While the AMA continues to address registration legally and through Congress, members are being asked to register with the FAA. Pilots do not register their aircraft, they register as a pilot and place their registration number in all of their aircraft.
For decades, the AMA has had a tremendous safety record. For this reason, and based on the protections from Section 336 that we helped pass into law, we do not believe that our 188,000 members should be subject to the UAS registration rule. Section 336 is part of the 2012 FAA Modernization and Reform Act in which Congress recognized the effectiveness of community-based safety guidelines and exempted recreational/hobbyists from any new regulations.
The AMA is working with Congress and looking at legal options to address registration. On a parallel path, we are advocating on behalf of our members directly with the FAA to find a solution. On January 15 Rich Hanson, Bob Brown, Gary Fitch, Chad Budreau, and AMA’s legal counsel conducted a meeting with the FAA. During the visit the AMA discussed several issues impacting the modeling community including registration. We brought a list of our members’ concerns and asked the FAA for a clarification or a resolution to our concerns.
We raised multiple questions around the guidelines pilots must agree to during the registration process, such as the requirement to stay below 400 feet. The FAA acknowledged that AMA members should continue to follow AMA’s community-based safety code. We also discussed and the FAA confirmed that the language on the FAA registration site is a guideline, not regulation. This guideline is not directed at the AMA community but rather, it is a simplified set of safety guidelines geared to the general public.
We specifically addressed the 400 foot altitude limitation and explained how under appropriate circumstances some modeling activity necessarily occurs above 400’ and other activity occurs at altitude to protect modelers and spectators on the ground. The FAA understands that this community flies higher than the guideline and acknowledged that AMA pilots can abide by their own safety code which is proven to provide safe aeromodelling operations
We also raised concerns with the FAA about a possibly stricter registration process for large model airplanes over 55 pounds such as requiring an “N” number. The FAA acknowledged these concerns and we discussed possible ways to revise the large model aircraft registration process going forward.
In addition, we discussed the numerous affiliate AMA members, non-US citizen or non-US resident competitors, and citizens who are currently away from the states who have not been able to register on the FAA site. The registration site so far has not accepted foreign applications, foreign addresses or foreign IP addresses. The FAA shares our concern about this and is working on a solution, which is expected in early February.
Many of our members have raised concerns about the privacy and security of the federal registration database. While we know that the database will be searchable by federal registration number, we do not know yet what additional information will be publicly available. We expressed strong concerns with the release of personal information, especially the personal data of AMA’s youth members . We will continue to press the FAA to safeguard the security of our members’ personal information.
We understand there are AMA members who do not have a computer or do not want to submit a credit card during the application process. We discussed with the FAA the use of a paper application, which currently is only available at local FAA Flight Standards Ditrict Offices (FSDO). To make these paper applications easier to obtain, AMA is working to acquire these documents, which we can send to members who request them. As for members who are willing to register online, but cannot or do not want to submit credit card information, the FAA has agreed to accept gift credit cards such as Visa or Mastercard.
For those clubs that own a model aircraft as an organization and not as an individual, we requested clarification as to how to register the model. We concluded that those models should be registered under the registration of one of the club leaders. To protect that club leader who voluntarily placed his number in or on the club aircraft, the member should have a written document from the club indicating he or she should not be held responsible and is simply providing a registration number on behalf of the club.
Finally, there is confusion around whether members register themselves or their aircraft. Members register themselves and place their number in or on their aircraft.
At the end of our meeting with the FAA, we invited FAA representatives to join the AMA leadership at a nearby flying site to showcase firsthand AMA’s safety protocols, demonstrate club camaraderie and mentoring, and provide the opportunity for the FAA to speak with AMA members in-person.