[NSRCA-discussion] FAA Registration begins December 21

Thu Dec 17 13:57:12 AKST 2015

Scott,

            You are very correct.  On a practical level, I know that the FAA is critically understaffed and underfunded to the point they can barely keep full-scale aviation policed.  However, the nightmare scenario will now be hanging over the heads of every R/C modeler who relies on their full-scale ticket to make a living or who someday hopes to use it to make their living.

-Keith Hoard

-klhoard at outlook.com

From: NSRCA-discussion [mailto:nsrca-discussion-bounces at lists.nsrca.org] On Behalf Of Scott McHarg via NSRCA-discussion
Sent: Thursday, December 17, 2015 16:32
To: Peter Vogel <vogel.peter at gmail.com>
Cc: General pattern discussion <nsrca-discussion at lists.nsrca.org>
Subject: Re: [NSRCA-discussion] FAA Registration begins December 21

Problem is when the FAA already holds your certification in their hands, what do you do?  To stay out of trouble, I may register anyway.  I couldn't afford to have the FAA pull my certificate for any reason, quite literally.

Scott A. McHarg

VSCL / CANVASS U.A.S. Research Pilot

Texas A&M University

PPL - ASEL

On Thu, Dec 17, 2015 at 4:23 PM, Peter Vogel <vogel.peter at gmail.com <mailto:vogel.peter at gmail.com> > wrote:

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 <mailto: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 <mailto:nsrca-discussion at lists.nsrca.org> > wrote:

 Subject: Re: [NSRCA-discussion] FAA Registration begins December 21
 To: "Ted Sander" <tedsander at comcast.net <mailto:tedsander at comcast.net> >, "General pattern discussion" <nsrca-discussion at lists.nsrca.org <mailto: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 <mailto: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 <mailto: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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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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