Category Archives: AMA

URGENT ACTION NEEDED – Unite Against Proposed “Remote ID” Rulemaking

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Dear Members,

AMA Government Affairs sent us an email relating to FAA's recent Notice of Proposed Rule Making (NOPR) for "Remote ID" of UAS.  As written, this NOPR could have significant, negative impact to the modeling community and how we may conduct our hobby.  However, as usual, AMA Government Affairs does have a plan and a strategy to work with the FAA to achieve the best possible outcome (on the final rule) for its membership.  But, they need our help!

The comment period for the NOPR on Remote ID is open now.  AMA is requesting, and the Board of AAM strongly agrees, that all AMA members (and other interested parties) provide comment to FAA.  As usual, AMA has automated this process.  The instructions and link, for providing comment may be found below (in the email from AMA Government Affairs).  To begin, simply click on the "COMMENT NOW" button below.  However, you will also need to "cut and paste" the text from AMA's Template Comment into the comment box.  The Template Comment appears below.

Please note that comments are more effective if they are customized and personalize.  AMA is encouraging everyone to edit the template to include your personal experience, or create your own message entirely.  I have included a copy of my Comment on AAM's website as an example.

The comment period ends 3/2/2020, but please don't delay, DO IT TODAY!!!

Thanks in advance for your cooperation,

Joe Pirozzoli, President
Arvada Associated Modelers

AMA’s 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 would 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. 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. 

You can also view some detailed comments made by Gordon Collyer below.

[gview file="https://www.arvadamodelers.com/wp-content/uploads/Detailed-Remote-ID-Comments1.16.20.pdf"]

Consequences and Impact of the “FAA REAUTHORIZATION ACT OF 2018”

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Members,

First, I want to thank everyone that participated in the call to action to oppose this legislation.  Unfortunately, and despite our best efforts, President Trump signed the FAA Reauthorization Act of 2018 (“2018 Act”) into law on Oct 5, 2018.  Sad news to be sure, yet according to AMA, our voices were heard loud and clear and AMA is still in negotiations with the FAA as it pertains to certain provisions of the 2018 Act.

How is the 2018 Act different than the legislation that was passed in 2012 (i.e. the “FAA Modernization and Reform Act of 2012)?  Primarily, as it pertains to modelers and hobbyists, the 2018 Act no longer has a “Special Rule for Model Aircraft” (formerly referred to as Section 336).  There are, however, several provisions in the 2018 Act relating to our hobby that were championed by our government affairs team at AMA.  Some of these provisions require continued dialogue and coordination with the FAA.  The provisions, in the 2018 Act, which primarily impact our hobby are contained in Section 349 (please see attached).  One of the most impactful provisions of Section 349 is the rule limiting operation of aircraft to no more than 400 feet above ground level.

Fortunately, according to AMA, there are NO changes that AMA members need to follow immediately.

AMA is telling its members that we should continue to fly in accordance with AMA’s safety guidelines and local club rules, and that existing agreements between AMA clubs and the FAA should continue to be followed.  I would add that neither AAM nor the City of Arvada are in a position or inclined (in any way) to enforce FAA regulations at this time.

The most important take-a-way from all of this is that, for now, we are operating under the same set of AMA guidelines and Club rules that have always been in place.  Of utmost importance to our future, is the continued safe operation of model aircraft according current AMA and Club rules as AMA continues to work cooperatively and diligently with FAA’s leadership in Washington to address the issues that impact our hobby.  

You can learn more about this legislation and the work that AMA is doing with the FAA at this link:

https://www.modelaircraft.org/about-ama/advocacy

Lastly, the end of the year is quickly approaching.  I would like to encourage everyone, especially those of you who have calendar year renewals, to get your AAM and AMA memberships renewed soon.

Best regards and happy holidays,

Joe Pirozzoli, Director Public Relations
Arvada Associated Modelers

URGET ACTION REQUIRED! Ask Congress to Vote “NO” on FAA Reauthorization!

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Once again, we are in a battle for our rights and freedom as responsible, law-abiding modelers.
 
The last time I wrote you, we were trying to protect Section 336 (i.e. the Special Rule that protected model aircraft).  This new Bill (H.R. 302) repeals Section 336 and replaces it with a much more restrictive and onerous rules (i.e. Section 349 – see link below or the attached document).  I’ve highlighted critical items in the attached document.
 
“As written, this bill puts our community (modelers) under the authority of the FAA, which means the agency can, at any time, impose additional regulations on model aircraft. In addition, the bill specifically imposes a 400′ altitude limit on model aircraft operating within the programming of a community-based organization (CBO), which will curtail long-standing AMA competitions and events that support local charities and non-profits. These and other changes will make it even more difficult to fly and will stifle the broader benefits of model aviation to STEM education and the broader aviation community.

It is important for you to know that this bill has not yet been voted into law. This is a critical moment and Congress needs to hear from our members on the harm this bill would do to our safe, long-standing hobby.“

 
The easiest way for you to write your representatives is to use the link below.  However, I highly encourage you to personalize the form letter provided.  Edit the letter to described how this legislation will also impact your individual and community activities!
 
 
Form letter provided:
 
*******
Dear [Official],
 
I am a model aviation hobbyist and I am deeply concerned about the impact the FAA Reauthorization Act of 2018 would have on my community, given the modifications made to the Special Rule for Model Aircraft, also known as Section 336.  I strongly urge you to vote “no” on the FAA bill. 
 
The current language in this bill is a non-starter. It puts unnecessary and burdensome restrictions in place that will curtail – or even cancel – long-standing model aviation competitions and events, which support local charities and non-profits. Beyond harming charities, the bill may stifle the benefits of model aviation to STEM education and manned aviation. Model aviation hobbyists have been flying safely in the skies since before the FAA was even created. We’re not the problem. Yet, this bill will deal a devastating blow to our hobby and the many local communities, charities and educational programs we support. On behalf of hobbyists like me across the country, I urge you to vote “no” on the FAA Reauthorization Act of 2018.
 
Sincerely,
[Your Name]
*******
 
Thanks, and please DO NOT hesitate, ACT NOW!!!  It is extremely important that WE ALL participate in this movement.

AMA Requests Help to Protect Section 336

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The AMA has sent out the following email:

Dear AMA club leaders,

Most of you have probably read our recent letter to AMA members, requesting help to protect the Special Rule for Model Aircraft (Section 336). We are requesting our clubs’ assistance to reach as many model aircraft enthusiasts as possible and amplify our message.

Congress has begun drafting language to address Section 336.  During this process, some are asking for the repeal of Section 336 – which has allowed AMA to manage our members and fly safely and responsibly, as we have for over 80 years. Losing the Special Rule would be an enormous burden for our hobby.

There are currently two paths to fly legally in the U.S. – either under Section 336 or under the FAA’s Small UAS Rule (Part 107).  If Section 336 is repealed, everyone will have to take an in person test, pay for a remote pilot’s certificate, and fly under Part 107 rules.  Under Part 107, an individual must be at least 16 years of age to obtain the remote pilot’s certificate, so this path leaves AMA’s 50,000 youth members unable to fly.

This is a critical moment to let your elected representatives know the importance of Section 336 to education, innovation, and hobbyists. You can help by doing the following:

  1. Share AMA’s Facebook and Twitter posts to contact their legislators.
  2. Forward this email (or the original email request) to your club member list, in case our membership records do not contain a person’s most current email address or as a reminder to those that have not yet contacted their representatives. 
  3. Mention this campaign at the flying site and during your next meeting to your members that may not utilize email or social media.

Please ask everyone to click here to send a letter to your elected representatives in support of the Special Rule for Model Aircraft. In addition to sending a letter, you will also have an opportunity to call your representatives. We encourage everyone to take the time for this as well.

We need your help to demonstrate the value of the Special Rule for Model Aircraft for our community and future generations of hobbyists. We appreciate your assistance in protecting Section 336 and promoting the safe integration of model aircraft into the national airspace system.

Sincerely,

AMA Government Affairs

AMA ALERT: RESPONSE NEEDED to FAA Model Aircraft Registration Rule

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Dear AAM Members,

Hopefully by now you have received an email from AMA or have visited the AMA website to learn about the FAA’s recent “Registration and Marking Requirements for Small Unmanned Aircraft” rule and that the AMA has suggested to wait until the FAA registration deadline of February 19, 2016 at the latest to register.  This will give the AMA more time to fight this registration from at least two known fronts: challenging the definition of “aircraft” and working with the FAA to exclude AMA members from the registration. The ultimate goal is to get Congress to throw out the FAA rule on model aircraft registration altogether (impacts all modelers), but in the event that doesn’t work, the hope would be that AMA membership is sufficient registration for the FAA and only non-members would have to comply with this new registration rule. AMA’s public stance is its membership body hasn’t been the problem so they shouldn’t have to be included in the FAA registration.

It is extremely important that every single one of us respond to the FAA’s UAS Registration rule because of its highly aggressive approach and potential detriment to our hobby.  The response deadline is January 15, 2016 so please do not delay.  YOU MUST RESPOND!

There are four ways to respond, but easiest way by far is via email as follows:

Email: Go to http://www.regulations.gov which posts the rule for your review. Follow the online instructions for sending your comments electronically.

It is important to respond in a thoughtful and meaningful manner.  Please refer to the following link for: Tips for submitting your comments.

The following Summary of tips are meant to help you submit comments that have an impact and which will help agency policy makers improve federal regulations.

Summary

  • Read and understand the regulatory document you are commenting on.
  • Feel free to reach out to the agency (or others within AAM) with questions.
  • Be concise but support your claims.
  • Base your justification on sound reasoning, scientific evidence, and/or how you will be impacted.
  • Address trade-offs and opposing views in your comment.
  • There is no minimum or maximum length for an effective comment.
  • The comment process is not a vote – one well supported comment is often more influential than a thousand form letters.

Additional Resources

  • The AMA provided guidance for commenting on the FAA UAS Registration interim rule
  • The PDF of the presentation given at the AAM January 2016 club meeting
  • Here is an example of a well-written and detailed response for your reference.  Please note, this is not an official position or response by AAM or its Board of Directors.

For more information or questions, please contact any of the AAM board members.

Thank you and please act quickly!

AMA ALERT: RESPONSE NEEDED to FAA Model Aircraft Rule

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Dear AAM Members,

Hopefully by now you have received an email from AMA or have visited the AMA website to learn about the FAA’s recent “Interpretation of the Special Rule for Model Aircraft” as it pertains to “FAA Modernization and Reform Act of 2012.”

It is extremely important that every single one of us respond to the FAA’s interpretation because of its highly aggressive approach and potential detriment to our hobby.  The response deadline is September 23, 2014 so please do not delay.  YOU MUST RESPOND!!

There are 4 ways to respond (please see details below), but easiest way by far is via email as follows:

Email: Go to http://www.regulations.gov. Follow the online instructions for sending your comments electronically.

It is important to respond in a thoughtful and meaningful manner.  Please refer to the following link for: Tips for submitting your comments.

The following Summary of tips are meant to help you submit comments that have an impact and which will help agency policy makers improve federal regulations.

Summary

  • Read and understand the regulatory document you are commenting on.
  • Feel free to reach out to the agency (or others within AAM) with questions.
  • Be concise but support your claims.
  • Base your justification on sound reasoning, scientific evidence, and/or how you will be impacted.
  • Address trade-offs and opposing views in your comment.
  • There is no minimum or maximum length for an effective comment.
  • The comment process is not a vote – one well supported comment is often more influential than a thousand form letters.

Additional Documents and Resources

Additional information and interpretation of the FAA’s intent provided by Joe Falconer:

  1. Section 336 also prohibits the FAA from promulgating “any rule or regulation regarding a model aircraft, or an aircraft being developed as a model aircraft” if the following statutory requirements are met:
    • The aircraft is flown strictly for hobby or recreational use;
    • The aircraft is operated in accordance with a community-based set of safety guidelines and within the programming of a nationwide community-based organization;
    • The aircraft is limited to not more than 55 pounds unless otherwise certified through a design, construction, inspection, flight test, and operational safety program administered by a community-based organization;
    • The aircraft is operated in a manner that does not interfere with and gives way to any manned aircraft; and (This is the FAA’s way of leaving room for future changes in dealing with UAVs and the NAS. Notice this has never changed.)
    • When flown within 5 miles of an airport, the operator of the aircraft provides the airport operator and the airport air traffic control tower…with prior notice of the operation…
  2. (AMA) FAA interpretive rule Negates Congress’ intentions:
    • The FAA is stating, “the prohibition against future rulemaking is not a complete bar on rulemaking that may have an effect on model aircraft.” The rulemaking limitation applies only to rulemaking actions specifically “regarding a model aircraft or an aircraft being developed as a model aircraft.”
    • Therefore the rulemaking prohibition would not apply in the case of general rules that the FAA may issue or modify that apply to all aircraft, such as rules addressing the use of airspace for safety or security reasons.
    • The statue does not require FAA to exempt model aircraft from those rules because those rules are not specifically regarding model aircraft.
    • The FAA interprets the section 336 rulemaking prohibition as one that must be evaluated on a rule-by-rule basis.
  3. FPV – VLOS:
    • Aircraft must be visible at all times to the operator
    • That the operator must use his or her own natural vision (corrected if needed by standard eyeglasses or contacts)
    • People other than the operator may not be used in lieu of the operator for maintaining visual line of sight.  ***** Under the criteria above, visual line of sight would mean that the operator has an unobstructed view of the model aircraft. *****
    • While the statute would not preclude using an observer to augment the safety of the operation, the operator must be able to view the aircraft at all times.
  4. Commercial – Any operation not conducted strictly for hobby or recreation purposes could not be operated under the special rule for model aircraft. Clearly, commercial operations would not be hobby or recreation flights. 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.

For more information or question, please contact Joe Pirozzoli or Joe Falconer.

Thanks, and please act quickly!