Are there any Nationwide CBO's other then the AMA?
03-19-2015, 05:07 AM
#226
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Then please allow me to provide the complete citation:
Senate bill with modifications… Language including model aircraft for the purposes of sports,competitions and academic purposes is removed and replaced with ``hobby''. The modified section includes language requiring that the model aircraft must be operated in a manner that does not interfere with and gives way, to all manned aircraft. In addition, language that requires that model aircraft flown within five miles of an airport will give prior notification to the airport and the air traffic control (ATC), and that model aircraft that are flown consistently within five miles of the ATC will do so under standing agreements with the airports and ATC. Lastly,language is added that will ensure that nothing in this provision will interfere with theAdministrator's authority to pursue enforcement action against persons operating model aircraft who endanger the safety of the national airspace system. In this section the term ``nationwide community-based organization'' is intended to mean a membership based association that represents the aeromodeling community within the United States; provides its members a comprehensive set of safety guidelines that underscores safe aeromodeling operations within theNational Airspace System and the protection and safety of the general public on the ground;develops and maintains mutually supportive programming with educational institutions,government entities and other aviation associations; and acts as a liaison with government agencies as an advocate for its members.
"association that represents the aeromodeling community within the United States."
represent
verb rep·re·sent \ˌre-pri-ˈzent\
: to act or speak officially for (someone or something)
community
noun, com·mu·ni·ty often attributive \kə-ˈmyü-nə-tē\
: a group of people who have the same interests, religion, race, etc
If you could manage to get Webster and/or congress to change the CBO definition to "association that represents the aeromodeling membership within the United States." then and only then would I agree with you.
Frank
03-19-2015, 05:31 AM
#227
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This may be off topic but didn't the FCC once try to monitor our hobby without success.
The FAA and or any other Org will find it almost impossible to enforce anything on modelers especially those who are on there property.
The FAA and or any other Org will find it almost impossible to enforce anything on modelers especially those who are on there property.
03-19-2015, 05:37 AM
#228
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Frank, there is no exclusivity to "represent the modelling community" and being a CBO, If there were multiple organizations that met the CBO requirements we would have a choice. The programming of one might require membership, the programming of another might not. Unfortunately only one organization today meets the requirements of a CBO that being the AMA. Keep in mind the law says "the programming of the CBO" not the "programming approved by the FAA". The FAA has not interpreted "programming" and IMHO they will reluctant to do so.
The AMA has the responsibility to its membership to disclose what "within the programming of" means for the use of Sec 336.
The AMA has the responsibility to its membership to disclose what "within the programming of" means for the use of Sec 336.
03-19-2015, 05:43 AM
#229
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It appears to me that your parsing of the definition is faulty by your overlooking of a key statement;
"association that represents the aeromodeling community within the United States."
represent
verb rep·re·sent \ˌre-pri-ˈzent\
: to act or speak officially for (someone or something)
community
noun, com·mu·ni·ty often attributive \kə-ˈmyü-nə-tē\
: a group of people who have the same interests, religion, race, etc
If you could manage to get Webster and/or congress to change the CBO definition to "association that represents the aeromodeling membership within the United States." then and only then would I agree with you.
Frank
"association that represents the aeromodeling community within the United States."
represent
verb rep·re·sent \ˌre-pri-ˈzent\
: to act or speak officially for (someone or something)
community
noun, com·mu·ni·ty often attributive \kə-ˈmyü-nə-tē\
: a group of people who have the same interests, religion, race, etc
If you could manage to get Webster and/or congress to change the CBO definition to "association that represents the aeromodeling membership within the United States." then and only then would I agree with you.
Frank
So perhaps if you could get Congress to change that wording then we could be in agreement.
03-19-2015, 05:47 AM
#230
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I am still amused by the hypocrisy of those people who are willing to benefit from the efforts of the AMA but who steadfastly refuse to support it.
03-19-2015, 06:19 AM
#231
I'm not so sure the disagreement centers around supporting the AMA , I believe the point is that folks are reluctant to see aircraft modeling become "AMA or no way" . In a truly fair and just system , anyone , AMA member or not , should be allowed to practice the aircraft modeling hobby so long as they don't endanger the public any more than we AMA members do while following our safety code . When it finally comes down to "Be AMA or you can't fly , period" we WILL have all lost something of extreme value , our free will to safely practice a hobby without forced association with any person or organization .
I am and always will be an AMA member , and this is by my free will of choice to support an organization that I feel best represents my interests .
BUT !!!!
What I CAN'T and WON'T support is any plan of "belong to a CBO or don't fly" ! Simply following the accepted safe practices should be enough .
I guess like Brad says , this will all become a moot point as far as the AMA itself is concerned once a second CBO appears . Well , most of it anyway . but the bottom line here is the appearance of even 1000 CBOs would not mitigate my distaste of being FORCED to belong to any one of em .
I am and always will be an AMA member , and this is by my free will of choice to support an organization that I feel best represents my interests .
BUT !!!!
What I CAN'T and WON'T support is any plan of "belong to a CBO or don't fly" ! Simply following the accepted safe practices should be enough .
I guess like Brad says , this will all become a moot point as far as the AMA itself is concerned once a second CBO appears . Well , most of it anyway . but the bottom line here is the appearance of even 1000 CBOs would not mitigate my distaste of being FORCED to belong to any one of em .
03-19-2015, 06:38 AM
#232
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Your passive aggressive snarkiness aside, I'll accept that part of the definition is that a CBO represents the aeromodeling community if you can accept that when they said "Provides its members with a safety program" that means the safety program is for the use and benefit of the members. They clearly did not say "Provides the aeromodeling community with a safety program."
So perhaps if you could get Congress to change that wording then we could be in agreement.
So perhaps if you could get Congress to change that wording then we could be in agreement.
You do not have to accept that part of it, it is the language that is used in the definition. If pointing out the facts to you are passive aggressive snarkiness and are offensive to you then I suggest you report my posts. Otherwise your personal opinions about me or anyone that does not agree with you does not mean squat when you examine the facts. Fact is neither you or anyone else has provided a quote from the law or the FAA interpretation that states that one must be a member of a CBO to safely fly an RC aircraft.
Frank
03-19-2015, 06:44 AM
#233
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I'm not so sure the disagreement centers around supporting the AMA , I believe the point is that folks are reluctant to see aircraft modeling become "AMA or no way" . In a truly fair and just system , anyone , AMA member or not , should be allowed to practice the aircraft modeling hobby so long as they don't endanger the public any more than we AMA members do while following our safety code . When it finally comes down to "Be AMA or you can't fly , period" we WILL have all lost something of extreme value , our free will to safely practice a hobby without forced association with any person or organization .
I am and always will be an AMA member , and this is by my free will of choice to support an organization that I feel best represents my interests .
BUT !!!!
What I CAN'T and WON'T support is any plan of "belong to a CBO or don't fly" ! Simply following the accepted safe practices should be enough .
I guess like Brad says , this will all become a moot point as far as the AMA itself is concerned once a second CBO appears . Well , most of it anyway . but the bottom line here is the appearance of even 1000 CBOs would not mitigate my distaste of being FORCED to belong to any one of em .
I am and always will be an AMA member , and this is by my free will of choice to support an organization that I feel best represents my interests .
BUT !!!!
What I CAN'T and WON'T support is any plan of "belong to a CBO or don't fly" ! Simply following the accepted safe practices should be enough .
I guess like Brad says , this will all become a moot point as far as the AMA itself is concerned once a second CBO appears . Well , most of it anyway . but the bottom line here is the appearance of even 1000 CBOs would not mitigate my distaste of being FORCED to belong to any one of em .
Frank
03-19-2015, 06:55 AM
#234
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I'm not so sure the disagreement centers around supporting the AMA , I believe the point is that folks are reluctant to see aircraft modeling become "AMA or no way" . In a truly fair and just system , anyone , AMA member or not , should be allowed to practice the aircraft modeling hobby so long as they don't endanger the public any more than we AMA members do while following our safety code . When it finally comes down to "Be AMA or you can't fly , period" we WILL have all lost something of extreme value , our free will to safely practice a hobby without forced association with any person or organization .
I am and always will be an AMA member , and this is by my free will of choice to support an organization that I feel best represents my interests .
BUT !!!!
What I CAN'T and WON'T support is any plan of "belong to a CBO or don't fly" ! Simply following the accepted safe practices should be enough .
I guess like Brad says , this will all become a moot point as far as the AMA itself is concerned once a second CBO appears . Well , most of it anyway . but the bottom line here is the appearance of even 1000 CBOs would not mitigate my distaste of being FORCED to belong to any one of em .
I am and always will be an AMA member , and this is by my free will of choice to support an organization that I feel best represents my interests .
BUT !!!!
What I CAN'T and WON'T support is any plan of "belong to a CBO or don't fly" ! Simply following the accepted safe practices should be enough .
I guess like Brad says , this will all become a moot point as far as the AMA itself is concerned once a second CBO appears . Well , most of it anyway . but the bottom line here is the appearance of even 1000 CBOs would not mitigate my distaste of being FORCED to belong to any one of em .
03-19-2015, 07:05 AM
#236
bradpaul
&
phlpsfrnk: If U guys don't stop arguing among your selves U won't be flying anything more than a KITE with a maximum 400' string. The FAA is going to make U follow the either the rules of the CBO/AMA or get a federal licence and comply with all the FAA REGS and registrations ect. that go with full scale to fly R/C TOYS in the NAS ...make no mistake about that. Now go read the NPRM and respond in an intelligent and thoughtful and courteous Way to said NPRM and the FAA.
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[TD="align: left"]Members encouraged to comment on FAA's sUAS NPRM
On February 23, 2015, the FAA published its proposed regulations for small unmanned aircraft systems (sUAS) as a notice of proposed rulemaking (NPRM). AMA has created a suggested template for comments, which we strongly encourage you to edit and personalize. Unless extended, the deadline for submitting comments is 11:59 p.m., Friday, April 24, 2015. Click below to use our template to comment.
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[TD="align: left"]Members encouraged to comment on FAA's sUAS NPRM
On February 23, 2015, the FAA published its proposed regulations for small unmanned aircraft systems (sUAS) as a notice of proposed rulemaking (NPRM). AMA has created a suggested template for comments, which we strongly encourage you to edit and personalize. Unless extended, the deadline for submitting comments is 11:59 p.m., Friday, April 24, 2015. Click below to use our template to comment.
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Last edited by HoundDog; 03-19-2015 at 07:11 AM.
03-19-2015, 07:22 AM
#237
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: If U guys don't stop arguing among your selves U won't be flying anything more than a KITE with a maximum 400' string. The FAA is going to make U follow the either the rules of the CBO/AMA or get a federal licence and comply with all the FAA REGS and registrations ect. that go with full scale to fly R/C TOYS in the NAS ...make no mistake about that. Now go read the NPRM and respond in an intelligent and thoughtful and courteous Way to said NPRM and the FAA.
Exactly... That's why I was agreeing...LOL Now, if you and Silent would quit arguing on behalf of AMA we might get something done around here LOL
BTW I prefer to send my own letter...
03-19-2015, 07:32 AM
#238
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What is the programming of the CBO (AMA)?
Is membership required?
We need an answer and keep these dates in mind.............................
Is membership required?
We need an answer and keep these dates in mind.............................
General Membership Meeting
May 14, 2015
At the Joe Nall event
Woodruff, South Carolina
May 14, 2015
At the Joe Nall event
Woodruff, South Carolina
May 16-17, 2015
EC Meeting
Following the Joe Nall event
Woodruff, South Carolina
Open meetings where the questions need answered. EC Meeting
Following the Joe Nall event
Woodruff, South Carolina
03-19-2015, 07:39 AM
#239
I'm not so sure the disagreement centers around supporting the AMA , I believe the point is that folks are reluctant to see aircraft modeling become "AMA or no way" . In a truly fair and just system , anyone , AMA member or not , should be allowed to practice the aircraft modeling hobby so long as they don't endanger the public any more than we AMA members do while following our safety code . When it finally comes down to "Be AMA or you can't fly , period" we WILL have all lost something of extreme value , our free will to safely practice a hobby without forced association with any person or organization .
I am and always will be an AMA member , and this is by my free will of choice to support an organization that I feel best represents my interests .
BUT !!!!
What I CAN'T and WON'T support is any plan of "belong to a CBO or don't fly" ! Simply following the accepted safe practices should be enough .
I guess like Brad says , this will all become a moot point as far as the AMA itself is concerned once a second CBO appears . Well , most of it anyway . but the bottom line here is the appearance of even 1000 CBOs would not mitigate my distaste of being FORCED to belong to any one of em .
I am and always will be an AMA member , and this is by my free will of choice to support an organization that I feel best represents my interests .
BUT !!!!
What I CAN'T and WON'T support is any plan of "belong to a CBO or don't fly" ! Simply following the accepted safe practices should be enough .
I guess like Brad says , this will all become a moot point as far as the AMA itself is concerned once a second CBO appears . Well , most of it anyway . but the bottom line here is the appearance of even 1000 CBOs would not mitigate my distaste of being FORCED to belong to any one of em .
Well it looks like U won't be flying anything but a KITE with a 400' string or get your federal DRONE license ... just U wait and see.
The FAA is PISSED that congress gave them a mandate to promote Commercial service and make the NAS save for them and than proceeded to tell them that they can't mess with TOY Airplanes ... Well the FAA doesn't like to be told HOW to do their job. That's why we got the interpretation of congress amendment #336 that we got. Moral of this "Aesop fable" is don't exacerbate the situation by telling the people FAA that control your life that U aren't going to do comply with their Rules and regulations.
Now read the NPRM and try to respond to it in a courteous and intelligent manor.
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[/TD][TD="width: 360, bgcolor: #bcbcbc"]Tuesday, March 17, 2015[/TD]
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AMA's Response to the FAA's sUAS NPRM
On February 23, 2015, the FAA published its proposed regulations for small unmanned aircraft systems (sUAS) as a notice of proposed rulemaking (NPRM). This began a 60-day period during which the public can comment on the proposed regulations. When finalized, the proposed rules would become the safety regulations for operating small,non-recreational, unmanned aircraft.
In accordance with the Special Rule for Model Aircraft (the AMA amendment) established by Congress in the FAA Modernization and Reform Act of 2012 (P.L. 112-95), the new regulations would not apply to model aircraft operated within the safety programming of a nationwide community-based organization. This is good news for AMA members; however, the FAA has said that to be exempt from regulations, model aircraft operators must operate within the parameters of the Special Rule set out by Congress in 2012.
The NPRM references FAA's June 2014 interpretation of the Special Rule. As indicated in detail in updates to our members last summer , the AMA has taken exception to several aspects of FAA's interpretation. The main areas of concern are that the FAA's interpretation:
• Asserts model aircraft to be "aircraft" and effectively makes model airplanes subject to all regulations applicable to full-scale aircraft.
• Makes model aircraft subject to airspace requirements that have never been applicable in the past and with which it is impossible or impractical to comply.
• Effectively changes the criteria for operating within 5 miles of an airport from the requirement of providing prior "notification" to a requirement of obtaining prior permission.
• Narrowly defines "hobby and recreation" and puts in question the activities of the supporting aeromodeling industry and AMA's educational programs.
• Rigidly defines the requirement to operate within visual line of sight and targets the use of a specific aeromodeling technology/equipment, namely first-person view (FPV) goggles.
Overall, the AMA views the proposed sUAS regulations as a positive step. With one exception that may impact model aircraft manufacturers, it essentially takes the language in the 2012 Special Rule for Model Aircraft (the AMA amendment) and places it in the federal aviation regulations.
We encourage members to submit comments commending the FAA for appropriately separating model aviation from the new regulations. However, AMA would also encourage members to include in their comments the need to resolve the discrepancies stemming from the Interpretive Rule before finalizing the sUAS rule. In any case, it's important that our members provide their comments in support of the proposed rule. It's possible that there will be members of the public or aviation industry who will be opposed to a rule that protects the model aviation hobby, and we need to make sure that our voices are heard in support of continued community-based self-governance.
Comments on the proposed sUAS rule can be made by clicking here. Read the proposed rule carefully, particularly the sections concerning "model aircraft," and submit comments on areas where you have a concern as well as thoughtful and productive comments in areas where you feel there could be improvement. AMA has created a suggested template for comments, which we strongly encourage you to edit and personalize. Unless extended, the deadline for submitting comments is 11:59 p.m., Friday, April 24, 2015.
[h=4]Template Comment for AMA Members
(copy the template, click the comment now button below, and paste into the comment field)[/h]
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[TD="align: left"]I am writing in response to the FAA's proposal to regulate small unmanned aircraft systems, including model aircraft. [Insert personal introduction details such as: I am a [job/profession], a member of the Academy of Model Aeronautics, and have been safely and responsibly flying model aircraft for ___ years. I am also a model aircraft club officer/educator/designer, etc.]
I support the exemption of recreational model aircraft from the regulation of unmanned aircraft systems. As Congress recognized, self-governance under community-based safety guidelines has worked exceptionally well for decades, and should remain in place. However, I have the following concerns about the FAA's proposal: [choose all that you feel apply, and feel free to add other comments]
The FAA has repeated its June 2014 statement that model aircraft are "aircraft" subject to all existing aviation regulations. The FAA must revise this interpretation so that it is in agreement with what Congress directed in 2012, which is that recreational model aircraft are subject to community-based safety guidelines, not aviation regulations. Similarly, the regulatory proposal excludes ultralight vehicles, moored balloons, kites, amateur rockets, and unmanned free balloons from the FAA's aircraft operating regulations but neglects to expressly exclude model aircraft. The proposed regulation should make it clear that model aircraft meeting the criteria established by Congress are not subject to aviation regulations.
Also, the proposal leaves out the part of the statute that excludes "an aircraft being developed as a model aircraft" from aviation regulations. This exclusion must be added to the regulations. Companies in the model aircraft industry should not be regulated as if they are aircraft manufacturers.
The FAA bases its proposal on its June 2014 interpretation of the law concerning model aircraft. There were 33,000 comments submitted last summer concerning that interpretation [including mine]. The future regulations for model aircraft should not be based on incorrect interpretations of what Congress wrote. Some of the interpretations that should be changed to the extent they form the basis for any current or future regulation include:
• Making model aircraft subject to airspace requirements such as air traffic control clearance, that have never been applicable in the past and with which it is impossible or impractical to comply. Congress indicated the maximum obligation, which is actually stricter than what the FAA's guidance has been for the past 34 years: notifying the airport when operating within five miles. That is the most that model aircraft hobbyists should have to do.
• Rigidly defining a requirement to operate within visual line of sight and that calls into question the use of a specific technology or equipment, namely first-person view (FPV) goggles. The language of the 2012 statute concerning "within visual line of sight" indicates how far away a person should fly the model aircraft, not what method of control may be used for the recreational experience. The proposal for commercial unmanned aircraft acknowledges that an observer (spotter) can be used to ensure airspace safety, just as the AMA's community-based safety guidelines do.
• Narrowly interpreting the words "hobby or recreational use." You should not regulate people who are flying model aircraft in connection with the hobby just because they receive payments. For decades, enthusiasts have participated in contests and competitions that have cash prizes, have been paid to instruct others on how to safely fly models, and have received compensation for aerobatic displays. These payments incidental to the hobby do not change the underlying recreational purpose of the activity or make the hobby any less safe, and regulating these activities would be highly disruptive to the hobby without any benefit.
Respectfully,
[Name]
[Optional] AMA Member Number: _________[/TD]
[/TR]
[/TABLE]
[/TD][TR]
[TD="align: left"]I am writing in response to the FAA's proposal to regulate small unmanned aircraft systems, including model aircraft. [Insert personal introduction details such as: I am a [job/profession], a member of the Academy of Model Aeronautics, and have been safely and responsibly flying model aircraft for ___ years. I am also a model aircraft club officer/educator/designer, etc.]
I support the exemption of recreational model aircraft from the regulation of unmanned aircraft systems. As Congress recognized, self-governance under community-based safety guidelines has worked exceptionally well for decades, and should remain in place. However, I have the following concerns about the FAA's proposal: [choose all that you feel apply, and feel free to add other comments]
The FAA has repeated its June 2014 statement that model aircraft are "aircraft" subject to all existing aviation regulations. The FAA must revise this interpretation so that it is in agreement with what Congress directed in 2012, which is that recreational model aircraft are subject to community-based safety guidelines, not aviation regulations. Similarly, the regulatory proposal excludes ultralight vehicles, moored balloons, kites, amateur rockets, and unmanned free balloons from the FAA's aircraft operating regulations but neglects to expressly exclude model aircraft. The proposed regulation should make it clear that model aircraft meeting the criteria established by Congress are not subject to aviation regulations.
Also, the proposal leaves out the part of the statute that excludes "an aircraft being developed as a model aircraft" from aviation regulations. This exclusion must be added to the regulations. Companies in the model aircraft industry should not be regulated as if they are aircraft manufacturers.
The FAA bases its proposal on its June 2014 interpretation of the law concerning model aircraft. There were 33,000 comments submitted last summer concerning that interpretation [including mine]. The future regulations for model aircraft should not be based on incorrect interpretations of what Congress wrote. Some of the interpretations that should be changed to the extent they form the basis for any current or future regulation include:
• Making model aircraft subject to airspace requirements such as air traffic control clearance, that have never been applicable in the past and with which it is impossible or impractical to comply. Congress indicated the maximum obligation, which is actually stricter than what the FAA's guidance has been for the past 34 years: notifying the airport when operating within five miles. That is the most that model aircraft hobbyists should have to do.
• Rigidly defining a requirement to operate within visual line of sight and that calls into question the use of a specific technology or equipment, namely first-person view (FPV) goggles. The language of the 2012 statute concerning "within visual line of sight" indicates how far away a person should fly the model aircraft, not what method of control may be used for the recreational experience. The proposal for commercial unmanned aircraft acknowledges that an observer (spotter) can be used to ensure airspace safety, just as the AMA's community-based safety guidelines do.
• Narrowly interpreting the words "hobby or recreational use." You should not regulate people who are flying model aircraft in connection with the hobby just because they receive payments. For decades, enthusiasts have participated in contests and competitions that have cash prizes, have been paid to instruct others on how to safely fly models, and have received compensation for aerobatic displays. These payments incidental to the hobby do not change the underlying recreational purpose of the activity or make the hobby any less safe, and regulating these activities would be highly disruptive to the hobby without any benefit.
Respectfully,
[Name]
[Optional] AMA Member Number: _________[/TD]
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03-19-2015, 07:45 AM
#240
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What I CAN'T and WON'T support is any plan of "belong to a CBO or don't fly" ! Simply following the accepted safe practices should be enough .
Well it looks like U won't be flying anything but a KITE with a 400' string or get your federal DRONE license ... just U wait and see.
The FAA is PISSED that congress gave them a mandate to promote Commercial service and make the NAS save for them and than proceeded to tell them that they can't mess with TOY Airplanes ... Well the FAA doesn't like to be told HOW to do their job. That's why we got the interpretation of congress amendment #336 that we got. Moral of this "Aesop fable" is don't exacerbate the situation by telling the people FAA that control your life that U aren't going to do comply with their Rules and regulations.
Now read the NPRM and try to respond to it in a courteous and intelligent manor.
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[TD="width: 360, bgcolor: #a0defd"]Academy of Model Aeronautics
Member Communication[/TD]
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[TD="width: 360, bgcolor: #bcbcbc"]Tuesday, March 17, 2015[/TD]
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On February 23, 2015, the FAA published its proposed regulations for small unmanned aircraft systems (sUAS) as a notice of proposed rulemaking (NPRM). This began a 60-day period during which the public can comment on the proposed regulations. When finalized, the proposed rules would become the safety regulations for operating small,non-recreational, unmanned aircraft.
In accordance with the Special Rule for Model Aircraft (the AMA amendment) established by Congress in the FAA Modernization and Reform Act of 2012 (P.L. 112-95), the new regulations would not apply to model aircraft operated within the safety programming of a nationwide community-based organization. This is good news for AMA members; however, the FAA has said that to be exempt from regulations, model aircraft operators must operate within the parameters of the Special Rule set out by Congress in 2012.
The NPRM references FAA's June 2014 interpretation of the Special Rule. As indicated in detail in updates to our members last summer , the AMA has taken exception to several aspects of FAA's interpretation. The main areas of concern are that the FAA's interpretation:
• Asserts model aircraft to be "aircraft" and effectively makes model airplanes subject to all regulations applicable to full-scale aircraft.
• Makes model aircraft subject to airspace requirements that have never been applicable in the past and with which it is impossible or impractical to comply.
• Effectively changes the criteria for operating within 5 miles of an airport from the requirement of providing prior "notification" to a requirement of obtaining prior permission.
• Narrowly defines "hobby and recreation" and puts in question the activities of the supporting aeromodeling industry and AMA's educational programs.
• Rigidly defines the requirement to operate within visual line of sight and targets the use of a specific aeromodeling technology/equipment, namely first-person view (FPV) goggles.
Overall, the AMA views the proposed sUAS regulations as a positive step. With one exception that may impact model aircraft manufacturers, it essentially takes the language in the 2012 Special Rule for Model Aircraft (the AMA amendment) and places it in the federal aviation regulations.
We encourage members to submit comments commending the FAA for appropriately separating model aviation from the new regulations. However, AMA would also encourage members to include in their comments the need to resolve the discrepancies stemming from the Interpretive Rule before finalizing the sUAS rule. In any case, it's important that our members provide their comments in support of the proposed rule. It's possible that there will be members of the public or aviation industry who will be opposed to a rule that protects the model aviation hobby, and we need to make sure that our voices are heard in support of continued community-based self-governance.
Comments on the proposed sUAS rule can be made by clicking here. Read the proposed rule carefully, particularly the sections concerning "model aircraft," and submit comments on areas where you have a concern as well as thoughtful and productive comments in areas where you feel there could be improvement. AMA has created a suggested template for comments, which we strongly encourage you to edit and personalize. Unless extended, the deadline for submitting comments is 11:59 p.m., Friday, April 24, 2015.
Template Comment for AMA Members
(copy the template, click the comment now button below, and paste into the comment field)
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Well it looks like U won't be flying anything but a KITE with a 400' string or get your federal DRONE license ... just U wait and see.
The FAA is PISSED that congress gave them a mandate to promote Commercial service and make the NAS save for them and than proceeded to tell them that they can't mess with TOY Airplanes ... Well the FAA doesn't like to be told HOW to do their job. That's why we got the interpretation of congress amendment #336 that we got. Moral of this "Aesop fable" is don't exacerbate the situation by telling the people FAA that control your life that U aren't going to do comply with their Rules and regulations.
Now read the NPRM and try to respond to it in a courteous and intelligent manor.
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[TD]To view this email as a web page, go here.[/TD]
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You're receiving this email because of your affiliation with the Academy of Model Aeronautics.
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[/TD][TD="width: 360, bgcolor: #a0defd"]Academy of Model Aeronautics
Member Communication[/TD]
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[/TD][TD="width: 360, bgcolor: #bcbcbc"]Tuesday, March 17, 2015[/TD]
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AMA's Response to the FAA's sUAS NPRM
On February 23, 2015, the FAA published its proposed regulations for small unmanned aircraft systems (sUAS) as a notice of proposed rulemaking (NPRM). This began a 60-day period during which the public can comment on the proposed regulations. When finalized, the proposed rules would become the safety regulations for operating small,non-recreational, unmanned aircraft.
In accordance with the Special Rule for Model Aircraft (the AMA amendment) established by Congress in the FAA Modernization and Reform Act of 2012 (P.L. 112-95), the new regulations would not apply to model aircraft operated within the safety programming of a nationwide community-based organization. This is good news for AMA members; however, the FAA has said that to be exempt from regulations, model aircraft operators must operate within the parameters of the Special Rule set out by Congress in 2012.
The NPRM references FAA's June 2014 interpretation of the Special Rule. As indicated in detail in updates to our members last summer , the AMA has taken exception to several aspects of FAA's interpretation. The main areas of concern are that the FAA's interpretation:
• Asserts model aircraft to be "aircraft" and effectively makes model airplanes subject to all regulations applicable to full-scale aircraft.
• Makes model aircraft subject to airspace requirements that have never been applicable in the past and with which it is impossible or impractical to comply.
• Effectively changes the criteria for operating within 5 miles of an airport from the requirement of providing prior "notification" to a requirement of obtaining prior permission.
• Narrowly defines "hobby and recreation" and puts in question the activities of the supporting aeromodeling industry and AMA's educational programs.
• Rigidly defines the requirement to operate within visual line of sight and targets the use of a specific aeromodeling technology/equipment, namely first-person view (FPV) goggles.
Overall, the AMA views the proposed sUAS regulations as a positive step. With one exception that may impact model aircraft manufacturers, it essentially takes the language in the 2012 Special Rule for Model Aircraft (the AMA amendment) and places it in the federal aviation regulations.
We encourage members to submit comments commending the FAA for appropriately separating model aviation from the new regulations. However, AMA would also encourage members to include in their comments the need to resolve the discrepancies stemming from the Interpretive Rule before finalizing the sUAS rule. In any case, it's important that our members provide their comments in support of the proposed rule. It's possible that there will be members of the public or aviation industry who will be opposed to a rule that protects the model aviation hobby, and we need to make sure that our voices are heard in support of continued community-based self-governance.
Comments on the proposed sUAS rule can be made by clicking here. Read the proposed rule carefully, particularly the sections concerning "model aircraft," and submit comments on areas where you have a concern as well as thoughtful and productive comments in areas where you feel there could be improvement. AMA has created a suggested template for comments, which we strongly encourage you to edit and personalize. Unless extended, the deadline for submitting comments is 11:59 p.m., Friday, April 24, 2015.
Template Comment for AMA Members
(copy the template, click the comment now button below, and paste into the comment field)
[TABLE="width: 600, align: center"]
[TR]
[TD="align: left"]I am writing in response to the FAA's proposal to regulate small unmanned aircraft systems, including model aircraft. [Insert personal introduction details such as: I am a [job/profession], a member of the Academy of Model Aeronautics, and have been safely and responsibly flying model aircraft for ___ years. I am also a model aircraft club officer/educator/designer, etc.]
I support the exemption of recreational model aircraft from the regulation of unmanned aircraft systems. As Congress recognized, self-governance under community-based safety guidelines has worked exceptionally well for decades, and should remain in place. However, I have the following concerns about the FAA's proposal: [choose all that you feel apply, and feel free to add other comments]
The FAA has repeated its June 2014 statement that model aircraft are "aircraft" subject to all existing aviation regulations. The FAA must revise this interpretation so that it is in agreement with what Congress directed in 2012, which is that recreational model aircraft are subject to community-based safety guidelines, not aviation regulations. Similarly, the regulatory proposal excludes ultralight vehicles, moored balloons, kites, amateur rockets, and unmanned free balloons from the FAA's aircraft operating regulations but neglects to expressly exclude model aircraft. The proposed regulation should make it clear that model aircraft meeting the criteria established by Congress are not subject to aviation regulations.
Also, the proposal leaves out the part of the statute that excludes "an aircraft being developed as a model aircraft" from aviation regulations. This exclusion must be added to the regulations. Companies in the model aircraft industry should not be regulated as if they are aircraft manufacturers.
The FAA bases its proposal on its June 2014 interpretation of the law concerning model aircraft. There were 33,000 comments submitted last summer concerning that interpretation [including mine]. The future regulations for model aircraft should not be based on incorrect interpretations of what Congress wrote. Some of the interpretations that should be changed to the extent they form the basis for any current or future regulation include:
• Making model aircraft subject to airspace requirements such as air traffic control clearance, that have never been applicable in the past and with which it is impossible or impractical to comply. Congress indicated the maximum obligation, which is actually stricter than what the FAA's guidance has been for the past 34 years: notifying the airport when operating within five miles. That is the most that model aircraft hobbyists should have to do.
• Rigidly defining a requirement to operate within visual line of sight and that calls into question the use of a specific technology or equipment, namely first-person view (FPV) goggles. The language of the 2012 statute concerning "within visual line of sight" indicates how far away a person should fly the model aircraft, not what method of control may be used for the recreational experience. The proposal for commercial unmanned aircraft acknowledges that an observer (spotter) can be used to ensure airspace safety, just as the AMA's community-based safety guidelines do.
• Narrowly interpreting the words "hobby or recreational use." You should not regulate people who are flying model aircraft in connection with the hobby just because they receive payments. For decades, enthusiasts have participated in contests and competitions that have cash prizes, have been paid to instruct others on how to safely fly models, and have received compensation for aerobatic displays. These payments incidental to the hobby do not change the underlying recreational purpose of the activity or make the hobby any less safe, and regulating these activities would be highly disruptive to the hobby without any benefit.
Respectfully,
[Name]
[Optional] AMA Member Number: _________[/TD]
[/TR]
[/TABLE]
[/TD][TR]
[TD="align: left"]I am writing in response to the FAA's proposal to regulate small unmanned aircraft systems, including model aircraft. [Insert personal introduction details such as: I am a [job/profession], a member of the Academy of Model Aeronautics, and have been safely and responsibly flying model aircraft for ___ years. I am also a model aircraft club officer/educator/designer, etc.]
I support the exemption of recreational model aircraft from the regulation of unmanned aircraft systems. As Congress recognized, self-governance under community-based safety guidelines has worked exceptionally well for decades, and should remain in place. However, I have the following concerns about the FAA's proposal: [choose all that you feel apply, and feel free to add other comments]
The FAA has repeated its June 2014 statement that model aircraft are "aircraft" subject to all existing aviation regulations. The FAA must revise this interpretation so that it is in agreement with what Congress directed in 2012, which is that recreational model aircraft are subject to community-based safety guidelines, not aviation regulations. Similarly, the regulatory proposal excludes ultralight vehicles, moored balloons, kites, amateur rockets, and unmanned free balloons from the FAA's aircraft operating regulations but neglects to expressly exclude model aircraft. The proposed regulation should make it clear that model aircraft meeting the criteria established by Congress are not subject to aviation regulations.
Also, the proposal leaves out the part of the statute that excludes "an aircraft being developed as a model aircraft" from aviation regulations. This exclusion must be added to the regulations. Companies in the model aircraft industry should not be regulated as if they are aircraft manufacturers.
The FAA bases its proposal on its June 2014 interpretation of the law concerning model aircraft. There were 33,000 comments submitted last summer concerning that interpretation [including mine]. The future regulations for model aircraft should not be based on incorrect interpretations of what Congress wrote. Some of the interpretations that should be changed to the extent they form the basis for any current or future regulation include:
• Making model aircraft subject to airspace requirements such as air traffic control clearance, that have never been applicable in the past and with which it is impossible or impractical to comply. Congress indicated the maximum obligation, which is actually stricter than what the FAA's guidance has been for the past 34 years: notifying the airport when operating within five miles. That is the most that model aircraft hobbyists should have to do.
• Rigidly defining a requirement to operate within visual line of sight and that calls into question the use of a specific technology or equipment, namely first-person view (FPV) goggles. The language of the 2012 statute concerning "within visual line of sight" indicates how far away a person should fly the model aircraft, not what method of control may be used for the recreational experience. The proposal for commercial unmanned aircraft acknowledges that an observer (spotter) can be used to ensure airspace safety, just as the AMA's community-based safety guidelines do.
• Narrowly interpreting the words "hobby or recreational use." You should not regulate people who are flying model aircraft in connection with the hobby just because they receive payments. For decades, enthusiasts have participated in contests and competitions that have cash prizes, have been paid to instruct others on how to safely fly models, and have received compensation for aerobatic displays. These payments incidental to the hobby do not change the underlying recreational purpose of the activity or make the hobby any less safe, and regulating these activities would be highly disruptive to the hobby without any benefit.
Respectfully,
[Name]
[Optional] AMA Member Number: _________[/TD]
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03-19-2015, 07:46 AM
#241
My Feedback: (58)
Join Date: Dec 2001
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What is the programming of the CBO (AMA)?
Is membership required?
We need an answer and keep these dates in mind.............................
Is membership required?
We need an answer and keep these dates in mind.............................
General Membership Meeting
May 14, 2015
At the Joe Nall event
Woodruff, South Carolina
May 14, 2015
At the Joe Nall event
Woodruff, South Carolina
May 16-17, 2015
EC Meeting
Following the Joe Nall event
Woodruff, South Carolina
Open meetings where the questions need answered. EC Meeting
Following the Joe Nall event
Woodruff, South Carolina
03-19-2015, 07:52 AM
#242
Join Date: Mar 2004
Location: Orange County,
CA
Posts: 5,312
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Silent,
You do not have to accept that part of it, it is the language that is used in the definition. If pointing out the facts to you are passive aggressive snarkiness and are offensive to you then I suggest you report my posts. Otherwise your personal opinions about me or anyone that does not agree with you does not mean squat when you examine the facts. Fact is neither you or anyone else has provided a quote from the law or the FAA interpretation that states that one must be a member of a CBO to safely fly an RC aircraft.
Frank
You do not have to accept that part of it, it is the language that is used in the definition. If pointing out the facts to you are passive aggressive snarkiness and are offensive to you then I suggest you report my posts. Otherwise your personal opinions about me or anyone that does not agree with you does not mean squat when you examine the facts. Fact is neither you or anyone else has provided a quote from the law or the FAA interpretation that states that one must be a member of a CBO to safely fly an RC aircraft.
Frank
03-19-2015, 08:18 AM
#244
Senior Member
Join Date: Jan 2009
Location: Spring Hill, FL
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Frank
03-19-2015, 08:44 AM
#245
My Feedback: (58)
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His contention is based on loosely worded implications and some default that he feels AMA has a monopoly on... Not expressly detailed in law or defined by FAA any standard to which any CBO might qualify...so in short, his position is just a bunch of hooey. Not worth the bandwidth he wasted...LOL
03-19-2015, 08:44 AM
#246
Join Date: Sep 2009
Location: Aguanga,
CA
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And yet you refuse to provide a quote from a meaningful source like the final Bill SEC 336 or the FAA Interpretation of that law. I accept the definition provided in the congressional committee's report. I accept it as a whole and not just the "parts" you parsed out of it. I'll ask again. Where does it say that one must be a member of a CBO to safely fly an RC aircraft.
Frank
Frank
03-19-2015, 08:57 AM
#248
Senior Member
Join Date: Jan 2009
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Posts: 893
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His contention is based on loosely worded implications and some default that he feels AMA has a monopoly on... Not expressly detailed in law or defined by FAA any standard to which any CBO might qualify...so in short, his position is just a bunch of hooey. Not worth the bandwidth he wasted...LOL
03-19-2015, 09:03 AM
#249
Join Date: Mar 2004
Location: Orange County,
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And yet you refuse to provide a quote from a meaningful source like the final Bill SEC 336 or the FAA Interpretation of that law. I accept the definition provided in the congressional committee's report. I accept it as a whole and not just the "parts" you parsed out of it. I'll ask again. Where does it say that one must be a member of a CBO to safely fly an RC aircraft.
Frank
Frank
