FAA open comment on registration

[david beazley]

Here is a link to the open comments on the FAA registration issue.

http://www.regulations.gov/#!documentDetail;D=FAA-2015-4378-0022

From Hip Pocket forum

"The FAA has opened an entry for public comments on the proposal to require registration of all "aircraft" operated in the US. For those unfamiliar, the FAA has shown no vision for what the registration requirements will be, who will pay for them, or how they will be enforced. The only thing they have expressed with any clarity is the desire to impose registration requirements on “any contrivance invented, used, or designed to navigate, or fly in, the air” which is a truly disturbing position."

Just because CL was labeled as "tethered flight" in the past, I wouldn't  bank on that staying the same.  We are talking about bureaucrats here folks, inside the beltway types who know what is best for the American people...

[RC Storick]

My comment to the FAA

One more money grab that it totally UN enforceable. There are already rules and laws in place and no one to police those. The toy drones that are flown by kids do place a danger to the public if flown in a unlawful manner. However the AMA already has flight rules and registration in place and those toy buyers do not comply with those. My fear is the drone issue will be lumped all together with the model aircraft community.

If you are going to regulate drones please be sure not to include line of sight flight by the model aircraft community.

[Dick Pacini]

Would I have to register my Frisbee and my boomerang?

[Tim Wescott]

Would I have to register my Frisbee and my boomerang?

I gather from the FAA's comments on that link that if you drive too fast over a bump and become airborne you need to register your car with them.

[david beazley]

maybe we should all write our comments, take them in person to the FAA, fold them up as a paper airplane have a mass launch!

[Mike Griffin]

I have some friends who are big time RC flyers and they are nervous about this.  They are taking it seriously.

Mike

[Brett Buck]

All of which demonstrates the foolish position the AMA is taking, linking drones and ARFs along with regular modelers, and encouraging irresponsible behavior.

     Brett

[Bill Johnson]

First, everyone should understand that it is clearly stated in the proposal that Congress has mandated the change.
Second, the definition of an aircraft, that has been around for decades, "Aircraft” is defined as “any contrivance invented, used, or designed to navigate, or fly in, the air", was also confirmed by Congress.
Third, a "model aircraft", by definition, must be within visual range, which FPV UAVs are flown well beyond that.
Fourth, as UAV violations of NAS continue to double every year, how long will it be before one of them brings down an aircraft with real people on board?
 
Given my fourth point, how long will it before this community wakes up and understands that FAA regulations may be written by lawyers, but it is in blood of dead men?

[Fredvon4]

I have commented many times on these things, mostly Amateur radio related with the FCC

Always astounds me how many have and opinion but fail to read the proposal, the agencies intent, or the current law, and try to answer the specific questions they seek information or opinions for

Clear to me the Congress told the FAA to start enforcing that which is already law, well defined, and tested:

REF tested: Administrator v. Pirker, NTSB Order No. EA-5730, at 12 (Nov. 17, 2014) (affirming that the statutory definition of aircraft is clear and unambiguous and “includes any air aircraft, manned or unmanned, large or small.”). Because UAS, including model aircraft, are aircraft, they are subject to FAA regulation, including the statutory requirements regarding registration set forth in 49 U.S.C. 44101(a), and further prescribed in regulation at 14 CFR part 47.

I encourage every one to comment before Nov 6th.

I do for a fact know they have teams reviewing and sorting the comments. A few years back, twice I had to retrieve quite a bit of data from them for a report I did as an Army Test and Evaluation Command (ATEC) Test Officer.

Read their specific questions and try to answer or opine relating to the question

You may opine that they should do nothing but it is worthless writing

I have read a cross section (55) of the 325+ comments...most are worthless

It would help a lot if most aero modelers would focus on the massive effort it would take to register every modeler much less each and every aircraft. Many of us have over 20 model airplanes.
How would they ever know how many scratch built aircraft there exists?
How much is this going to cost me/us?
Is there a negative impact to the business and suppliers of kit, ARFs, parts, and associated hobby supplies?
How many adult citizens will not be aware due to a significant part of the population (IIRC it is 18%) does not use the internet?
What are the impacts if I decide to NOT comply and register my models?
Question #2 begs the question how are we to transfer ownership from swap meet or e-bay etc. used aircraft?
Question #4 is a big area we can educate the members on by describing a class of model, it's use, quantity constructed in a year or lifetime and how many destroyed during trimming , testing or flying

I think the best we can do is inform the members just how massive, expensive, and unworkable registration of ALL unmanned aircraft is

In 2012, Congress confirmed that UAS, including those used for recreation or hobby purposes, are aircraft consistent with the statutory definition set forth in 49 U.S.C. 40102(a)(6). See Public Law 112-95, sec. 331(, 336 (defining an unmanned aircraft as “an aircraft that is that is operated without the possibility of direct human intervention from within or on the aircraft,” and model aircraft as “an unmanned aircraft that is capable of sustained flight in the atmosphere, flown within visual line of sight of the person operating the aircraft, and flown for hobby or recreational purposes”

These members need to know there are millions of citizens with millions of unmanned aircraft.

Our focus; control line flight is just a meager proportion of the universe of all unmanned aircraft. But we must insist (in numbers) that tethered flight air craft should be exempt

Hell dime store $1.89 hand launched gliders would require registration unless we respond well to question #4

[CircuitFlyer]

Sorry Fred, too late.  There are numerous tethered UAV's already on the market.  CL won't get an exemption that easily.

The poop is starting to hit the fan.  It's everywhere, even in Canada we are going to get hit with new rules next year.  They are proposing regulating all UAV's including model aircraft for recreational purposes.  The only good news is in the current proposal all MAAC members would be exempt.  I sure hope they don't screw it up for international competitors/competitions.

Paul

[Larry Borden]

I hear all of you talking, but how many of you have responded to all this?
Just asking?
The more we shower the do nothing Congress and their minions, then maybe we can make a difference. To me it's nothing but a grandstanding effort by the elected idiots, for the sheeple to make it look like they're actually doing something. Much ado about nothing. IMHO I think there are a Hell of a lot more important issues that are ACTUALLY threatening this country. ISIS, budgets, closing the borders, growing threats from Russia and China. But then that's just me.

[Dick Pacini]

Today I received an email from AMA advising of the campaign to respond to DOT and FAA about the proposed UAS registration.  The message provided sample responses that AMA suggests we copy and paste in the response form.

I browsed the sample responses and read in the second paragraph of the first response where "line of site" instead of line of sight was used twice.  It is appalling that a grammatical error such as this could slip by in a document intended to be taken seriously and read by serious people.

There is no excuse for such an error.  This isn't a facebook posting or a text message between friends.

[Pat Chewning]

I think I will respond like this:

Model aircraft (definition needed) can be self-registered by including the owner's  identifying information on the aircraft in a legible form.

e.g.  Owners name 
     OR
e.g.  Owner's SSN
     OR
e.g.  Owner's AMA number
     OR
e.g.  Owner's drivers's license number

[Fredvon4]

Several comments pointed out this from a Congressional conference report and asked how they intended to ignore this mandate from congress

I do not know what wording got into the final bill or if it was actually passed as law

112TH CONGRESS
2d Session
REPORT
112–381
FAA MODERNIZATION AND REFORM ACT OF
2012
CONFERENCE REPORT
TO ACCOMPANY
H.R. 658


SEC. 336. SPECIAL RULE FOR MODEL AIRCRAFT.
(a) IN GENERAL.—Notwithstanding any other provision of law
relating to the incorporation of unmanned aircraft systems into Federal
Aviation Administration plans and policies, including this subtitle,
the Administrator of 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—
(1) the aircraft is flown strictly for hobby or recreational
use;
(2) the aircraft is operated in accordance with a community-
based set of safety guidelines and within the programming
of a nationwide community-based organization;
(3) the aircraft is limited to not more than 55 pounds unless
otherwise certified through a design, construction, inspection,
flight test, and operational safety program administered
by a community-based organization;
(4) the aircraft is operated in a manner that does not interfere
with and gives way to any manned aircraft; and
(5) when flown within 5 miles of an airport, the operator
of the aircraft provides the airport operator and the airport air
traffic control tower (when an air traffic facility is located at
the airport) with prior notice of the operation (model aircraft
operators flying from a permanent location within 5 miles of an
airport should establish a mutually-agreed upon operating procedure
with the airport operator and the airport air traffic control
tower (when an air traffic facility is located at the airport)).
(b) STATUTORY CONSTRUCTION.—Nothing in this section shall
be construed to limit the authority of the Administrator to pursue
enforcement action against persons operating model aircraft who endanger
the safety of the national airspace system.
(c) MODEL AIRCRAFT DEFINED.—In this section, the term ‘‘model
aircraft’’ means an unmanned aircraft that is—
(1)   capable of sustained flight in the atmosphere   
(2) flown within visual line of sight of the person operating
the aircraft; and
(3) flown for hobby or recreational purposes

[Brett Buck]

Several comments pointed out this from a Congressional conference report and asked how they intended to ignore this mandate from congress

I do not know what wording got into the final bill or if it was actually passed as law

   It is my understanding that it was passed.

    Brett

[Fredvon4]

Dead line is tomorow

[Russell Shaffer]

It is really pretty easy to comment on the FAA site.  If you have the Tower email just click on their button and away you go.  5 minutes to do it.

[Target]

As I stated in the Tower Hobbies thread, My thoughts are to register the FPV gear and GPS/Autopilot gear DURING sale.
Traditional LOS (Line of SIGHT) modeling hasn't, and doesn't need to be registered, as it is not the problem.
FPV and other non-LOS modeling is.

Regards all.