FAA Issues Interim Final Rule for External Marking Requirement

The FAA issued an Interim Final Rule today that will require drone pilots and model aircraft pilots to display their FAA-issued registration number on the outside surface of their aircraft. The rule will take effect on Monday, February 25, which means the markings must be in place for any outdoor flight beginning on that date.

Although most AMA members already have their FAA registration number posted on the outside of their aircraft, AMA will be submitting comments to the FAA requesting a waiver process for those who might be burdened by external markings, such as members who fly scale replica model aircraft. Most importantly, this rule does not change the original acceptable methods of external marking, nor does it specify a particular external surface on which the registration number must be placed. The requirement is simply that the registration number must be seen upon visual inspection of the aircraft’s exterior.

As you know, the registration requirement is not new. Congress reinstated this requirement in December 2017 with the passage of the National Defense Authorization Act. Although this rule was flexible and allowed the registration marking to be placed in an enclosed compartment, law enforcement officials and FAA partners have expressed concerns about the safety risks a concealed explosive device could pose to first responders when opening a compartment to find a registration number.

If you would like to submit your own comment on the Interim Final Rule, simply visit www.regulations.gov and search for “RIN 2120-AL32.” You can also visit www.faa.gov/news/updates/?newsId=93045 to learn more. The deadline for public comment ends on March 15, 2019.

If you are uncertain if you have a valid FAA registration, you can access your FAA account at https://faadronezone.faa.gov/#. This site will allow you to view your personal FAA registration number and expiration date. We strongly advise you to avoid registering your model aircraft anywhere other than the official FAA website. If you register under Section 336, there is a $5 fee for a three-year registration, and hobbyists receive one identification number for all of their aircraft. Please be aware of unofficial registration websites that charge exorbitant fees or require separate registration fees for each recreational aircraft.

We continue to work closely with the FAA to determine the best path forward regarding recreational UAS operating requirements. We have already received numerous questions from our members and have posted the most frequently asked questions and answers below. As always, thank you for your continued support, and please reach out with any further questions or concerns at amagov@modelaircraft.org.

Q: How does UAS registration affect my membership? 
A: AMA club or member benefits are not contingent on UAS registration. We encourage all members to follow Federal regulations, but we are not policing UAS registration.

Q: Do I have to register every aircraft?
A: You only need to register your name, physical address, and email address once. You will receive a single FAA registration number which is to be placed on the outside of all of your aircraft along with your AMA number.

Q: Do only drones and multirotor operators need to register?
A: Anyone who flies a model that can freely navigate in the air and uses a remote control device (e.g. RC transmitter) is required to register. This includes drones, traditional fixed wing model aircraft, model helicopters, and other remote controlled model aircraft. If you exclusively fly models under a half pound (250 grams or .55 pounds), indoors, control line, or free flight models – you do not need to register.

Q: Do I need to list both my AMA number and my federal registration number on my aircraft?
A: Yes, you need to list both your AMA number and Federal registration number on your aircraft

Q: Should clubs, contest directors, or event leaders require all pilots be registered?
A: No, we are not asking our clubs or contest directors to police UAS Registration. That decision is up to each individual club and event leader.

Q: I only fly CL, FF, or indoors – do I need to register?
A: No. If you exclusively fly indoors, FF, or CL you do not need to register.

Q: Does my large model aircraft require an N number?
A: AMA representatives, including AMA’s legal counsel, met with the FAA on January 15, 2016, and this was one of the many questions that were raised. The FAA representatives confirmed that AMA members, operating models under the Large Model Airplane Program, should not have to apply for an N number.

Q: I am an Affiliate Member, do not live in the US, or I am not a US Citizen. How do I register?
A:Everyone, including foreign nationals and tourists, who operate a UAS for hobby or recreational purposes outdoors in the U.S. must use the FAA’s online registration system. These non-U.S. citizens or non-permanent U.S. residents will receive the same registration certificate as U.S. Citizens or permanent U.S. residents. However, this certificate will function as a “recognition of ownership” document. This document is required by the Department of Transportation for foreign nationals to operate legally in the US.

Visiting pilots can only use a computer with a United States IP address to register. When arriving in the states, pilots can register using a US computer at a hotel, guest home, or even at AMA HQ.

Thank you,
AMA Government Affairs