AMA IN ACTION Advocating for Members
Welcome to the Academy of Model Aeronautics' Advocacy Blog. As the FAA looks to regulate the use of small unmanned aircraft systems (sUAS) and as Congress and state legislatures consider legislation with potential impact on the hobby, this site will keep you informed of the latest news, events and industry updates, and serves as an outlet to let your voice be heard by AMA and key officials nationwide.
Chris Savage and Erin Dobbs invite members from AMA’s Government Relations Team to discuss the FAA UAS registration.They address commonly asked questions and AMA’s suggestion that members hold on registration while the AMA pursues legal and political remedies.
Watch the video and learn more about AMA Air at https://air.modelaircraft.org.
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Keep talking to us. Every little bit of information is something of value to myself and I suspect others as well. An information vacuum is the perfect place for rumors and misinformation.
I am delaying my registration for now but that delay is not open-ended. I appreciate your continuing support of our hobby.
Dave
As a modeler for many years starting with Wakefield rubber, C\L, R/C and now FPV quads, I appreciate the AMA standing up
for all modelers. Thank you. Now—I am retired from the FAA, controller, Regional Office and FAA pilot, so I know the foe,
and in this issue they are the foe. Because of all the media attention there are those in the FAA that, knowing essentially nothing
about model aircraft of any type, whether a ROG windup the kids have or a turbine powered multi engine scale model, are driven to
respond to the pubic about an issue totally overblown, in my opinion.
An example of a danger to all aircraft much higher that R/C models, one which over the years has caused a number of fatalities,
is the danger that birds pose, one recently case being the DC 9 in the Hudson, one which thankfully no one died, but one which
they could have easily died. I might mention that I am also a former military pilot, commercial, helicopter, instrument , multi and FI.
What is the FAA doing about this problem—-in my FAA career, we realized we couldn’t do anything about birds, so we tried to advise pilots by NOTAMS and suggest routes to avoid bird areas. This should be done with all club flying areas, similar to an “aerobatic box”. Lots of non modeler pilots may not like it but this is a fact: all aircraft have equal rights to airspace, whether it is a 747 or a J 3
with proper equipment. So—what is the point—-well, if the FAA insists that our models are “aircraft” then we can respond that maybe the FAA is opening a can of worms they might want to rethink. Maybe they should consider adopting the AMA guidelines concerning model operation (all categories of models).
Sorry to be so long winded, but the FAA needs to butt out and don’t screw things up for us.
Thanks again
Tom
While I see your point about the comment made in the video about it being similar to putting a license plate on your car if you operate on public road way, I think it misses the mark. In a lot of situations, especially with regards to multirotors, they are flown in areas that are not occupied by manned, registered aircraft (ie below 400AGL, often over private property, etc). The analogy is really more like the DMV requiring you to put license plates on radio controlled cars driven on in a park or on private property. It is just stupid. I think we need to stop excepting the FAAs logic that a.) These are real aircraft, and b.) They inherently pose a risk to real aircraft. The FAA should be focusing on how to keep models from effecting manned aircraft not on regulating what sUAS are doing when operated outside of where manned aircraft can fly. I would really like to see the AMA consistently push that point of view to both the FAA and the media. I find it really discouraging that when I search the internet for news stories about the sUAS registration there isn’t any real media focus on the fact that the FAA is overreaching and violating section 336 of the FAA M&RA’12.
Chad says “…as a Community Based Organization…” and then details things we can do that others cannot. Please publish the letter from FAA that approved the AMA’s request to be designated a CBO. I’d point out that absent FAA recognition as a CBO, the AMA is not in fact a CBO. We don’t get to “self declare.” If that were the case, why can’t I declare myself a CBO? See the point?
In multiple conversations with the FAA including at the Memorandum of Understanding signing at the AMA Expo in 2013, the FAA does recognize the AMA as a CBO.
The AAA does not register cars. The EAA or AOPA do not register manned aircraft. BoatUS and others do not register watercraft. ALL of these are registered by government. Why should we think that model aircraft will be any different?
Because they are models, not inhabited vehicles. Are you suggesting that model cars should also be licensed?
Also, the federal government does not register cars. That is the state government.
And for those of us that are scale modelers, what then? To put an N number on a scale aircraft would ruin our pursuit. Further, anyone wishing to abuse model aircraft can easily do so without registering. And since the register is public, a false number could easily be located to at least give the appearance of “registration.”
The government does not have the right to impose regulation on everything.
As I said earlier, and knowing the FAA’s penchant for overstepping its authority, I sense that their next NPRM will be a requirement to possess an A&P license to build a model airplane, if we do not fight back now. Part 339 currently puts the FAA in violation of their own regulations, and this appears to be the gist of the case before the court of appeals. Time to let our employees in the Capitol building hear about this abuse of power and make them reign in the FAA yet again.
Yes, please keep us updated. I believe a daily update is a reasonable request, even if its just to say, “Still waiting on…” or “We followed up with…but no response yet.” Every little bit will help keep members’ nerves calm and shows you have our best interest in mind. Thanks.
WHAT MORE DOES AMA WANT ? Owners using the model aircraft for hobby or recreation will only have to register once and may use the same identification number for all of their model UAS. The registration is valid for three years.
They need to change the Safety Guidance.
If I accepted the Safety Guidance I am agreeing with the government that “I will fly below 400 feet”.
If I then do fly my planes above 400 feet I am breaking at least 1 law.
The same law that Martha Stewart when to jail for, basically lying to them.
I don’t lie to the IRS.
I’m not going to lie to the FAA.
So the AMA has to do something.
Ed Filkins
By inserting the mandatory set of “I will…” questions at the penultimate page in registration they overstepped the proposed Interim Rule and law as far as I can see. The rule talks to the benefits of “acknowledging” good safety practices by owners when they register, but the process has very serious legal implications, deeply troubling simplistic language, and enough room for a lawyer on either side of an argument to drive a truck through. Who gave the FAA that authority and who had it added to the registration process that way? Someone with a dictator-streak in him/her.
Thank you Erin, Chad, Chris and Rich for your efforts and update. Please keep us posted when our club members can participate in the FAA’s 30 day public comment period.
Our club will communicate, effectively.
Happy Holidays to each of you,
Calvin
I disagree with AMA assertion that section 336 allows model aircraft pilots to operate legally as this Public Law 336 protects them. The FAA do not accept this.
From FAA document 7396. See link below, comment period still open!
“FAA opinion on section 336 of Public Law 112-95
The FAA disagrees with the comments asserting that the registration of model aircraft is prohibited by section 336 of Public Law 112-95. While section 336 bars the FAA from promulgating new rules or regulations that apply only to model aircraft, the prohibition against future rulemaking is not a complete bar on rulemaking and does not exempt model aircraft from complying with existing statutory and regulatory requirements. As previously addressed, Public Law 112-95 identifies model aircraft as aircraft and as such, the existing statutory aircraft registration requirements implemented by part 47 apply.
later in FAA document
IFR Requirement: The FAA disagrees with commenters who stated that all small unmanned aircraft should be registered with the AMA and that AMA should be exclusively responsible for the registry. The FAA is specifically directed by statute to develop and maintain an aircraft registry. Accordingly, the FAA cannot abdicate its responsibility to AMA or any other organization outside the FAA.
Link to full document
https://www.regulations.gov/#!documentDetail;D=FAA-2015-7396-0001
(type in 7396 in the search bar)
I forgot to add, I fly and own many 2 and 3 m sailplanes and am very concerned about a 400′ hard ceiling.
As it seems to me, as part of the FAA registration processes, one must acknowledge and accept this 400′ ceiling.
Page one of the registration process, among other listed items,
“I will fly below 400 feet”
later to proceed to page two, one must check off
“I have read, understand and intend to follow the safety guidance”
SO that seems to me to be a tacit acceptance and responsibility to restrict my flying to a 400′ ceiling. Or I can’t register my sailplanes.
Thank you AMA for your work on this.
Registration with the FAA registration process limits you to the 400-feet ( 122-meters ) AGL ceiling limit no matter how close or far you may be from the nearest airport, whether you are an AMA member or not. With the AMA, members have followed the rulings: within 3-miles of an airport ~ maximum 400-feet AGL ceiling; within 5-miles or further from an airport ~ 400-feet AGL or higher ceiling.
On 25 November, the FAA issued notice N JO 7110.891 forbiding model aircraft operations in the Washington D.C. SFRA. As of today, 26 December, we have not received specific guidance from AMA regarding the notice. Some of the 14 clubs in the SFRA are shutting down, some are not. What is the AMA’s official position regarding this notice?
So the guy on the left (whoever he is – no introductions) using the analogy of licensing automobile driving, would have us taking flying exams by the FAA (like cars for a driving license! Then, maybe an FAA physical. The analogy holds, as we are licensing the flyer, and not the aircraft. One can drive any car, if licensed.. Then you have flying while drinking (I didn’t say drunk flying..) just alcohol tests by some disgruntled park guard. This is crazy. I have 30 years flying in the military, 36 years in the major airlines, and safety is an issue, but a drone weighing three pounds (Phantom 3)presents almost no risk to any civilian aircraft. I vote for regulation by membership in AMA!!
I urge you to contact your congressional reps TODAY. Here’s text of letter and email I sent, Please leverage for your message as you see fit. Do this TODAY!
Honorable US Congressman Firstname Lastname,
I am writing to express my opposition to the FAA’s decision to require registration for all privately owned and operated radio controlled aircraft. I respectfully request your representation of my position on this issue to Congress and the FAA, and am requesting your support of the efforts of the Academy of Model Aeronautics (AMA) as related to this issue. Ultimately, I am requesting that model aircraft operated according to the rules of the AMA be exempt from any FAA registration. The FAA is requiring registration between December 21, 2015 and February 19, 2016. I am requesting your assistance in establishing an immediate hold of any required registration until full vetting of the FAA’s intent and rules can occur and aircraft operated according to AMA rules can be exempted from FAA registration.
The AMA has successfully self-governed fixed-wing and rotor model aircraft since 1936. Members of the AMA agree to uphold and abide by a strict set of rules to assure safe flying. Most AMA members belong to a local flying club which typically maintains a dedicated flying field and model-sized runway (AMA club facility). Each of these clubs — and there are hundreds across the U.S. — closely monitor and instruct their members to fly safely and under control in designated AMA club facilities that are approved by local governments. The AMA has prescribed clear and specific rules by which these AMA club facilities are governed. No one is permitted to operate an aircraft at AMA club facilities without following AMA rules. Aeromodelers follow AMA rules to ensure their personal safety as well as the safe return of the model aircraft itself, which is often the result of significant investments of time, care and money. Also, formal AMA membership provides liability insurance coverage for flight activities at the AMA club facility. Suffice to say, safe flight operation is paramount for AMA modelers.
Congress recognized the safe and sensible approach to self-governance which the AMA has practiced for years by passing in 2012 a special rule called the “Special Rule for Model Aircraft”. The Special Rule for Model Aircraft in the FAA Modernization and Reform Act of 2012 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 (CBO) such as the AMA. In spite of this special rule, the FAA now states all model aircraft are required to be registered. Meanwhile, the FAA’s contention that model aircraft should be considered aircraft is currently the subject of pending litigation. Congress by no means intended to grant a free pass to flyers within this system. Instead, it left risk mitigation and the development of appropriate safety guidelines to organizations like AMA.
I understand and appreciate the FAA’s concerns about the proliferation of multi-rotor aircraft, or “drones” that occasionally are in fact operated in a risky fashion. The operators of drones often consider these flying machines as toys rather than piloted aircraft and are unaware of what constitutes “safe and appropriate flying”. Recent news accounts report of “incursions” where drones have inappropriately entered certain protected airspace or have been operated too close to full-size aircraft. These infractions do not occur when AMA member pilots are involved. If this were not true we would be hearing about radio controlled airplanes and helicopters constantly infringing upon restricted airspace or causing continual risk to full sized aircraft. I cannot recall one instance of such an issue. The FAA should focus its efforts towards non AMA situations.
I find the FAA’s required registration to be a gross infringement upon my freedom to practice model aviation. It is also yet another example of unnecessary government intervention upon my activities. I challenge the FAA to show evidence where forced registration will eliminate inappropriate operation of model aircraft and drones. As with other required registration situations, those that cause trouble will be the ones not registered. Law abiding, or in this case AMA rule abiding, pilots will be infringed upon by unnecessary FAA regulation.
In summary, I am requesting your assistance and representation in order to;
1) Obtain an immediate hold of any required registration until full vetting of the FAA’s intent and rules can occur and aircraft operated according to AMA rules can be exempted from FAA registration.
2) Partner with and support the AMA in order to change the FAA’s stance to that as I have explained in this letter.
For your reference, here are web links from the AMA web site with information about this issue:
Director of AMA Governmental and Regulatory Affairs: Mr. Rich Hanson amagov@modelaircraft.org
http://www.modelaircraft.org/aboutama/organization/hqstaff.aspx
amablog.modelaircraft.org/amagov/2015/12/14/ama-reacts-to-dot-uas-registration-rule/
amablog.modelaircraft.org/amagov/2015/12/14/ama-and-the-faa-registration-process/
amablog.modelaircraft.org/amagov/2015/12/16/amas-voice-gains-national-exposure/
This is the “Know before you fly” effort of AMA to educate drone owners of AMA safety guidelines:
amablog.modelaircraft.org/mediaroom/2015/12/17/amazon-among-more-than-20-organizations-joining-know-before-you-fly/
I would welcome an opportunity to speak with you personally about this issue. Please let me know if you would like to have a conversation. I would also appreciate a response to this letter and continued updates of your progress on this issue.
Respectfully yours,
Requiring every model airplane owner in this country to register with the FAA will have no effect on rogue drone pilots. In fact the real out come will be a glut of paperwork with no real change in behavior.
If you want to restrict the capabilities of drones, require the manufactures to build in limits. This can be easily accomplished.
Enforce prior existing regulations, which have had no effect on rogue drone pilots
Drones often have GPS navigation, model airplanes don’t.
Drones can be launched from anywhere, model airplanes need a runway of some sort.
Drones may be programmed to fly autonomously including auto-return to base, model airplanes need constant line of sight for piloting.
Model airplanes require skills that can only be learned by training, drones can and are often flown out of the box with little or no training at all. .
Many of the infractions have been committed by persons that are not members of the A.M.A.
AMA members have an solid safety record and have been flying for years .
I have been flying model airplanes for only 5 years and have never flown near a full scale aircraft, near buildings or over crowds of people.
The current A.M.A. rules are more than adequate, The clubs that I fly with have safety officers, these individuals do enforce A.M.A. guidelines.
We do not need another level of bureaucracy from an agency that may know little of the activity they are supposed to be regulating.
The A.M.A. is a well established group with a lot of knowledge and experience do not ignore their input in dealing with the issue of drones.
Lee H Fisher
ama 992681
When is the AMA going to file a lawsuit and request in injunction? I have over 25 years experience dealing with government bureaucracies and a lawsuit is the only solution left available. The rule is already in effect, co comments will simple be discarded and our elected officials don’t care.
If this is not challenged in court in a timely manner, the government will consider it settled and the AMA and this hobby will simply cease to exist in the US.
Rob Campbell
AMA 120825
Rob Campbell is right. SUE, it’s the only way to slow them down. I’ll bet money (or make a donation) that when the AMA met with FAA representatives, the FAA nodded, smiled and gave the impression that they were in complete agreement with the AMA – just before they issued the directive, written the way they wanted – as broadly as possible.
AMA – go to court, it’s the only way to get their attention.
Richard Shilling
AMA 47254, LSF 226
I agree. There is already law regarding this matter. Take it to court to at least force them to get a real answer. This is a proper place for a lawsuit.
C Brooks
AMA 902224
https://www.forbes.com/sites/johngoglia/2016/01/04/faa-sued-in-federal-court-over-drone-registration-rules/
ONE PERSON has the guts enough to sue the FAA while the AMA wants to “talk” to FAA.
Talk with a big stick or you won’t have 180,000 members for long.
FAA registration by AMA members does not make sense, registration of drones at time of purchase, now that makes sense. Enrolling the general public as AMA members, who have no
intention of following AMA safety rules only potentially, stains the AMAs safety record and portrays
the AMA as being ineffective at controlling the model air space. A few weeks ago there
was discussion about an app to identify the drone by scanning would register it directly to the FAA at the time of purchase, or was I imagining this?
Chad, registration and this gooey term “education” is not going to make irresponsible people
responsible. I believe every person that sends a craft into the air, knows, that there is
a potential for it to crash into something or someone.
Your video occurred before the FAA meeting at the AMA Expo I am not happy with the
comments “Hoot” Gibson made, Are you?. Tell Bob Brown to stop promoting drones and AMA membership in the MA magazine. Stop boasting about “streamlining” the registration process, that is not something to be proud of, you guy should be ashamed of it. Again, the FAA is not going to stop at registration, there are more SFRA in line and more fields target for closure. I wonder if the AMA headquarters and flying site is targeted for closure? What will you guys do then, move from Muncie?