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AMA letter to FAA, have you READ IT?

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AMA letter to FAA, have you READ IT?

Old 02-20-2020, 07:26 PM
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dabigboy
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Default AMA letter to FAA, have you READ IT?

I've been mulling over the language of the remote ID NPRM and the supporting documents on the FAA's website. Tonight was the first time I actually read the letter AMA sent to the FAA back in Nov 2018. I'm afraid my opinion of AMA just dropped several notches.

Here's the letter: https://www.regulations.gov/document...2019-1100-0014

Almost right away, we're off to a bad start. Here's an excerpt:

"We ask for FAA collaboration in adopting remote identification requirements that reflect the operational use of UAS
model aircraft, under AMAs safety programming, pose no new risk to the airspace"

Notice how they qualify safe operation of model aircraft right off the bat with the mention of "AMA's safety programming". As if people who don't explicitly conform to AMA guidelines are automatically less safe.

Here's another:

"Congress has long recognized that model aircraft operating within a community-based organization do
not pose the same safety and security challenges of more sophisticated UAS"

This looks like a bold-faced lie. Considering the legal concept of a "community-based organization" as it relates to RC aircraft is kinda a new thing, I don't see how AMA can say that Congress "has long recognized" anything to do with a model aviation-related CBO.

Weight limit:

"AMA recommends the agency consider a one-kilogram threshold for model aircraft that must comply with the new requirements"

AMA clearly didn't get what they wanted on this point in the NPRM, but 1 kg is only a little over 2 pounds. Sure, it's better than the 250g threshold we're facing now, but even the most basic .40-sized trainer is gonna be well more than double that.

But that's not all....for aircraft over this weight, AMA goes on to offer two alternatives to remote ID:

"...(1) operating at fixed
flying sites or (2) a software-based solution."

This is pretty much EXACTLY what ended up in the NPRM. The FPV guys have no need or interest in traditional flying sites. In fact, they PREFER other, more interesting locations (to say nothing of the guys doing it for hire, who are going to be pretty much anywhere BUT a dedicated flying field). AMA just threw them under the bus....along with folks who fly on their own property, at small airports, in local parks, etc (the 1 kg request notwithstanding...there are plenty of parks and open public spaces that can easily and safely accommodate much larger models).

And here I'd been thinking AMA was on-board with the conventional wisdom that model aircraft are outside the FAA's authority, shouldn't be thrown into the same category as the upcoming generation of autonomous commercial aircraft, and should not be regulated at all. The whole letter seems very self-serving. Instead of saying "Hey FAA, we've been flying longer than you've existed, we're safe, and we're not bothering anyone", they jumped on board with the new remote ID scheme, seeking meaningful concessions only for their own members flying at officially chartered AMA sites.

The way I see it, AMA actually got pretty much what they asked for, along with one show-stopping caveat: the 12 month limit on establishing FRIAs. I have to wonder if we'd have been better off if the AMA had not been involved at all!

To any AMA officers and/or faithful supporters on this board: I'm not trying to beat up on AMA. I found this letter surprising and disturbing, and I want the community to understand AMA's role in all this. I started flying RC when I was 12, and maintained an AMA membership much of that time (when I was actively flying), up until about 5 years ago when I got away from the hobby. We needed you to take a stand for our grassroots aviation culture (and, indeed, for personal liberty) and go toe-to-toe with the FAA on this issue. I'm disappointed at what I see as the organization frittering away the future of model aviation for its own short-term interests.

Matt
Old 02-21-2020, 05:58 AM
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And this kind of follows along with what many of us have been saying all along. The AMA is only looking at building it's membership numbers and treasury. By requesting only AMA sanctioned sites(aka FRIA sites), they are effectively saying to the FAA that they want it to be law that you must join the AMA or forget about flying ANYWHERE!!!!!
What the AMA has basically said is that glider competitions, float flying and any other sort of events not held at AMA sanctioned fields will now be illegal. I guess, when the hobby dies, the AMA can sit back in their home office complex and say "It was a good run, while it lasted" and not "We did our job and R/C flying will continue for years to come".
Old 02-21-2020, 06:07 AM
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That's not it at all.

The hope is that FRIA sites can be established and flexible, NOT cut off in 12 months.

Also that an app based solution for non fixed flying sites can be established to cover float flying and private use and the like.
Old 02-21-2020, 06:47 AM
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Originally Posted by BarracudaHockey View Post
That's not it at all.

The hope is that FRIA sites can be established and flexible, NOT cut off in 12 months.

Also that an app based solution for non fixed flying sites can be established to cover float flying and private use and the like.
To use an "app based" solution requires a smart phone and access. Not all locations have coverage to make that work and I personally don't have a smart phone since I don't need or want one. That means any location where you can't get coverage will now be an "illegal site" based on that alone and I would be illegal everywhere but a FRIA site unless I get a smart phone with internet access, something that costs big bucks in my area. Sorry Andy, but I'm still not buying it and stand by my previous post.

Last edited by Hydro Junkie; 02-21-2020 at 07:33 AM.
Old 02-21-2020, 06:50 AM
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Lets say you're at home.

You have an app, you say I'm going to be at 36.13N 81.40W at 1pm for 2.5 hours. You get approval, you go fly.

That's the hope
Old 02-21-2020, 07:10 AM
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Originally Posted by dabigboy View Post
(1) operating at fixedflying sites or
(2) a software-based solution.
This is pretty much EXACTLY what ended up in the NPRM.
Not at all. A "software based solution" would be something like LAANC. Not a requirement to have a "beacon" permanently installed in each plane broadcasting location and altitude in real time.

You left out a few other things. The AMA did not ask for universal registration requirements. Nor did the AMA ask for a prohibition on flying "amateur built" aircraft outside of club fields. Nor did the AMA ask for all the "UAS Producer" provisions that essentially make it impossible for individuals to build Remote ID compliant models.

To me, it looks like the AMA asked for two common sense alternatives: An exemption for existing flying sites, and a simple notification of intent to use the airspace outside of flying sites. I think they were just as surprised as the rest of us by what the FAA responded with.
Old 02-21-2020, 07:21 AM
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Originally Posted by BarracudaHockey View Post
Lets say you're at home.

You have an app, you say I'm going to be at 36.13N 81.40W at 1pm for 2.5 hours. You get approval, you go fly.

That's the hope
Sadly that is not the reality today. RID will not involve permission to fly, that is a separate issue. RID will be all about announcing who you are, where you are, and what you're flying and how. Your method minus the permission part is what it should be. Let's hope the FAA is swayed by responses they have received.
Old 02-21-2020, 07:28 AM
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I wasn't implying "permission to fly" Bill, I was implying that you notify them where you will be flying if outside a FIRA and during what hours.
Old 02-26-2020, 02:57 PM
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Trying not to be too critical and can't take credit for this observation as it was pointed out to me by a leader member - it's all right there in the Official AMA Safety Code and it isn't being referenced in this letter; we've already been abiding with a 400' restriction within 3 miles of an airport and complied with remote identification by labeling our aircraft with our personal info. While writing my comment for the RID NPRM, I found out we no longer have that simple one page safety code that has a few points under four sections: General, R/C, FF, and C/L. Now, it's a Safety Booklet that is so convoluted and cluttered with pictures that it looks very difficult to comprehend or follow.

This is what I remember from my start in R/C and similar to what is posted at the club's airfield:



Old 02-26-2020, 04:30 PM
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You realize you are looking at a 36 year-old version of the Safety Code, right? The current Safety Code has no altitude limits based on simple proximity to an airport. It is all about airspace. In Class G the current limit os 400 feet. If you are within the surface area of controlled airspace associated with an airport it is either as dictated in you LOA for a fixed site or according to the LAANC altitude grid map altitude.
Old 02-26-2020, 07:42 PM
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Do what make sense. Just fly. When FAA can enforce their proposal in 4 years or whatever it turns out to be, and they believe they can find every remote site in the USA and maintain enforcement, then they have won.

Until then, I should complete my lifetime flying aircraft as usual in the hobby with ease as I have for the last 40 years, and nothing is going to change that, ever. Not AMA, not FAA, not any self serving agency.
Old 02-26-2020, 07:59 PM
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You have four days left to submit NPRM comments. Why not do that instead of making argumentative posts here? Who knows -- maybe you'll hit the right combination and cause the FAA to make substantial changes or chuck the whole job? There'll be plenty of time for recriminations AFTER March 2.
Old 02-28-2020, 11:56 AM
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Because the there won't be any changes made by the FAA. They want to give National Airspace safety without any RC/drone interference, and give law enforcement an easy way of tracking drone activity. Nothing is going to stop or change that.
Are you new to this country?

Old 02-28-2020, 07:17 PM
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Originally Posted by J330 View Post
Because the there won't be any changes made by the FAA.
If we don't ask for any, that becomes a self-fulfilling prophecy.

Three days left. He who doesn't post comments has no right to complain about the result!

Old 02-29-2020, 02:09 AM
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Originally Posted by J330 View Post
Because the there won't be any changes made by the FAA. They want to give National Airspace safety without any RC/drone interference, and give law enforcement an easy way of tracking drone activity. Nothing is going to stop or change that.
Are you new to this country?
And AMA knows it. In most recent Model Aviation, they're already trying to "shape expectations" of their members:

"I think it is also important that we have realistic expectations regarding the regulation of our hobby. When terms such as Homeland Security and National Defense enter the conversation at the government level, we should not expect that AMA or any other person or group could stop all of the proposed regulations."
- AMA Editor Jay Smith, Model Aviation Magazine, March 2020, page 6

Last edited by franklin_m; 02-29-2020 at 02:14 AM.
Old 02-29-2020, 08:37 AM
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Originally Posted by franklin_m View Post
And AMA knows it. In most recent Model Aviation, they're already trying to "shape expectations" of their members:

"I think it is also important that we have realistic expectations regarding the regulation of our hobby. When terms such as Homeland Security and National Defense enter the conversation at the government level, we should not expect that AMA or any other person or group could stop all of the proposed regulations."
- AMA Editor Jay Smith, Model Aviation Magazine, March 2020, page 6
And what about this quote is inaccurate?

Over the last month or so (and really longer than that), its been obvious that this RID requirement was in fact driven by DHS and DOD, with the FAA being made the scapegoat

But I forgot, the AMA can do nothing right, right?

R_Strowe
Old 02-29-2020, 09:29 AM
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Originally Posted by R_Strowe View Post
And what about this quote is inaccurate?

Over the last month or so (and really longer than that), it’s been obvious that this RID requirement was in fact driven by DHS and DOD, with the FAA being made the scapegoat

But I forgot, the AMA can do nothing right, right?

R_Strowe
The point being that AMA is speaking out of both sides of their mouth. On one hand you have the ED and government affairs giving members the impression their efforts are making a difference, and on the other hand you have others shaping expectations in anticipation of yet another loss. Regulation is coming. And I think we'll see very few changes from the proposed rule.

And those touted membership numbers? It will be interesting to watch them change if they start charging youth members. I can just imagine the discussion. "We're not converting free youth memberships to paying memberships, so I've got this great idea ... let's make them PAY for what wasn't working when it was free!"

Last edited by franklin_m; 02-29-2020 at 10:45 AM.
Old 02-29-2020, 01:15 PM
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Originally Posted by R_Strowe View Post
Over the last month or so (and really longer than that), its been obvious that this RID requirement was in fact driven by DHS and DOD, with the FAA being made the scapegoat
All the more reason to submit comments.

Originally Posted by franklin_m View Post
Regulation is coming. And I think we'll see very few changes from the proposed rule.
"Very few" is not NONE, and someone even now might have a really good idea which lets the FAA accomplish legitimate regulatory objectives while making rules and procedures less onerous. Of course those whose real agenda is to clear the airspace for commercial drone traffic will disagree.
Old 02-29-2020, 02:24 PM
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Originally Posted by grognard View Post
"Very few" is not NONE, and someone even now might have a really good idea which lets the FAA accomplish legitimate regulatory objectives while making rules and procedures less onerous. Of course those whose real agenda is to clear the airspace for commercial drone traffic will disagree.
You're right. One very welcome change would be to not compel membership in PRIVATE dues collecting organization in order to exercise privilege of flying in PUBLIC airspace w/ non-compliant equipment. It's just like saying that in order to drive on public highways w/ an antique vehicle you have to be a member of AAA. That would be a change I could support.
Old 02-29-2020, 02:41 PM
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Franklin, can you explain to me how AMA fits the definition of private?
Old 02-29-2020, 03:03 PM
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Originally Posted by franklin_m View Post
One very welcome change would be to not compel membership in PRIVATE dues collecting organization in order to exercise privilege of flying in PUBLIC airspace w/ non-compliant equipment.
The NPRM requires no such thing.

- In general, flying non-compliant UAS in public airspace is prohibited after the grace period expires. Such aircraft will be restricted to FRIAs.
- A FRIA operated by a private entity (such as an AMA chartered club) is analogous to a PRIVATE airport. Only the owner, and others invited by the owner, have the right to operate there. This is true NOW (without Remote ID) and will be the SAME with Remote ID. "The public" cannot reasonably claim to have lost privileges it never had in the first place.

If "the public" would like to continue to fly outside FRIAs without Remote ID, it would be better to lobby for higher weight thresholds for registration for fixed-wing UAS flown within VLOS for "limited recreational" purposes. That's a change I could support - and included in my comments.

Old 02-29-2020, 03:55 PM
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at some point, ya just gotta accept the truth of the following...

"God, grant me the serenity to accept the things I cannot change,
Courage to change the things I can,
And wisdom to know the difference."

makes life much easier to live.
Old 02-29-2020, 04:18 PM
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Originally Posted by grognard View Post
The NPRM requires no such thing.

- In general, flying non-compliant UAS in public airspace is prohibited after the grace period expires. Such aircraft will be restricted to FRIAs.
- A FRIA operated by a private entity (such as an AMA chartered club) is analogous to a PRIVATE airport. Only the owner, and others invited by the owner, have the right to operate there. This is true NOW (without Remote ID) and will be the SAME with Remote ID. "The public" cannot reasonably claim to have lost privileges it never had in the first place.

If "the public" would like to continue to fly outside FRIAs without Remote ID, it would be better to lobby for higher weight thresholds for registration for fixed-wing UAS flown within VLOS for "limited recreational" purposes. That's a change I could support - and included in my comments.
The problem isn't the FRIA being operated by a private entity, it's the AMA chartered club part. The AMA is thinking that new flyers will be required to join their ranks if they want to stay in the activity and the regulations that are being proposed will force it by law.
Old 02-29-2020, 04:31 PM
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Except that you won't be forced to join anything. Those of us that already are members of a club will simply continue to do what we are now, only change is the site will be called a FRIA. Those who fly out of schoolyards and such will need to become remote ID compliant. Nobody is forcing membership. Just as you are right now, you have the choice to join or not.
Old 02-29-2020, 05:12 PM
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Originally Posted by mongo View Post
God, grant me the serenity to accept the things I cannot change...
That's March 3rd...

Originally Posted by mongo View Post
Courage to change the things I can...
That's March 2nd...

Originally Posted by mongo View Post
And wisdom to know the difference.
That's a little under 52 hours from now.


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