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FAA: CBO Membership NOT required to comply with 336

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Old 07-28-2016, 06:50 PM
  #126  
Chris P. Bacon
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Originally Posted by cj_rumley
Good point. I can see the economic advantage of propagating that disinformation to increase membership/revenue flow.
It was analysis, not advantage, but hey, the truth is what you want it to be.
Old 07-28-2016, 06:53 PM
  #127  
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Originally Posted by porcia83
I'd rather do my own legwork than rely on someone else, cred or no cred. To each their own.
Same here. Knowledge is power. Can't imagine not being self-sufficient and relying on others (on a public Internet forum no less) as my only source for important information.
Old 07-28-2016, 07:17 PM
  #128  
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Originally Posted by cj_rumley
Good point. I can see the economic advantage of propagating that disinformation to increase membership/revenue flow.
Good point. That might explain why that misinformation continues on the site of the private dues collecting organization...some as recently as the 28th.

Chad Budreau on 25 July - "To operate within AMA’s programming, membership is required [emphasis added]."
Tyler Dobbs on 28 July - "To operate within AMA’s nationwide community-based programming, a pilot needs to be a member [emphasis added]."

But the only authoritative source, on the question whether membership is required to comply with Section 336, is the Federal Aviation Administration.

"The FAA does not interpret PL 112-95 Section 336 (a) (2) as requiring membership in a CBO .... You must only follow the guidelines of a CBO."
- FAA UAS Integration Office email on July 12, 2016.
Old 07-28-2016, 07:21 PM
  #129  
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Old 07-28-2016, 07:26 PM
  #130  
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Originally Posted by Chris P. Bacon
It was analysis, not advantage, but hey, the truth is what you want it to be.
bye
Old 07-28-2016, 07:30 PM
  #131  
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Originally Posted by cj_rumley
bye
Old 07-29-2016, 03:38 AM
  #132  
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Originally Posted by cj_rumley
Yes, it's clear that cred doesn't matter to you. Got it, quite some time past.
And it's clear that some type of "cred" appears to only matter to you. What are we 12 year olds talking about how big our fathers gun is, or how we have more Pokemon cards than someone else?

I'll tell ya what, I place "cred" with people who actually do something. Not the people who have gone from one mission, to another mission which is sitting on the sidelines taking pot shots at an organization they despise, yet continue to be part of. Or better yet people who post stalk and make veiled comments to others trying to dox them about their volunteer work on behalf of organizations. Is that behavior that instills credibility? The torch and pitchfork crowd, along with those who jump on the bandwagon because it's easier to whine then work, occasionally have some good points. They lost the ability to leverage that information long ago, because it's drowned out in the waterfall of complaints, cynicism, and negativity. These kind of folks, the Debbie Downers of the day, have been around forever, nothing will ever be right, or good enough. Were you around in the 80's when the same type of people "stormed the AMA headquarters" thinking they would find graft and bribes and nefarious activities? Ya, it didn't turn out to well for them, they were humiliatingly wrong. But hey, I'm sure they had "cred" among their own.

I'd rather look to those that went out and got involved, in a meaningful way, and put their money where their mouth is. And even then, I'm going to do my own due diligence to validate and verify what they are saying. The parroting of the same thing we see here and in many other threads now is ineffective except for 3 or 4 people, and if you can't see that's it's been done to validate and further an ongoing narrative well then, oh well.
Old 07-29-2016, 04:09 AM
  #133  
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Originally Posted by porcia83
The parroting of the same thing we see here and in many other threads now is ineffective except for 3 or 4 people, and if you can't see that's it's been done to validate and further an ongoing narrative well then, oh well.
Except that in just three days, almost 1200 people have now seen that the FAA does not require membership in a CBO to comply with section 336. And that's just on this site. Most have been silent, but they have the source documents and are now able to make a better informed decision on whether or not membership in a private dues collecting organization is warranted.

I consider it a public service. So yes, I did do something. Researched the law, found the right government office, crafted the question, got the definitive answer from the government agency, and shared in a number of places to maximize information sharing.
Old 07-29-2016, 04:20 AM
  #134  
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Originally Posted by franklin_m
Except that in just three days, almost 1200 people have now seen that the FAA does not require membership in a CBO to comply with section 336. And that's just on this site. Most have been silent, but they have the source documents and are now able to make a better informed decision on whether or not membership in a private dues collecting organization is warranted.

I consider it a public service. So yes, I did do something. Researched the law, found the right government office, crafted the question, got the definitive answer from the government agency, and shared in a number of places to maximize information sharing.
1200 views= #streetcred? Do you actually think that all 1200 views represent people who didn't know this before? It's an AMA thread...people are going to come into it in part just to see what's going on.

You did do something, I agree. But again, I could also start a thread and say "registration is required" and get 1500 hits, what's the point? You manufactured a controversy or question after multiple attempts at boxing Chad into a corner (which you never managed to do), then asked a self serving question to get an obvious answer, and want to now label that as as public service? O/K I guess it was. The information is out now, and the issue dealt with accordingly. For now.
Old 07-29-2016, 04:56 AM
  #135  
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Originally Posted by franklin_m
Except that in just three days, almost 1200 people have now seen that the FAA does not require membership in a CBO to comply with section 336. And that's just on this site. Most have been silent, but they have the source documents and are now able to make a better informed decision on whether or not membership in a private dues collecting organization is warranted.

That was me, I viewed the page 1195 times because I just couldn't believe it.

I consider it a public service. So yes, I did do something. Researched the law, found the right government office, crafted the question, got the definitive answer from the government agency, and shared in a number of places to maximize information sharing.
..
Old 07-29-2016, 04:59 AM
  #136  
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Originally Posted by porcia83
1200 views= #streetcred? Do you actually think that all 1200 views represent people who didn't know this before? It's an AMA thread...people are going to come into it in part just to see what's going on.
Well, in all fairness, Chad and Tyler at AMA HQ apparently didn't know, and still don't (as of yesterday at least).


Originally Posted by porcia83
You did do something, I agree. But again, I could also start a thread and say "registration is required" and get 1500 hits, what's the point? You manufactured a controversy or question after multiple attempts at boxing Chad into a corner (which you never managed to do), then asked a self serving question to get an obvious answer, and want to now label that as as public service? O/K I guess it was.
Well, I checked a couple web analytics pages, and RCU gets a much higher ranking for traffic than AMA's site (typically double the ranking or close to it). With postings on other sites, pushing the info to some drone publications, I'd say I got the PR ball rolling.

Many of those drone fliers out there that AMA hoped to capture as new members with the AMA's "interpretation" of the rule, now know the FAA's interpretation (the only one that counts by the way). You don't have to be a member of AMA to comply with the "..comply with safety guidelines and within the programming" part of the law. They can also see plainly that what AMA continues to say is wrong.



Originally Posted by porcia83
The information is out now, and the issue dealt with accordingly. For now.
Two comments cited word for word in Federal Register by FAA on why why AMA should not be involved in registration. Definitive answer from FAA that AMA membership is not required to comply by law, and exposing what Chad and Tyler are telling people is wrong. A growing PR effort to spread this good news to all those droners out there who might have been wrongly led to believe they had to join some organization to be legal.

I'd say I'm not doing too badly so far. And to think, it would have been so easy to for AMA to have me working with them... I would have been happy with a single vote by the EC on one proposal. But they wouldn't even put it to a vote.
Old 07-29-2016, 05:01 AM
  #137  
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Originally Posted by Chris P. Bacon
Except that in just three days, almost 1200 people have now seen that the FAA does not require membership in a CBO to comply with section 336. And that's just on this site. Most have been silent, but they have the source documents and are now able to make a better informed decision on whether or not membership in a private dues collecting organization is warranted.

That was me, I viewed the page 1195 times because I just couldn't believe it.

I consider it a public service. So yes, I did do something. Researched the law, found the right government office, crafted the question, got the definitive answer from the government agency, and shared in a number of places to maximize information sharing

No matter how hard you try, you can't put lipstick on that pig.

Think of all those "droners" out there, folks AMA hoped to capture as members, who now know that membership is NOT required to comply with the law.
Old 07-29-2016, 05:05 AM
  #138  
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Originally Posted by franklin_m
No matter how hard you try, you can't put lipstick on that pig.

You're right, I can't, but I'm watching how you do it so well and taking notes.

Think of all those "droners" out there, folks AMA hoped to capture as members, who now know that membership is NOT required to comply with the law.

I was up all night worrying about it.
..
Old 07-29-2016, 05:08 AM
  #139  
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Originally Posted by Chris P. Bacon
Originally Posted by franklin_m
Think of all those "droners" out there, folks AMA hoped to capture as members, who now know that membership is NOT required to comply with the law.

I was up all night worrying about it
And it appears the AMA is as well. As they should be.

They've been exposed for promulgating a position that is, at best, woefully uninformed. At worst, deliberate deception.

Last edited by franklin_m; 07-29-2016 at 05:14 AM.
Old 07-29-2016, 05:12 AM
  #140  
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Originally Posted by Chris P. Bacon
Originally Posted by franklin_m
No matter how hard you try, you can't put lipstick on that pig.
You're right, I can't, but I'm watching how you do it so well and taking notes.
And to think, I did it all from my laptop w/o leaving my house. Not one dollar of lobbying money spent.

Just a knowledge of how government works and how to illustrate to them that a policy to require AMA membership would have to be applied to all similar organization (AOPA and EAA for example).
Old 07-29-2016, 05:18 AM
  #141  
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Originally Posted by franklin_m
And it appears the AMA is as well. As they should be. They've been exposed for promulgating a less than truthful position.
What makes you think they were up all night worrying about it? Putting more lipstick on your pig? By the way, that FUD color looks great!

Again the truth is what you want it to be.

It's funny how the FAA's response you received never said how you can prove you are following the guidelines of a CBO.
Old 07-29-2016, 05:21 AM
  #142  
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Originally Posted by franklin_m
And to think, I did it all from my laptop w/o leaving my house. Not one dollar of lobbying money spent.

Just a knowledge of how government works and how to illustrate to them that a policy to require AMA membership would have to be applied to all similar organization (AOPA and EAA for example).
You should still create a non-profit so you can write off your time, laptop depreciation, electric, and all your other operating expenses as permitted by law.

You've done a great public service here and all those 1200 unique visitors have great expectations of more to come.
Old 07-29-2016, 06:12 AM
  #143  
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Originally Posted by Chris P. Bacon
Again the truth is what you want it to be.
Well, on this topic at least, the truth is as the FAA cited it, NOT what the AMA is saying.



Originally Posted by Chris P. Bacon
It's funny how the FAA's response you received never said how you can prove you are following the guidelines of a CBO.
Complying with the guidelines is pretty trivial. I'm doing it already. I plan to have a copy with me so I can show point by point how I'm complying.
Old 07-29-2016, 06:13 AM
  #144  
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Originally Posted by Chris P. Bacon
You've done a great public service here and all those 1200 unique visitors have great expectations of more to come.
Thank you for the compliment.

The PR effort will expand if nothing else. I'm trying to make sure that as many folks as possible are informed of the FAA's interpretation that membership is not required to comply with PL112-95 Section 336 para (a)(2).
Old 07-29-2016, 06:25 AM
  #145  
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Originally Posted by franklin_m
Well, on this topic at least, the truth is as the FAA cited it, NOT what the AMA is saying.

Has it been tried in court yet?

Complying with the guidelines is pretty trivial. I'm doing it already. I plan to have a copy with me so I can show point by point how I'm complying.

Certifying makes it official. The membership application is a legally binding contractual agreement. Anything else is purely speculation.
..
Old 07-29-2016, 06:28 AM
  #146  
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Originally Posted by franklin_m
Thank you for the compliment.

The PR effort will expand if nothing else. I'm trying to make sure that as many folks as possible are informed of the FAA's interpretation that membership is not required to comply with PL112-95 Section 336 para (a)(2).
More reason to form a non-profit, those TV and radio commercials can get expensive. Billboards around Munice might not be to expensive. With upcoming Olympics a few well placed TV commercials would have significant impact.
Old 07-29-2016, 06:29 AM
  #147  
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Franklin, your efforts are appreciated... it does appear that there continues to be a problem with +55lb and jet aircraft. A public law cannot (and should not appear to) force you to join any organization. AMA should respect that and stop making such statements.
Old 07-29-2016, 07:10 AM
  #148  
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Originally Posted by on_your_six
Franklin, your efforts are appreciated... it does appear that there continues to be a problem with +55lb and jet aircraft. A public law cannot (and should not appear to) force you to join any organization. AMA should respect that and stop making such statements.
I agree, and thanks.
Old 07-29-2016, 07:12 AM
  #149  
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Originally Posted by Chris P. Bacon
More reason to form a non-profit, those TV and radio commercials can get expensive. Billboards around Munice might not be to expensive. With upcoming Olympics a few well placed TV commercials would have significant impact.
That's a good suggestion, but for the time being I don't think that's needed. But thanks for helping keep this thread at the top of the feed - ensures more people see what the FAA said!
Old 07-29-2016, 07:14 AM
  #150  
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Originally Posted by franklin_m
That's a good suggestion, but for the time being I don't think that's needed. But thanks for helping keep this thread at the top of the feed - ensures more people see what the FAA said!
Always happy to help out during a life threatening emergency.


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