{"id":2761,"date":"2015-12-28T12:34:06","date_gmt":"2015-12-28T16:34:06","guid":{"rendered":"https:\/\/amablog.modelaircraft.org\/amagov\/?p=2761"},"modified":"2016-01-15T16:00:03","modified_gmt":"2016-01-15T20:00:03","slug":"guidance-on-submitting-comments-to-the-faas-interim-rule-on-uas-registration","status":"publish","type":"post","link":"https:\/\/amablog.modelaircraft.org\/amagov\/2015\/12\/28\/guidance-on-submitting-comments-to-the-faas-interim-rule-on-uas-registration\/","title":{"rendered":"Guidance on Submitting Comments to the FAA\u2019s Interim Rule on UAS Registration"},"content":{"rendered":"<p>AMA is \u00a0fully considering all possible legal and political options for alleviating this unnecessary regulatory burden on our members.<\/p>\n<p>In the meantime, you can help by making your voice heard with the FAA. Specifically we are asking all AMA members to submit comments on the FAA\u2019s interim rule on registration. The deadline to submit comments is January 15, 2016. All comments can be submitted at <a href=\"https:\/\/1.usa.gov\/1Jegj0C\">https:\/\/1.usa.gov\/1Jegj0C<\/a>.<\/p>\n<p>Below are recommended messages to convey in your comments:<\/p>\n<p>\u2022 Express your disappointment with the registration rule. As a member of the Academy of Model Aeronautics (AMA), I am disappointed with the new rule for UAS registration. I am a long time model aircraft flyer, who has operated under the guidance of the largest community-based organization (CBO) in the world for many years.<\/p>\n<p>\u2022 Highlight AMA\u2019s history and safety record. Since 1936, AMA has published safety standards and offered training programs for our members \u2013 more than 20 years before the FAA was created. Our National Model Aircraft Safety Code has been recognized by Congress as well as by state legislatures as a safe and effective means of managing model aircraft enthusiasts like me.<\/p>\n<p>\u2022 Note that you already register with AMA. Additionally, AMA\u2019s safety program already instructs me to place my AMA number or name and address on or within my model aircraft, effectively accomplishing the safety and accountability objectives of the interim rule.<\/p>\n<p>\u2022 Make it clear this rule is contrary to the intent of Congress. The new rule is contrary to the intent of Congress in Section 336 of the 2012 FAA Modernization and Reform Act. Section 336, also referred to as the \u201cSpecial Rule for Model Aircraft,\u201d clearly prohibits the FAA from promulgating any new rules for recreational users operating within the safety guidelines of a community based organization. In addition, the FAA\u2019s contention that model aircraft should be considered aircraft and are subject to existing regulation is currently the subject of pending litigation.<\/p>\n<p>\u2022 Affirm that as an AMA member you should be exempt from federal registration. The registration process is an unnecessary burden for me and the more than 185,000 other AMA members. AMA\u2019s membership program should be deemed an acceptable means of compliance and AMA members should be exempt from registering with the FAA.<\/p>\n","protected":false},"excerpt":{"rendered":"<p>AMA is \u00a0fully considering all possible legal and political options for alleviating this unnecessary regulatory burden on our members. In the meantime, you can help by making your voice heard with the FAA. Specifically we are asking all AMA members to submit comments on the FAA\u2019s interim rule on registration. [&#8230;]<\/p>\n","protected":false},"author":3,"featured_media":3955,"comment_status":"open","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"wds_primary_category":0,"footnotes":""},"categories":[116,7],"tags":[],"class_list":["post-2761","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-dot","category-faa"],"_links":{"self":[{"href":"https:\/\/amablog.modelaircraft.org\/amagov\/wp-json\/wp\/v2\/posts\/2761","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/amablog.modelaircraft.org\/amagov\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/amablog.modelaircraft.org\/amagov\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/amablog.modelaircraft.org\/amagov\/wp-json\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/amablog.modelaircraft.org\/amagov\/wp-json\/wp\/v2\/comments?post=2761"}],"version-history":[{"count":6,"href":"https:\/\/amablog.modelaircraft.org\/amagov\/wp-json\/wp\/v2\/posts\/2761\/revisions"}],"predecessor-version":[{"id":2805,"href":"https:\/\/amablog.modelaircraft.org\/amagov\/wp-json\/wp\/v2\/posts\/2761\/revisions\/2805"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/amablog.modelaircraft.org\/amagov\/wp-json\/wp\/v2\/media\/3955"}],"wp:attachment":[{"href":"https:\/\/amablog.modelaircraft.org\/amagov\/wp-json\/wp\/v2\/media?parent=2761"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/amablog.modelaircraft.org\/amagov\/wp-json\/wp\/v2\/categories?post=2761"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/amablog.modelaircraft.org\/amagov\/wp-json\/wp\/v2\/tags?post=2761"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}