Silent-AV8R,
The Small Unmanned Aircraft System or sUAS rulemaking by the FAA is clearly a significant issue for the AMA and the membership. When you read the FAA documentation it’s clear that their primary motivation is to avoid collisions between manned and unmanned aircraft.

What do I think the AMA should do? I think they are taking the right steps by first being involved in the Aviation Rulemaking Committee or ARC. A review of the ARC’s recommendation shows that the ARC members are in favor of granting more latitude to Model Aircraft operations that are conducted in accordance with an FAA accepted set of standards established and administered by a community based association. In other words an organization like the AMA and its Safety Code meet that standard. I haven’t seen any indication that a, “400 foot hard altitude limit at all times and in all locations” is being proposed. That doesn’t mean it is not possible that the AMA safety code would not require additional requirements.

We need to always remember the motive is to reduce the chance of a collision with a manned aircraft. If the AMA hasn’t already documented all known collisions between R/C aircraft and manned aircraft they should. They should identify any trends and determine if they resulted from ignoring the safety code or a lapse in the safety code. If it is the latter action should be taken to enhance the safety code. Having this information would provide analytical data for the cause of the collision, and I hope document how rare it is so the situation is put in perspective. That data will be important when responding to the Notice of Proposed Rulemaking or NPRM. I respond to NPRM’s as part of my job. When the FAA receives responses they don’t give any weight to statements like, “this is unfair”, “we don’t need this rule”, and the like. They are looking for fact based responses that either disprove a point in the rule, or an alternative proposal that will result in the same level of safety. It sounds like the AMA is doing the right thing by reviewing the safety code, and preparing for the NPRM. We as members should be prepared to write our own responses to the NPRM, and to our legislature.

It is quite possible the AMA will need to add requirements to the safety code. I think a good one would be to require signage at fields alerting flyers of any known areas of manned flight in the area of the field. The AMA could start a new push to be vigilant about conflicts with manned aircraft, one that is featured in communication both written and on the internet. This could be similar to the membership drive that is now in full swing. That kind of proactive stance could not be faulted. In the end perhaps when we operate above some ceiling or speed an observer will be required to watch for conflicts with manned aircraft. We really don’t know it all depends on the NPRM.