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.