available today. Any registration that would exist should be done electronically through a well-managed web interface.
    Q7: What type of information should be collected during the registration process to positively identify the aircraft owner and aircraft?
    To answer this question one must assume that the agencies have any right to the personal information of those people who want to operate model aircraft, even minors and those operating small toys. Although it is our opinion that the agencies do not have a right or justified need for this information, if forced to comply, the only information that should be required would be name and mailing address.
    Q8: How should the registration data be stored? Who should have access to the registration data? How should the data be used?
    This is a much larger question that probably needs to be answered by privacy advocates and attorneys. In our opinion, if the data is taken it should be securely saved on encrypted servers and should only be available to law enforcement under a judge’s rule.
    Q9: Should a registration fee be collected and if so, how will the registration fee be collected if registration occurs at point-of-sale? Are there payment services that can be leveraged to assist (e.g. PayPal)?
    Requiring any fee to be collected for registration will reduce innovation and technological advancement in the US. This would place an unfair burden on those who may barely be able to afford to purchase model aircraft in the first place and may place barriers to continued education and technological advancement.
    Q10: Are there additional means beyond aircraft registration to encourage accountability and responsible use of UAS?
    We believe enforcing existing regulations and allowing individuals to operate under the guidelines of the AMA are sufficient to allow for safe operation of model aircraft in US airspace. As stated by the AMA, “Model aviation, operated within the safety programming of the Academy of Model Aeronautics (AMA), has an impeccable 80-year track record of operating safely and simply requiring AMA members to now register their aircraft would have no impact on that record.”
    Registration of model aircraft would have had little to no effect on the few rogue pilots that have caused concern with the FAA and DOT and would only serve to prevent law abiding citizens from enjoying the freedom and liberty set forth by the US Constitution. Working with the model aircraft industry to help educate those on what defines safe operation rather than taking an adversarial approach to the industry would go a long way to helping to keep the US airspace safe, which is what all of us desire.

  5. Any type of registration requirement other than what AMA members already do, is not only pointless, but it is not going to produce anything short of killing off some of the hobby.

    The AMA and others need to press the issue that this is in direct violation of the 2012 Reform and Modernization act.

  6. I’ve been a responsible member of the AMA and an avid RC pilot for the past 19 years.
    I am also amember of my local RC club, and fly RC sport planes and helicopters there often.

    That said, I’ve owned a RC quadcopter with a video camera on it for over a year now. So I see both sides of this fence. Quadcopter activity should in no way affect existing modem model aviation, which has been around for decades. Any regulation on them should be limited to models with specific capabilities. The majority of us stay under the 400 ft. ceiling and are responsible with our quadcopters. Per the AMA’s review of the FAA’s drone-sighting report, over 99% of them are bogus reports, or pilots that are flying safely and legally under 400′, nowhere near airports. A few bad apples are causing a lot of fuss for the rest of us, who have significant financial investments in our aerial videography platforms. As someone who’s watched firsthand as frozen turkeys were fired into jet engines for testing, I find the entire issue ludicrous. Commercial aircraft have thick windshields and are impervious to RC quadcopters, even in the event that one was somewhere in the same vicinity. This seems more like uncle sam not liking the idea of the public having their own eye in the sky.
    I’m hope the fear mongers don’t prevail.

  7. This is a perfect example of government run wild. Millions of these devices are purchased, given as gifts, traded, sold, repaired, modified, discarded and reused by hobbyists from young children to octogenarians. To think that the government can keep track of an individual drone/toy/UAS over the life af the device is shear arrogance. And to think that maybe knowing who purchased one, not knowing who uses it years later, will contribute in any way to “safety” is stupidity. This concept is unworkable and ridiculous. It will serve no purpose other than building a bureaucracy for the harrassment of the hobbyist. Any and all funding for implementation of this set of rules should quickly prohibited.

  8. I agree with John Farkas with his reference to AAA being AMA (Academy of Model Aeronautics). As an organization we are concerned with the safety issues regarding the misguided use of drones (first person view), however we should be reluctant to embrace the FPV operation of model aircraft outside of the line of sight of a flight assistant who has the model in line of sight, while following all tried and proven safety guidelines.

  9. I believe the AMA is at fault and partly responsible for this type of “drone” activity to be confused with RC modeling. The very core of AMA – Academy of “Model” Aeronautics has/had to do with the modeling of a full scale aircraft be it fixed wing or helicopter or some resemblance thereof.

    The “drone” following or people that tend to gravitate to the “drone” market who had nothing to do with modeling before the introduction of “drones” have no interest in the AMA let alone following guidelines set forth by the AMA and FAA. In an effort to get these people on board with AMA the leadership of the AMA has blurred the lines between modeling and FPV/Drones. This was nothing more than a “money grab” effort on the behalf of the AMA in order to gain members/raise revenue.

    Think I’m wrong? Follow the money. There is an estimate that approximately 1,000,000 “drones” will be purchased this holiday season alone. In the interest of cutting the AMA a little slack let’s say 1/4 of them go to someone responsible enough to follow FAA/AMA proposed regulations and join the AMA; (Yes, I know there is not a mandate yet), that would end up being $18,750,000 to the AMA. FOLLOW THE MONEY.

    1. The money to follow comes from the commercial interests. All of the companies expressing an interest in using drones for their last mile deliveries including Google, Amazon, Walmart and others. That money is used to lobby the FAA, DOT, and congress to convince them that the airspace should not be cluttered with hobby drones because it is needed for commercial purposes. The FAA then proceeds with an advertisement blitz to convince the news media and public that drones are a serious hazard to the public airways. Unfortunately, too many people are buying into this notion that scores of bad actors are flying drones irresponsibly and that the government needs to regulate. Never mind that they want to regulate flying of quad-copters in your own backyard below the level of your trees or house roofing. AMA is the only organization that could push back against those interests.

  10. Here was my submission to the FAA in their request for comments for their proposal to register model aircraft. This is what I wrote:

    This model aircraft registration system concept is ill conceived as not only does it violate the hobby aircraft carve-out in the 2012 law, it creates a new and unwieldy system of regulation that simply would not hold up in court to the inevitable challenges as the “public safety” loophole this is predicated on would not hold up under any critical scrutiny by a 3rd party, such a judge or jury, or Supreme Court Justice. And without ensuring the operators are schooled in the safe operation of their model aircraft within the national airspace, it doesn’t even achieve it’s stated goal!

    Instead, the effort to create a system (only to spend more money defending it and then dismantling it when that fails) is better exerted towards creating a practical solution to the problems posed by model aircraft in the national airspace.

    A good model to base this solution on is the national frequency spectrum and amateur radio operators (ham radio operators), where many of the problems of co-existence were solved ages ago. For ham radio, the equipment isn’t registered, the operator is licensed for it’s use and is able to use any equipment for any non-commercial operation he is licensed for once he passes a test of knowledge for the safe and responsible operation of that equipment.

    And like most ham operators who own many different pieces of equipment, a hobby aircraft modeler usually owns several different hobby models that have a large range of performance and operational characteristics (usually a dozen or more, if our local club is any indication).

    Given that registration does not guarantee a model aircraft operator understands the rules of safely for operating in the national airspace, licensing model aircraft operators similar to how hams are licensed may be the ONLY path to ensure each flight is performed by a responsible individual who has proven knowledge of how to operate his hobby aircraft safely.

    And that’s IS what this is about, isn’t it, the continued safe operation of model aircraft in the national airspace? Your proposal to simply register model aircraft doesn’t even make a dent in that problem, and could instead exacerbate it, making it worse!

    Yes, licensing hobby aircraft operators would require changes to the law. But I believe you will find wide support for this in both Congress and the modeling community as it’s a proven solution with a track record of working for ham operators and has protected other national assets for scores of years. And for equipment that may be used by unlicensed operators, FCC Part 15 provides a template for similar rules to license the actual equipment and could be used as well with similar limits to operation that conceptually parallels the emitters that Part 15 governs, but in the model aircraft world.

    Respectfully submitted 11/5/2015 10:00AM by:

    James Lummel
    Kingman, AZ

  11. Since the quads came out….the GPS tracking the signal boosting, the upgrades with videos. I predicted four years ago that this would be the end of our hobby. I say this in reference to our normal AMA sanction fields that we love and protect. We are getting closer and closer to loosing it all. I fly in three AMA clubs. Anger is the general concenous among us all.
    GPS should be banned. Nothing should be flown over 2 pounds. Banning GPS is common sense. This is a military type weapon being tracked by GPS. BAN FPV. FPV is just fuel to the fire of idiots wanting to take one more step above all the other guys. On top of this, most of the guys breaking the law are not AMA members. They know if you can’t track them..,,.they will continue to do idiotic things like flying through a city, buzzing around airports, and buzzing high traffic bridges and yes….even flying through tunnels for instance NYC. You have seen the videos of guys driving while passengers are flying the quad. Thing that soon will get people killed.
    Again…..if an idiot downs a jet liner, we are out of a hobby.

  12. The problem so far has been from large multirotors. It would be appropriate to have the registration requirement in steps. First only include large multirotors (maybe 15 or 20lb up) with FPV. Then wait a year or two and see if the number of incidents decrease.

    1. I have a 6 motor and an 8 motor frame as well as a 280 quad. I can tell you fairly that the 6 and 8 motor frames with their attached hardware constitute a sizable investment, and are never, ever flown in an irresponsible manner. The 280 is regularly in contact with trees and dirt. None of them are ever flown without spotters and never in a manner that they cannot be put down safely. I disagree with the implication that large multirotors are the culprit. Your average 4 motor midline machine seems to be the one in the news all the time, the guys with expensive gimbals and cameras are simply not that stupid.

  13. No registration of any of my planes please, This Gov. has gone 100% communist and it makes me sick!

  14. No registration whatsoever until we see a definition of “UAV”, “Drone” and “model aircraft” in the Title 14 Part 1 of the FAR’s

  15. I feel the answer is EDUCATION … and it should begin with the manufacture and then be followed up by the retailer “(Hobby Shop)- Best Buy – Target and all the others” If they are going to sell them then they need to be held responsible also.. AMA has a perfect track record due to education… Not that there hasn’t been a few accidents but when your talking hundreds of thousands of modelers flying everyday that’s one hell of a track record.. I’m not sure the FAA grasp what it will take to maintain a registration process for all UAS vehicles… They need to figure out witch UAS’s will have to be registered and then register them at point of sale,just like registering to purchase a firearm.. For those who are smart enough to build one from scratch should be smart enough to know how to go on to a website set up by the FAA to register there UAS aircraft.. EDUCATION EDUCATION EDUCATION

    1. We agree, education is a key part to the solution. The FAA has adopted our Know Before You Fly Campaign in an effort to educate pilots.

  16. Education education, education is not the anwser to the reckless and dangerous and
    reckless use of drones in our national airspace. Neither is registration of all
    model aircraft keep those who choose to defy the government or any and all public laws
    on the books. On each bottle bottle of alcohol is a waring lable, people are and
    have been educated about alcohol abuse yet approximately 88,000 deaths accured in 2012. Education for guns, the use Tabacco products, legal and illegal drug use still cause deaths when not taken propertly. Registration will not stop those who choose to fly any model aircraft in a reckless or dangerous manner. Registration of anyhing is done to collect taxes, fees, or trace the object back to the owner for prosecution if used in a reckless or dangerous manner. No amount of making one aware of the safety precautions or the danger our model planes can do will stop those who were born
    stupid to common sense or whats right. I am a member of the AMA and being a member of the AMA will not stop anyone from what is happening in our national airspace with these drone operators.The FAA can stop the use of all model aircraft in one way, to show its in the public interest to do so and even when they make false statements about the amount of near xrone misses they add up in shear numbers and the public
    becomes fearful and if you havent’t noticed nll accross america local,cxounty, state and in our Federal Parks we find our model aircraft restricted or completly banned in some cases. The older people are asking the AMA to wake up from their sleep and see that the FAA should not be trusted to do whats right. I was a firegighter and supervisor, instructor for years. I learned all the education and safety training
    classes in the world didn’t stop someone from doing something supid. and if you turn
    your back on a gasoline fire after you think its out and walk away from it it could
    burn you rear end and damage your pride. The FAA is much like that folks.

  17. FYI gentleman! AMA said don’t register yet, but here in Phoenix FAA is not playing around.Something very interesting happen this morning at the flying field. We were stopped at the field by the Phoenix Aviation Department FAA for not having our planes registered! The guy was really cool and gave us a phone number to call before we take off flying at the field to let the tower know we are flying (we are 4.5 miles from tower)–second he said we have to register our planes because effective Jan 1 they are going to enforce the rule no matter where you fly–even at a sanctioned field! So I went on line to SKYHARBOR.COM and followed the steps to register–It is free for three years and one registration will cover all your planes. I had to pay 5 dollars but it will be returned after I complete registration–Very Cheap and worth not having to worry about it anymore!!! Just thought: I will not be renewing my AMA as it seems they have been crushed by the government and the FAA! Back to being a outlaw flyer, according to the AMA.

  18. The highest I can go is 65 feet I do not think all this applies to Controline aircraft.We fly with safety in mind.

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