External Marking Requirement for FAA Registration

On February 15, 2019 the FAA posted a rule in the Federal Register requiring all unmanned aircraft owners to display their FAA registration number on an outside of the aircraft. UAS operators may no longer place registration numbers in an interior compartment of the aircraft. The rule went into effect on February 25, 2019. In response to this Interim Final Rule, AMA submitted the following public comment:

The Academy of Model Aeronautics (AMA) represents nearly 200,000 model aircraft hobbyists across the country. Founded in 1936, we are the nation’s largest organization representing those who fly model aircraft for recreational and educational purposes. For years, our National Model Aircraft Safety Code has been recognized by Congress, as well as state legislatures, as a safe and effective means of managing model aircraft hobbyists. Our members know where, when and how to fly safely and they do not pose any new risk to the airspace.

Since 2015, we have participated in the Federal Aviation Administration’s (FAA) efforts to establish a registration rule for small unmanned aircraft systems (UAS). We have long held that federal registration of UAS makes sense at an appropriate threshold of weight, capability and other safety-related characteristics. However, we continue to believe that federal registration should not apply at such a low threshold that it includes toys. Most importantly, it should not burden model aircraft hobbyists who have operated harmoniously and safely in our nation’s skies for decades.

AMA members already comply with AMA’s own registration system. When joining AMA, members provide personal identification and contact information, and affirm that they will abide by AMA’s safety guidelines. Members are instructed to place their membership number or their name and address on or within their aircraft. Over the years, this has proven to be an effective means of linking and identifying the owner-operator of a model aircraft to his or her platform.

Although the interim final registration rule is duplicative for AMA members, we have complied. Most AMA members already have their FAA registration number posted on the outside of their aircraft. Unfortunately, for some of our members, including the small percentage of AMA members who fly scale replica model aircraft, the interim final registration rule creates a significant burden. For these AMA members, affixing an FAA registration number on the external surface of the aircraft diminishes the accuracy of the scale replica model. The accuracy of the model is critical because it is the primary factor by which these models are judged in competitions nationally and globally.

AMA understands and appreciates the intent behind the interim registration rule’s requirement to affix the FAA number on the outside of the aircraft. In no way do we want to create safety risks for law enforcement officials or first responders who might be tasked with opening a compartment on a model aircraft to find a registration number. However, we do not believe that model aircraft create any new risk.

Given the relatively small number of scale replica in the airspace today, we urge the FAA to consider a waiver process for our niche community of responsible hobbyists who have been flying safely for years. Just as in the full-scale aviation community, there are exceptions to exterior aircraft marking. A waiver process will ensure that passionate and law-abiding scale replica modelers have an opportunity to continue their beloved hobby without interference.

We look forward to continuing to work closely with the FAA regarding recreational small UAS operating requirements. As always, we are committed to ensuring the safety of our nation’s skies for all.