FAA Register Model-Aircraft

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drone sold today won’t continue to fly once the model aircraft exceeds the very limited range of the transmitter, the motors progressively slow down until the aircraft is on the ground


2. All sUAS/model aircraft over 250 gr. (8 oz.) must be registered.

Oppose - AMA members should be excluded from any registration process. AMA’s National Safety Code, Item 2, Section (f), of AMA membership, requires AMA members to affix their name, address, and AMA license number in/on their UAS/model-aircraft. The government’s ability to identify an AMA owner of a model aircraft involved in an incident already exists. This would considerably reduce the cost to the government to create and maintain a mandated registration system for AMA members. Adding an additional requirement for AMA members to register at the federal level is contrary to the intent of the Special Rule for Model Aircraft in the FAA Modernization and Reform Act of 2012. Public Law clearly states that the FAA is prohibited from promulgating any new rules for recreational users operating within the safety guidelines of a community-based organization.


3. All sUAS/model aircraft are subject to manned aircraft rules published in Federal Aviation Regulations (FAR).

Oppose - To date the only rule in the FAR the court has said applies to model aircraft is 91.13 for “careless and reckless flying”. The FAA has not completed its responses to the 34,000 comments submitted on the FAA’s interpretation of Public Law 112-95 Section 336 nor have they responded to the 3,800 comments on Notice of Proposed Rule Making (NPRM) and should do so before creating any regulation for AMA members.


4. The DOT/FAA claim emergency action is necessary because of "Close Call" incidents involving drones and manned aircraft.

Oppose -The DOT/FAA have relied on unquantified and unqualified UAS/model-aircraft/drone incident reports. If the FAA media release in August that stated “Pilots Report Close Calls with Drones Soars in 2015” could be substantiated, then the FAA would be able take emergency action to create a regulation requiring registration. Otherwise, the FAA should have followed administrative procedure act involving a complete NPRM process.The AMA detailed analysis in September of the FAA data found that of the 764 incidents reported, only 27 were identified as “close calls” and of those 27 the most serious incidents including actual crashes involved government authorized military drones not civilian. Other flights were in compliance with operating legally. The data doesn’t support that consumer drone operators were causing serious problems requiring emergency action. Additional, no AMA members were found to be involved in any “close call’ incidents.


Including AMA members in a registration process for sUAS/model aircraft may be setting the stage for who knows how many more manned federal aviation regulations the FAA wants to turn into unmanned model aircraft regulations. AA



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