AMA Reacts to DOT Task Force Recommendations on UAS Registration

As a member of the task force, AMA agrees that registration of UAS makes sense at some level and for flyers operating outside the guidance of a community-based organization or flying for commercial purposes. Unfortunately, as written, these recommendations would make the registration process an unnecessary and unjustified burden to our 185,000 members, who have operated harmoniously within the aviation community for decades and who register and provide their personal contact information when joining the AMA. For this reason, AMA wanted to include dissenting comments in the final task force report, but was prevented from doing so.

Adding an additional requirement for AMA members to register at the federal level is contrary to the intent of the Special Rule for Model Aircraft in the FAA Modernization and Reform Act of 2012. Public Law clearly states that the FAA is prohibited from promulgating any new rules for recreational users operating within the safety guidelines of a community-based organization. Congress by no means intended to grant a free pass for individuals who operate model aircraft. Instead, it clearly intended to leave risk mitigation and the development of appropriate safety guidelines for the operation of these devices by the members of the AMA to the nationwide community-based organization.

More importantly, there is no finding or indication that any AMA member was involved in the incidents and sightings that lead to the decision to require UAS registration. In fact the AMA has proactively partnered with the FAA and other industry stakeholders in an effort to educate the new unmanned aircraft (“drone”) enthusiasts through the “Know Before You Fly” campaign. AMA members have been flying safely for decades, and our members are not the problem. Safety has been the cornerstone of our organization for over 80 years and, with our stellar safety record, AMA’s members strive to be a part of the solution. However, the solution should not involve our members bearing the burden of new regulations.

Unfortunately the task force recommendations may ultimately prove untenable by requiring the registration of smaller devices that are essentially toys and do not represent safety concerns. Based on its years of experience the AMA cautioned against unnecessarily encumbering the toy industry and urged the task force to consider several factors when determining the threshold at which UAS technology should be registered – including weight, capability and other safety-related characteristics. But, the recommendations do not reflect this comprehensive approach. The task force only considered weight, requiring any device up to 250 grams (0.55 pounds) to register. We believe weight should be only one of several factors considered when determining where the threshold should be for UAS registration.


  1. Second to last paragraph should read ‘…any device over’ (versus ‘up to’).

    Please clarify that the task force recommendations did not differentiate between model airplanes, helicopters and “drones”. ‘Same registration requirement for anything that flies and is over 250 grams?

    My fear is that when the next serious incident occurs, the FAA will be directed to take corrective actions such as mandatory training and other hoops to jump through that will have little bearing on my AMA modeling hobby activities.

    1. The task force did not differentiate between model planes, helicopters, and “drones” or mulitrotors. Anything that flies by a ground control system (transmitter/radio) over 250 grams will require registration if this recommendation is applied.

  2. “Public Law clearly states that the FAA is prohibited from promulgating any new rules for recreational users operating within the safety guidelines of a community-based organization.” If this is true will any pursue legal actions if the recommendations are enacted or just roll over and take it? This is all about as useful as wanting gun owners to be registered – it affects people who are law-abiding citizens not criminals. I also wonder how registration will have any hope of being enforced, especially on the smaller end of the scale. OK, rant over now. 😉

  3. The AMA has over 170000 members. Where are they. There has been very little out cry from the members. You here the usual talk at the field. Most of it is wrong. There is a lot of rumors out there.
    Get your clubs involved!!!! Learn the facts and stay away from the rumors. Read the AMA blogs and statements. Let’s all do our part and help inform our members.

    1. The recommendations may change before the FAA/DOT places them in action. As it is understood now, the parent would be required to register the aircraft if the child is less than 13 years old.

  4. The 250 gram limit is not unreasonable. OSHA and others use the following calculator to determine the extent of an injury that results from an object of a specific weight dropped from a particular height. Of note, the injury potential even assumes the victim is wearing an industry standard construction hard hat. A 250 gram item is indeed more than capable of causing significant or fatal injuries in drops from well below the 400′ FAA recommended maximum.

    1. Frank, your drop calculator leaves out a very important number – coefficient of drag. A 250g bullet falls with more force than a 250g piece of paper due to its resistance in the air. These FAA numbers were also based on falling over a heavily populated urban area, a place where we are not even supposed to fly. The 250g limit is foolish; a 249g “drone” is OK, but a 250g “drone” is not. This is illogical.

    2. If one were to read RTFAR Final Report in the reference, calculations for probability of a LETHAL event, page 8 about half way down the G-man contradicts himself by saying “For these purposes, we have used population density numbers reflecting a relatively densely packed urban environment. We have done so DESPITE the fact that sUAS operations are prohibited over unprotected persons not connected to the operation.”

  5. The new law regarding sUAS implements fines for non-compliance which of course include imprisonment. So… an previously “registered” operator of a sUAS may be subject to imprisonment if said operator fails to re-register the sUAS because the operator has transitioned to “owner” as the sUAS is hanging from the shop ceiling and is no longer flown. Read the text of the law. Just as you control your sUAS so you are controlled by the state.

  6. The only two purposes of the FAA attempt to license model aircraft are (1) to increase the size of government by increasing their staff to handle the model airplane data and (2)the second purpose is to provide them with an alibi for the next criminal incident. The head of the FAA can then stand before the congressional investigators and whine that they took all necessary precautions by forcing the license law. Everybody knows that license bearing model airplanes, drones and guns don’t get into criminal activity. It’s the unmarked and untraceable ones that do the damage.

    Apart from the AMA work, this effort is going to result in another Obamacare website debacle. The government man wants to register EVERYONE who has EVER bought or owned a model. At 250 grams that means billions of toy flying objects. How do they plan to enforce this? Swat team the local school grounds and soccer fields? Subpoena the sales records of ALL sales outlets? Maybe they will seize imported flying models at Customs? Oh, I see a great new venue for the G-man to fulfill!

  7. This legislation will KILL model aircraft activity. The feds that wrote it are ivory tower intellectuals with the intent of expanding their power and control. The premises they used for the probabilities are guess-based and calibrated for the worst-case scenario.

    By their definition, a football at 410 to 450 grams is an aircraft threat. The G-man made the 250 gram calculation based on the 400 foot allowed maximum altitude. Have you ever seen a 260 gram aircraft at 400 feet? Maybe if it were a big balloon?

    Most people have insurance for that worst-case eventuality rather than a quorum of professional rule-writers. An interesting note is that the FAA will gleefully impose a $25,000 fine for failure to register. But no mention is made of liability for damages that may occur in the event that their probability of failure is met.

    The RTFAR Final Report shows that the G-man has no ability to make meaningful rules for anything other than full scale aircraft. But they sure do want that registration. Register my guns, register my model planes; how about registering mental cases that actually kill people?

    Please explain in a logical fact-based way how registering every flyer on earth is going to make me safe? The FAA G-men so far haven’t been able to trace laser hits on cockpits of full scale planes, which is a far greater threat to safety. The G-man so far has not been able to track drones that fly into controlled airspace. So I’m sure that registering me, a model flyer in Montana or Utah will allow them track down drones violating LAX airspace, no?

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