Gov. Relations Blog – AMA Officers, Clubs and Members updating and sharing the latest Federal, State and Local government UAS regulatory news pertaining to AMA aeromodeling.

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  • 08 Feb 2020 10:15 PM | Andrew (Administrator)

    A new coalition has launched to protect the model aviation hobby industry, starting with the fight for a better rule on remote identification of unmanned aircraft systems (UAS). The coalition includes aviation associations, hobby shops and manufacturers. As a united front and voice, the AMA Coalition has been sharing their concerns regarding the proposed rules on remote ID on Capitol Hill this week. Many offices acknowledged that the proposed rule goes much too far. While most offices were aware of the modeling community’s dissatisfaction, they had failed to grasp the extreme approach outlined in the proposed rule. The coalition helps to show that AMA is not the only one concerned with Remote ID. Representative Woodall noted that our strength in numbers is impactful since AMA has previously been the only group to bring about concerns regarding the proposed rules on Remote ID. To learn more about the AMA Coalition, visit modelaircraft.org/govcoalition.


    The coalition has visited the following office’s and the message is being well-received:
    Angie Craig, Representative of Minnesota
    Eleanor Holmes Norton, Representative District of Columbia
    Garret Graves, Representative of Louisiana
    Greg Pence, Representative of Indiana
    Kyrsten Sinema, Senator, Arizona
    Paul A. Gosar, D.D.S., Representative of Arizona
    Pete Stauber, Representative of Minnesota
    Rob Woodall, Representative of Georgia
    Rodney Davis, Representative of Illinois
    Ross Spano, Representative of Florida
    Steve Cohen, Representative Tennessee
    Committee on Commerce, Science, and Transportation
    Committee on Transportation and Infrastructure Majority Staff


  • 28 Jan 2020 10:13 PM | Andrew (Administrator)

    Earlier this month, AMA, the Experimental Aircraft Association (EAA) and several other groups requested that the FAA extend the official comment period on the proposed rule for remote identification of UAS (remote ID). We were informed today that the FAA has declined this request. The comment period will end on March 2, 2020.


    Fighting for a better remote ID rule continues to be AMA’s top priority. To achieve the best possible outcome, we need everyone in the model aviation community to help.


    Please submit a formal comment to the FAA ASAP, before the deadline on March 2, 2020.

    AMA HQ has drafted several template comments that you may use as guidance when writing your own comment. We strongly encourage you to make your comment personal and to highlight your own concerns with the proposed rule. AMA members are all unique, and we fly a number of different disciplines that will be impacted in different ways by this rule. It is important that we tell the FAA how each of us will be impacted individually and emphasize they cannot force us into a one-size-fits-all approach.


    Please contact AMA’s government affairs team at 765-287-1256 or amagov@modelaircraft.org with any additional questions or concerns.


  • 20 Jan 2020 10:10 PM | Andrew (Administrator)

    On December 26, the FAA released a proposed rule for remote identification of UAS. There are several areas of concern with the proposed rule that AMA will be pushing back on and we need your help advocating for change. We encourage everyone to submit a comment to the FAA’s proposed rule for remote ID. The comment period is open until March 2, 2020. AMA has drafted multiple templates that you may use as guidance when forming personal comments. When writing your comment, please identify your own concerns with the proposed rule. It is important to provide a summary of how the proposal will impact your model aircraft operations and include data to back up those concerns. For example, use numbers and address the financial impact the proposal will have on you and suggest alternative solutions.


    Please submit a formal comment to the FAA as soon as possible.

    To submit a comment, go to the remote ID proposal page on the federal website here. Click on the green “SUBMIT A FORMAL COMMENT” button at the top right-hand side of the page. Complete the form and click on the “SUBMIT COMMENT” button at the end. Please note that comments and information provided are public knowledge. Click below to use the drafted templates to express your concerns. You may submit more than one comment.


    Template Comment on UAS Remote ID: General

    Template Comment on UAS Remote ID: Registration

    Template Comment on UAS Remote ID: Education

    Template Comment on UAS Remote ID: Amateur-Built Aircraft


    Please take into account that these are templates that can be used to frame your individual thoughts on the NPRM. All comments are taken into account and every comment matters. Contact our government affairs team at 765-287-1256 or amagov@modelaircraft.org with any additional questions or concerns. The latest information can be found at www.modelaircraft.org/govModel Aviation, and on social media.


  • 20 Jan 2020 10:07 PM | Andrew (Administrator)

    The week of January 13, the Government Affairs team traveled to Washington, DC to address AMA’s concerns with the proposed Remote ID rule. AMA met with multiple congressional offices to discuss the impact the proposed rule would have on all aspects of the hobby. We were able to share our community’s concerns regarding the NPRM and gained support from many on Capitol Hill. Many members of Congress have agreed to contact the FAA regarding our concerns. Furthermore, there are many stakeholders within the industry that are equally concerned with the Remote ID NPRM, and AMA is working with those organizations to show a united front against the proposal. AMA wants to come together as an industry to find a solution to Remote ID that promotes compliance from recreational users, one that makes sense and is not overly burdensome for users. Soon, we will be asking members to contact their senators and representative.


    Additionally, AMA attended a meeting with the FAA and the 11 other organizations that were selected to make recommendations for the upcoming recreational knowledge and safety test. We learned that many of the elements we advocated for regarding the recreational knowledge and safety test were accepted. AMA is working to find the best solution to provide the test to our members while ensuring a sensible approach and privacy concerns are addressed. The test is expected to be rolled out sometime in 2020.


    Please contact our government affairs team at 765-287-1256 ext 236 or amagov@modelaircraft.org with any additional questions or concerns. The latest information can be found at www.modelaircraft.org/gov, Model Aviation, and on social media.


  • 03 Jan 2020 10:04 PM | Andrew (Administrator)

    Template Comment on UAS Remote ID


    I am writing in response to the FAA’s notice of proposed rulemaking on remote identification of unmanned aircraft systems (UAS). I am deeply concerned that some elements of the proposal could impose significant costs on the model aviation community and unnecessarily restrict existing, safe model aircraft operations.


    First, while I am glad the proposal includes an option to comply with remote ID by flying at an approved fixed site, I am concerned that the rule arbitrarily limits the number of approved sites and prohibits the establishment of new sites. As such, the rule appears designed to phase out these sites over time, rather than treat them as a viable long-term option for complying with remote ID. I encourage the FAA to view fixed flying sites as part of a viable long-term solution to remote ID and to amend the rule to allow for the establishment of new sites in the future.


    Second, the FAA must create a pathway for remote ID compliance at AMA events and competitions, which may not take place at fixed flying sites. These events take place in defined locations for a short period of time, like an air show. For remote ID compliance purposes, they should be treated like fixed flying sites. I encourage the FAA to create a light process for event organizers to apply for and receive, waivers from remote ID requirements for these ad hoc events and competitions, many of which support local charities.


    Third, the rule must consider hobbyists who fly in rural areas with little or no internet connectivity. As I read the proposed rule, I could be required to have an internet connection even if flying at an approved fixed flying site in a rural part of the country. Unfortunately, some rural areas don’t have adequate cell service, which means I could not be able to fly under the limited remote ID option. Rural locations are frequently the safest places to fly because they are away from people, other aircraft and structures. The FAA needs to provide a solution for these areas, such as the ability to comply from home or other WIFI-enabled locations.


    Finally, the FAA should reconsider the proposal to register each aircraft, which will impose a cost and compliance burden on the model aviation community. While individual registration may make sense for beyond line of sight operations, it is an unnecessary requirement for aircraft designed to be flown within line of sight. We build and fly model airplanes because it is a passion; and many of us own dozens, if not hundreds, of aircraft of different shapes and sizes, some of which we fly infrequently. The time and cost involved in registering each model individually would be substantial and runs counter to the current registration framework for recreational operators. Also, aircraft that are built by hand do not have serial numbers, which makes individual registration more difficult.

    Again, I urge you to carefully consider and address my concerns about the remote ID proposal. Model aviation is the natural precursor to careers in aviation, including commercial pilots and engineers and more – jobs which the U.S. desperately needs to fill. Model aviation supports a $1 billion hobby industry responsible for thousands of existing U.S. jobs. We simply cannot afford to further harm the model aviation hobby with overly burdensome requirements.

    Use this template to form your comment on the federal website here.


  • 02 Jan 2020 9:52 PM | Andrew (Administrator)

    The notice of proposed rulemaking (NPRM) released on December 26, 2019 suggests three options for compliance with remote identification. The full 319-page rule can be downloaded and read here.

    Standard Remote ID: This is how many UAS that are not model aircraft would comply with remote ID. The proposed requirement is for UAS to broadcast identification and location information directly from the aircraft and simultaneously transmit that same information to a Remote ID UAS service provider through an internet connection. This would be done through equipage on the UAS.

    Limited Remote ID: This is another option to comply with remote ID for UAS flying no more than 400 feet from the control station and within visual line of sight. The proposed requirement is for UAS to transmit information through the internet only, with no broadcast requirements. This would be done through equipage on the UAS.


    FAA-Recognized Identification Areas: This is how many traditional model aircraft will comply with remote ID. This does not require any equipage on the model aircraft. Under the proposal, models (and other UAS manufactured before the compliance date) would be permitted to fly at certain specific geographic areas established under this rule specifically to accommodate them. These locations would need to be submitted to the FAA for approval and renewed every four years.

    In addition, to these three remote ID compliance options, the FAA has proposed to revise the existing UAS registration requirements to require all owners of unmanned aircraft to register each unmanned aircraft individually. Furthermore, the owners of standard or limited remote identification unmanned aircraft would have to provide the serial number of all unmanned aircraft registered. The serial number would establish the unique identity of the unmanned aircraft.


    Detailed Summary of Major Provisions


    (page 21 of the NPRM)

    ISSUE PROPOSED REQUIREMENT

    Registration Requirements

    Individual registration of

    unmanned aircraft and

    conforming changes

    Requires the individual registration of all unmanned aircraft registered

    under part 48.

    Requires each unmanned aircraft to be registered under a unique registration number. Eliminates existing option to allow multiple recreational unmanned aircraft to register under a single registration number.

    Serial numbers for

    unmanned aircraft


    The unmanned aircraft serial number provided as part of an application for aircraft registration for a standard remote identification or limited remote identification unmanned aircraft would be the serial number issued by the manufacturer in accordance with the requirements of part 89.

    The owner of a small unmanned aircraft would have to include the manufacturer and model name of the unmanned aircraft during the registration or registration renewal process, and for any standard or limited remote identification unmanned aircraft, the serial number issued by the manufacturer.


    Adds clarifying language for existing registration requirements for part 107 operators.

    Telephone number(s) for applicant for registration

    Requires telephone number(s) of applicant at time of registration.

    Operating Requirements

    Applicability of operating requirements

    The remote identification operating requirements would apply to: (1)

    persons operating unmanned aircraft registered or required to be registered under parts 47 or 48; and (2) persons operating foreign civil unmanned aircraft in the United States.

    Remote identification

    requirements generally


    No person would be allowed to operate a UAS within the airspace of the United States unless the operation is conducted under one of the following: (1) the UAS is a standard remote identification UAS and that person complies with the requirements of § 89.110; (2) the UAS is a limited remote identification UAS and that person complies with the requirements of § 89.115; or (3) the UAS does not have remote identification equipment and that person complies with the requirements of § 89.120.

    Standard remote identification UAS Remote identification:

    If the internet is available at takeoff, the UAS would have to do the following from takeoff to landing:


    (1) connect to the internet and transmit the required remote identification message elements through that internet connection to a Remote ID USS; and

    (2) broadcast the message elements directly from the unmanned aircraft.


    If the internet is unavailable at takeoff, or if during the flight, the unmanned aircraft can no longer transmit through an internet connection to a Remote ID USS, the UAS would have to broadcast the message elements directly from the unmanned aircraft from takeoff to landing.

    In-flight loss of broadcast capability:


    A person manipulating the flight controls of a standard remote identification UAS that can no longer broadcast the message elements would have to land as soon as practicable.


    Operation of standard remote identification UAS:

    A person would be allowed to operate a standard remote identification UAS only if it meets the following requirements:

    (1) its serial number is listed on an FAA-accepted declaration of compliance;

    (2) its remote identification equipment is functional and complies with the requirements of proposed part 89 from takeoff to landing; and

    (3) its remote dentification equipment and functionality have not been disabled.


    Limited remote identification UAS Remote identification:

    The UAS would have to do the following from takeoff to landing:

    (1) connect to the internet and transmit the required remote identification message elements through that internet connection to a Remote ID USS; and

    (2) be operated within visual line of sight.


    In-flight loss of remote identification:

    A person manipulating the flight controls of a limited remote identification UAS would have to land as soon as practicable when it cannot transmit the message elements through an internet connection to a Remote ID USS.


    Operation of limited remote identification UAS:

    A person would be allowed to operate a limited remote identification UAS only if it meets the following requirements:

    (1) its serial number is listed on an FAA-accepted declaration of compliance;

    (2) its remote identification equipment is functional and complies with the requirements of proposed part 89 from takeoff to landing; and

    (3) its remote identification equipment and functionality have not been disabled.


    UAS without remote identification

    The limited number of UAS that do not have remote identification equipment would be allowed to operate within visual line of sight and within an FAA-recognized identification area.

    With authorization from the Administrator, a person may operate a UAS that does not have remote identification for the purpose of aeronautical research or to show compliance with regulations.


    FAA-recognized identification areas:

    Applicability Prescribes procedural requirements to establish an FAA-recognized identification area.

    Eligibility Only a community based organization (CBO) recognized by the Administrator would be allowed to apply for the establishment of an FAA-recognized identification area.


    Requests for establishment Application:

    A CBO requesting establishment of an FAA-recognized identification area would have to submit an application within 12 calendar months from the effective date of the final rule. The FAA will not consider any applications submitted after that date.

    Required documentation:

    A request for establishment of an FAA-recognized identification area would have to contain the following information:

    · Name of the CBO making the request.

    · Declaration that the person making the request has the authority to

    act on behalf of the CBO.

    · Name and contact information, including telephone number(s), of

    the primary point of contact for communications with the FAA.

    · Physical address of the proposed FAA-recognized identification

    area.

    · Latitude and longitude coordinates delineating the geographic

    boundaries of the proposed FAA-recognized identification area.

    · If applicable, a copy of any existing letter of agreement regarding

    the flying site.

    Approval of an FAA-recognized identification area:

    FAA would approve or deny applications for FAA-recognized identification areas, and may take into consideration matters including but not limited to: the effects on existing or contemplated airspace capacity, critical infrastructure, existing or proposed manmade objects, natural objects, or the existing use of the land, within or close to the proposed FAA-recognized identification area; the safe and efficient use of airspace by other aircraft; and the safety and security of persons or property on the ground.


    Amendment:

    Any change to the information submitted in the application for establishment of an FAA-recognized identification area would have to be submitted to the FAA within ten calendar days of the change. Such information includes, but would not be limited to, a change to the point of contact for the FAA-recognized identification area, or a change to the community based organization’s affiliation with the FAA- recognized identification area.


    If the community based organization wishes to change the geographic boundaries of the FAA-recognized identification area, the organization must submit the request to the FAA for review. The geographic boundaries of the FAA-recognized identification area will not change until they have been approved or denied in accordance with § 89.215.


    Duration of an FAA-recognized identification area:

    An FAA-recognized identification area would be in effect for 48 calendar months after the date the FAA approves the request for establishment of an FAA-recognized identification area.

    Renewal:

    A request for renewal would have to be submitted no later than 120 days prior to the expiration of the FAA-recognized identification area in a form and manner acceptable to the Administrator. The Administrator may deny requests submitted after that deadline or requests submitted after the expiration of the FAA-recognized identification area.


    Expiration and termination Expiration:

    Unless renewed, an FAA-recognized identification area would be automatically cancelled and have no further force or effect as of the day immediately after its expiration date.


    Termination prior to expiration (by request):

    A CBO may submit a request to the Administrator to terminate an FAA-recognized identification area. Once an FAA-recognized identification area is terminated, that CBO may not reapply to have that flying site established as an FAA-recognized identification area.


    Termination by FAA:

    FAA would be able to terminate an FAA-recognized identification area for cause or upon a finding that the FAA-recognized identification area could pose a risk to aviation safety, public safety, or national security or that the person who submitted a request for establishment of an FAA-recognized identification area provided false or misleading information during the submission process.

    Once an FAA-recognized identification area is terminated, that CBO may not reapply to have that flying site reestablished as an FAA recognized identification area.


    Petition to reconsider the FAA’s decision to terminate an FAA recognized identification area:

    A CBO whose FAA-recognized identification area has been terminated by the FAA would be able to petition for reconsideration by submitting a request for reconsideration and establishing the grounds for such reconsideration within 30 calendar days of the date of issuance of the termination.


  • 26 Dec 2019 9:46 PM | Andrew (Administrator)

    The FAA released its proposed rule on remote identification (remote ID) on December 26, 2019. AMA has been advocating for our hobby throughout the remote ID rule process to include voting privileges as a member of the Remote ID Aviation Rulemaking Committee. We are reviewing this notice of proposed rulemaking on remote ID, however, an early read indicates that some of our proposals were accepted, including not requiring onboard equipage for our members at our flying sites. Please look for future communications from AMA as we review the entire proposed rule. Because this is not a final rule, we will likely ask for our members to help us shape the ultimate regulation by participating and providing comments and feedback to the FAA.


    Q: What is the email the FAA sent out about remote ID?

    A: In 2016 the FAA announced plans to remotely track unmanned aircraft. On December 26, 2019, the FAA published its proposed rule on remote identification in the Federal Register. This is a proposed rule, not a final rule. Please continue to monitor AMA communication because we will likely encourage members to participate in the rulemaking process to comment and shape the final rule.


    Q: What does this proposed rule say for recreational fliers and AMA members?

    A: As we review the 319-page document, the initial read appears to show that AMA remains successful in advocating that our members will not require onboard equipage when at a flying field or approved location. The FAA gives flexibility for recognized community-based organizations (CBOs).


    Q: What is AMA stance on remote ID?

    A: AMA has long advocated for a common-sense approach to remote ID. Because our operations do not pose any new risk to the airspace, the burden of remote ID should apply to unmanned aircraft capable of navigating beyond visual line of sight of the operator or spotter or operations outside our safety programming. Some AMA proposals would allow recreational operators to meet the safety and security objectives of the rule without onboard equipage by operating at fixed flying sites or by using a software-based app solution.


    Q: Has AMA had any say in the remote ID rulemaking?

    A: AMA has been advocating on behalf of our members from the beginning on remote ID, to include as a voting member on the 2017 Remote ID Aviation Rulemaking Committee. AMA continues to serve on FAA advisory committees and safety teams addressing remote ID.


    Q: I heard AMA mention fixed flying sites. What about members who are not flying at a fixed site?

    A: For members not at a flying field, it’s unknown if members can use a ground-based solution such as an app to satisfy remote ID without onboard equipage. We will share more as we read and review the 319-page proposed rule.


    Q: Where can I read the proposed rule?

    A: You can read the entire proposed rule and FAA’s announcement at https://www.faa.gov/news/press_releases/news_story.cfm?newsId=24534.


    Q: What Happens Next?

    A: AMA will continue to shape the rule before it is finalized to include asking members to participate in the rulemaking process. Please monitor communication for more information. In March 2020, the FAA will begin reviewing comments and feedback to shape the final rule. This process could take days or years.


  • 23 Dec 2019 9:41 PM | Andrew (Administrator)

    At the beginning of December, AMA participated in a safety risk management (SRM) panel at the national level, in Washington, DC, with the FAA and other stakeholders to address the 400’ altitude issue in controlled airspace. As a result of the national SRM panel, the FAA selected four AMA clubs in controlled airspace to participate in SRM panels at the local level.


    The clubs were selected by the FAA because they had requested to operate at flights over 400’ AGL at their fixed site. These panels included the AMA club contacts, AMA HQ, FAA national, local Air Traffic Operations and other stakeholders. During these panels, safety data and air traffic patterns were looked at based on the location of the fixed site to the airport. Based on the analysis, mitigations were discussed to operate safely at higher altitudes. The four clubs that participated in these panels have each been granted flights over 400’ at their fixed site in controlled airspace.


    Moving forward, the FAA will be working on a case by case scenario to select clubs to participate in local SRM panels to grant flights over 400’. This will be a slow, lengthy process but congress recognizes AMA’s longstanding safety record which is why the FAA has shown flexibility in working with our fixed flying sites.


    If you have questions, please contact AMA Government Affairs at (765) 287-1256 or amagov@modelaircraft.org.


  • 18 Dec 2019 9:37 PM | Andrew (Administrator)

    Last week, the AMA Government Affairs team had a promising meeting with FAA Deputy Administrator Dan Elwell to discuss the new regulations on recreational UAS that are negatively impacting the model aviation hobby. This meeting was an important milestone in our work to protect AMA members and model aviation as the agency implements Section 349 of the FAA Reauthorization Act of 2018.


    The most pressing issue facing modelers right now is the FAA’s policy to limit modelers to an arbitrary 400-foot altitude limit in controlled airspace. Based on our meeting this week, we will likely have a solution to the altitude restriction issue soon.


    We used this week’s meeting to explain to Deputy Administrator Elwell that, although most of the modeling community can operate safely under 400 feet AGL, there are some cases in which the altitude limit actually makes our operations less safe. The industry’s number one goal is to keep our airspace safe, therefore the FAA has agreed to work with AMA to find a solution to this problem. AMA has been participating in a Safety Risk and Management Panel, with the FAA and stakeholders, to address the altitude restriction issue and find a process to grant operations above 400 feet.


    Importantly, we discussed with the FAA the process by which AMA will be officially recognized as a community-based organization (CBO). Although most already unofficially recognize AMA as a leading CBO, this official process will position our organization to more effectively comply with the regulatory requirements and ultimately serve AMA members better. It will also help AMA help others who may be new to the hobby and still need to learn how to fly safely and responsibly.

    If you have any questions or concerns, please feel free to contact the government affairs team at 765-287-1256 ext. 236 or amagov@modelaircraft.org. We are always happy to chat with you.




  • 07 Jul 2019 1:33 PM | Andrew (Administrator)

    The AMA Executive Council and the Government Affairs team took a trip to Washington, D.C. to advocate for our hobby. We had many productive and encouraging meetings with leaders at the FAA, members of Congress and several of our allies in the aviation community.


    Throughout these meetings, we continued to emphasize AMA’s commitment to safety and education. We also highlighted examples of how flying model aircraft is a pathway to STEM-related to careers and the work we do to support local charities.

    Importantly, we discussed the upcoming FAA rule-makings for recreational UAS, and we were encouraged by the positive tone of the dialogue. The FAA recognizes the importance of the model aviation community and wants to continue our longstanding partnership. On Capitol Hill, members of Congress pledged support to AMA and stand ready to weigh-in with the FAA on our behalf, as needed.


    We also spoke with representatives from ATC to discuss the Letters of Agreement process. We’ll continue working closely with them to ensure that there is no disruption in our ability to fly. We’ve also learned that LAANC (the FAA’s low altitude authorization and notification capability system) will be available for recreational operators in controlled airspace on July 23, 2019. Currently, only Part 107 pilots have access to LAANC and recreational pilots are able to fly only at charted flying sites in controlled airspace. We will provide more information regarding LAANC as it becomes available.

    Rest assured – we are taking a proactive approach in working with government officials to influence the new regulations for recreational UAS in a way that is favorable for AMA members.


    Thank you for your continued support of AMA. As always, please reach out with any questions at amagov@modelaircraft.org.


    Kind regards,
    AMA Government Affairs Team


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