Guidance on Submitting Comments to the FAA

The AMA has recommended that our members hold off on registering their model aircraft with the FAA until advised by the AMA or until the FAA’s legal deadline of February 19. Holding off on registration will allow time for AMA to fully consider all possible legal and political options for alleviating this unnecessary regulatory burden on our members.
In the meantime, you can help by making your voice heard with the FAA. Specifically we are asking all AMA members to submit comments on the FAA’s interim rule on registration. The deadline to submit comments is January 15, 2016. All comments can be submitted at http://1.usa.gov/1Jegj0C.
Below are recommended messages to convey in your comments:

  • Express your disappointment with the registration rule. As a member of the Academy of Model Aeronautics (AMA), I am disappointed with the new rule for UAS registration. I am a long time model aircraft flyer, who has operated under the guidance of the largest community-based organization (CBO) in the world for many years.
  • Highlight AMA’s history and safety record. Since 1936, AMA has published safety standards and offered training programs for our members – more than 20 years before the FAA was created. Our National Model Aircraft Safety Code has been recognized by Congress as well as by state legislatures as a safe and effective means of managing model aircraft enthusiasts like me
    .
  • Note that you already register with AMA. Additionally, AMA’s safety program already instructs me to place my AMA number or name and address on or within my model aircraft(s), effectively accomplishing the safety and accountability objectives of the interim rule.
  • Make it clear this rule is contrary to the intent of Congress. The new rule is contrary to the intent of Congress in Section 336 of the 2012 FAA Modernization and Reform Act. Section 336, also referred to as the “Special Rule for Model Aircraft,” clearly prohibits the FAA from promulgating any new rules for recreational users operating within the safety guidelines of a CBO. In addition, the FAA’s contention that model aircraft should be considered aircraft is currently the subject of pending litigation.
  • Affirm that as an AMA member you should be exempt from federal registration. The registration process is an unnecessary burden for me and the more than 185,000 other AMA members. AMA members should not be required to register with the FAA.

Thank you,
AMA Government and Regulatory Affairs Team
amagov

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