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Response needed, AMA Model Aircraft Rule

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Old 07-01-2014, 03:46 PM
  #1
AndyAndrews
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Default Response needed, AMA Model Aircraft Rule -Mods Please sticky

Jet Jocks,

From the AMA:

"The Academy of Model Aeronautics has issued an action alert to its membership, partnering organizations, and aeromodeling media requesting immediate response to FAA's interpretation of the Special Rule for Model Aircraft, released June 23. The purpose of the action alert is to notify the FAA through public comment that this rule significantly impacts the entire aeromodeling community and that this community is resolute and committed to protecting the hobby."

It would have been helpful if the AMA provided this like other advocacy agencies but they didn't. I have taken it upon myself to clip and paste and revise the AMA letter to reflect a personal message to the FAA. All one has to do is to clip and paste the text below HERE:

http://www.regulations.gov/#!submitC...2014-0396-0001

Next download the PDF file from my dropbox and upload it using the FAA's UPLOAD feature. This PDF has the specifics that won't fit in the comment box:

https://www.dropbox.com/s/xsy55iz0oo...%20Concern.pdf


Suggested Text to use in comment Box:
---------------------------------------------------------------------------------------------------------------------------------

Individual Remote Control Modeler Areas of Concern
FAA Interpretive Rule Regarding the Special Rule for Model Aircraft

Docket number FAA-2014-0396

To Whom it May Concern:

In my personal review of the document I found a number of areas objectionable. Moreover, I believe the Interpretive Rule as a whole is in essence a backdoor approach to enacting new regulatory requirements without complying with the Congressional mandated Administrative Procedures Act. It is an abuse of the provision for Interpretive Rule under 5 U.S. Code § 553, and is contrary to Public Law 112-95, Sec. 336 which states, “the Federal Aviation Administration may not promulgate any rule or regulation regarding a model aircraft or an aircraft being developed as a model aircraft, if… the aircraft is operated in accordance with a community-based set of safety guidelines and within the programming of a nationwide community-based organization.” The Interpretive Rule specifically addresses model aircraft operated within the safety programming of a nationwide community-based organization, AMA, and it effectively establishes new rules to which model aircraft were not previously subjected, i.e. model aircraft must meet the regulatory requirements for operating in particular classes of airspace.

Please see the attached PDF document going into specifics regarding my objection to this proposed rule.

Sincerely,

YOUR NAME HERE

----------------------------------------------------------------------

Add what you want but this covers the basics. I really hope this helps others post comments to the FAA regarding this issue. This is serious folks. Lets get the word out.

Andy


Last edited by AndyAndrews; 07-06-2014 at 08:10 AM.
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Old 07-01-2014, 04:04 PM
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I just tested it and it works. Just clip and paste the comments text and then upload the PDF file from my dropbox for the specifics.:

[h=2]Your Receipt[/h]
  • 3
    Your Receipt

  • 2
    Your Preview

  • 1
    Your Information


[TABLE="class: GLHWMP-BJVD"]
[TR]
[TD="class: GLHWMP-BHVD, align: center"]Your Comment Tracking Number: 1jy-8czc-kpcf[/TD]
[TD="class: successInfo msgBox GLHWMP-BKVD, bgcolor: #FFFCDD"]Your comment will be viewable on Regulations.gov after the agency has reviewed it, which may be an indefinite amount of time. Use your tracking number to find out the status of your comment.[/TD]
[/TR]
[/TABLE]

[h=3]Your comment:[/h]Comment:Individual Remote Control Modeler Areas of Concern
FAA Interpretive Rule Regarding the Special Rule for Model Aircraft

Docket number FAA-2014-0396

To Whom it May Concern:

In my personal review of the document I found a number of areas objectionable. Moreover, I believe the Interpretive Rule as a whole is in essence a backdoor approach to enacting new regulatory requirements without complying with the Congressional mandated Administrative Procedures Act. It is an abuse of the provision for Interpretive Rule under 5 U.S. Code § 553, and is contrary to Public Law 112-95, Sec. 336 which states, “the Federal Aviation Administration may not promulgate any rule or regulation regarding a model aircraft or an aircraft being developed as a model aircraft, if… the aircraft is operated in accordance with a community-based set of safety guidelines and within the programming of a nationwide community-based organization.” The Interpretive Rule specifically addresses model aircraft operated within the safety programming of a nationwide community-based organization, AMA, and it effectively establishes new rules to which model aircraft were not previously subjected, i.e. model aircraft must meet the regulatory requirements for operating in particular classes of airspace.

Please see the attached PDF document going into specifics regarding my objection to this proposed rule.

Sincerely,
Roy Andrews

Uploaded File(s)(Optional)
  • Individual Remote Control Modeler Areas of Concern.pdf: success




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Old 07-01-2014, 04:06 PM
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Mods,

If you find this info helpful to the community, please STICKY it so everyone has a chance to submit comments to the FAA regarding this issue.

Thank you,
Andy Andrews
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Old 07-01-2014, 07:56 PM
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Is there another way to voice this issue?
Do our Congressmen deal with the FAA?
I think another letter sent to an elected official might also help if thats possible I just dont know the chain here.

Also, are there any senior marketing people on here from Boeing, Lockheed, etc? You would do well to help out because the future of model aviation is here and with your help it will still be around for generations to come. I know Boeing has a model air club and field in WA so I think it would be something your people would and should be interested in helping out the community at large with.
The PR would be great and the benefit to the model aircraft community would be very appreciated.

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Old 07-01-2014, 09:16 PM
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Quote:
Originally Posted by AndyAndrews View Post
Jet Jocks,

From the AMA:

"The Academy of Model Aeronautics has issued an action alert to its membership, partnering organizations, and aeromodeling media requesting immediate response to FAA's interpretation of the Special Rule for Model Aircraft, released June 23. The purpose of the action alert is to notify the FAA through public comment that this rule significantly impacts the entire aeromodeling community and that this community is resolute and committed to protecting the hobby."

It would have been helpful if the AMA provided this like other advocacy agencies but they didn't.

Andy,
I was thinking the same thing when they sent out the notice. Nothing, not even a few suggested lines. Pretty amateurish for an advocacy group. They need to get their act together. Thanks for doing this.
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Old 07-02-2014, 06:13 AM
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I sent my comments in.
Andy thanks for your work on this issue!
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Old 07-02-2014, 06:33 AM
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I just sent mine in.
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Old 07-02-2014, 06:59 AM
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sent
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Old 07-02-2014, 01:45 PM
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sorry meant to post to another forum. Andy this is a good write up, but I am not defending FPV.


IIRC, when this whole mess with the FAA, sUAS integration, NPRM got rolling (2005?), the AMA was clear:

Model Aircraft = Line of Site.....no FPV

Now the AMA is doubling down on FPV when this "5 mile airport approval" disaster is hitting.

Last edited by mr_matt; 07-02-2014 at 01:53 PM.
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Old 07-02-2014, 02:02 PM
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You know, I could potentially see how FPV could be fun and have a great hobby aspect to it.

I can see myself wanting to "virtually" sit in the cockpit of my bandit as I do vertical take off and flat spins, etc.... just to see what flying aerobatics might approach to feeling like.

But long distance FPV over homes or what ever, just seems like a different kind of Remote control. Not the kind I'm interested in condoning if it is endangering what so many of us really enjoy: Line of sight RC. Its like my own airshow everytime I fly.

How "married" is the AMA (and hence us, me!) to FPV I wonder?
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Old 07-02-2014, 02:08 PM
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Quote:
Originally Posted by ravill View Post
How "married" is the AMA (and hence us, me!) to FPV I wonder?
Married and buried
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Old 07-02-2014, 02:09 PM
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I agree that we shouldn't be lumped in with the FPV guys. The problem is that we are being lumped in with the FPV guys in the FAA's response. I don't recall reading anything in the AMA response to the FAA about FPV. It's not in the letter at all. This affects US too guys.
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Old 07-02-2014, 02:47 PM
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Andy, I wish you would have posted your outline yesterday, as I sent my response to the FAA, already. Sad to admit but your wording is better than mine, with all the references to the congressional law numbers and such, BUT, my plain everyman wording will still get the point across and not look like a Cut and paste form letter, I hope.
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Old 07-02-2014, 02:57 PM
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Quote:
Originally Posted by Terry Holston View Post
Andy, I wish you would have posted your outline yesterday, as I sent my response to the FAA, already. Sad to admit but your wording is better than mine, with all the references to the congressional law numbers and such, BUT, my plain everyman wording will still get the point across and not look like a Cut and paste form letter, I hope.
Terry, All that matters is that you responded. We don't want the FAA making us report to the managers of Airports before we fly etc. This thing is a real mess.
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Old 07-02-2014, 05:36 PM
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I am not a jet Jock, however I did submit the letter. Hope this helps

Glenn
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Old 07-02-2014, 06:06 PM
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Quote:
Originally Posted by willig10 View Post
I am not a jet Jock, however I did submit the letter. Hope this helps

Glenn
LOL, you don't have to be. This one affects us all. Thanks for Submitting!!
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Old 07-02-2014, 06:32 PM
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Even though I could care less about the FPV guys (I can say the same about Foamie fliers as well though ) or the guys wearing all the sponsored shirts flying sponsored airplanes, I have also submitted my comments as outlined by you Andy.

Solidarity, as I see it, is the only way to prevail.

Just because I think we should outlaw foamies, quadcopters, Noobs with helicopters, long range FPV, doesn't make me right. Even though I know I am, in my own head.

Last edited by ravill; 07-02-2014 at 06:34 PM.
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Old 07-02-2014, 06:50 PM
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Submitted! Thanks for the direction and help Andy
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Old 07-03-2014, 11:30 PM
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Done!!!
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Old 07-04-2014, 06:41 AM
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bump.
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Old 07-06-2014, 08:03 AM
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Old 07-06-2014, 03:48 PM
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another bump
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Old 07-06-2014, 05:02 PM
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Old 07-06-2014, 05:59 PM
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I'm curious as to whether the 2 major RC distributors in NA are working with the AMA in fighting this intrepretation.
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Old 07-07-2014, 07:20 PM
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