Comments from District I on FAA/DOT Proposed sUAS/model-aircraft Registration

     Andy Argenio DI VP 

 On October 22 the DOT/FAA’s announced that      they intended to have a registration process        created and implemented for sUAS/model-aircraft  before Christmas. They provided for a comment period up to November 6. With only 350 comments submitted by November 2nd, the AMA sent a request to its members who in the next few days brought the total comments up to over 4,500 as of November 6th. 

    I have summarized in the rest of this column some of the comments and suggestions that I have heard from AMA members along with what I posted to the government website.

    Nearly all AMA members believe that we should be excluded from any registration process, whether the process involves registering the operators or their aircraft. AMA’s National Safety Code, Item 2, Section (f), of AMA membership, requires AMA members to affix their name, address, and AMA license number in or on their UAS/model-aircraft. We have been doing this for years and feel that the ID information on our aircraft should satisfy the government’s ability to identify an owner of a model aircraft involved in an incident with the process we use. This would considerably reduce the cost to the government to create and maintain a mandated registration system for AMA members. The FAA would remain in compliance with Public-Law-112-95 Section 336, if they exempted us from this registration process.

    AMA members also disagree with the FAA/DOT that we are subject to the rules for registration of manned aircraft in the Federal Aviation Regulations (FAR). To date the only rule in the FAR that the court has said applies to model aircraft is 91.13 for “careless and reckless flying”. 

    The FAA needs to complete its responses to the 34,000 comments submitted on FAA’s interpretation of section 336 of PL-112 before implementing a registration process that includes members of a community based organization (CBO). 

    Members have expressed their concern that the FAA have relied on unquantified and unqualified UAS/model-aircraft incident reports to prompt the necessity for UAS registration. AMA’s analysis report of the incidents clearly indicates that the number of “near misses” appear to be in the dozens, not nearly a thousand, based on notations in the FAA’s records. 

    Most members believe that an attempt to create an easy to use electronic registration system, for implementation by mid-December, is unlikely to be completed in the time allotted. AMA members would rather have sufficient time for a process to be proposed and vetted through the NPRM as required in the administrative procedure act (APA) to provide an adequate comment period and FAA response time before a registration system is placed in the FAR as a regulation or policy.

    If registration is unavoidable, members told me they would only be willing to register their name and address. They would be unwilling to register each of their aircraft especially were they have already affixed their contact information on them. As we are learning, AMA member’s 79 years of operating model aircraft safely and responsibly in accordance with AMA’s National Safety Code has only temporarily excluded us from FAA regulations. 



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