|Model aviation needs your help to ensure future regulations do not place unnecessary burdens on our community. Last month, the FAA issued an advanced notice of proposed rulemaking (ANPRM) regarding the safe and secure operations of small unmanned aircraft systems (UAS). In this ANPRM, the FAA is currently seeking comments on potential new rulemaking for operational and performance restrictions on UAS, including model aircraft. Some of the parameters being considered include altitude, airspeed, stand-off distances and unmanned aircraft traffic management.
AMA has long held that the hobby of model aviation has introduced no new risk into the airspace, and therefore should not be subject to any new regulations. AMA is in the process of submitting comments to the FAA to this effect, urging the agency to take into consideration the existing safety guidelines for modelers and the differences between model aircraft and commercial drones – the FAA cannot and should not take a one-size-fits-all approach to regulating them.
It is critical that we voice our support for the hobby by submitting a comment to the Federal Register regarding this ANPRM. Click here to submit a comment or visit www.regulations.gov and search for Docket No. FAA – 2018 – 1086; Notice No. 18-08. Below you’ll find a suggested template for comments, which you can customize with your personal story and then copy and paste into the comment field on the Federal Register website. The current deadline for submitting comments is 11:59 pm on April 15, 2019.
Rulemaking is a lengthy process but rest assured that AMA will continue to advocate for our members and keep you informed as it progresses. You can read FAQs regarding this ANPRM or reach out with any further questions or concerns at email@example.com. As always, thank you for your continued support!
Template Comment for AMA Members: ANPRM Safe and Secure Operations
I am writing in response to the FAA’s advanced notice of proposed rulemaking on the safe and secure operations of small unmanned aircraft systems (UAS), including model aircraft. My position is simple: model aviation has introduced no new risk into the airspace, and therefore should not be subject to new regulations.
As the FAA considers new rules for UAS, I urge the agency to take into consideration the existing safety guidelines for modelers and account for the fact that model aircraft and commercial drones are not the same – the FAA cannot and should not take a one-size-fits-all approach to regulations. Not only would that approach run counter to the long-standing principles guiding both manned and unmanned aviation regulations, but it would also place an unnecessary burden on hobbyists like me who have been flying model aircraft for recreational and educational purposes safely for many years.
Hobbyists who fly model aircraft do not need to be included in new rules for drone operators because we already follow our own proven set of safety guidelines, often at remote fixed flying site locations. All AMA members fly according to the organization’s safety code, which has been recognized by Congress as an effective means for managing the modeling community. Our existing safety guidelines work – and there’s no reason to add new rules.
For example, AMA members always fly within visual line of sight of their aircraft, which allows model aircraft pilots to see and avoid anything that may be flying nearby. Also, AMA members must maintain a 25-foot distance between their aircraft and any individuals whenever they are flying. At competitions and events, spectators are required to stay behind a well-defined line, typically 50-100 feet away from the flight line where pilots are operating models, depending on the size of the event and aircraft.
Advanced drones, however, have created the possibility for new risk, and that’s why AMA has supported giving the FAA the authority it needs over sophisticated drones with advanced capabilities, such as those designed for sustained and controlled navigation beyond visual line of sight. The FAA could use the presence of a navigational system that utilizes multiple waypoints as a means of differentiation between model aircraft and sophisticated drones.
New restrictions on model aviation could have a detrimental impact on long-standing model aviation events and competitions that support local charities and non-profits. Beyond curtailing events and harming charities, new rules would have a chilling effect on youth involvement in the hobby and stifle the benefits of utilizing model aviation in STEM education, ultimately hindering efforts to attract youth to the aviation industry.
Again, I urge you to consider model aviation hobbyists separately from operators flying sophisticated drones as you work on new rules for UAS. Not all model aircraft and drones are the same, so the FAA cannot simply take a one-size-fits-all approach.