[NSRCA-discussion] FAA Registration begins December 21

Peter Vogel vogel.peter at gmail.com
Thu Dec 17 14:17:19 AKST 2015


Because, as I anticipated earlier this week, this is a sufficient
"enforcement action" to wake up the lawsuit the AMA filed in 2014 based on
the FAA's interpretation document for the special rule for model aviation.

Peter+

On Thu, Dec 17, 2015 at 3:03 PM, Randy Forbus via NSRCA-discussion <
nsrca-discussion at lists.nsrca.org> wrote:

>
> Now why is AMA asking us to hold off registering
>
> ------------------------------
> *From:* NSRCA-discussion <nsrca-discussion-bounces at lists.nsrca.org> on
> behalf of Keith Hoard via NSRCA-discussion <
> nsrca-discussion at lists.nsrca.org>
> *Sent:* Thursday, December 17, 2015 10:55 PM
> *To:* 'General pattern discussion'
>
> *Subject:* Re: [NSRCA-discussion] FAA Registration begins December 21
>
>
> 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>
> 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> 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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-- 
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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