{"id":8058,"date":"2026-08-25T10:19:00","date_gmt":"2026-08-25T14:19:00","guid":{"rendered":"https:\/\/amablog.modelaircraft.org\/amagov\/?p=8058"},"modified":"2026-08-25T14:56:06","modified_gmt":"2026-08-25T18:56:06","slug":"comments-requested-two-fcc-proceedings-could-affect-model-aviation","status":"publish","type":"post","link":"https:\/\/amablog.modelaircraft.org\/amagov\/2026\/08\/25\/comments-requested-two-fcc-proceedings-could-affect-model-aviation\/","title":{"rendered":"Comments Requested: Two FCC Proceedings Could Affect Model Aviation"},"content":{"rendered":"\n

AMA is urging members to submit comments in two Federal Communications Commission (FCC) proceedings that could affect recreational model aviation: ET Docket No. 21-232 and Docket No. 26-189.<\/strong> Each proceeding addresses a separate proposal and requires its own comment.<\/p>\n\n\n\n

AMA previously asked members to comment on Docket No. 26-189<\/a>, which concerns foreign-produced UAS and UAS critical components. We continue to encourage members who have not yet commented to do so. We are now also asking members to comment on ET Docket No. 21-232<\/strong>, which proposes broad changes to the FCC’s equipment authorization process. Instruction steps and a comment template can be found at the end of this article.<\/p>\n\n\n\n

Together, these proceedings could affect the equipment, components, and supply chains that support recreational model aviation.<\/p>\n\n\n\n

1. ET Docket No. 21-232: Changes to the FCC Equipment Authorization Process<\/strong><\/p>\n\n\n\n

This proceeding might have the broadest potential implications for model aviation.<\/p>\n\n\n\n

The FCC is considering a broad set of changes to its equipment authorization framework. Among other items, the FCC proposes new requirements for devices in “Covered List sectors,”including UAS and UAS critical components, that could require equipment to undergo FCC certification even when it would otherwise qualify for a different authorization process or be exempt from authorization.<\/p>\n\n\n\n

The FCC is also considering new supply chain disclosure requirements, including hardware and software bills of materials that identify components, their producers, and production locations. Other proposals address the importation and marketing of covered equipment, software and firmware, equipment authorization terms, registration of equipment currently subject to the Supplier’s Declaration of Conformity, and other aspects of the FCC’s equipment authorization system.<\/p>\n\n\n\n

For model aviation, these proposals raise concerns about the availability, cost, and continued development of the equipment and components that hobbyists use every day.<\/p>\n\n\n\n

The FCC’s proposed definition of “UAS critical components” is particularly important. The proposal identifies categories that include data transmission devices, communications systems, flight controllers, ground control stations, navigation systems, sensors and cameras, batteries and battery management systems, and motors that are designed and intended primarily for UAS use.<\/p>\n\n\n\n

Many of these technologies and components have legitimate civilian and recreational applications. AMA believes that the FCC should carefully distinguish equipment that presents a genuine national-security concern from ordinary equipment that is used by recreational modelers, educators, retailers, and other legitimate users.<\/p>\n\n\n\n

Comments on ET Docket No. 21-232 are due September 8, 2026.

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2. Docket No. 26-189: Foreign-Produced UAS and UAS Critical Components<\/strong><\/p>\n\n\n\n

As explained in our previous article<\/a> from August 17, the FCC is considering restrictions on the importation and marketing of certain foreign-produced UAS and UAS critical components.<\/p>\n\n\n\n

AMA’s primary concern with this proposal is its potential treatment of UAS that weigh 55 pounds or more as “military-grade” UAS<\/strong>. That definition could capture large-scale model aircraft that AMA members have safely built and flown for decades under AMA’s established safety programs.<\/p>\n\n\n\n

The proposal also raises concerns that involve other equipment and components, including batteries and charging equipment, as well as potential effects on commercial businesses and educational programs.<\/p>\n\n\n\n

Comments on this proceeding are due September 2, 2026.<\/strong><\/p>\n\n\n\n

If you have not already done so, please see our previous article<\/a> for additional information and comment templates for Docket No. 26-189<\/strong>.<\/p>\n\n\n\n

AMA supports reasonable efforts to protect national security and to strengthen the security of the communications and UAS supply chain. At the same time, policies that are designed to address national security risks should be carefully targeted so that they do not unintentionally restrict legitimate recreational aviation or make ordinary hobby equipment unnecessarily difficult or expensive to manufacture, import, sell, or maintain.<\/p>\n\n\n\n

If you build large-scale model aircraft, purchase equipment from hobby retailers, rely on imported components, operate a hobby shop, teach students using model aircraft, participate in competitions, or simply enjoy the hobby, your firsthand experience can help the FCC understand the real-world consequences of these proposals.<\/p>\n\n\n\n

Your comment does not need to be lengthy or technical. The most useful comments explain how you participate in model aviation and how a particular proposal could affect you. A template for ideas and guidance can be found at the bottom of this article, along with instructions on how to submit public comments.



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Please reference the two FCC Dockets and their comment deadlines below<\/em><\/p>\n\n\n\n

Docket<\/strong><\/td>Issue<\/strong><\/td>Comment Deadline<\/strong><\/td><\/tr>
26-189<\/strong><\/td>Foreign-produced UAS and UAS critical components, including the proposed 55-pound “military-grade” definition<\/td>September 2, 2026<\/strong><\/td><\/tr>
21-232<\/strong><\/td>Broad changes to FCC equipment authorization and supply-chain requirements<\/td>September 8, 2026<\/strong><\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n

If you want your concerns considered in both proceedings, you should submit a separate comment to each docket.<\/p>\n\n\n\n

The model aviation community has an opportunity to make sure that the FCC understands how these proposals could affect our hobby. Please take a few minutes to make your voice heard.<\/p>\n\n\n\n

These comments are an important part of that effort, but they are not the only action being taken. AMA is actively engaging with federal policymakers, government agencies, industry partners, and other stakeholders to pursue additional avenues for protecting recreational model aviation and addressing the potential impacts of these proposals. Member comments help strengthen those efforts by demonstrating the breadth of the model aviation community and providing policymakers with firsthand accounts of how these policies could affect real people, businesses, educators, and organizations.

Comment Submission Steps \u2013 ET Docket 21-232<\/u><\/em>

Step 1.<\/strong> Download the template below, add a signature, and the desired personal details. The template given addresses technical aspects, but members are encouraged to incorporate their personal experiences with aviation.


Step 2.<\/strong> Follow this link to the Federal Comment portal

– https:\/\/www.fcc.gov\/ecfs\/filings\/express<\/a><\/p>\n\n\n\n


Step 3. <\/strong> At the top of the form, you must<\/strong> enter \u201c21-232\u201d into the text box marked:

 “*Proceeding(s): Specify the FCC proceeding(s) to which your filing refers\u201d


<\/em>Step 4.<\/strong> Provide personal information as required.


Step 5.<\/strong> Copy information from the completed template and paste into the primary comment box. You may then review and submit the comment. The form allows for email confirmation, if you desire.

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