Dear members,
I’m writing to provide you with an update on the U.S. Department of Transportation’s UAS registration task force. As you may be aware, the task force met for several days last week and AMA’s Rich Hanson represented our members’ interests in all of the discussions.
We’re limited in how much we can divulge about these meetings because all task force members agreed to a set of ground rules. These rules prohibit us from publicly discussing any details of the task force’s internal deliberations. With that said, there has been some misinformation, as well as some inaccuracies surrounding this issue, so we want to provide you, our members, with as much information as we can while still respecting the integrity of the process.
During the task force meetings, AMA strongly argued for our members to be exempt from federal registration, as Congress intended with the Special Rule for Model Aircraft in the FAA Modernization and Reform Act of 2012. This special rule states that the FAA does not have the authority to promulgate any new rules on recreational users operating under the safety guidelines of a community-based organization such as AMA.
AMA members have been flying safely for decades, and we made it clear that our members are not the problem. With our stellar safety record, AMA can be part of the solution, but our members shouldn’t have to bear the burden of new regulations. Meanwhile, as our members know, AMA already has in place its own voluntary registration system.
For the new legions of consumer drone users who are not AMA members, we do think that registration makes sense at some level when UAS technology meets an appropriate threshold of weight, capability and other safety-related characteristics.
The task force’s detailed recommendations to the FAA are scheduled to become public on Friday, November 20. AMA intends to make our views explicitly clear in these final recommendations and we will continue to advocate for our members to be exempt from registration if the final recommendations state otherwise. And once this information is made public, we will also be able to more openly and publicly address the registration proposal.
In the meantime, we encourage our members to submit comments on the FAA’s registration proposal through the regulations.gov portal. Although comments were due by November 6, the docket remains open and the U.S. Department of Transportation has indicated that it will consider all comments received. To submit a comment, click here: https://www.regulations.gov/#!documentDetail;D=FAA-2015-4378-0022.
We thank you for your continued support of AMA and look forward to working alongside you on these important issues.
Kind regards,
Dave Mathewson
Executive Director
Ridiculous! I can fly my drone 200′ over someones property and show them what their property and the condition of their roof all day long so long as I do it for free. If they want to give me $20 bucks for my trouble I need an FAA 333 exemption, or a COA and in either case an minimum of a Sport Pilot’s License.
Don’t get me wrong. Someone flying a big heavy drone up 400 feet or more out of VLOS should be closely monitored and regulated. However needing FAA certifications “a PIC must hold either an airline transport,
commercial, private, recreational, or sport pilot certificate” because I’m being paid to fly (hover) a Phantom 3 Standard 200′ is ridiculous.
One aspect of drone flying that seems to be missed or ignored is that most video links and some control links are in the amateur radio bands. Getting paid is against FCC rules for amateur radio use.
Most are operating as Part 15 “unlicensed” devices within Part 15 frequency allocations which also overlap the Amateur Radio Service allocations, notably at 902-928 Mhz, and 2.4-2.45 Ghz, and possibly video links in the 5 Ghz allocation. Model UAS control links and video links are typically operating as Part 15, not Part 97. The difference is that Part 15 has low power emission limits and no protection from interference from Part 97, or other shared/licensed users of those spectrum allocations.
There is no prohibition against commercial use of Part 15 – indeed, many wireless mics used in commercial production are now operating as Part 15 devices at 902 or 2400 Mhz bands. Many wireless hotspots charge a fee for access, yet they are operating as Part 15 in the 2.4-45 Ghz band.
“We’re limited in how much we can divulge about these meetings because all task force members agreed to a set of ground rules. These rules prohibit us from publicly discussing any details of the task force’s internal deliberations.’
So disappointed to hear that the AMA has fallen so low so as not to be transparent with it’s members!
Hi Sierra,
Now that the rules have been announced, we will be sharing more details. You can read our response at https://amablog.modelaircraft.org/mediaroom/2015/11/23/ama-reacts-to-dot-task-force-recommendations-on-uas-registration/.
AVweb:
https://www.avweb.com/avwebflash/news/FAA-Says-Drone-Registration-Will-Be-Do-It-Yourself-225199-1.html
Something to be thinking about:
It appears from all indications that the FAA is going to require a registration of sorts for certain UAVs. The debate for what will need to be registered appears to be centered over a weight threshold. I am sure that the AMA will argue down to the last minute for AMA members to be exempt based on our stellar record. But they are only one voice out of many. I don’t think that we need to get too exited about this until the rule actually gets published, but it raises some issues regarding flying at AMA club fields. Will AMA clubs be expected to enforce the FAA registration regulation by not permitting unregistered aircraft to fly? I would expect to lose a few members if that were to be the case as there some members who will simply refuse to bow to what they feel is governmental intrusion into the lives of those who are not causing the problems.
Yes we at the AMA are arguing against many of points in the recommendations. Aircraft weighing 250 grams easily belong in the toy category. Canada has a tiered system that starts with aircraft weighing more than 2 kg. The FAA/DOT Task Force weight limit of 250 grams is unrealistic and overly burdensome. More importantly, we believe weight should not be the only determining factor to trigger registration. AMA has said before that the capability of the aircraft should also be a factor in determining the threshold for UAS registration. Most members who fly recreational should not have to register.
I certainly hope the AMA is doing more than just arguing the points stated. I see you did not mention that this goes against the 2012 ACT, that protects the recreational flyer from the FAA’s draconian laws. I certainly appreciate all the AMA does for the membership, however I hope there is much more planned and very soon. Many members are stating they will not renew and some clubs are saying that maybe it is time for new representation. I certainly hope some major progress is made soon, before it is too late.
D. Shannon
AMA 709192
Where is the AMA response to the release of the proposals on Friday, Nov 20? I cannot express too strongly how important it is to be open and above board with the membership, while respecting any valid government restrictions. But lack of response indicates not being on top of the issues.
Thanks for all you do.
AMA 188885
https://amablog.modelaircraft.org/mediaroom/2015/11/23/ama-reacts-to-dot-task-force-recommendations-on-uas-registration/
Hi Charles,
You can read our response at https://amablog.modelaircraft.org/amagov/2015/11/23/ama-reacts-to-dot-task-force-recommendations-on-uas-registration/.
We have already lined up media interviews. Expect to see more exposure in the media soon.
Thank you for your support and membership!
Please keep updates coming. It is important to me and other members. This blog is where I will refer fellow fliers to when they have questions. When all the decisions are made, I would also like to see an advisory style communication recommending actions we, as members, should consider taking. Thanks for your work.
AMA 865867