[NSRCA-discussion] FAA Registration begins December 21

Thu Dec 17 13:23:59 AKST 2015

Dear AMA Members,

Yesterday, the AMA Executive Council unanimously approved an action plan to
relieve and further protect our members from unnecessary and burdensome
regulations. This plan addresses the recently announced interim rule
requiring federal registration of all model aircraft and unmanned aircraft
systems (UAS) weighing between 0.55 and 55 pounds.

AMA has long used a similar registration system with our members, which we
pointed out during the task force deliberations and in private
conversations with the FAA. As you are aware, AMA's safety program
instructs all members to place his or her AMA number or name and address on
or within their model aircraft, effectively accomplishing the safety and
accountability objectives of the interim rule. AMA has also argued that the
new registration rule runs counter to Congress' intent in Section 336 of
the FAA Modernization and Reform Act of 2012, otherwise known as the
"Special Rule for Model Aircraft."

The Council is considering all legal and political remedies to address this
issue. We believe that resolution to the unnecessary federal registration
rule for our members rests with AMA's petition before the U.S. Court of
Appeals for the District of Columbia. This petition, filed in August 2014,
asks the court to review the FAA's interpretation of the "Special Rule for
Model Aircraft." The central issue is whether the FAA has the authority to
expand the definition of aircraft to include model aircraft; thus, allowing
the agency to establish new standards and operating criteria to which model
aircraft operators have never been subject to in the past.

In promulgating its interim rule for registration earlier this week, the
FAA repeatedly stated that model aircraft are aircraft, despite the fact
that litigation is pending on this very question. The Council believes the
FAA's reliance on its interpretation of Section 336 for legal authority to
compel our members to register warrants the Court's immediate attention to
AMA's petition.

While we continue to believe that registration makes sense at some
threshold and for flyers operating outside of a community-based
organization or flying for commercial purposes, we also strongly believe
our members are not the problem and should not have to bear the burden of
additional regulations.  Safety has been the cornerstone of our
organization for 80 years and AMA's members strive to be a part of the
solution.

As we proceed with this process, we suggest AMA members hold off on
registering their model aircraft with the FAA until advised by the AMA or
until February 19, the FAA's legal deadline for registering existing model
aircraft.

Holding off on registration will allow AMA time to fully consider all
possible options. On a parallel track, it also allows AMA to complete
ongoing conversations with the FAA about how best to streamline the
registration process for our members.

In the near future, we will also be asking our members to make their voices
heard by submitting comments to the FAA's interim rule on registration. We
will follow-up soon with more detailed information on how to do this.

Thank you for your continued support of AMA. We will provide you with more
updates as they become available.

Kind regards,

The AMA Executive Council

Bob Brown, AMA President
Gary Fitch, AMA Executive Vice President
Andy Argenio, AMA Vice President, District I
Eric Williams, AMA Vice President, District II
Mark Radcliff, AMA Vice President, District III
Jay Marsh, AMA Vice President, District IV
Kris Dixon, AMA Vice President, District V
Randy Cameron, AMA Vice President, District VI
Tim Jesky, AMA Vice President, District VII
Mark Johnston, AMA Vice President, District VIII
Jim Tiller, AMA Vice President, District IX
Lawrence Tougas, AMA Vice President, District X
Chuck Bower, AMA Vice President, District XI

On Thu, Dec 17, 2015 at 2:22 PM, Dennis Bodary via NSRCA-discussion <
nsrca-discussion at lists.nsrca.org> wrote:

> And now the AMA says hold off on registering your aircraft
> --------------------------------------------
> On Thu, 12/17/15, Scott McHarg via NSRCA-discussion <
> nsrca-discussion at lists.nsrca.org> wrote:
>
>  Subject: Re: [NSRCA-discussion] FAA Registration begins December 21
>  To: "Ted Sander" <tedsander at comcast.net>, "General pattern discussion" <
> nsrca-discussion at lists.nsrca.org>
>  Date: Thursday, December 17, 2015, 5:16 PM
>
>  Sorry, that was page 36 for
>  non-political individuals.
>
>  Scott A. McHarg
>  VSCL / CANVASS U.A.S. Research
>  PilotTexas A&M UniversityPPL -
>  ASEL
>
>  On Thu, Dec 17, 2015 at
>  4:13 PM, Scott McHarg <scmcharg at gmail.com>
>  wrote:
>  According to them.....
>  http://www.faa.gov/news/updates/media/2015-12-13_2120-AK82_RIA.pdf
>
>  "Benefits" start on page
>  29
>  Scott A. McHarg
>  VSCL / CANVASS U.A.S. Research
>  PilotTexas A&M UniversityPPL -
>  ASEL
>
>  On Thu, Dec 17, 2015 at 4:11 PM, Ted
>  Sander via NSRCA-discussion <nsrca-discussion at lists.nsrca.org>
>  wrote:
>   Missing from the official
>  publicity of all this is the “What is this going to
>  do?”.  Is there any “official” information about what
>  registration hopes to accomplish (as opposed to the
>  “they’re coming to get us” theories)?  Even if it was
>  a page of “Know before you fly” info during the
>  registration process, I would be more supportive.  But all
>  I can speculate on is that it is to “Hope we find that one
>  little part that has the registration number on it”.
>  We’ve all seen RC mid-airs and crashes, and know that
>  often full recovery of parts is very difficult.  If
>  something bad happens, the odds seem pretty low that even if
>  there is a number, it will be found and traced to the owner,
>  even if there is one!It would perhaps be better to have
>  the FCC mandate registering receivers/control units that
>  have and “squawk” a unique identifier, than this poorly
>  thought out
>  solution!
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>
>
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-- 
Director, Fixed Wing Flight Training
Santa Clara County Model Aircraft Skypark
Associate Vice President, Academy of Model Aeronautics District X
Treasurer, National Society of Radio Control Aerobatics (NSRCA)
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