Remote ID Progress

The AMA Government Affairs team continues to work toward advocating for a more-inclusive solution to Remote ID.

AMA has been providing sensible recommendations for the hobbyist community to comply with Remote ID since this process started in 2017. The FAA is currently in the process of reviewing more than 50,000 comments that were submitted to the Notice of Proposed Rulemaking (NPRM). We were told that the recreational community had a large impact during the comment period and there were many identified issues with the rule that will need better solutions, which include cost, broadcast abilities, and FAA Recognized Identification Areas.

Through this process, AMA has been collaborating with various security agencies, industry leaders, the DOT, and others to work toward finding a common solution. We believe that the FAA plans to announce a final Remote ID rule by the end of the calendar year. After a final rule has been announced, there will be an implementation period that could take up to three years. This lengthy process allows AMA to continue advocating for a less-extensive solution for hobbyists to comply with Remote ID.

Safety Risk Management Process for Controlled Airspace

The AMA Government Affairs team has been working with clubs that are in controlled airspace to secure Letters of Agreement (LOA) for their flying sites. The FAA Reauthorization Act of 2018 requires all flying sites within controlled airspace to have a LOA with air traffic control (ATC) facilities. Throughout the past year, AMA has been working with a team within the FAA to obtain agreements for approximately 350 clubs. Most clubs had pre-existing agreements in place which helped streamline this process.

There are certain factors that are used to determine altitude limits at flying sites. In controlled airspace, altitudes are preapproved using the FAA’s UAS Facility map values. That stated, many flying sites need altitudes that are above the facility map values, which require a Safety Risk Management (SRM) panel to take place. Clubs can contact AMA and request altitudes higher than the FAA UAS Facility Map. These clubs will then be put on a priority list that AMA provides to the FAA. The requested altitude limit can vary at each flying site and will depend on the operations and safety mitigations that take place at the site.

SRM panels work to identify, analyze, and assess potential safety risks and find mitigations to ensure clubs can continue their safe operations at their flying sites. These panels consist of a trained facilitator on the SRM process, AMA representatives, FAA representatives, subject-matter experts or third-party stakeholders, and panel observers. Some factors that are analyzed include fixed site location in reference to the closest runway surface, airport departures and approach procedures, law enforcement activities, and manned air traffic operations. The goal of the SRM process is to treat any risks that are identified during the process and develop a plan to continue operating safely in the National Airspace System.

By the end of the year, the FAA hopes to provide a checklist in ATC manuals to conduct SRM panels at the local level in hopes of speeding up this process. At this time, there is only a process for SRM panels to be conducted for clubs in controlled airspace. We hope to have a process for clubs in uncontrolled airspace soon. AMA will continue to work with the FAA to advocate for our clubs and members. As always, please contact the Government Affairs department with questions and concerns at (765) 287-1256 or email amagov@modelaircraft.org.

AMA Government Affairs Update 5/22/2020

The AMA Government Affairs team continues to work with Congress and the FAA despite the ongoing pandemic.We have been able to conduct telephone meetings and participate in virtual video conferencing in order to continue our efforts to advocate for the hobby. In the past few weeks, we have seen developments that will impact our hobbyist community.

Throughout the last year, we have been working with clubs in controlled airspace to secure Letters of Agreement (LOA) with local air traffic control (ATC) facilities. In the last few weeks, we have been able to get many of these mutually agreed–upon LOAs signed and we are happy to see that this process is progressing more quickly. In addition to securing LOAs for our clubs, we have also secured a path for night operations at fixed flying sites in controlled airspace. To streamline the LOA process for our clubs, the FAA is working to finalize a LOA checklist that will be used in its ATC manuals.

We continue to conduct Safety Risk Management panels for clubs in controlled airspace that need to fly over the FAA UAS Facility Map altitude. The clubs that have gone through this process have been successful and are being approved for their requested altitudes. This process highlights potential safety risks and results in identifying safety mitigations in order to continue our safe operations.

We are being told that Advisory Circular (AC) 91-57C will be out for public comment sometime soon, and the FAA is working to finalize this AC sometime this calendar year. This AC will include an outline for community-based organization recognition and the recreational Knowledge and Safety test. In addition, we are hearing rumors that the FAA is on schedule for a final rule on Remote ID by the end of the calendar year. Recreational operators had a large impact during the comment period on the NPRM. We have heard that there were many identified issues with the rule that will need better solutions, which include cost, broadcast abilities and FAA Recognized Identification Areas. Again, thank you to everyone who commented on the NPRM.

AMA will continue to work with the FAA to advocate for our members. As always, please contact the Government Affairs department with questions and concerns at (765) 287-1256 or amagov@modelaircraft.org.

Technology Partners for Remote ID Development Announced

On May 8, the FAA sent an email to clarify their recent press release regarding the development of a Remote ID Cohort. Their original email led to confusion among the model aviation community as to what the development of the Cohort meant for the proposed Remote ID rule. The FAA clarified that the Cohort is not part of the decision-making process for the proposed Remote ID final rule. Their mission will be to help the FAA develop technology requirements for other companies to develop applications needed for Remote ID. The FAA is still in the process of reviewing the more than 53,000 comments submitted regarding the proposed rule.

The companies, selected through a Request for Information process in December 2018, are Airbus, AirMap, Amazon, Intel, One Sky, Skyward, T-Mobile, and Wing.

AMA has been advocating for our hobby throughout the entire Remote ID rule process, including applying to be involved in this initial group. However, AMA was not selected due to the technology and communication-based requirements that we do not meet as a community-based organization. Although not selected as a member of the Cohort, we will continue developing our existing partnerships with companies involved, Congress, the FAA, and other industry partners to find common sense solutions for Remote ID requirements that work for our community.

Please continue to monitor your email and modelaircraft.org for updates regarding remote ID.

For an update on AMA’s Government Affairs advocacy work, listen to episode 34 of the AMA

Podcast. 

AMA Government Affairs Update 4/1/2020

Due to COVID-19, the Government Affairs team is working remotely to continue our advocacy efforts. The safety of our staff, members, and community is AMA’s top priority and unfortunately, COVID-19 has affected certain ongoing projects. The FAA has temporarily put Safety Risk Management (SRM) panels on hold until further notice. However, we are continuing altitude limitation conversations with the FAA’s Air Traffic Operations, Flight Standards, and UAS Integration Offices. Before the COVID-19 stay-at-home guidance was issued, two SRM panels were successfully conducted and both clubs were able to show that safety risks could be mitigated to an acceptable level up to their requested altitudes. We are working with the FAA to update the priority list for AMA clubs in controlled airspace that would like to go through the SRM process. In our discussions with the FAA, we are also exploring options for a waiver process for fixed sites in uncontrolled (Class G) airspace.

AMA continues the fight against the FAA’s remote ID proposal. We have been meeting with multiple industry leaders, such as EAA, Google, and AOPA, to come together as one voice and discuss a sensible, inclusive approach to the remote ID rulemaking. On March 12, the FAA released a Request for Information (RFI) to seek input regarding Low Altitude Manned Aviator Participation in UAS Remote Identification. The RFI calls on operators of manned aircraft who operate at low altitudes to comment how their operations would be impacted by remote ID and to see how they can receive and use the network or broadcast UAS remote ID information. They also want to engage low altitude manned aviators and others who are interested in exploring how UAS Remote ID can improve safety and reduce collision risk between UAS and manned aircraft at low altitudes. AMA will continue working with our allies to bring the best possible outcome regarding remote ID.

In addition, we are reviewing an executive order that has been drafted by the Trump administration which would ban the federal government’s use of foreign made UAS, including model aircraft. The executive order would bar federal government departments and agencies from procuring, repairing or servicing a UAS manufactured “in whole or in part” by any company from a foreign country viewed to be “engaged in a long-term pattern or serious instances of conduct significantly adverse to the national security of the United States or its allies.” The government would also seek to stop anyone with a federal contract, agreement, or grant from using a foreign-made UAS and stop people from flying them on or over federally-managed or owned lands. This order could impact AMA members operating on military property, National Parks, Army Corps of Engineer lands, and EPA managed sites. AMA is trying to work with the White House and Office of Management and Budget to shape the draft language before the executive order is signed by the president. We will share any updates regarding this executive order when we learn more.

Kind Regards,
AMA Government Affairs

A new coalition has launched to protect the model aviation hobby industry, starting with the fight for a better rule on remote identification of unmanned aircraft systems (UAS). The coalition includes aviation associations, hobby shops and manufacturers. As a united front and voice, the AMA Coalition has been sharing their concerns regarding the proposed rules on remote ID on Capitol Hill this week. Many offices acknowledged that the proposed rule goes much too far. While most offices were aware of the modeling community’s dissatisfaction, they had failed to grasp the extreme approach outlined in the proposed rule. The coalition helps to show that AMA is not the only one concerned with Remote ID. Representative Woodall noted that our strength in numbers is impactful since AMA has previously been the only group to bring about concerns regarding the proposed rules on Remote ID. To learn more about the AMA Coalition, visit modelaircraft.org/govcoalition.

The coalition has visited the following office’s and the message is being well-received:
Angie Craig, Representative of Minnesota
Eleanor Holmes Norton, Representative District of Columbia
Garret Graves, Representative of Louisiana
Greg Pence, Representative of Indiana
Kyrsten Sinema, Senator, Arizona
Paul A. Gosar, D.D.S., Representative of Arizona
Pete Stauber, Representative of Minnesota
Rob Woodall, Representative of Georgia
Rodney Davis, Representative of Illinois
Ross Spano, Representative of Florida
Steve Cohen, Representative Tennessee
Committee on Commerce, Science, and Transportation
Committee on Transportation and Infrastructure Majority Staff

Earlier this month, AMA, the Experimental Aircraft Association (EAA) and several other groups requested that the FAA extend the official comment period on the proposed rule for remote identification of UAS (remote ID). We were informed today that the FAA has declined this request. The comment period will end on March 2, 2020.

Fighting for a better remote ID rule continues to be AMA’s top priority. To achieve the best possible outcome, we need everyone in the model aviation community to help.

Please submit a formal comment to the FAA ASAP, before the deadline on March 2, 2020.

AMA HQ has drafted several template comments that you may use as guidance when writing your own comment. We strongly encourage you to make your comment personal and to highlight your own concerns with the proposed rule. AMA members are all unique, and we fly a number of different disciplines that will be impacted in different ways by this rule. It is important that we tell the FAA how each of us will be impacted individually and emphasize they cannot force us into a one-size-fits-all approach.

Please contact AMA’s government affairs team at 765-287-1256 or amagov@modelaircraft.org with any additional questions or concerns.

On December 26, the FAA released a proposed rule for remote identification of UAS. There are several areas of concern with the proposed rule that AMA will be pushing back on and we need your help advocating for change. We encourage everyone to submit a comment to the FAA’s proposed rule for remote ID. The comment period is open until March 2, 2020. AMA has drafted multiple templates that you may use as guidance when forming personal comments. When writing your comment, please identify your own concerns with the proposed rule. It is important to provide a summary of how the proposal will impact your model aircraft operations and include data to back up those concerns. For example, use numbers and address the financial impact the proposal will have on you and suggest alternative solutions.

Please submit a formal comment to the FAA as soon as possible.

To submit a comment, go to the remote ID proposal page on the federal website here. Click on the green “SUBMIT A FORMAL COMMENT” button at the top right-hand side of the page. Complete the form and click on the “SUBMIT COMMENT” button at the end. Please note that comments and information provided are public knowledge. Click below to use the drafted templates to express your concerns. You may submit more than one comment.

Template Comment on UAS Remote ID: General

Template Comment on UAS Remote ID: Registration

Template Comment on UAS Remote ID: Education

Template Comment on UAS Remote ID: Amateur-Built Aircraft

Please take into account that these are templates that can be used to frame your individual thoughts on the NPRM. All comments are taken into account and every comment matters. Contact our government affairs team at 765-287-1256 or amagov@modelaircraft.org with any additional questions or concerns. The latest information can be found at www.modelaircraft.org/gov, Model Aviation, and on social media.

The week of January 13, the Government Affairs team traveled to Washington, DC to address AMA’s concerns with the proposed Remote ID rule. AMA met with multiple congressional offices to discuss the impact the proposed rule would have on all aspects of the hobby. We were able to share our community’s concerns regarding the NPRM and gained support from many on Capitol Hill. Many members of Congress have agreed to contact the FAA regarding our concerns. Furthermore, there are many stakeholders within the industry that are equally concerned with the Remote ID NPRM, and AMA is working with those organizations to show a united front against the proposal. AMA wants to come together as an industry to find a solution to Remote ID that promotes compliance from recreational users, one that makes sense and is not overly burdensome for users. Soon, we will be asking members to contact their senators and representative.

Additionally, AMA attended a meeting with the FAA and the 11 other organizations that were selected to make recommendations for the upcoming recreational knowledge and safety test. We learned that many of the elements we advocated for regarding the recreational knowledge and safety test were accepted. AMA is working to find the best solution to provide the test to our members while ensuring a sensible approach and privacy concerns are addressed. The test is expected to be rolled out sometime in 2020.

Please contact our government affairs team at 765-287-1256 ext 236 or amagov@modelaircraft.org with any additional questions or concerns. The latest information can be found at www.modelaircraft.org/gov, Model Aviation, and on social media.

Template Comment on UAS Remote ID

I am writing in response to the FAA’s notice of proposed rulemaking on remote identification of unmanned aircraft systems (UAS). I am deeply concerned that some elements of the proposal could impose significant costs on the model aviation community and unnecessarily restrict existing, safe model aircraft operations.

First, while I am glad the proposal includes an option to comply with remote ID by flying at an approved fixed site, I am concerned that the rule arbitrarily limits the number of approved sites and prohibits the establishment of new sites. As such, the rule appears designed to phase out these sites over time, rather than treat them as a viable long-term option for complying with remote ID. I encourage the FAA to view fixed flying sites as part of a viable long-term solution to remote ID and to amend the rule to allow for the establishment of new sites in the future.

Second, the FAA must create a pathway for remote ID compliance at AMA events and competitions, which may not take place at fixed flying sites. These events take place in defined locations for a short period of time, like an air show. For remote ID compliance purposes, they should be treated like fixed flying sites. I encourage the FAA to create a light process for event organizers to apply for and receive, waivers from remote ID requirements for these ad hoc events and competitions, many of which support local charities.

Third, the rule must consider hobbyists who fly in rural areas with little or no internet connectivity. As I read the proposed rule, I could be required to have an internet connection even if flying at an approved fixed flying site in a rural part of the country. Unfortunately, some rural areas don’t have adequate cell service, which means I could not be able to fly under the limited remote ID option. Rural locations are frequently the safest places to fly because they are away from people, other aircraft and structures. The FAA needs to provide a solution for these areas, such as the ability to comply from home or other WIFI-enabled locations.

Finally, the FAA should reconsider the proposal to register each aircraft, which will impose a cost and compliance burden on the model aviation community. While individual registration may make sense for beyond line of sight operations, it is an unnecessary requirement for aircraft designed to be flown within line of sight. We build and fly model airplanes because it is a passion; and many of us own dozens, if not hundreds, of aircraft of different shapes and sizes, some of which we fly infrequently. The time and cost involved in registering each model individually would be substantial and runs counter to the current registration framework for recreational operators. Also, aircraft that are built by hand do not have serial numbers, which makes individual registration more difficult.

Again, I urge you to carefully consider and address my concerns about the remote ID proposal. Model aviation is the natural precursor to careers in aviation, including commercial pilots and engineers and more – jobs which the U.S. desperately needs to fill. Model aviation supports a $1 billion hobby industry responsible for thousands of existing U.S. jobs. We simply cannot afford to further harm the model aviation hobby with overly burdensome requirements.

Use this template to form your comment on the federal website here.