[NSRCA-discussion] FW: Hold Off On Registering Model Aircraft

Mon Dec 21 05:41:04 AKST 2015

From: Academy of Model Aeronautics [mailto:AMA at modelaircraft.org] 
Sent: Thursday, December 17, 2015 4:19 PM
To: drmikedds at sbcglobal.net
Subject: Hold Off On Registering Model Aircraft

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Academy of Model Aeronautics
Member Communication

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Thursday, December 17, 2015

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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 

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