Response Needed to FAA Model Aircraft Rule

132 comments

1. Its a total scam but give the technology to law enforcement or private industry that supplies the fed with the same gadgets its ok! FREE AIR SPACE! Majority of US citizens have no intentions of any harm upon others. Be nice if hidden organized gang stalking they are utilizing would stop from the sky as well!

   1. My response is simple, exclude model aviation from any rules. The simply truth is that we fly our models in line of sight, say no more than 500 yards away, you have to see the plane to fly the plane. We have been self regulating for the entire time the AMA has been in existence. We should be excluded and not governed.

      1. Not free flight models. Please don’t make statements about distance and line of sight based solely on R/C.

2. My concerns regarding the FAA Interpretive Rule for Model Aircraft docket number FAA-2014-0396

   It is my opinion that the FAA modernization and Reform Act of 2012 and the Special Rule for Model Aircraft are heavily under the influence of Home Land Security and the Terrorist Control Acts. There is no direct mention of these in any of the language as it is conveniently covered and hidden by “Safety of the Public” statements.
   Any flying object controlled or not can present an airspace hazard. What’s clear here is the summary statement by the FAA “…If a model aircraft operator endangers the safety of the National Airspace System, the FAA has the authority to take enforcement action against those operators for those safety violations.”
   So the intent is clearly a punitive interpretation more than a safety concern.
   I believe that the omission of the Terrorist Act verbiage is because it is clearly evident to any patriotic US citizen that the inclusion of any such reference would be totally moot and irrelevant to preventing terrorist actions.
   That said, it is perhaps seen by Home Land Security and FAA to have rules “on the books” as an aid to prosecuting terrorist’s actions or attempts at using model aircraft technology for such actions.
   However, FAA legislation and rulemaking also impacts the freedoms and enjoyment of hobby and recreational use of model aircraft flight operations. I applaud the creation of the Special Rule for Model Aircraft.
   I am a fifty year member of the Academy of Model Aircraft (AMA) member and a past associated club president.
   I am a forty year licensed private pilot and past associated chapter president with Experimental Aircraft Association (EAA)
   I am a fifty year FCC licensed advanced class Amateur radio (W5EHS) and Lifetime American Radio Relay League member past ARRL associated club president.
   My point is all these organizations are nationally and worldwide recognized as being able to privately provide safety guidelines, self regulations, equipment inspections, and testing (qualifying) of its own members without federal USA intervention. They of course follow all federal regulations and supportive of the regulation process.
   I support the Academy of Model Aeronautics’ areas of concern on the FAA “interpretations” of the Rule Regarding the Special Rule for Model Aircraft. The AMA statement has far more reference to proper document numbers and laws than I could ever discover for myself.
   The FAA is not only attempting to tell me what I can read and understand for myself, but adding additional regulation. You have lowered your standard practice to that of a news commentator who comes on the air after the US President’s State of the Union address and tries to tell the public the “media” version of what the President said or meant to say and adding their “Spin”.
   In the same way, the AMA comments are doing the same thing from a different view. So I completely understand the process of commentary on rule making.
   However, the result in the process you have added specific language in your interpretation as outlined in the AMA Comment, which extends authorization to control levels not apparent in the parent document.
   I am in favor of low Federal regulation and more local level control of model aviation in general. It is the clubs and peer pressure that regulates law abiding citizens in the hobby of Model Aviation. We of course need rules and support by the FAA with safety concerns. The pure hobby of Model Aircraft Flying has never been a national threat and certainly never will be.
   The expansion of the technology of model aircraft into business use and possible weapons of purposeful injury and destruction should be handled totally separate from “A Special Rule for Model (hobby) Aircraft.”
   Let Hobby of Model Aircraft Flying be self policing as much as possible.

   1. 73 OM, great comments. It is just SOP for the current Administration. K8MX

      1. Sorry, call was supposed to be KD8MX.

   2. Well said “Ramblin Dan” . This is just more bureaucratic BS by our over extended government.

   3. The FAA – like the EPA and the IRS – is just another of ‘bama’s personal Gestapos. I strongly doubt letters will help at all. They are Socialists who wish nothing less than total control over every aspect of every American’s life. To make America “Oceania.” If we are to do anything effective against them it will be to vote (and encourage all others we know to vote) against them in the upcoming elections – and those beyond. The people now running the FAA don’t care what we think or want, they care only of what they want for us – whether we want it or not.

3. AMA, your areas of concern are certainly valid and you make good points, but please don’t overlook the fact that the FAA is also effectively trying to ban FPV flight. AMA rules provide a safe (and conservative in my opinion) method of flying FPV. FPV is a big part of the future of model aviation, and it should be embraced – not banned. Please work with the FAA to convince them that guidelines on FPV should come from AMA and not the FAA.

   1. I agree Brent. I am both a General Aviation pilot and avid modeler, but not everyone who buys or builds a model RC aircraft follows the rules of AMA or any other rules when it comes to safe flying and operation of the aircraft/helicopter/multi-rotor. You can go on UTube and see people using FPV flying through cities and under overpasses. This is dangerous to everyone. The fact that the FAA is putting some restraints on the model aircraft industry is brought on by these kind of careless acts. I see no problem with the FAA wanting anyone within 5 miles of an airport having to report to them. It is a safety measure for us who are general aviation pilots and will provide information that these aircraft are operating in the area. And if the modeler is flying within their responsible airspace, no one is hurt. Unfortunately the few mess it up for the many. It was only a matter of time before the FAA got involved. The modeling community has been very lucky up to this point that no strict rules have been applied to them as they have on general aviation. A 200 mph RC Jet aircraft that is 10 feet long is just as dangerous as a Cessna 172 in the wrong hands.

      1. Bill, I agree with pretty much every thing you said, as a pilot for over 40 years I can and do agree that flight safety is paramount. But here is the But….

         Bill, they are effectively outlawing ALL FPV, that is not “some Restrictions” That is gutting an entire industry. FPV flight is central to a hundred applications for industry and ag, Fire Safety and Search and Rescue.

         On calling the tower? I have worked at a scope in the navy and trying to de-conflict traffic is a fine art at best, now we are gonna have yahoos calling the tower on the phone saying well I am gonna fly my Phantom over the Auto Lot at the corner of Fifth and Central….I hope to only be there an hour or so, Then later after lunch I am going over to the river festival and get some aerials there… I will probably launch from the sidewalk on the north side of the river, and fly around a bunch, but I don’t know where cause I have no idea where the shot will be till I get there…..

         Do you get my point, Number one, This is NOT going to be helpful since the controller amazingly does not have Joe’s car lot at 5th and Central on his scope, and even if it is the secondary controller taking the call, that is someone in the tower who is now on the PHONE instead of looking over his partners shoulder or handling ground control, or updating ATIS or whatever it is he is currently paid to do.

         While I agree on one hand that reporting is a nice idea, If I am flying at a hundred feet or three hundred feet over a car lot, you as a responsible Pilot BETTER be at least two hundred feet above me and more than likely if your more than a mile or two from the field, you better be at Pattern Altitude or above over a built up area. I totally agree that iresponsible yahoos who fly under overpasses and other idiotic stuff is dangerous and ruins it for everybody, and THOSE people should be Cited, Prosecuted Fined or Jailed. We need standards that people can and have to abide by.

         Flying a Phantom over a car lot is not rocket science, but the pilot should have training, insurance and if he dumps it on the car lot, he and the owner can settle it. If he crashes in the street and hits a bus, His Insurance better be paid up and maybe he ends up having to get refresher training at an AMA certified Club.

         Outlawing FPV is Stupid, Outlawing Stupidity is Impossible, but educating the pilot, providing quality training and teaching safe and responsible operation is none of those. In fact NOT doing so is.

         1. Oh yeah and multiply those calls by 20 a day…..

4. I have been an ama member for 35 years. When I saw $3500 multi rotor platforms I knew this was going to happen. I wrote ama about it but was blown off. Our “hobby providers” have caused this by getting involved in platforms that are anything but “hobby”.
   You cant just blame the government for all this. They are responding to a trend. I kow I will take flak for this, but if I was on the outside of our hobby looking in, Id be scared XXitless about what we are flying. Our hobby bungled the perception issue, and in politics, perception is everything.

   1. I am in complete agreement with you! A small group of ‘poor little idiot FPV rich kids” are going to ruin the hobby for everyone! From what I gather, if a pilot in command was flying the master radio, he could hold the trainer switch for the FPV ‘copilot’ to fly,, as long as the master pilot can see the model and is not wearing goggles! What is wrong with that?

      1. Lol Geez Day, What is your problem with Rich Kids? You sound like one of those old farts screaming you kids get off of my lawn!!! lol, There are just as many idiot poor kids out there doing stupid stuff. I mean you can build a multirotor for a hundred bucks or buy one with FPV and an lcd screen built into the TX for $300. That is barely what kids pay for a pair of shoes these days.

         I do agree with your second assertion, about the spotter flying the master, I think that is a solution for the problem, as long as they keep within maybe a thousand to 1500 feet horizontally. Beyond that, the spotter is essentially useless.

         I am gonna take some heat for this but Long Range FPV, that is a totally different animal, and while I have seen a few FPV rigs with double articulated camera mounts, (In fact I own one but have not installed it yet) I agree with most people that without the ability to look over your shoulder in both directions, situational awareness is severely compromised to a degree that would be unsafe. Beyond that, you do not have a spotter, you can not hear an aircraft approaching you and to me, that is a recipe for an accident.

         1. Matt Eyelash I can tell by your comment that you have never once in your life ever flown FPV.

      2. I agree this whole FPV group mentality is “we own the airspace and we can do anything we want”. Its total garbage and I don’t want any of that attitude at my flying field or in the AMA.

         Please post your comments to the FAA its great here but vent your concerns and ideas to them in an intelligent manner.

         1. Very few of us think that way. There are some bad apples but they should be dealt with individually. Privacy is big issue. Safety is less in my opinion. Foam, wood, plastic. At worst someone gets a few stitches. Stay away from airports and stay away from private property. Don’t fly over people. I think that’s very fair. But to over reach like this? These are hobby planes! Serious slippery slope to regulate like this. Most people fly FPV under half of a mile. Pretty harmless in a field for fun and the general appreciation for aviation. I get angry too when I see these idiots flying over stadiums or in the city. That’s what we should deal with.

      3. What is wrong with that is everything you said.
         For one, I’m 46 years old, an active AMA member, and not a stupid rich kid. FPV is here and it is more safe than my nitro models. I know this because I fly FPV. I researched this perspective of flying for 8 months, built my first rig with good equipment and have flown for 2 years with ZERO incidents. Let me tell you this again: ZERO incidents. FPV flying is a lesson in safety, preparedness and accountability just like my nitro models. I truly hope that one day you will see that this is safe and enjoyable and in no way “ruins the hobby for everyone!……” This actually invigorates the hobby.
         Ignorance breeds fear DAY. FPV is nothing to fear.

   2. I have been involved for 30+ years my self. What does the cost have to do with it? As if $3500 for a multi rotor is more than a tricked out TREX 800E Pro? or turbine Jet? Hell, the cheapest Jetcat turbine is $2995.00 and that’s just the engine… https://www.sitewavesstores5.com/mm5/merchant.mvc?Screen=PROD&Store_Code=JetCat&Product_Code=P20-SE&Category_Code=TURB

   3. I am in total agreement with ron … the feds would rather C.Y.A.’s than attempt to deal with the ” common Sunday flyer “. Let’s hear from the folks who supply up to 6 or 8 electric motors and speed controls for each of these multi rotor craft.

   4. I’m sorry but in the 60’s did the guys flying Control Line airplanes say that those Rich Kids with their 499.99 Kraft 4 channel radios (Oct 1963.. look it up its quite interesting, https://www.rchalloffame.org/Exhibits/Exhibit36/) are going to destroy the hobby.
      499.99 was $3,825.37 in todays dollars, https://www.dollartimes.com/inflation/inflation.php?amount=5&year=1963
      No, people and the government were more sensible then. They didn’t file their RC planes into the crowded airspace. And the government didn’t ban them because they thought they might.
      I’m sure if the government doesn’t shut all model flying down, that in the future “Model Aviation” will have a few pages dedicated each month to line of sight flying as they do now for Control Line and Free Flight.

5. I’m a long-time AMA member (30+ years), and although I have mixed feelings about the fact that anybody can buy a drone and fly it anywhere he pleases, I believe Brent has struck to the heart of the matter: This is about FPV. The FAA has essentially made it a federal crime to fly a model airplane via FPV, and the agency has narrowed the definition of a model aircraft to make it easier for the FAA to regulate unlicensed drone operations.

   I suggest the following reading for anyone wishing to understand the entire picture:

   1) FAA Advisory Circular AC 91-57 (09 June 1981). “Voluntary” guidelines for model airplane operations. Establishes 400 feet as the ceiling for model aircraft, and “suggests” notification of airport operators or air traffic control if flying within 3 miles of an airport. See rgl.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular.nsf/0/1acfc3f689769a56862569e70077c9cc/$FILE/ATTBJMAC/ac91-57.pdf

   2) 72 FR 6689 – Unmanned Aircraft Operations in the National Airspace System (13 February 2007). References FAA Advisory Circular AC91-57 in a “Rules and Regulations” policy statement, thus elevating the content of the “Advisory Circular” one step toward the status of a set of regulations. Establishes the clear division of unmanned aircraft into three categories (public, civil and model). Reiterates that a model aircraft “should” be flown no higher than 400 feet. See http://www.gpo.gov/fdsys/pkg/FR-2007-02-13/pdf/E7-2402.pdf

   3) FAA Modernization and Reform Act of 2012 (14 Feb 2012). Elevated the suggestions contained in the FAA Advisory Circular AC 91-57 to law. Establishes into law the FAA policy that “a model aircraft is an aircraft.” Extends the “permission zone” around airports from 3 miles to 5 miles. Establishes a requirement that a model aircraft must be flown “within the visual line of sight” of the operator, which sets the stage for prohibiting flying model aircraft via FPV. Also, interestingly, establishes a requirement that a model aircraft must be flown “within the programming” of a national organization such as the AMA, which would imply that all model aircraft pilots must be a member in good standing of such an organization. What does this mean for park flyers? See http://www.modelaircraft.org/files/HR658_020112.pdf

   4) FAA Interpretation of the Special Rule for Model Aircraft (18 June 2014). Flatly states that it is the FAA’s position that the Act precludes the operation of a model aircraft via the use of “vision-enhancing devices, such as binoculars, night vision goggles, powered vision magnifying devices, and goggles designed to provide a “first-person view” from the model.” Also makes it clear that the FAA can enforce a number of regulations in any case in which the FAA deems the operation of a model aircraft to be unsafe, regardless of whether or not the aircraft otherwise meets the requirements of the definition of a model aircraft, and furthermore, establishes the FAA’s authority to regulate model aircraft if a regulation concerning aircraft in general happens to include them. See 02b954f.netsolhost.com/docs/model_aircraft_spec_rule.pdf

   1. It is always the criminals that get the lawful people in trouble, in the UK we had two authorised gun owners go on separate shooting sprees, the government banned all guns except shot guns and single shot rifles. It is the same with modelling, you can go out and purchase a camera carrying quad copter and fly where you want, belong to no association or club and break every law there is regarding flying unmanned aircraft, the FAA seems to see this as uncontrolled AMA members, if they impose their strict regulations on AMA members who is going to police the gung-ho cowboys doing what they want when they want.

6. If you keep your model in line of sight like has always been the rule, there is no problem,,, and to keep it in line of sight, you can’t be wearing goggles!! What is the big problem?? We just have a new group of poor little idiot rich kids in the FPV community , that are going to ruin our hobby for all of us. Forget the FPV garbage and fly like we have always done! Get over it, you cry babies!

   1. All too true. Along with the “FPV rich kids,” and overreaching government policy we can add YouTube, and the plentiful “watch this” culture that frequently displays our hobby beyond the edge of common sense.

   2. Ah yes, lets blame the rich kids…. What a bunch of bull. I can buy a Mobius camera and a 5.8ghz transmitter for about a hundred bucks, throw it on a pizza box and fly it around all day. Your falling for their Divide and Conquer strategy. I will forget your condescending attitude towards anybody who doesn’t fly the way you want, you must be some crybaby stick builder.

      Think about this, Making FPV illegal makes the whole SUAV INDUSTRY illegal. This means that any small business trying to develop a system will not be able to compete with the people making the DRONES THAT KILL PEOPLE. The Boeing and the General Atomic’s of the world are laughing with delight!! We just outlawed ALL the competition. Oh WAIT the government will still be flying Camera Platforms, but we the people, nooooooo we cant be trusted with a two pound aerial camera system. If your worried about your government spying on you, don’t think you should be able to spy back a bit? We have privacy laws on the books that can be enforced be it for a peeper with a telescope or a UAV.

      If your really worried about privacy take your SMART PHONE out of your pocket and throw it in the toilet for a few minutes, then take it out and feed it to your garbage disposal. You are carrying a microphone and a camera system that can be turned on at will by anybody with the proper app. Do your research.
      As for YOUR version of the Hobby.. The FAA just bent you over without lube. They just outlawed any competitions you are planning because if anybody gets any compensation for flying a model aircraft they are now a criminal. Should they decide that is a felony, you the person who talked to your buddy and set up the competition are now Co-Conspirators in the furtherance of that crime. ALL competitions are now illegal since they are set up to provide a financial or material gain to a person or persons for flying a Model Aircraft.

      Don’t let them divide the hobby into the RICH KIDS vs the cranky old curmudgeons! This is much more than folks flying FPV for fun, it is Scientists being able to research remotely in the jungle. Archaeologists being able to use UAV’s to discover new dig sites. It is police and firefighters being able to do their jobs more safely. It is farmers being able to monitor their crops for disease and other problems. And yes finally it is the ability to excite the imagination of flight in a young persons eyes. One who probably looked into the hobby and saw it full of angry old farts who hate kids and shun anything new.

      Take a good look around you. Your hobby is GROWING only because of FPV and Multi-rotor. If you can’t see that your not safe to fly LOS cause your BLIND. Local Hobby Shops are dropping like flys. The ones that are surviving are stepping up and selling Multi rotors and Foamies to a new generation of people who have a much greater vision of this hobby and this technology that the old school “Fly like we have Always Done” crowd will ever have. THE AMA should be congratulated for trying to help make this new portion of the hobby safer and enjoyable by more people, instead of crying about the good old days when kids were poor and you could look down your nose at them. YOU and your attitude is what is killing this hobby. Instead of calling em rich little idiot kids, how about instead you start a FREE Multi-rotor training Class to make sure they do it RIGHT and SAFELY. Put up flyers at your field, ALL your LHS’s (if you have any left) and embrace the technology. That is what the AMA is all about, not getting into class warfare and snotty comments.

      1. OUTSTANDING !! Very well said Matt !

      2. Well said, I agree with everything you say in this comment.

      3. Excellent response MATT.

      4. Good post! Well said!

      5. great post

      6. Agreed Matt, well written!

         But I don’t feel too angry at the ignorant words of the curmudgeons. I understand they are responding in much the same way the FAA is responding, with fear of some thing they have not taken the time to understand.

         Perhaps with this sort of encouragement, they both will do a little more research and realize the error of their thoughts… we can hope anyway 🙂

      7. I agree with Matt. Just look at RC Groups, the forums with the most viewers and participants are multirotor. And I own and fly a DJI F-450 quad, NAZA/GPS and this technology is really fascinating. With a Go Pro hanging off the front it takes good video/stills too. But I fly it strictly LOS.
         I am more concerned with the way the FAA have expanded the altitude limit from 400 feet within 5 miles of an airport, to a 400 foot restriction EVERYWHERE.
         This is a serious restriction for those of us who fly sailplanes (I have an Xplorer 3800 ) various hotliners, and many smaller sailplanes that can zoom above 400\’ in a few seconds!
         What about scale aerotow meets? I was invited to one last fall and it was great. 400\’ for 25 foot scale sailplanes? That would be a joke.
         So lets all stand together. This 400\’ restriction will really kill much of the RC flying I fly.
         Incidentally model aircraft got me interested in flying as a career many years ago. I flew for a major Airline, for 32 years, and hold type ratings on DC-9, B-767 and Airbus 320/321 aircraft.

7. The FAA definition of “aircraft”, as defined in U.S.C. 40102; and 14 C.F.R. 1.1 is seriously flawed as it applies to model aircraft. It does not consider the size, weight, or means of control of an aircraft, which is paramount when considering rules governing remotely controlled model aircraft. Model aircraft are a mere fraction of the size and weight of full-size, human-carrying, aircraft.
   Any FAA licensed pilot can attest to the fact that the skills and knowledge required to control an RC model are entirely different than those required to pilot a full-scale aircraft. The operation of full-scale aircraft is conducted from within the aircraft as opposed to the operation of remotely controlled model aircraft which are operated outside the aircraft.

   Governing model aviation by Part 91 is comparable to governing automobile traffic by those same rules. Part 91 is focused on the prevention of injury and/or death and property damage. The odds against a model aircraft causing either is astronomical.

   Another major problem with governing the operation of miniature model aircraft under Part 91 is SCALE. Model aircraft do not carry humans and are MUCH smaller and lighter than full scale aircraft. Part 91 rules are grossly inappropriate for governing model aviation.

8. The FPV statement is an over-reach. The FAA will see more lawsuits from industry and media. The loss of FPV capability will ensure that US business and media will be left behind the rest of the world. This will be challenged. Progress is never made without manageable risks. The FAA denying FPV without a clear and timely path to some type certification is not acceptable.

9. I am allowed to own a gun (in most states…for now). I am allowed to go out to a range, or to a gun club, even out in the country (in some states…for now) and shoot it. I can legally use it to hunt game. There are TONS of laws on the books restricting the use of guns. For example, I can\’t use it to shoot another person unless it is in self-defense. That doesn\’t stop many, many people from using guns to rob, kidnap, coerce and kill others. Laws and rules of this nature do much more to stifle freedom of the law-abiding than they do to protect the innocent. Criminals are going to act like criminals…regardless of the FAA\’s interpretation of these rules. If the FAA is trying to wrangle the verbiage to stop the use of FPVs in terrorism, the terrorists aren\’t going to give a rat\’s patootee how the FAA chooses to enforce these rules. I would rather see the language changed to forbid the use of model aircraft in the commission of crimes, or with the intentional to cause harm to persons or property.

   The innovations in model aviation have come largely through our hobbyist endeavors, and through the developers and vendors who are satisfying the hobbyist demand. One of our local law enforcement groups is using FPV drone equipment that is readily available to the general consumer through mainstream hobby outlets. I see no reason for the FAA to restrict the use of model aircraft in business endeavors. Again, this will fuel innovation and development of new technology that has the potential to benefit us all.

   1. Wow, a reasonable post! Thanks for that. Local LE is using it to SAVE LIVES. Lets not outlaw it because somebody feels like they might be spied upon by persons unknown. If that is the case get rid of your cel phone since that is a Wireless BUG that can be turned on at will with a keystroke if you have the software.

10. The AMA should have never given its ok to FPV flying in the first place. What did you expect.

    1. The AMA did not give its OK to flying FPV, they don’t have an authority to regulate anything at all. They can kick you out of the organization but they lack any ability to REGULATE anything.

       The AMA seeing that there were indeed a lot of untrained yahoo’s out there doing stuff that bordered on criminally stupid decided they better try and set some Standards and some recommendations for safe operation because if they buried their heads in the sand and did nothing the problem would not go away and when a major incident did happen, everybody would blame them for not stepping in and helping remedy the situation.

       The AMA should be commended, because they ARE attempting to help the situation, and the FAA in reinterpreting the rules in a grossly punitive manner, is acting in a reprehensible and despicable manner designed to drive a wedge in the hobby.

       I believe training should be required, even if it is a half day seminar on safe opperations, and a discussion on how dangerous even a foam EDF aircraft can be at a hundred miles an hour. Outlawing FPV removes the ability for INDUSTRY and Farmers to use this technology. You keep Search and Rescue organizations from using it to save lives, and a hundred other applications. Don’t throw the baby out with the bath water.

11. The FAA has more important issues to deal with,leave us alone,and weed out the unqualified pilots flying airliners around country on drugs or booze…..

12. Leave us alone,the FAA has more pressing issues to deal with,weed out the unqualified pilots,and the drug or alcohol abusers flying around our skies with thousands of people on board!!!!

13. A lot of great points here. Many had been warned early on, business and incomes are being affected by the rules put forth by FAA, they are making criminals out of any person flying and getting paid for a video/photo.
    My biggest problem, Why should a farmer not be able to use the available technology to provide better crops, make more money and have an overall safer and more productive farm than in years past. We have unmanned vehicles on the ground, cars, tractors, trains that are in contact with thousands of people every day. You would think FAA would be somewhat educated about the technology before making criminals out of “Drone” pilots.
    Line of sight vs FPV?
    Safety First, We have height restrictions, I can see where they will stand hard on this one unless they enforce some form of “FPV Pilot Training” for UAV’s

14. The FAA has more important issues to deal with, other than trying to restrict an already severely restricted sport.. Spend more effort weeding out the many marginally
    qualified pilots flying around the country on drugs or alcohol with the lives of thousands people…….

15. According to a strict interpretation of this rule, you need permission to play frisbee within 5 miles of an airport. A frisbee is
    (1) capable of sustained flight in the atmosphere;
    (2) flown within visual line of sight of the person operating the aircraft; and
    (3) flown for hobby or recreational purposes.

    This is an HUGE overreach of government. I also don’t understand why I can check on my “recreation” crops with a camera mounted on my plane, but if I want to sell them, I’ve just broken the law. How does selling my crops make my plane unsafe?

    1. No frisbee I have ever thrown has been capable of sustained flight. Also, I don’t “operate” it since I have no control over it after I throw it. Don’t get me wrong, I’m not exactly happy about this, but your comment is a bit of an exaggeration.

       1. No, LOL I think the exaggeration is on the part of the FAA. Your definition of sustained flight is relative. Is it based around flight time? Is a 3D heli that only flies for 5 minutes sustained flight, how about a DLG that does not catch a thermal? Agree on the FAA over-reach. That is an understatement and from the posts I am seeing they are starting to divide the hobby into the “keep it the way it was, we hate new fangeled stuff” crowd and the innovators and technology hounds that keep moving the hobby forward. That works for the FAA just fine, divide and conquer. This new interpretation destroys the hobby, no more competitions, Sponsored Teams, are a thing of the past. How many of us could afford to fly 3D helicopters and train to a competition level if they had to buy all the parts themselves at RETAIL. No, Cant have a discount, that would be sponsoring the flyer by allowing them financial GAIN. NO, this is a disaster for ALL of us in the hobby and all these posts pointing fingers do nothing to change that. We need to stop this at once. We need to band together and embrace the new, and teach the value of building skills and a safe operating ethic for everyone. One post blamed it on the “Rich Spoiled Kids who are Cry Babies” Really? that is the kind of attitude that drives people from this hobby. We are poised to help our hobby explode in popularity and instead we have people looking down their noses on anybody who buys a ready to fly foamy instead of stick building their model.

          Stop with this elitist bullpucky. The Genie is out of the bottle kids, and wishing and bitching ain’t gonna put it back in. Instead of blaming those dang kids, how about offering free multi-rotor safety lessons. How about having a quiet calm discussion with someone about the hobby and dare I say it, maybe even put on the goggles and see what the excitement is about.

          YES multirotor and autopilots make it so virtually anybody can fly an RC aircraft and the old barrier of crushed match sticks on the ground is GONE forever. Good!!! As thousands and thousands of new people step into the hobby it is an opportunity and in fact a moral imperative that we help them be as safe and responsible pilots as WE are. If we don’t then we get what we deserve.

       2. oh no sir he is in complete control with his comment the government will not discern between a plane and a Frisbee in their eyes the law is the law we all have seen ridiculous interpretations in the past and they will continue in the future…think about it.

16. Most has been covered in the above comments and I am in full agreement.

17. To me, FAA-2014-0396 is another “DO AS I SAY-NOT AS I DO” intrusion into our private lives and activities this must not stand!

18. These rulings are definitely too far reaching for the average modeler.

19. Who was it that said, ‘This is not your father’s modeling hobby anymore’? The technology is rapidly advancing, as we all know. This is enabling many thousands of new hobbyists to just ‘buy and fly’ sophisticated aircraft. Many of these newcomers have zero experience, training or understanding about piloting, air safety, or the rules. Too many of them are flying in ways that endanger manned aircraft. For example, some FPV pilots are flying their aircraft way beyond visual line of sight and at altitudes that threaten real aircraft. This is simply a fact, unfortunately.

    These increasing dangers will result in new restrictions on the hobby. The FAA’s safety concerns will take precedence over hobbyist’s concerns, as they must. And it’s concerns about safety are driving the FAA’s latest moves, not some sinister motives to harm the hobby.

    IMO, the AMA needs to work with the FAA on the growing safety problem, rather than fighting with them. It’s a losing battle. Better to face the issues head-on and focus on ways to improve safety, as the AMA has done in the past. The modeling community would be wise to pull together to face this problem directly and form an action plan.

    If and when a model aircraft causes a serious accident, this hobby will suffer greatly. Better for this community to become proactive now and try to avoid a calamity, IMO. There have been some excellent blog discussions around this very idea on DIYDrones lately. There appears to be a broad consensus that a proactive approach is needed.

    Regarding the FAA’s authority over model aircraft, the ‘interpretation’ document spells out their legal position. While the AMA argues that model aircraft are not subject to the FAA regulations per the statute, the FAA argues that in fact they are under certain conditions. Specifically, a model aircraft falls under the authority of the FAA if/when it operates in a manner that is outside of criteria spelled out in the statute. So, for example, flying FPV beyond the visual line puts the operator and vehicle under the authority of the FAA, since it is operating outside of model aircraft criteria.

    The FAA has clear authority over air safety. And risks to safety are increasing. Who do you think will come out ahead in this argument?

    1. The AMA HAS been working with the FAA, they have been for YEARS. The FAA completely blindsided the AMA and the general public with this reinterpretation of the rules.

       I totally agree that a proactive approach is needed, and that they and the FAA need to work on the growing safety problem along with manufacturers of multi-rotors and other FPV systems. I agree that safety comes first, I am a pilot, been one for 40 years. I also think that the modeling community has a poor record of being a welcoming and open place to learn and grow. The Cranky Old Fart posts on this are a prime example. I have dozens of friends that shun the AMA and clubs because of the COF’s and their condescending attitudes.

       Safety of manned aircraft is always paramount, and to that end people have to be trained and educated to make sure they don’t endanger the public, be they on the ground or in a Cessna 172 at 3000 feet, or an airliner on approach to LAX or SFO.

       To that end manufacturers are already starting to add Geo-Fencing and altitude restrictions to their flight controllers, the DJI line has that from the NAZA thru the A-2 and USR and many others are following suit. They also have it so the unit will have restricted flight envelopes near airports, and in fact will not fly at all within certain distances from major airports. This is in accordance with guidance from European agencies and countries where not only is FPV legal, commercial operation of a SUAV is as well. Lets look at their model, look at their Certification procedures for operators, and come up with a reasonable and workable solution for all concerned. Personally I agree that people should be trained to be safe, responsible flyers, but this hobby is absolutely famous for it’s standoffish attitude. It even pervades the Local Hobby Shops, where sales people make fun of multi-rotor people to their faces. They feel superior because they fly LOS and YOU DON’T.

       Don’t get me wrong, there are plenty of friendly and helpful people in the hobby, but it only takes a couple of C,O,F’s to send a new person packing. We are poised to get a whole new generation of people off the couch and away from their game consoles, lets welcome them and teach them and look at the hobby through new eyes. Lets work together for the betterment of all.

       1. Very well said, Matt. I agree completely. And it’s good that model aircraft are being sold with built-in flight restrictions for the sake of safety. Those factory settings should be made difficult to override, IMO. I the case of some model aircraft being sold today, turning off the geofence requires nothing more than a button flip. Unacceptable.

20. I have always enjoyed watch all kinds of RC aircrafts. RC modeler build and fly for fun they try different kinds of aircrafts I think it great that they put a camera on them and get the feeling that they are flying threw their model witch is Great please don\\\’t limit them from having their enjoyment by putting more restrictions on them please don\\\’t treat them like some one who is going to hurt some one unless there is evidence to prove it. Let have our fun with all our aircrafts that we build or fly.

21. These are valid concerns and the AMA make good points, but we need to keep the FAA from banding FPV flight also. AMA rules provide a safe method of flying FPV in my opinion. FPV is a big part of the future of model aviation, and it should be not banned. I would like to see the AMA work with the FAA to help them see that guidelines on FPV flying should come from people and AMA and not the FAA. I hope that everyone that has a passion for flying stands together to supports us.

22. I think that First Person View is a terrible idea and should be banned. There simply is not enough situational awareness to make this safe. If you really feel you need to fly in this manner, take flying lessons and become a real pilot.

    1. Believe me, I would if I could afford it. Flying is expensive, and people who hobby fly (who can’t afford to put in a lot of time) are MUCH more dangerous than any FPV pilot. Being a model pilot, you already know this, I’m sure. FPV flight is as close to ‘the real thing’ as I’ll ever see, and I make a good living.

    2. From your post I sense you have very little experience in most of the applications of FPV, and only judge it by the folks who fly at any altitude they feel like and in blatant disregard for the safety of others. MOST of us keep to the recommended 400 ft and below ceiling and follow the other safety policies and recommendations put forth by the AMA and heartily endorsed by the FAA. If I am flying at a hundred feet with a spotter in clear air over the countryside, away from an airport, the only manned aircraft I should would encounter is someone flying illegally below the 500 foot minimum AGL specified in the FAR’s and taught to every pilot from day one.

       Banning the technology is not the answer, anymore than telling people not to smoke will get them to quit. Education is the answer and taking steps to make the activity safer. I have been a pilot for over 40 years, I love flying FPV because I get to see things from the air in a SAFE and unique manner. I can hover over a river and look a beautiful scene, I can fly over a tree line on a mountainside and enjoy the beauty of a sunset, and RECORD that beauty for millions of other people to enjoy who can NEVER afford Ground School let alone the rental cost of even a Cessna 150.

       Your assertion that the pilots of FPV aircraft are the only ones who enjoy the flight shows you have only the narrowest concept of the hobby and it’s global reach. Skilled FPV pilots and Cinematographers have created hundreds of not THOUSANDS of amazing videos allowing the world to see earth from a different and frankly beautiful perspective.

       If you want to play statistics, Poorly trained and out of practice doctors flying Bonanza’s and other General Aviation aircraft have killed SCORES of passengers and even the occasional person on the ground, and yet someone Flying a 2-5 lb RC aircraft that will failsafe if it looses control signal from the operator and return to home, is somehow more dangerous?

       Trained Pilots Kill themselves and others all the time. Tired Pilots on an Aero Mexico flight flying into LAX failed to see and avoid a general aviation pilot and rained death and destruction down on a neighborhood a mile from my house. The General Aviation Pilot was flying VFR and had a new TCA chart which he had just bought, which was WRONG. The FAA chart still showed a Natural Gas Storage Tank as a VFR landmark that had been gone for over a YEAR. This was a known landmark in Long Beach for decades, and had been torn down to put in a new shopping mall.

       The media was quick to blame the GA pilot but the investigaton showed that the Aero Mexico flight was 400 feet lower than directed, and ran over the GA pilot from behind. Since the Aero Mexico flight was under controller supervision and had been advised of the aircraft, they were in fact at fault. The GA pilot could not see directly behind him and had no way of knowing the DC-9 crew was going to decapitate him through their lax attitude and sloppy flying.

       Being a trained pilot does not relieve you of the opportunity to be an idiot. Anymore than being a driver training instructor can prevent you from getting a DUI on the way home from Dinner.

23. I would suggest that all responses to the FAA be copied to your congressman and senators. I was involved in responses to our government when the FCC tried to change our frequencies many years ago. The only reason it did not happen was the responses received by your congressman and senators.

24. I have flown R/C model on many of the Air Force Bases I was stationed during my 28 years in the service. The rules were to simply call the tower, which was manned 24/7, and advise them were you were and that you would stay below pattern height. Time passed and I retired from Pease AFB, NH where I ran into the deputy FAA administer. He advised me ALL model flying was prohibited because he had flown models as a kid and KNEW how dangerous the were. He sited damage to planes, espionage(!)and, in general, too much trouble to keep track of as additional reasons. MNPrc9

    1. I agree with you Dennis, There are plenty of RC fields on Air Force bases and as you say, they have been there for DECADES. I have never heard of a SINGLE RC aircraft vs Air Force asset incident. I can be pretty sure that if one HAD occurred, the Air Force would have shut down each and every one of them in about a DAY.

       I Flew just last week at a field on Mather Air Force base. Yes, Mather is decommissioned now and handles air freight, civilian traffic up to and including a guy who owns a T-38, and State and Local Law Enforcement rotary and fixed wing aircraft. This RC field has been here through all of that. No menace to air traffic. Just a bunch of military and later civilians having fun. Pattern Altitude at most fields is 800 to 1000 feet above the field, we fly at hard ceiling of under 400. The only hazard we ever saw was wake turbulence from a 707 or other heavy drifting a mile or so over to where we were flying. That makes for some interesting flying!

       The FAA administrator you talked to must have been one of those guys with large piles of match sticks in a heap on maidens. And after that experience and the Cranky Old Fart syndrome that tends to pervade the hobby he probably had a bad taste in his mouth his whole life. Wonder what he would feel like if somebody put the goggles on him and showed him the beauty of the hobby from a different perspective.

25. Dear AMA,
    After reading the FAA bulletin and trying to master the legalese, I believe that the AMA should draft a template as AOPA does for its members
    It’s not that members (me) couldn’t figure this out, but why not provide a template from your legal team that makes the response more pertinent and easy to understand
    We can then add any additional comments but the meat and potatoes would be in the proper context.
    Thanks
    Andy Garello

26. My background: Commercial Pilot, Flight Instructor, Instrument Rating, Multi-engine rating, journeyman Radar Air Traffic Controller, model airplane builder from grade school until present age of 73.

    The FAA has taken a somewhat hands-off approach to Experimental Aircraft, Sport Pilots and Ultra-Light Aircraft. Even your Cessna or Piper aircraft is not regulated under Visual Flight Rules unless within positive control airspace.

    The practice of visual control and separation of aircraft has proven as safe or safer than any other, and enables a much higher volume of traffic. Even tower controllers use visual separation by pilots.

    Therein lies the problem of FPV flight. If the remotely controlled aircraft leaves the sight of the pilot or safety pilot, half or more of your vision is lost. I do not know how to effectively address that issue to comply with the safe separation of aircraft and aerial vehicles under the standard Visual Flight Rules. Instrument Flight Rules?

    1. Bob, this issue of RC aircraft leaving the sight of the pilot is non existent for all practical purposes. At that point , it becomes another type of defined aircraft, possibly defined as a remote drone or guided missile. So lumping together all types of radio control aircraft does not make good sense. I also have been in aviation all my life and flew RC aircraft for over 50 years, RC aircraft are flown in uncontrolled airspace under 500 ft , no collision avoidance problem exists . We don’t need another 100 pages of FAA ill defined regulations by well intended government bureaucrats, for flying private RC aircraft. For the future of our hobby, let’s hope this issue get’s solved with common sense.

       1. Thanks David, While I can see Bob’s point, and I agree with most of what you post, in reality, flying under 400 feet with FPV goggles and a good TX is is not as you allude, a guided missile. The platform is still under my control even though I would indeed have a hard time figuring out orientation with the naked eye. As I said it is not a guided missile, it is an RC aircraft with a competent pilot still in the loop who has complete control, and is being flown in a predictable and concise manner.

          I hasten to point out at least with all the multirotor I fly, if that control loop is compromised my RC aircraft goes into failsafe and utilizing the GPS on board returns to my takeoff point and lands within a foot of where I enabled it. Compare that to someone with a turbine powered F-4 Phantom ripping around at a couple hundred miles an hour, who for whatever reason has a control issue. THAT is an UNGUIDED and potentially Lethal Projectile. Even a Foamie EDF is not something I feel comfortable facing down, I have seen what one of those can do. Personally that is a lot scarier to me than a 4 lb multi-rotor sitting in a hover, and when it runs out of battery initiating a CONTROLLED decent to the ground and shutting down,

          The AMA has sanctioned and continues to sacntion competitions where pilots fly 3D helicopters both electric and Nitro in insane maneuvers through which they are on the very edge of controlling their craft and they do it 30 feet from themselves and their spotter. they do this with 700 mm carbon blades turning at in excess of 2000 RPM! Personally that is in my opinion juggling chain saws, where a malfunction of the saw will cause it to fly uncontrollably in whatever direction the laws of physics and the limited if any control the pilot may have left will force it to go.

          While I can’t cite any injuries at AMA events such as XFC these 3D helicopters HAVE resulted injuries, a Team Sponsored pilot was tragically killed by his helicopter while practicing at field near his house in New Jersey for an upcoming event. Personally I find these aircraft and the manouvers they perfom un-nerving, and I land and leave the flight line anytime someone has one up.
          I agree that we dont need an extra hundred pages of ill defined regulations or to be put under the FAR Part 91, We are not an airline and we are not carrying passengers. I do believe education and LIMITED additonal guidance from the FAA is warranted, and that the AMA, the FAA, the Manufacturers and other interested parties should be working together to make it a safe and enjoyable hobby. Let’s hope they can do this, and do it soon.

          1. Matt,
             The fatal flaw in your argument is the term “competent pilot”. Who determines when a pilot is competent? (pshhhhhhh …sound of a can of worms opening)

27. Regarding the FAA Interpretive Rule for Model Aircraft docket number FAA-2014-0396

    Over the past 75 years of the evolving hobby of flying model aircraft there hasn’t been one serious accident resulting in death from an AMA member. The FAA is ignoring the exemption that Congress spelled out in the law. The Federal Aviation Administration may not promulgate any rule or regulation regarding a model aircraft or an aircraft being developed as a model aircraft,…” if established criteria are met. I believe if the FAA ignores the law as it has been written that the AMA will need to take this up to the Supreme court to fight their authoritarian law. There are much more serious issues regarding the safety of Airlines regarding pilots health, maintenance, homeland security that the FAA was designed to keep the public safe in the skies not radio controlled aircraft which haven’t harmed anyone like airline accidents , terrorist attacks such as 911 etc.

28. I have had intermittent AMA membership over the past 48 years (probably between 25 and 30 years total membership under at least 3 differnt AMA membership numbers) and appx 8 years as a Life Member.

    Part of FAA\\\’s new interpretation is a reaction to a court case where an idiot got away with creating a significant public safety hazard and had his fines overturned due to FAA not having provided definitions that are in this new document.

    Part of it is reaction to evidence that AMA really has no control over the unsafe antics of people who are not AMA members, evidenced by youtube videos of grossly unsafe FPV flights.

    Part is possibly due to further youtube evidence of AMA CDs and other \\\”elites\\\” ENCOURAGING violations of its own safety code rules at major events…

    Cost of entry into the operation of miniature remotely controlled aircraft has dropped and ready to fly complete systems are now far cheaper than just the kit to build a beginner\\\’s model used to be. This has helped the hobby through allowing more people to participate but it is also hurting the hobby by allowing people to enter with no real effort in producing or preparing the models for flight. What most long time modelers see as a sport many newcommers see as toys.

    Relatively recent techological advancements (FPV, 2.4 ghz spread spektrum and even more advanced radio links, cheap autopilot and stabilzing systems) have created the ability for people to do STUPID STUFF that was impossible for the average modeler less than 10 years ago. Without actual laws to restrict those actions, AMA has very little capability to influence the actions of people, especially people who are not members of the organization.

    Then there was the clause in the FAA reauthorization legislation which was an attempt to restrict FAA from excessively regulating the hobby. You do not step on a snake\\\’s tail without expceting to get bit by the snake…. That legislation was not written clearly enough, in failing to define what a model aircraft is and what operating limits needed to be imposed to differentiate hobby grade modeling from UAV/UAS systems. So the FAA has decided to make their own definitions.

    The FAA is reacting to a NEED for regulation that does exist. The strongest penalty possible for the AMA to impose is to revoke membership and/or revoke the \\\”site insurance\\\” at some club\\\’s field if the situation is bad enough to warrant that action. (I think the site insurance revokation has been done ONCE in the history of AMA) That potential has NO EFFECT on the vast majority of people flying miniature aircraft because AMA members represent a miniority of the people who fly RC models.

    The primary response when an AMA member points out safety infractions to a non-AMA model flyer is… \\\”F\\\” the AMA.

    You don\\\’t want to hear it… but there it is.

    1. I couldn’t agree more with everything you’re said. There is a real and growing air safety problem due to model aircraft flown by stupid operators. The FAA must and will respond. The AMA should join the FAA and deal with the safety issue by generating ideas and initiatives. Fighting the FAA is a waste of time and a losing battle. Air safety concerns will trump hobbyist’s concerns every time.

       1. I am in complete agreement with both of you. We need meaningful and sensible rules regulation. I do find disturbing the Snake Analogy, since the FAA is supposed to be fair, and act in a reasonable manner to insure the safety of the flying public, not lash out because it is pissed of it got it’s hat handed to it in court. Lets hope we can get to a reasonable set of regulations and hopefully get the AMA and ALL the clubs to do more to bring the Non AMA folks into the fold. Yes, some will never join, and to be honest I flew for years as a non member, but I decided I better be part of the solution, and support the organization that is looking out for the hobby. Otherwise I have nobody to blame but myself if we get jacked around by the FAA.

29. FAA “knee jerk”reaction handled with a”blanket indictment”

30. Did no one see this coming the AMA should have never supported FPV. Does the AMA think they can change how the FAA thinks? The FAA is right this time.

31. Did no one see this coming the FAA had to do this. The public does not want drones flying around there homes or business. The AMA should not support FPV.

    1. First of all they are not Drones, second of all the laws against peeping and invasion of privacy are already on the books. A lot of businesses WANT to use SUAV’s to help them do their jobs. Pipeline and powerline inspections, Flare Stack inspections at refineries, hundreds of other applications for the technology are you suggesting we throw all that away because some meat packing plant in Texas got caught with gross pollution violations by a reporter with a UAV?

       The AMA supports FPV to help FPVers learn to fly safely and responsibly. If you didn’t like BMW drivers would you decide they cant have training? Would you then be surprised when BMW drivers had more accidents and killed more people?

       Use common sense, require Geo-Fencing and altitude restrictions on flight controllers, have AMA and local clubs provide free training and help on making sure they fly correctly and safely. If you find some miscreant on YouTube flying at 3000 feet in controlled airspace then the FAA should have the authority to prosecute them and the case should be pretty easy since it is usually pretty apparent from their post and video they are above 400 feet. Common sense and education.

32. Airspace needs to be safe, not exclusive. We all need to be sure that we conduct ourselves with the same professionalism as a aircraft pilot. We should be concerned that pilots, passengers, spectators, sport fliers, etc. are safe, and not deprived of the opportunity to fly.

33. Several years back I made the comment to friends that we are our own worst enemies. There is always someone in the crowd who has to have the biggest, fastest, most expensive model pane on the field. is it any wonder that someone has finally said ‘gee that thing could carry a bomb’, and the Feds are off and running.People use the word ‘Drone’ like it is something sinister. All of our RC models have been drones since the beginning. Our problems didn’t start until the ‘mine is bigger than yours’ ‘mine cost more’ ‘I need a bigger trailer to haul my planes in than yours’ attitude took over. Now the Feds are on all of us.

34. […] of Model Aircrafts (AMA) is asking for hobbyists or those interested in jumping into RC flight to contact the FAA and express their concerns over this new ruling. You have till July 25th, 2014 to make your thoughts […]

35. Comment: Congress has passed legislation that establishes and defines the “hands-off” regulatory approach to be followed by the FAA when considering regulation of model aircraft used strictly for hobby or recreational use, if established criteria are met. The Federal Aviation Administration’s (FAA) response entitled, “Interpretation of the Special Rule for Model Aircraft” clearly ignores the intent of Congress and the wording of a specific law of the United States. In developing this document, the FAA has totally distorted the intent of a law that is very clear and unambiguous in its intent and purpose. The FAA’s Interpretive Rule establishes new restrictions and prohibitions on the operation of model aircraft, restrictions and prohibitions that were not in place previously. The FAA has decided that the operation of model aircraft may come under Part 91, again in total disregard for a narrowly focused law passed by Congress banning this action by the FAA. The FAA must accept the simple clearly written law that states in part, “The Federal Aviation Administration may not promulgate any rule or regulation regarding a model aircraft or an aircraft being developed as a model aircraft”. It’s the law!

    1. “The Federal Aviation Administration may not promulgate any rule or regulation regarding a model aircraft or an aircraft being developed as a model aircraft”

       Yes, that is one line from the statute/law. But you left out the phrase, “if established criteria are met.”

       If you read the FAA interpretation document carefully, you’ll see that they taken a clever approach to establish their regulatory authority. The approach is to interpret the definition of a ‘model aircraft’ as one that strictly operates per the criteria specified in the statute. So, for example, if a model aircraft travels beyond the line of sight of the operator, it is operating outside of the statute criteria and therefore is subject to FAA authority. In other words, you cannot interpret the law/statute by quoting just one line.

       I agree with the FAA’s approach, btw. And the FAA’s interpretations will likely will hold up against AMA arguments.

36. I agree with “Ramblin Dan” and his comments concerning: The expansion of the technology of model aircraft into business use and possible weapons of purposeful injury and destruction should be handled totally separate from “A Special Rule for Model (hobby) Aircraft.” Let the Hobby of Model Aircraft Flying be self policing as much as possible. I wlll also add that I’m not a beginner in the r.c. hobby. I have been active in the r.c. hobby for over 36 years, been a club officer, have my A&P mechanic license with the F.A.A., and been actively working in the regional airlines, for the past 15 years. I oversee “safety” in the airlines as a Q.C. Inspector and provide oversight for the maintenance operations.I also have been very active as an rc modeler with (3)A.M.A. sanctioned r.c. clubs over the years, in the states of Illinois, Tennessee, and now Indiana. All (3) of the A.M.A. r.c. clubs I have, and now belong to, uphold “Safety”, as their #1 priority, and this is very important for people to understand. The A.M.A. sanctioned r.c. fields and clubs, I have belonged to, also have taken the public’s safety as spectators, watching our club events, very seriously, also. It’s rare, but when a club member or nonmember is flying an r.c. aircraft unsafely & inconsistent with the r.c field/clubs rules/regulations, the clubs have always self “policed”, with the advent of a club safety officer, as well as each club member having a responsibility to maintain safety, at all times. I believe the F.A.A. is doing an excellent job, providing “oversight” for the Part 121 Airlines, and all “full scale” aviation businesses, airshows, and events. Additionally, I propose the F.A.A. regulate all large scale drones, of a certain large weight/size class, that are used for business, police, government,or homeland security agencies only. This is a hobby to be enjoyed, by anyone, who has an interest in it. I follow F.A.A. safety guidlines at all times in my employment. I fly r.c airplanes, for enjoyment, as well as the “social” aspect of connecting with people at r.c. clubs/events, in my personal time. The r.c. hobby is very safe, and I know all the fellow modelers out there, want to keep it the way it is. This is a very unique hobby, in that you have to have knowledge of aerodynamics, and have a technical aptitude. Not anyone off the street, can just purchase an r.c. airplane, and the associated equipment and go flying, successfully. The F.A.A. oversees full scale aviation, and should oversee; very large scale drones *(ie: business, government security businesses), and the A.M.A. clubs oversee the r.c. hobby, as it was meant to be. The r.c. retailers are already hurting from the bad economy, and family owned hobby shops have been closing their doors, due to lack of customers. Lets do what we can to improve the hobby, and make it more enjoyable for future generations, instead of hurting it.

37. While not being interested in any type of FPV flying at all I believe that those who are active in it should be held to a code of conduct as we watch this type of hobby evolve. Flying within light of sight, contacting a airport and a spotter are all great ideas & will keep the sport as safe as it can be. The use of a transponder with a unique marker could also add an extra element of safety as well. While I consider the sky a \”free\” space I also feel it should be safe for all who share it. Government regulation has many drawbacks but for purely safety reasons and safety reasons alone enforceable regulations have a place in today\’s society.

38. I TOTALLY AGREE WITH THE ABOVE CONCERN IN REGARDS TO FPV CATEGORY AND SHOULD BE A SEPARATED DISTINCT CATEGORY OF THE HOBBY REQUIRING SPECIAL ATTENTION SO HAS TO NOT TO INTERFERE WITH THE TRADITONAL BRANCHES OF OUR HOBBY REQUIRING A MORE ELABORATE CONTROL AND CONTROL SYSTEM TO PREVENT THE MISSUSE AND ABUSE AND UNAUTHORISED DEPLOYEMENT IN RESTRICTED AREA OF THIS TYPE THECHNOLOGY FOR UNDEFINED USERS OPERATORS AND SALE AND THECHNOLOGY TRANSFER SHOULD BE TIGHTLY MONITORED AS TO AVOID THE MISSUSE BY AN UNDEFINED ENTITY,FOR UNDEFINED PURPOSES AND BY UNQUALIFIED OPERATORS WITH UNKNOWN OBJECTIVES AND CREDENTIALS.

39. The FAA is clearly in violation of Congressional intent and the resolution of this problem should be relatively easy: AMA needs to sue. However, AMA is also not without fault. By supporting FPV it placed itself on a collision course with the FAA. Only the willfully blind could not see that this situation would result. In fact, AMA by its constantly “chasing the market fad” has wandered far from what it is actually supposed to be: an Academy. At one time it promoted a fulfilling and skills developing hobby by supporting building skills development. Now it promotes acquisition of RC ready-mades or of whatever commercially available toy that represents the latest gee-gaw fad employing RC. And now it has gotten itself and, supposedly, all of us in trouble for it. The FAA banning of FPV is a much needed action. It is too bad that it has to come about this way.

    1. Wow Scott, your playing right into their hands. Divide the hobby and you easily conquer them. Your attitude is why I left the hobby years ago. That I don’t spend weeks or months stick building some massively overpriced kit should not make me ANY less of a Member of the AMA than you. Your Elitist attitude is what drives people away from clubs and the hobby in general. It is clear from your post that you look down your nose at anybody and everybody who doesn’t “Stick Build”. Your rant on gee-gaw fads would be laughable if they were not so tragic. FPV is what is building this hobby. That people can experience flight without leaving the ground is wonderful and exhilarating. That the AMA saw that this was something they wanted to help make a SAFER and more acceptable portion of the hobby by putting out guidelines instead of burying their heads in the sand is very commendable. That the AMA is constantly “chasing the market fad” as you put it is called keeping up with the times. Not every person in this hobby wants to build a Scale Stinson, or a Scale Mustang. Maybe they want a DURABLE aircraft to learn on instead of kindling after their first mistake while learning. I can agree on one thing, the AMA should indeed sue. What the AMA should also do is cull its ranks of exclusionistic minded curmudgeons who only want what their version of reality contains. I mean have you really read your post? I see you in a rocking chair with suspenders and a corn cob pipe yelling at those dang kids to get off your lawn! Attitudes like you express are why this hobby is so small to begin with. I have had my fill of cranky old farts telling me my new newfangled thingamajig has no place in their airspace or at THEIR club. I am a member of a couple AMA Sanctioned clubs, and am a proud member of AMA BECAUSE they saw the handwriting on the wall and decided they had to help make this new technology work, because it was not going away. Making FPV illegal makes ALL aerial camera systems illegal, making cops and firefighters jobs more dangerous. Making people who have to throw on body armor and clear out Mexican CARTEL grows at gunpoint on public lands and private property that much harder. Now instead of them flying a UAV over the location and scouting it, they get to go in BLIND. All thanks to narrow-minded Luddites who can’t or won’t accept change.
       Please be sure to attend the next cops funeral in your home town and explain to the widow how you were just protecting somebody’s privacy. Explain to that farmer why he has to pay a Thousand dollars an hour to have someone risk their lives to scan his fields with a camera system when that same farmer could do it himself for the cost of about two hours flying time and put NOBODY at risk because he would be flying a SUAV below two hundred feet. The only aircraft below the mandatory legal limit of 500 feet should be a crop duster and I think if its his Field he should know if there is a duster scheduled. No, your attitude belongs on the wall, gathering dust with your stick built planes. Step into THIS century and embrace solutions not exclusions.

40. It is simply the government trying to take over everybody’s life. They target a group one at a time. They simply want full control of everything; and they will get it by any means by hook or crook. Our government has been lieing to us since President George Washington. So, what makes you think things are going to change now? When they are done with the AMA, they will target another group. It is that simple, and WE are to blame.

    1. Perfect example of Govt incompetance. They can’t define what they want to control so they target everything then say we’ll let you know what is OK and what is not. Our freedoms are being erode daily by this crowd WE elected in Washington. And don’t try to blame the Govt….We ARE the govt. Wake up America, before it’s too late! God help us it’s not too late already

41. I agree with most of the folks here that said the Gov’t is looking for more control over our lives…Like a real terrorist is going to give a crap about laws and rules…and guess what we let them get away with it! For the most part I really like what Ramlin Dan had to say!

42. I have been playing with model airplanes for about 50 years and always come to the hobby as a safe haven and for peace of mind. I never would have thought anybody would turn it into something sinister. I think the issue is, who is going to be allowed to invade our privacy, as has been done locally by real estate agents or by our Government (both parties) to control people with a different philosophy. Some police chief officer in the South wants to buy armed drones so he can reach out from his office and touch someone.

    So, we need rules. Rules are for people who have lost their empathy for others. If, as a nation, were going to turn into peeking Toms, then we need a rule so we don’t get peeked. If were going to kill people with drone air strikes, we need rules to keep it from happening to us. Rules are made to deal with the five percent of the population that has no common sense or have never heard of the golden rule. As it is said, all that is required for the bad to succeed is to have the good keep silent.

    hmb

    1. Unfortunately, the 5% that you reference will probably ignore the rules so what is the point? Do you really think some nutcase who loads an RC with a bunch of explosives won’t do it because it is against the rules?

43. Agree with Scott. FPV is ruining our hobby not the FAA. In a desperate move to attract younger members the AMA is asking for trouble. Old guys using old arguments without understanding how 20 year olds think. I fly a $12,000 Hexacopter with a video down-link and would never fly without Line of Sight. Way to risky. The FPV technology, combined with lipo batteries, and basic GPS makes for potential disaster in the hands of the uneducated or irresponsible. I don\\\’t understand why an organization that promotes rc safety would be against what the FAA is trying to do. Seems like people are more worried about \\\”government control\\\” and \\\”personal freedom\\\” and less about safe flying.

    1. Come on Jim. You do realize that you came across as a person who is of the elite & feels the hobby is just for the elite right? You felt the need to profess your investment of $12,000 and then suggest that technology in the hands of the uneducated can be a disaster. FPV is an evolving segment of the overall sport that you may not understand and therefore are incapable to embrace. You are part of the problem and offer no answers. I see your type of thinking at the clubs. Personally I don’t fly FPV but respect those that do as long as it is in a responsible way. 20 year old men & women think differently because they have grown up with the technology of today. The AMA is trying to wrap their arms around that because they understand the future lies with them. They are not flying less safe. They are flying with the technology of today. Geesh, Bully for you and your $12000 Hexacopter with a video down link

44. Cahill, Richlen, Lynch, Ussery has it right. It is all about control. We must wake up and start to pay attention to who we are voting into office or soon the government will have total control over all of us (many will argue that has already happened).

45. Fellow AMA members,
    I agree with most of the replies posted so far. But you are talking to the wrong audience. We will never get the FAA to change their tune by speaking among ourselves. So, please log onto Regulations.gov and post your comments there. If they don’t hear from us, who knows what “rule” (posing as an Interpretation) they’ll “promulgate” next?

46. I have read a lot of good, bad and ridiculous points here. Hear is my two cents. First the FAA does not make law and in my opinion are over reaching and will lose. Big business and the future will see commercial FPV and drone use regardless of what the FAA says. The FAA cannot stop this from happening period! So, my suggestion is that the FAA embrace this and work to help make FPV and drone use to be safe. I do agree that there needs to be laws governing the operation and use, but not laws that prevent it. Here is the most important point. That if those laws created be the one who have that power to create them are broken, that the fine or punishment be strictly enforced. I say this because we have current laws dealing with other topics that are not enforced which have and are leading to a disregard for the law all together. So, I hope the FAA gets smart and realizes that they can not stop progress and gets on board to help it and not hinder it.

47. I happen not to be an “RC” hobbyist – I fly control-line model aircraft. RC did not please me sufficiently to force myself to pursue it further. Nevertheless, I am lumped in with the admittedly larger number who do fly RC.
    …Control-line is limited in the ‘range’ the model can cover – the length of the flying lines in both horizontal and vertical distance.
    >…Still, the perceived threat in the Interpretive Rule applies to my facet, and to Free Flight modeling, as these are not addressed.
    …. We will all always be considered responsible for the actions of irresponsible and dangerous persons. WE agree to the established safety guidance of the AMA; they don’t.
    …. We cannot force ‘outsiders’ to abide by AMA guidance; neither can the FAA. If there are criminal abuses, they should be punished at the individual offender level, not against an entire recreational activity and the law-abiding businesses that serve it.

48. I have, and I suggest you all do so, and in fact repeatedly. This is a very very dangerous precedent. This is not just about FPV, This re-interpretation of the rule makes any sponsored pilot at any competition a criminal. So the very act of holding a competition, (since winning may indeed provide someone financial gain to an individual for flying a model aircraft) will now become illegal. If the Feds decide the act is indeed a felony, then the very conversation of Planning a competition is indeed “conspiracy in the Furtherance of a Felony”. We need to stop this at once. This is NOT what Congress dictated, and they fully recognize this. They are completely out of line, and out of control on this.

49. @HMB, We already have laws against peeping Tom’s. Every State and Municipality has them on the books. The issue has been perverted into a privacy issue when If I want I can peek over your fence with a Go Pro and a pool Pole, or a long lens from on top of a Truck parked in the alley.

    That some Sheriff wants to buy an armed drone, does not mean anybody is going to let him fly it, or keep him in office if he buys one. As for general Law Enforcement use, the same laws and policies that apply to gathering evidence in the furtherance of an investigation should and DO apply. It doesn’t matter if it is on a UAV at 200 feet or a Hughes 500C at a thousand. More importantly the FAA has decided to completely go postal on this hobby, and make any sponsored Team Pilot a criminal for flying. READ the whole thing, they are trying to Split the hobby by making EVERYBODY pay for what they consider some horrible uncontrollable threat to the nation!! The Horrible uncontrollable threat here is the FAA who has completely lost control of itself. If this Stands, you can write the hobby right back into the stone age. The rest of the world will continue to develop SUAV technology, and we will go to jail if we even think about it. Don’t think so? WHAT SUAV do you know is out there without at least one camera on it? How is it safer to fly LOS if your a thousand feet laterally away from your takeoff point than If you have a Spotter watching it and you are in the Goggles seeing things up close and personal? Your not, but they dont care, they are puppets being run by Lawmakers who don’t know a DRONE from a $20 mall store toy helicopter. The same Lawmakers who are totally OK with our Drones in other counties slinging Hellfire missiles left and right. Hypocritical bunch of bull if you ask me.

50. You can’t punish someone for a horrifically stupid act unless you make that act illegal. What ever it is that you fly, do it in a responsible manner and don’t worry about it.

51. Isn’t the real issue the camera (or other data collection device attached to the aircraft. Would anyone be scared of a model that is essentially blind?

    1. No… the issue with FPV is “see and avoid” Full scale aircraft are unlikely to be able to see and avoid an appx 2 ft sqare quadcopter that is hovering in their flight path until it is too late to avoid hittin it. The FPV system does not give good vision in a wide enough field to ensure that the operator can see the oncoming full scale aircraft unless it happens to be pointed in the right direction…

       This is why the AMA recommends (Safety Code) a second person to ensure the model stays in line of sight and to observe for other aircraft. Its just not safe to fly FPV without being able to ensure the model won’t get into the path of full scale.

52. Since most people are lazy and unwilling to write a letter on their own, it might be a good idea for the AMA to post several possible letters and people could use those as a starting point or just send them in as is.

53. Let’s not forget this gem ….
    “The statute requires model aircraft to be flown strictly for hobby or recreational purposes. …. (5) Likewise, flights that are in furtherance of a business, or incidental to a person’s business, would not be a hobby or recreation flight. Flights conducted incidental to, and within the scope of, a business where no common carriage is involved, generally may operate under FAA’s general operating rules of part 91. See Legal Interpretation to Scott C. Burgess, from Rebecca B. MacPherson, Assistant Chief Counsel for Regulations (Nov. 25, 2008). Although they are not commercial operations conducted for compensation or hire, such operations do not qualify as a hobby or recreation flight because of the nexus between the operator’s business and the operation of the aircraft. ”

    Under this interpetation, the owner or employee of a hobby shop that sells model aircraft could not legally fly a product from the store as it does not fit the FAA definition of “hobby or recreational use”.

54. Simply stated, You can’t legislate good judgement and you can’t legislate away stupidity. When government tries to do so, it most often squelches the law abiding citizen’s ability to pursue their interests, be it hobby or entrepreneurial, but has little or no effect on criminal acts. I truly believe that the intent of the FAA is to keep our national airspace safe but their proposals will not do so and might very well have the opposite effect.

55. I’ve written my Congressman and both Senators. I STRONGLY recommend everyone else do the same. Instead of whining and complaining here, get on the phone, email, or write a letter to the places where it will do the most good. Our entire hobby is at stake. If we allow this to take affect, EVERYONE LOOSES.

56. So, if the FAA bans FPV, then that means people will not fly FPV at RC airfields which is probably the safest place to fly. So, people being people will do their FPV in other locations. Probably locations that are a lot more inappropriate for FPV. So, in essence, the FAA is actually making things more dangerous.

57. \”MOST of us keep to the recommended 400 ft and below ceiling and follow the other safety policies and recommendations put forth by the AMA and heartily endorsed by the FAA. \”

    In fact, most don\’t and didn\’t. It\’s unfortunate this is occurring but the FAA interputation is immediate. The writing is not on the wall, it\’s on the severe fines that are already being written against violators with more on the horizon. Multiple business owners are currently drafting communications for responce, the FAA will not hear them as they are a minor blip on the radar screen compared to the negative votes that were drafted unanimously by the board committee. Their decision was made and trust me, they do not feel bad about the business owners sudden loss of profit margins. If there are any changes in the distant future, it won\’t be due to these owners bonding together to draft their replies, it will only be due to a positive majority of business owners that propose the technology use for other benefits including law enforcement and public safety. Problem is, they aren\’t coming forward in the numbers necessary to sway the decision already made and now enforced.

58. Lets flip this right now……….
    How many full scale airplane crashes have killed passengers? How many of those passengers were rc modelers? How many modelers lost their life because the plane they were in crashed and killed every single person on board?

    I will argue that it is far more dangerous for an AMA member to be a passenger on a doomed airplane that is about to crash nose first into the ground. I believe it is much safer to be standing on the ground flying a model airplane at an AMA sanctioned field with my friends.
    When my model crashes nobody gets hurt. When an airliner crashes, everybody dies.

    How many AMA members have lost their lives because the FAA didnt do their enforcement job and make airlines correct known problems with aircraft?

    Never once in the history of modern aviation is there any record of an AMA member’s model plane downing a full scale aircraft.

59. I\’m 65 and been flying FPV for 5 years. The cost, I started with my laptop and had to buy a $5.00 thing to make the Video on the laptop. Then I got the Video camera $16.95
    Then the big money came in trans. and receiver Video.$ 85.00
    \”O\” $15.00 for my License.
    I now have a Quad made from PVC .
    Some people will never be able to adjust to new thinks and think EVEYONE should stay in the stone Age.
    FPV is no different than many of the planes being flown well over 400Ft with just LOS!!!
    Some AMA members go by the rules and some don\’t. I\’m One that believe we all need reasonable rules to keep the hobby safe. But not to Kill the Hobby!
    today the FAA is going After FPV. Tomorrow will it be the Gliders, or the Giant Planes.
    or just any flying models???

60. Gentlemen,

    As an AMA member for over 35 years, and an active hobbyist and leader member, I must take exception to your response to the FAA ruling interpretation, and want to express that your are not communicating my views on the issues. I think you have responded impulsively, emotionally, and in a manner that may prove most to be counter-productive. To wit:

    I agree that FPV flying should be prohibited; it is a collective accident waiting to happen, a terrorist tool about to be applied, and even previous to the current proposed ruling, I was disappointed to see you promoting it in Model Aviation.

    I agree that the umbrella extended to model aviation should not extent to commercial applications of our technology. I am troubled by real estate agents taking drone pictures under the umbrella of our hobby. Although I do agree that the FAA should clarify that those who provide equipment to the recreational hobby community should be able to do so as a hobbyist, not a business. I will express that to the FAA.

    I agree that large models should be limited to 55 pounds at takeoff.

    I agree that model activities conducted within 5 miles of an airport should be reported to that airport.

    I agree that any model activities that endanger the collective airspace should be subject to the same regulations applied to the entire airspace. Like the fool at the Pittsburgh baseball game, are you defending him? If not, then the FAA has been proven right on that point.

    The point you have missed is that many of your members are quite content to pursue their hobby without inviting the added scrutiny that your aggressive attitude might bring upon us.

    1. Regarding prohibiting FPV. So, do you think terrorists will not use FPV just because it is illegal? I mean seriously?? Also, you don’t need FPV to do something really bad. In fact, I doubt they would even use FPV with the advent of waypoints.

61. Game over for FPV
    https://nypost.com/2014/07/07/two-drones-in-near-miss-with-nypd-copter-over-gwb/

    Couple of idiots forced a police copter into evasive maneuvering. FAA now has proof that they need to ban FPV.

62. People fear of changes and start to make rules and regulations to make this changes as safe as possible. Changes in the hobby, such as FPV technology will help the hobby grow, of course in a positive way. Not only the hobby which is growing, but most importantly the community who grows along with the hobby. The hobby exists because the community exists.

    Anybody would agree if the rules and regulations support the growth of the hobby and provide safety for all of us. But rules which are strictly prohibition to changes which hinder or even stop the growth of the hobby, will bring disappointment to the community. I hope they would find the positive solution to this.

63. One of the reasons I built a quad was for fpv.Some people can’t afford to experience flight from a pilots perspective and most all people who fly fpv have nothing to gain by invading peoples privacy. Will this keep the government from using them as well?

64. I have just submitted a comment regarding free flight to regulations.gov Free Flight pilots give way to manned aircraft even if their planes can’t. I also fly RC but lawyers who don’t fly either seem to be writing rules from their limited perspective. The AMA Safety Code has a free flight section, and a pilots will give way rule. Note that there is a 5000 character limit when you submit.

65. I’ve been reading as many reports and discussions about these new rules by the FAA and in my opinion the FAA is over-stepping it’s authority just like the TSA and Homeland Security is targeting, detaining, searching, and harrassing private pilots (without search warrants) that are traveling far from any international borders under the guise that they are cracking down on illegal drug activities.

    As has been mentioned above, the FAA wants to outlaw FPV and severely restrict recreational flights of our models. Some of the restrictions are warranted, some are not.

    The problem is the FAA cannot even properly oversee the airlines and general aviation because of budget cuts and a shortage of personnel. How in the world are they going to police what they are proposing?

    As a pilot it’s against the regs to fly below 500 feel above a populated area unless for the purpose of take off or landing. In the past they’ve given us the ability to pretty much fly our models at will below 400 feet AGL and 3 miles or farther from airports I assume because they felt that would provide the proper separation of models and aircraft.

    Now because of a rapidly growing drone industry and some idiots that’s all changing and thanks to the news media (probably at the governments insistence) “DRONES” are now sinister devices!

    Everyone is arguing that people’s privacy is going to be invaded due to drone mounted camera’s and the new FPV technology. Your privacy has already been invaded people!

    You cannot travel anywhere outside your home in this country without a camera taking your picture! Before you jump on me, I do believe we need to all have our privacy in the confines of our own backyards but when you go to a mall or an event you cannot reasonably expect, and you don’t have, any privacy.

    I’ve seen some stories in the news where people are complaining their privacy was invaded by a drone flown over the beach. Those same people don’t say a word about the security camera that’s watching them while they lay on the beach! Or an indecent person with a pair of binoculars in the hotel behind them “checking them out”.

    Another news story was about a woman on the 24th floor of a high rise condo in some city feeling violated when she looked out her window and there was drone with a camera “looking” at her. Turned out it was a drone hired by the building owner to get some publicity shots for advertising the building. Oh, by the way, did I mention she was, by her own admission, standing in the window without any clothes on! Apparently she thought she had privacy standing in a window with the curtains pulled back!

    Another issue I struggle with, it’s perfectly legal (and no one will probably say a word to you) if you mount a camera on a 20′ or 30′ pole and take pictures in a public area but if you put the same camera on a drone and fly it at the same height, in the same location, and not over anyone it’s suddenly illegal or people feel like you are violating their privacy.

    No one seems to mind if an airplane with a very high resolution camera (way higher than a Go Pro) flies over their neighborhood and takes aerial photos of their neighborhood, but put a camera on a drone and lord everyone is up in arms.

    And what about Google taking pictures of your home from directly in front of your home? No one seems to mind that! Fly a drone with a camera down your street and see what reaction you get form your neighbors. BTW, I don’t condone flying down the street or over your neighborhood. Just using real world examples.

    Simple solutions to many of the issues using the technology we already have available:

    1.) Require everyone to go through formalized safety training and the theory of good modeling habits. Require the pilot to carry a certification card when flying or else get fined.

    2.) Make the manufacturers install hardware or software that limits the maximum height of our models to 400′. Whatever technology is used would have to be tamper proof.

    3.) Make the manufactures install hardware or software that prevents the model from traveling more than a predetermined distance from the transmitter. Whatever everyone agrees is the limit of LOS. Once again, it would have to be tamper proof.

    4.) Program the models so they cannot be flown closer than 5 miles to an airport or over known public arenas, stadiums, etc… One drone manufacturer already does this. for airports and certain types of airspace. Must be tamper proof.

    5.) Require the manufacturers to install safety devices that can be manually or automatically triggered so the model can be stopped and safely lowered to the ground in the event of a fly-away. This would have to be a separate fail-safe system that would instantly shut off power to the motors and release a parachute when triggered.

    6.) Have a set of severe penalties in the event someone is caught tampering with any of the above mentioned safety features!

    The only other thing is in my opinion there should be 3 distinct types of drones.

    Military/Law Enforcement/Search & Rescue
    Commercial
    Non-Commercial/Hobby

    Each should have it’s own set of rules and regulations. Each has a totally separate type of use and would be flown in totally different conditions and environments and therefore cannot possibly be expected to operate under the same regs.

    The bottom line is, no matter what your thoughts or opinions are, we all need to pull together to keep from becoming governed into extinction!

    Thanks for taking the time to read my post!

66. You cant lock out the people who follow the rules. I’ve been in this hobby for any years and have recently started a business shooting aerials and photography. I can stay under 400 and 5 away from airports but the FPV is fun and safe past time.

67. The picture becomes clearer after you read this …
    https://www.kramerlevin.com/files/upload/PirkerDecision.pdf
    The citation against Pirker is included at he bottom.
    Please note item 3.

68. I am not an AMA member. I have only flown toy copters and 1 model plane. I crash and crash a lot. I am however an interested party. I have for quite some time wanted to seriously get into the hobby but only because of the advent of quad copters and now with the addition of gps and go to home functionality and fpv it is something that finally I feel personally that it just might be now “safe” enough for me to fly:). I feel less likely to crash these things and perhaps a bit easier to learn. I have also a recent interest because I see some business opportunities particularly in the farming industry.

    Having stated that, I must now state this. I have seen this coming for quite some time and so should have the AMA and the FAA. But I think it is time to stop complaining and take a positive action.

    As a few others have mentioned, the AMA and perhaps hobby stores and other parties should get together and write a document that regulates the hobby, defines and categorizes hobby aircraft, suggests training and licensing options and how to get a license. Then push the sellers and hobby stores to include this training and info with every hobby aircraft they sell and even a rating system that clearly defines and labels the device that they sell and what license or training they need to fly it.
    Build a document that could regulate the hobby and then use any and all lobbying means to present this to lobby groups, government agencies, faa and media etc. Take a stand and present a course of self regulation for the hobby and tell the faa that these are the guidelines they should follow. Build the guidelines for them. You are the ones with the knowledge here and are the experts. Get together and do it. That is truly the only way the faa will listen her. Fight illogical actions with a logical and concise reaction.

    The faa should and probably would adopt it then instead of this willy nilly thing they seem to be doing now. Because they will try to regulate it and if you don’t do this now it will be messed up and messed up for a long time.

    That is my two cents.

69. The FAA drafted a policy letter in 2007, prohibiting any commercial use of UAVs unless they met with FAA approval. Unfortunately, the FAA had no rules to allow airworthiness or pilot certification of UAVs. So, Ipso Facto the FAA denied the use of UAVs for commercial use. In 1946, the Supreme Court ruled in Causby v. The United States that: “We have said that the airspace is a public highway. Yet it is obvious that if the landowner is to have full enjoyment of the land, he must have exclusive control of the immediate reaches of the enveloping atmosphere. The landowner owns at least as much of the space above the ground as the can occupy or use in connection with the land.” The FAA claims ownership of the NAS from the surface upward, which flies in the face of the Causby decision. TGhe question now is, who owns the airspace the FAA odr thje land owner. If the FAA has taken the airspace from the land owner, then it would appear a tort claim can be filed against the FAA for “taking without compensation” a violation of the fifth amendment. Maybe it’s time for a concerted effort by everyone involved for a class action suit against the FAA.

70. Here is how I commented… I believe Congress put the word “hobby” in quotes for a reason…

    I have been flying RC model airplanes for almost 30 years. I started as a child and have been self-taught. It has been a great hobby for learning technology. I have had minor injuries building model airplanes, but have not caused or had any injuries from flying model airplanes. This regulation impacts all individuals that fly model airplanes and diminishes the happiness and freedom that is achieved from this activity. I need to now understand FAA rules and regulations and stay up to date on legal matters to conduct this hobby. Its sad to see the hobby take this turn towards regulation and its sad I can\\\’t leave it to my kids the way I got it. Here is some feedback that will hopefully make some small improvement in this state of affairs.

    In the Committee notes the word \\\”Hobby\\\” is put in quotes: see- Language including model aircraft for the purposes of sports,
    competitions and academic purposes is removed and replaced with “hobby\\\’\\\’… These quotes are scare quotes – see definition from Wikipedia -\\\”Scare quotes or shudder quotes are quotation marks placed around a word or phrase to imply that it may not signify its apparent meaning or that it is not necessarily the way the quoting person would express its concept. The quotes serve a function similar to verbally prefixing a phrase with \\\”so-called\\\”. When referred to as \\\”scare quotes\\\”, the quotation marks are suggested to imply skepticism of or disagreement with the quoted terminology.\\\”

    Based on this definition, one interpretation of \\\”hobby\\\” is it is the so-called hobby of model airplanes as it stands today. If Congress meant the dictionary definition they would not have put quotes around the word. Congress intention was to preserve the present hobby, as defined by the current model airplane activities today.

    The definition of \\\’Hobby\\\’ used in the rule is overly narrow and will impact current RC modeling activities:
    AMA competitions. Competitors are often sponsored by vendors, making their participation in the activity more than a \\\’hobby\\\’ and provide income. This will impact the quality of the competition, the marketing and sponsorship, and therefore the industry built around RC modeling.

    RC modeling manufacturers would not be able to test fly model airplanes, or airplane component for sale under these rules, since these flights are clearly not hobby related. This will severely limit the innovation that has occurred in this field. Many RC companies today were started by modelers who developed products as part of their love of the hobby (for example Carl Goldberg, Sig Manufacturing, or look in any AMA magazine at the ads)

    There are other examples where the hobby language will impact the industry – for example, those that operate a model plane retail store, write about model planes for a living or review model planes for a living. In each of these cases the individuals fly their model indistinguishable from how a hobbyist would fly the plane in the airspace, yet they make a living from the effort.

    All the above examples are activities that are included in the \\\”hobby\\\” of model airplanes today. The \\\”hobby\\\” needs business activities to remain.

    One other point that is missing is that the vast majority of model airplane flying is done over land where the owner has given specific permission for the activity (like a club, or modeler\\\’s yard) or in a public park or area. This is a controlled environment and it provides a level of control and safety to the operation of model planes that does not exist with full scale aircraft that fly over the public at large. This significant difference in operation and the safety it provides should be taken into account in the rule.

    Thank you.

71. Formal Comments on Aspects of the Proposed FAA Interpretation of the Special Rule for Model Aircraft
    Docket No. FAA-2014-0396
    Nickolaus E. Leggett, FAA Licensed Pilot: Single-engine land airplanes, Aero-towed gliders, Hot air balloons. Inventor with three U.S. Patents

    Model Flight Notification Requirements:

    1. Requiring model aircraft pilots to notify airport operators (and when applicable control towers) before each flight within 5 miles of an airport is a huge burden on the airports as well as a huge burden on the modelers. In the case of the non-towered airports, the airport operator does not monitor the traffic flow which is managed by the pilots themselves. So he is not equipped to issue a knowledgeable permission even if he has time to answer all the phone calls from RC pilots. In the case of airports with control towers, the tower staff is not able to provide a reasonable decision about model flight on and around suburban patios or at low altitudes above suburban parks.
    2. Requiring park fliers and patio fliers to get permission would greatly inhibit model aviation in many suburban areas. How many calls are there going to be from kids on Christmas morning with their new model aircraft? Does it make sense to require permission for flights made around backyard trees such as at many suburban homes? Many of the drone flights, such as those made by quad copters, are flown at very low altitudes and low speeds under the tree-top heights on suburban properties. It is certain that manned airplanes are not being flown at these ultra-low altitudes.
    Recommended action: The FAA should modify its interpretation so that notification of airport operators and/or control towers is not required for model aircraft flights within 5 miles of an airport when the flights are less than 200 feet above ground level (AGL).

    Overall Altitude Restriction

    The stated 400-foot above ground level altitude limit is too strict for model aircraft flying conducted in rural areas. This limit should be adjusted to an altitude of at least 1000 feet in rural areas. Rural area can be defined as areas that are outside of Standard Metropolitan Statistical Areas (SMSAs).
    This liberalization is especially important for model sailplanes (gliders) that often depend on the use of thermal updrafts to remain in the air. These models are flown in circular patterns within the thermals to obtain some altitude and then they are flown on paths between thermals. Limiting gliders to 400 feet greatly limits their ability to use the thermal updrafts.

    Recreational Operation of Model Aircraft

    1. As a potential inventor of aircraft inventions, I have a major complaint with the notion that the model flying has to be strictly for recreational purposes. I can imagine developing a new technology as a strictly hobby vehicle and then, if it is successful, shifting it over to both commercial and hobby markets. This approach has been used frequently in the history of aeronautical inventions starting with the Wright brothers’ gliders. The new invention is started as a flying fun model that is later developed in a commercial environment. This reflects the fact that inventing is basically a quite playful and experimental activity where many wild ideas are tried until things settle down to a potentially practical technological solution.
    2. The FAA needs to avoid prohibiting inventive activity that is in itself a constitutionally protected activity. Independent inventors provide a very important service to the Nation’s economy, and they should be encouraged to engage in model aviation. For example, some of the important inventions by NASA engineers, such as lifting bodies, were first carried out off-hours as hobby model aircraft. Also, many of the full-scale aircraft builders at the Experimental Aircraft Association start out building their home-built designs that they later develop into commercial products.

    Recommended Action: The FAA should explicitly define the activities of independent inventors with model aircraft as recreational activity. In addition, the FAA should consider the activities of companies developing model aircraft for the hobby market as engaging in recreational activity.

    Many people who want to learn drone technology will start first through model aviation. I am one of these people. This self-training activity should not be considered to be commercial operation, just as learning about aviation in general from modeling is not considered commercial operation. Many major people in aviation started out learning aviation in model aviation activities. This is a precious resource that should be encouraged and protected by the FAA.

    First Person View (FPV) Flying of Model Aircraft

    First person view flying of model aircraft should not be blocked by the FAA. This is a valuable new technology that contributes to the modeling experience and is an area for new inventions and innovations.

    This type of operation adds to the safety of model aircraft flight because it enhances the precision of approaches and landings of model aircraft. It also provides the opportunity for future commercial drone pilots to gain experience with this new type of flying.

    Sociological Problems with the Proposed FAA Interpretation

    Many of the aspects of the proposed “interpretation” cannot be effectively enforced. For example, you cannot determine one’s goal for flying a model aircraft. The person’s long term goal may be commercial, but you certainly cannot prove it. It is best not to establish unenforceable rules.

    The FAA interpretation suggests certain hostility towards model aviation as well as some ignorance of basic general aviation procedures. This raises questions about other FAA rulemaking as well. The FAA should cooperate with the Academy of Model Aeronautics and go back to the drawing board on the Interpretation.

    Respectfully submitted,
    Nickolaus E. Leggett

72. I posted this today o the FAA website.

    Your Receipt

    3 Your Receipt
    2 Your Preview
    1 Your Information

    Your Comment Tracking Number: 1jy-8d77-tt4k Your comment will be viewable on Regulations.gov after the agency has reviewed it, which may be an indefinite amount of time. Use your tracking number to find out the status of your comment.
    Your comment:
    Comment: I have been an AMA member for 25 years and have been flying RC model airplanes continuously over that period. I read the interpretive rule, docket number FAA-2014-0396. It shocked me because it represents the most restrictive and repressive language ever imposed on my hobby.

    This new set of rules seems to be aimed at shutting down a major portion of the RC hobby, and/or making it almost impossible for me and my RC friends to continue enjoying what for us is an important part of our recreation.

    I recommend the following:
    1) Eliminate the restrictive rules contained in FAA-2014-0396 at RC club fields where flying is done by AMA members in accordance with AMA safety rules.
    2) Promulgate the AMA safety code so the public has a standard to use.
    3) Place controls only on those who violate the AMA safety code or who create a danger to the public.
    4) Leave the job of making rules regarding hobby activities to local government. I don’t want my federal taxes used to control a hobby. The FAA has bigger problems to solve than going after hobbyists.
    5) Learn from gun control law. These laws regulate the safe and honest citizens, but do nothing to curtail criminals and outlaws.

    The restrictive language you are using to control the RC hobby is creating waves of worry and concern among people who don’t have any idea what this is all about. Please don’t panic the public. Use common sense and understand that your restrictive rules will affect the people who you don’t have to worry about, but will not stop the dangerous loose cannons who could care less about the rules.
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    First Name: Joe
    Last Name: Marrone
    City: Merrimack
    Country: United States
    State or Province: NH
    This information will not appear on Regulations.gov:

    Comment: I have been an AMA member for 25 years and have been flying RC model airplanes continuously over that period. I read the interpretive rule, docket number FAA-2014-0396. It shocked me because it represents the most restrictive and repressive language ever imposed on my hobby.

    This new set of rules seems to be aimed at shutting down a major portion of the RC hobby, and/or making it almost impossible for me and my RC friends to continue enjoying what for us is an important part of our recreation.

    I recommend the following:
    1) Eliminate the restrictive rules contained in FAA-2014-0396 at RC club fields where flying is done by AMA members in accordance with AMA safety rules.
    2) Promulgate the AMA safety code so the public has a standard to use.
    3) Place controls only on those who violate the AMA safety code or who create a danger to the public.
    4) Leave the job of making rules regarding hobby activities to local government. I don’t want my federal taxes used to control a hobby. The FAA has bigger problems to solve than going after hobbyists.
    5) Learn from gun control law. These laws regulate the safe and honest citizens, but do nothing to curtail criminals and outlaws.

    The restrictive language you are using to control the RC hobby is creating waves of worry and concern among people who don’t have any idea what this is all about. Please don’t panic the public. Use common sense and understand that your restrictive rules will affect the people who you don’t have to worry about, but will not stop the dangerous loose cannons who could care less about the rules.

73. AMA is only an “Ad-hoc” group of people enjoying a hobby or trying to do so.

    I expect more of the same in AMA vs. the USG.
    Lip service and such standing in the place of say appearing at public hearings on CSPAN to defend the hobbyists.

    Over-reach is the way of American Governance now. More Patriot Act fascist abuse can be the only result.
    Maybe the People should stand up on their own two feet and stop handing the compete job of representation to the AMA.
    And I do not mean petitions to express displeasure and I do mean genuine seeking a redress of grievance if that constitutional mechanism was still extant.

74. https://www.youtube.com/watch?v=rvcN-0PikEU Stupid people tricks… a couple of feet one way and no collision… a couple the other and it would have been a fatality.

    And the model in this incident was HUGE compared to the quads…

    One of many incidents that make it obvious that offical regulation is required… not just some \”Good Old Boys Club\” set of rules with a non-enforcement policy.

75. My Submission, for what it’s worth:

    WHAT?! You mean I can’t sit in my lawn chair at the end of the runway, drinkin’ beer, eatin’ a tuna sandwich and zoning out in my video goggles flyin’ my 98lb, double-deca-copter, taking pictures of the jets as they pass below? That’s insane!

    Joking aside, all reasonable people can agree that it is understandable for there to be fearful, knee-jerk reactions when a rapidly advancing technology APPEARS to be threatening. And I stress the word ‘appears’ because there is very little evidence, that UAS technology is actually less safe or more invasive than any number of other current and legal human activities.

    In fact, Center for Disease Control data suggests that personal hygiene technology is way more dangerous than UAS technology ever could be… do you know how many people slip in the bathtub and are injured or killed each year? And as for invasiveness, there are already rules in place to deal with the ‘peeping-toms’, no matter what technology they use.

    Therefore it follows, when kept in perspective, that “drone” technology is not all that threatening. In its current state, and certainly in its near future (barring regulatory road blocks to grassroots innovation), this technology will self-evolve into one of the safest technologies available, as there are great incentives for UAS to be built and operated in the safest manner possible.

    For a few years now, I have been involved in designing, building and generally absorbing all things ‘small UAS’ in the pursuit of the happiness I get from aerial photography and film making. In that time, the number of advancements to make small UAS more safe and reliable is astounding.

    This technology has naturally developed its own high level of risk avoidance. Mainly because few have the money to burn by going around crashing these things into property or people… it self-regulates quite effectively amongst its users, and the evidence supports that.

    Yes, there are some very ignorant operators out there (private and commercial) and they have done very stupid things. These incidents have made it into the media and unfortunately have fanned the flames of the illogical, emotionally driven reactions that seem to be guiding the FAA’s small UAS rule making. But as history points out, no amount of regulation will ever prevent these ignoramuses from doing what they do.

    Regardless of your “mandate”, you cannot stop stupidity from happening, but you sure can encourage intelligence. And that is what I am encouraging the FAA to do with respect to regulating UAS as a whole and small UAS specifically.

    Obviously, UAS designed to fly within the National Airspace System need to be treated as manned aircraft. They should follow the applicable rules the FAA already has in place, and has effectively administered over the years. You guys have done a great job in that and I applaud your reasoned, measured and data driven approach to coordinating all that goes on within the NAS.

    However, for small UAS not designed to operate within the NAS, the regulations should only attempt to mitigate the REAL risks that exist and not the unfounded risk perceptions that many have offered.

    Unreasonably regulating small UAS that are very unlikely to cause any real or wide spread conflict within the NAS will only make ‘criminals’ out of innovators, farmers, kids, science teachers, RC model show pilots, tech-minded citizens, filmmakers, photographers, utility companies, etc. 

    Instead of confining the current and future generations of professional and amateur small UAS innovators and operators, the FAA should partner with these folks and encourage them to use their intelligence to come up with the best ways to sensibly implement and ingrate this useful technology into our lives.

    By earnestly doing this, not only will the American public benefit from the inevitable advancements, the FAA would have thousands of on-the-ground allies to keep the aforementioned ignoramuses in check.

    Given the above, I request that the FAA withdraw the recent ‘Interpretation of the Special Rule for Model Aircraft’ and then form a committee, much like the full-sized UAS Advising and Rulemaking Committee (except open to the public), made up of persons who are sensibly designing, building and flying small UAS for fun and profit. This group, in a timely manner, would come up with reasonable guidelines that the FAA would then use to oversee small UAS operations, both private and commercial..

    …because seriously, those farmers who are out there growing America’s food and surveying their crops ‘for pleasure’, really need to be doing so honestly as farmers of the 21 century and not as the FAA currently suggests they are, criminals who need to be fined for endangering everyone’s lives… now THAT, truly is insane.

    FAA, please let reason and data inform your small UAS rules, and if you need help, there are thousands of us out here who would be delighted to assist you in developing sensible rules.

    Thank You for your time. 

76. I wish I was articulate enough to comment on the various rules and actions that the FAA is considering and it’s impact on the remote control community, especially the AMA abiding flyers.
    My father started flying models in the 1930’s and ended up flying for Pan Am for 37 years. He taught me to fly of which I do to this day. I taught my son to fly and he is currently studying aeronautical engineering at college and is also flying drones/UAV’s for a defense contactor.
    It is because of the remote control/model airplane involvement listed above that the industry continues to grow, evolve and supply designers and pilots for our country.
    I would hate to see the FAA curtail our activities based on the few that ruin things for the many.

    1. Dan,

       What you wrote right here seems like a perfect comment to me. It’s to the point and reads as honest and heartfelt, exactly what the FAA needs to hear.

       I encourage you to simply cut and paste it to the Regulations.gov link above…

       …articulate-schmiculate, what you said in that one paragraph is way more valuable than any form letter full of someone else’s articulation’s.

       SO, go for it! They should hear what you have to say.

       Cheers!

77. To show you just how insane our government has become; after posting to regulations.gov I received THIS receipt.

    “Your comment will be viewable on Regulations.gov after the agency has reviewed it, which may be an indefinite amount of time. Use your tracking number to find out the status of your comment.”

    Which may be an indefinite amount of time…. Meaning they may never get to it and feel no responsibility to ever get to it. Hmmm I wonder if I can get to my taxes after an ‘indefinite amount of time’.

78. This is ANOTHER example of federal overreach. The FAA is 100% wrong on this one. We RC modelers do NOT represent a threat and never have. If they continue this push to make us criminals, they will ask for an increase in their budget (for enforcement), OR a law from Congress to force local LEO to enforce their crap rules. Either way… I WILL NOT COMPLY.

79. Great article. Thanks for the info, you made it easy to understand. BTW, Just in case anyone needs to fill out a FAA forms, I found a blank forms in this site PDFfiller. This site also has some tutorials on how to fill it out and several FAA forms that you might find useful. Here is a blank FAA Form 8060-13 that I was able to fill out.

80. FPV would not be possible without Radio over Laser, Spread Spectrum Radio or Over the Air Broadband Signals. All of which YOU the AMERICAN TAX PAYERS paid for under the guise of Advanced Research Necessary to Protect the Nation and Assist in the Safety of the Homeland. And, China builds it all for you. I spent over 1/4 of my life developing and testing such items for use in Public and Commercial. All of this reminds of the Encryption restrictions we have now. And, now we all have someone who can take the place of us at the Bank and own your identity easily. Because, YOU the TAXPAYER cannot use over 256 bit Encryption and cannot export anything using over 128 bit Encryption. I huffed and puffed at the FCC. One lone voice will not do, YOU ALL have to complain and loudly. THE FCC and FAA Admins are not like us, they get paid to follow the Executive Branch Initiatives, not morality or hold Sacred the American Way of Invention and Prosperity. Ben Franklin would be a terrorist and in a Fed Pen if he were to be dropped into our timeline just for flying an electrified kit and enjoying it all. Blue Skies to you ALL!!!

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