Remote ID Final Ruling

[Steve Fitton]

Does the new FAA ruling have any effect on us?

[Brett Buck]

Does the new FAA ruling have any effect on us?

  It shouldn't, but I am not particularly hopeful. This is what I sent back to the AMA:



  We believe that this does not apply to our operations, as we do not operate any UAS systems at our site. Only control-line aircraft are permitted. These are not UAS because they do not employ a “ground control station”.

  Please confirm and please confirm what steps have been taken in regard to:

     Ensuring that all guidance from the FAA to law enforcement officials includes the distinction between RC models/drones which ARE UAS systems, and CL and FF models that are not UAS systems
     Ensuring that any AMA interactions on behalf of our club and flying site LOA (letters of agreement) include a notice or clearly denote that there are no UAS systems permitted at the site

   This is a critical matter as it is patently impossible to comply with remote ID in our situation.

   Brett Buck
   President, Bay Area CLPA Association  Chartered Club #4357

[Teodorico Terry]

I do not believe that it affects C/L but it will be good to get confirmation.  Regarding R/C, based on what I read, there is a chance that R/C clubs might fall under the 3rd category (fields recognized by the FAA) which would make us exempt from the requirement.  We will see how this turns out.   If they get really serious about the 400ft requirement it will severely affect R/C operations.  I fly pattern as well and the nominal box height (60 degree elevation, 150 meters out) puts the top of the box at over 900 ft.  Those flying the FAI sequences need every foot of it.  Gliding and other activities will also be affected.  Having the transmitter on the model would make it really easy to tell if the 400ft ceiling has been broken.  Based on what I have seen it appears that the US is unique in its response to drones.  This is in part of why I became interested in C/L once again.

[Brett Buck]

I do not believe that it affects C/L but it will be good to get confirmation.  Regarding R/C, based on what I read, there is a chance that R/C clubs might fall under the 3rd category (fields recognized by the FAA) which would make us exempt from the requirement.  We will see how this turns out.   If they get really serious about the 400ft requirement it will severely affect R/C operations.  I fly pattern as well and the nominal box height (60 degree elevation, 150 meters out) puts the top of the box at over 900 ft.  Those flying the FAI sequences need every foot of it.  Gliding and other activities will also be affected.  Having the transmitter on the model would make it really easy to tell if the 400ft ceiling has been broken.  Based on what I have seen it appears that the US is unique in its response to drones.  This is in part of why I became interested in C/L once again.

      Quick answer is that RC is not going to escape this. The only hope they ever had was "the Special Rule for Model Aircraft" and that is long gone. As soon as they defined a UAS as they did, RC was going to be included, because drone regulation along these lines was always inevitable. Also inevitable was the fact that the large drone delivery interests were going to run over the AMA without even noticing them.

     The AMA is liable to screw CL, if indeed they haven't done so already, over the LOA situation, where they set themselves up as the intermediaries, and *they* negotiated with them and cut us out of the loop. They didn't even ask about the type of models flown.

     Brett

[Perry Rose]

The blame for the impending mess is squarely on the AMA. They had no idea on how to deal with the FAA and still don't but it's too late now. The AMA should have prepared a paper on how they would comply with the FAA's plan and submitted that to the FAA for approval. The FAA would check to make sure the plan would work probably suggest changes a back and forth a couple times and final approval. Could have been done in a few days.

[Teodorico Terry]

The impression I have, based on what I have read is that in some respect the FAA did not do what it said it was going to do and the AMA was caught by surprise.  Either way, the notion of delivery drones, in my view, is a rather dumb use of the technology.  When you consider weather conditions, limited payload and places where they could actually make a delivery it provides rather limited coverage.  There is also the risk of having or causing accident as well.  The biggest issue facing that industry is getting the item from the truck to the door step and there are other solutions for that.  Autonomous vehicles are almost here and there are robots being tested which could carry the package from the truck to the door.  I guess that I am old school but there are very few things that I would consider so essential that I have to have them within a couple of hours.  If that is the case, I get off my duff and take care of it myself.

[Brett Buck]

    I think both of you guys are probably not right - the AMA wasn't/isn't in any position to do much with the FAA. They tout their great influence with the government, but in reality, they are not players because they have no money to speak of, and in this case, they just got steamrolled by commercial drone interests.

    I think if finally dawned on them about a year and a half ago, when they, I kid you not, went from "drones are our future" to frantic phone calls to various leader members and club presidents about how "write your congressman today because drones are going to kill us" in the space of a day or so. *Many* people had told them exactly how it was going to work as early as 2015, they claimed they knew better and took a strategy that *they* would become the one-stop shop for the commercial drone people, the gatekeepers.

     That is so incredibly naive and eluded it is hard to find words for it. These people have bought entire regions of the country and run them as they see fit - Silicon Valley, for example - and are major players in presidential elections. The AMA, optimistically, is like a small-town Chamber of Commerce, the "Hooterville Benevolent Association",  sending their two top officers on a once-in-a-lifetime trip to Washington, and maybe getting in to see their representative's receptionist.

   The only hope they ever had was to defend the Special Rule for model aircraft, by dissociating and distinguishing model airplanes and drones as two fundamentally different things, one of which was a large commercial operation that everyone hates, are operated irresponsible in nearly all cases, and the other a bunch of aging duffers harmlessly recreating their youth that have never caused much of a problem for anyone.

    They instead took the strategy, believing their own bullsh*t, that they were the major players and could steer the results to their liking, and in the process, enlist the amateur drone toy purchasers to swell the numbers, and maybe make the commercial drone operators come to *them* to get permission to operate. When it came time to defend the Special Rule for Model Aircraft, they refused to. It fell to an *individual* to challenge it, which he did, successfully, in a single hearing. The AMA came close to taking credit for it, but in fact, they had nothing to do with it.

    Unfortunately, having failed to make the important distinction between model aircraft and drones, all that did was make the Special Rule an impediment to drone registration and licensing, which means the Special Rule went away without any argument. The rest was obvious.

   An additional and ongoing issue is that the AMA has repeatedly and steadfastly refused to make any distinctions between which model aircraft are UAS and not UAS. They are in it solely an entirely to deal with RC, the vast majority of their membership and are uninterested in the distinctions. That is an extension of the same sort of deluded reasoning above, they still think that they are going the mat for their vaunted "influence" and their commercial base - which is certainly not CL and FF.

     That alone tells you that they are not an "academy", but another commercial interest trying to maintain their market - a tiny market that Amazon could buy in its entirety for the money in the Amazon.com HQ coffee fund. The AMA fails to grasp the scale of what they are up against, even now.


   The actual law appears to exempt us because we are not an "unmanned aerial system" as defined. Whether that will help or not is very unclear, because even the AMA is anxious to not make that distinction.

    So, I think their is a very good chance that we will get buried or unduly burdended with completely inapplicable requirements that add nothing to aviation safety but require absurd workarounds that will be hard to comply with - or more likely, will just be ignored. Leavong us subject to thewhims of any random person who decides to complain.
   
    Brett

[Steve Helmick]

"The AMA, optimistically, is like a small-town Chamber of Commerce, the "Hooterville Benevolent Association",  sending their two top officers on a once-in-a-lifetime trip to Washington, and maybe getting in to see their representative's receptionist."

I'm pondering this, and wondering if the two top officers sent to DC were Andy and Barney, or if Barney was left in charge, and Andy took Opie.

CL doesn't seem to have a problem, but I am concerned about the fairly recent technology in FF, R/C DT. It looks like the Bee's Knees to me, and the transmitter is more akin to a new garage door opener transmitter or key fob than the typical R/C transmitter you're probably thinking of. It looks like there is no reason to bother the FAA with details on our technological advances. The Fox .15 Hurl is of zero concern, and they don't need to know about that.     

[Teodorico Terry]

Brett,

Thank you for the history lesson, you reminded me of a few things which I had forgotten.  I agree with you that at the time the idea of the AMA embracing drones seemed a little odd based on what we were seeing at our R/C field.  People would stop by to ask about them and if anyone flew them, if they could fly at the field, etc.  The minute the need to join the AMA and the club to be able to use the field the discussion was over.  They were never going to join either one so the AMA never got the boost in membership they thought they would.  The other one as you mentioned was lumping all R/C aircraft into the drone category.

Teo

[Teodorico Terry]

A friend of mine who was part of a "leaders roundtable" at the AMA just posted this to his R/C club.  Maybe there is some hope.

[Brett Buck]

A friend of mine who was part of a "leaders roundtable" at the AMA just posted this to his R/C club.  Maybe there is some hope.

    I was on that, too. Predictably it was conducted as if RC was the entire business. It wasn't particularly illuminating, but I didn't expect it to be, they didn't know and didn't have time to study it, either.

The requirement about internet connectivity was an issue, however, as before, what the AMA wanted was irrelevant, that was resolved when it became obvious that this would limit commercial drone flight in areas without internet connectivity, which would eliminate some flights and cause others to be routed circuitously.

  BTW, there is another rule that everyone seems to be ignoring and might prove to be very daunting, if universally applied - no exposed propellors!  Like, you need a guard over it to keep people from getting cut. I couldn't immediately see what the "out" for that might be for RC.

     I am every more convinced that everyone needs to memorize the phrase "not a UAS".

     Brett

[Dave_Trible]

AMA is holding a web conference in a few minutes.  I’ll try to watch.  During the last webinar they believed that CL and FF would slip under the wire unscathed IF they didn’t specifically bring it to the attention of the opposing side’s lawyers for arguments.  Guess I can understand the reasoning but let’s see what happens.

Dave

[Brett Buck]

AMA is holding a web conference in a few minutes.  I’ll try to watch.  During the last webinar they believed that CL and FF would slip under the wire unscathed IF they didn’t specifically bring it to the attention of the opposing side’s lawyers for arguments.  Guess I can understand the reasoning but let’s see what happens.

  So, if you don't explicitly call it out, we might win a court case. But that won't help you when Festus shows up with a noise complaint.

    Brett

[Steve Helmick]

Wondering if AMA's lawyers would come to our rescue if one of us was arrested by a LEO (Law Enforcement Officer) for flying CL? The LEO might think the FAA would appreciate their efforts in some way? Here in Renton, I'm not too concerned, because our PD has said on the phone that they only respond to felony offenses. But maybe CL flying is a felony? I'm just not sure where our offensive behavior fits in the legal system. Worse than BLM/ANTIFA rioting? Probably....    Steve

[Dave_Trible]

My quick take was everything in the air is considered a UAS- except CL- and only UAS will need to comply.  FF under 1/2 pound are also exempt.  Otherwise you’d buy a $20-50 widget to install in whichever airplane you are flying in FF and RC and trade it between airplanes.  My stunters-exempt, my old time free flights get a widget.

Dave

[Brett Buck]

My quick take was everything in the air is considered a UAS- except CL- and only UAS will need to comply.

   FF (absent RC DT) is definitely not a UAS by definition, there is no "ground control station", which is the same dodge that exists for CL. Whether anyone will actually know that, short of a precedent-setting court case, it very dubious to me.

    Brett

[Dave_Trible]

   FF (absent RC DT) is definitely not a UAS by definition, there is no "ground control station", which is the same dodge that exists for CL. Whether anyone will actually know that, short of a precedent-setting court case, it very dubious to me.

    Brett

Yep.  Play nice with Festas.

Dave

[L0U CRANE]

It may sound bonehead dumb, but try this: CL does not use Federal Airspace as it is understood: free flying... Lefts and rights... no  physical limit on location, range or altitude. Our paths are mechanically limited by our control lines, which we hold fast during flight...

We fly tethered model aircraft!  There's  NO remote - i.e., without physical connection - base of control. Our essential flight controls are operated by mechanical forces through the physical lines. (Granted, some non-flight functions could employ  2.4GHz devices... throttle, landing flaps, retractable landing gear, etc... But those do NOT control flight. )

The flier is the only ground-based control element. Taken to a (frivolous?) extreme, if the Federal rules are proper for CL flying, shouldn't the same rules apply to all department store toy 'tailless,'  box- or delta kites?

...and for all toy "drones" sold for young children? (The stores are informing all those parents and relatives to register with the Feds, aren't they?)  (HAH!!) 

[Dave Hull]

Still waiting to get my hands on the actual regs.

Until then, I doubt much has changed relative to control line. Same issues. Same arguments. Same non-decisions and non-statements by both the AMA and the FAA. Because they both want it that way.

We have one more critical card to play within the existing FAA process should we chose to do so. It will have to be done without AMA support since they are following a different agenda and have been under Hanson's direction since 2011. Personally, it won't be worth it unless some control-liner somewhere is made an example of somewhere, or the FAA puts out an Advisory Circular stating something to the effect that all model airplanes are sUAS's. Then we'll see.

Dave
President, Valley Circle Burners, AMA Club #4406

PS--Be careful attempting to compare control line (tethered flying) with kites. The FAA already has rules on the books covering kites, and it would ruin both fields my club currently uses. A review of prior posts on this should unearth details I provided previously.

[Brett Buck]

PS--Be careful attempting to compare control line (tethered flying) with kites. The FAA already has rules on the books covering kites, and it would ruin both fields my club currently uses. A review of prior posts on this should unearth details I provided previously.

   By the same token, *do not* use the word "tethered", because there are drones that operate exactly like normal quadcopters in all respects, but use a wired connection instead of radio - "tethered" drones. Those are, for sure, subject to regulation.

    Brett

[david beazley]

I was on the Leader Member call at 1130 am ET yesterday and asked the specific question about CL & FF. Here’s the link and the question is around 39:25.

[Scott Richlen]

I think that a major point being missed is that this whole thing is an incredible over-reach by the FAA.  It is full-blown totalitarianism.

What the FAA is saying is that WHEN YOU WALK OUT OF YOUR FRONT DOOR INTO YOUR OWN FRONT YARD YOU ARE NOW IN FEDERALLY REGULATED AIRSPACE.

[Dave_Trible]

I think that a major point being missed is that this whole thing is an incredible over-reach by the FAA.  It is full-blown totalitarianism.

What the FAA is saying is that WHEN YOU WALK OUT OF YOUR FRONT DOOR INTO YOUR OWN FRONT YARD YOU ARE NOW IN FEDERALLY REGULATED AIRSPACE.

They’ve pretty much considered everything above the grass FRA.  But in this case they were under pressure from commercial interests and Dept. of Home Security.  My impression was mostly the commercial drone lobby.  There are FAA folks who understand our position and didn’t really wish to mess us up.  Those are the ones who are winking at AMA about CL,  saying CL isn’t classed as UAS.

Dave

[CircuitFlyer]

The only consequence to control line from what I picked up is under the design and production requirements.  Once this is all in effect you will not be able to pay someone to build a complete, ready to fly, control line model for you.  That person would be considered a manufacturer and would be required to fulfil all of the requirements of subpart F for remote ID.  It would have to be a standard remote identification unmanned aircraft.  The design and production section of the new regs apply to all unmanned aircraft regardless of intended use or registration requirements.  Easy enough to get around the regs, buy it as an airframe without the motor.  Now it's a incomplete kit that you can finish yourself as a "home-built unmanned aircraft".

[Brett Buck]

They’ve pretty much considered everything above the grass FRA.  But in this case they were under pressure from commercial interests and Dept. of Home Security.  My impression was mostly the commercial drone lobby.  There are FAA folks who understand our position and didn’t really wish to mess us up.  Those are the ones who are winking at AMA about CL,  saying CL isn’t classed as UAS.

Dave

   Its a lot more than a wink and a nod, the way the law is written is pretty unambiguous on both FF and CL - no "ground control station" =  "not a UAS". Almost all model rockets, FF and CL are not UAS, by written law. They really were trying to define "drone", unfortunately for RC, there was no way to distinguish one from the other and the AMA made absolutely no attempt to, either.

     Brett

[L0U CRANE]

Brett, re: your reply #19... Thanks for the info!

Sure, there are TOW missiles and "tethered" drones, but we remain distinct in that our "tethers" mechanically  limit 'range' and apply physical forces through mechanical linkages to control surfaces. Their mechanical operation varies the "aircraft's" path and position on the hemispheric surface; they provide the essential flight controls.

We also have immediate and continuous mechanical feedback, without encroaching on the electromagnetic spectrum.

These may be trivial factors to actors with specific agendas, but I'd be (even further) disappointed to see our chosen pastime regulated out of existence.

...and, Oh, yeah...  Happy New Year to you and all!

[Brett Buck]

Brett, re: your reply #19... Thanks for the info!

Sure, there are TOW missiles and "tethered" drones, but we remain distinct in that our "tethers" mechanically  limit 'range' and apply physical forces through mechanical linkages to control surfaces. Their mechanical operation varies the "aircraft's" path and position on the hemispheric surface; they provide the essential flight controls.

   I would very strongly urge everyone to purge the word "tether" or "tethered" from your lexicon completely, when talking about this. That's because that is going to be specifically called out with regard to "tethered drones" which are certainly subject to regulation.

    If you talk to someone about control-line, they won't get it, but if you word "tethered", they will say, "OH, now I know what you mean, it says right here that they are regulated". End of hobby.

    Brett

[Dave_Trible]

Actually there are three 'categories' or approved methods for models that DO require monitoring:

1.  Manufactured drones or ready to fly airplanes: Manufacturers must put widgets in each device they build.  The buyer then sends the serial number of that widget to 'Drone Zone' .
2.  As previously described,  builders would have one or more registered widgets to install and/or trade between airplanes .
3.  You can fly at a REGISTERED and approved flying site without a widget if you keep it within a pre-described box or area.  Not sure about those dimensions.......
I would guess your club president is assuming your site will be one of these and this would mostly allow normal operations at that site.  OR he isn't aware of what's going on here.
There is also a clause for one-time Letters of Agreement to hold an event at a given site not otherwise approved-ie, maybe holding a contest at a local airport, military base, private field etc.  These rules begin in 58 days, but manufacturers are given 18 months to comply and individual model builders another year beyond that to comply.  The technology still needs development and they acknowledge that.

Dave

[Keith Miller]

The new rule clearly states that CL and FF models are NOT covered in the ruling.

[Dave Hull]

Keith,

For those of us who are still unable to download the rule, can you quote that section for us?

Dave

[david beazley]

here's the latest from AMA recappping the round table discussion and synopsis of the ruling with a PowerPoint of the highlights that effect AMA models and FAQ's

https://contentsharing.net/actions/email_web_version.cfm?ep=jSWAXeyO4YPrea0EUXywJG562u17QG-p13lNDZTm67A5775Vy_vmkhqOYJw2IyZ6wJKqpf7v06y3H4Z-Z3E60pCitbvaREOHmf89JvJD3IHuBPCy7o9F_L_jr_EOCXph

[Fred Underwood]

The new rule clearly states that CL and FF models are NOT covered in the ruling.

I just read this in FAQ from the link provided
" AMA maintains that Control Line and Free Flight do not meet the definition of unmanned aircraft systems."

Does AMA maintaining that make it FAA rule or AMA wish?

[Brett Buck]

I just read this in FAQ from the link provided
" AMA maintains that Control Line and Free Flight do not meet the definition of unmanned aircraft systems."

Does AMA maintaining that make it FAA rule or AMA wish?

    It is consistent with the wording of the actual FAA rule, which I have read, and I think has been posted here several times. I don't think the actual rule is at issue here, the problem is what direction the FAA gives down the line. Meaning you might win a court case, but have to go to court, if it becomes a point of interest.

   I would also note that almost everyone at the FAA that I have talked to , and that David has talked to (both in support of our "club"), have understood exactly what we were doing and that it was not a UAS. The AMA letter-of-agreement (LOA) dealings, however, appear to have no variation for the different types of models. We have never gotten a straight answer on that, nor have we gotten anything from either the AMA or the FAA regarding the new LOA that they negotiated ,other than our current LOA was going to be cancelled - whether we liked it or not.

    Brett

[Brett Buck]

 
NOTE:  They say Control Line is exempted, but have not decided on Free Flight.

   That's interesting and probably could be challenged because FF is certainly NOT a UAS as defined.

    Brett

[dave siegler]

NOTE:  They say Control Line is exempted, but have not decided on Free Flight.

Exempt is not the word I heard.  What I heard was the FAA was aware of Control line due to some vocal clubs advocating ( hey isn't that the AMA's job?  )  , did believe control line did not meet the definition of a , and did not want to include it in the meeting.  The Free Flight community did not speak up. 

Everyone is missing this, but I am not worried  The FAA.  I am worried about over zealous local law agencies in charge of investigation and enforcement.   

Being "ramp checked" by the local agency, having my plates run and drivers license checked does not sit well with me. 

[Brett Buck]

Everyone is missing this, but I am not worried  The FAA.  I am worried about over zealous local law agencies in charge of investigation and enforcement.   

   Bingo.

    Brett

[Chuck_Smith]

I don't think it's aimed at controline and as I've posted before all my dealings with the FAA have been pretty nice.

What discussed above though is the thing to worry about. There's almost universally one person who lives nearby to a flying site who's going to complain about the noise. Now they can add this to the harassment.


The AMA missed the boat. They should have simply asked for an exclusion for any model aircraft not equipped with onboard stabilization and/or navigation capabilities. That would have solved the problem.

Chuck

[Brett Buck]

I don't think it's aimed at controline and as I've posted before all my dealings with the FAA have been pretty nice.

What discussed above though is the thing to worry about. There's almost universally one person who lives nearby to a flying site who's going to complain about the noise. Now they can add this to the harassment.


The AMA missed the boat. They should have simply asked for an exclusion for any model aircraft not equipped with onboard stabilization and/or navigation capabilities. That would have solved the problem. \

    Maybe, but they already had the Special Rule for Model Aircraft which was a carefully-crafted carveout and that went away like "poof" as soon as it stood in the way of drone regulation - which was always inevitable. The AMA screwed the pooch when they tried to use the Special Rule to try to stop drone regulation, which was utterly inconceivable. Once that went away, the rest was entirely predictable (since I and many other people predicted it).

   The AMA failed to recognize the fact that drones and drone users were mortal threats to RC, and continued to discount it long after it was obvious to everyone else.  We are all now paying the price for that.

      Brett

[Dan McEntee]

The AMA missed the boat. They should have simply asked for an exclusion for any model aircraft not equipped with onboard stabilization and/or navigation capabilities. That would have solved the problem.

Chuck

     I'm in agreement with Chuck here, and it has been my position all along, that they should be licensing and regulating the technology, the on board guidance, stabilization, and any type of camera capability. That covers any kind of aircraft that uses these elements, and that is the core of the problem, not the type of aircraft t that it is. If it doesn't have any of this type of equipment, then if falls back under the typical recreational hobby type and the old special rule for model aircraft. All in all, I think the big wave has past on the drone thing. With Trumps impeachment proceedings and then the Covid crisis, drones have hardly even been in the news. I have seen more about the alleged "Jet Pack Guy" flying around LA  in the news lately, and maybe that will be the next big thing!!  While Buder Park was closed earlier in the year due to the pandemic panic, I was flying off a local abandoned shopping mall lot. Far away from any houses, and almost zero through traffic. Every once in a while some one would drive by with their teenager practicing driving (which I think is a whole hell of a lot bigger problem!!!) and some times a local LEO would drive by, wave, and maybe stop. I posed the question to one of them one time. He was sort of familiar with what I was doing and I gave a simple explanation of what the FAA was trying to do and asked him what he thought based on that. He basically said that it would take a lot of time and money to train law enforcement on the small details, and they definitely have more important things to do. If he was driving by, and saw that I was not creating a threat to anyone or to myself, he would not bother me. If he had an actual complaint, he would just encourage me to pack up and go, and then just report that no one was there when he got there. With all that local law enforcement has on their plate and all that they have to comply with, someone playing with a toy airplane would be really small potatoes. Unless of course, that someone was really doing something stupid, and there have been instances of that before, the LEO wouldn't have much choice but to do what he has to do. With the decrease in the participation of all aspects of the hobby (including quad copter operations) you would have to wonder how much of a problem in would be? I do think, though, that this is far from over and activists from the special interest groups for each discipline might have to take the bull by the horns to plead their own cases and see where it goes to from there.  Think about R/C soaring competitions, or even sport flying. There is a new member on the list that flies R/C pattern and he says it's all but impossible to fly the current equipment and maneuver schedule at 400 feet or lower.  What is needed is someone like that guy that pushed something through the courts on his own a year or so back to take the lead from AMA, who's lawyer pool and leadership group is obviously lacking in effectiveness.
   Time to break out the indoor stuff!!
   Type at you later and HAPPY NEW YEAR!!
     Dan McEntee

[Brett Buck]

     I'm in agreement with Chuck here, and it has been my position all along, that they should be licensing and regulating the technology, the on board guidance, stabilization, and any type of camera capability. That covers any kind of aircraft that uses these elements, and that is the core of the problem, not the type of aircraft t that it is. If it doesn't have any of this type of equipment, then if falls back under the typical recreational hobby type and the old special rule for model aircraft.

   Probably right - but that ship sailed 5-6 years ago.

      Brett
 

[Dane Martin]

The AMA missed the boat. They should have simply asked for an exclusion for any model aircraft not equipped with onboard stabilization and/or navigation capabilities. That would have solved the problem.

Chuck

I have to disagree with that. Most new "beginner" radio control planes and even pattern / IMAC planes have 2 or 3 axis gyro systems in them now. Even the super cheap RMRC recruit has a stabilization system. Just a normal, LOS RC airplane that's less than $100. So, that would still put radio control in the line of fire

[Dane Martin]

For example, this receiver has nothing to do with drones, or FPV or long range. It's nothing but a simple stabilization control to add to any RC aircraft.
Just look how many RTF airplanes come with Spektrum AS3X technology.

https://www.horizonhobby.com/product/alpha-6-stability-system/SPMAS1000.html

[Brett Buck]

I have to disagree with that. Most new "beginner" radio control planes and even pattern / IMAC planes have 2 or 3 axis gyro systems in them now. Even the super cheap RMRC recruit has a stabilization system. Just a normal, LOS RC airplane that's less than $100. So, that would still put radio control in the line of fire

    But there is no need to have those in the airplanes, you can certainly build RC planes without those. Eliminate them as "not model aviation" and you are set.

   The way it is written is actually worse that most of us are considering - and maybe makes our point. RTFs are differentially discriminated against, every single RTF (or possibly ARF) seems to require a unique remote ID, and presumably registration of each ID. So, in setting out to try to give the advantage to their core market, the AMA's end result was that they are doubly-screwed, and in significant danger of killing it.

   The next shoe to drop is how "build-it-yourself" is defined for purposes of FAA regulation - and whether or not the "builders" have to somehow type-certify or register as a manufacturer, and what that entails.

    What a clusterf*ck.

     Brett

[Brett Buck]

It doesn't make sense to me.   None of this is going to stop a person who wants to use a model airplane or drone in a bad way.   

Never did the think that flying a model airplane would be a criminal act.  I wish I knew the REAL REASON this is being done.  It isn't for safety.

    Rule 0 of all governmental action - the cardinal rule is to be seen to be "doing something" about a perceived problem. Whether or not that "something" is useful or valuable, or has the desired effect, is entirely beside the point.

   And of course it doesn't stop bad actors, any more than gun registration, licensing, etc. The only people that will comply and thus be burdened by these rules are those that were already acting responsibly, and didn't need the rules in the first place.

     For example, I expect that at the end of this, every RTF and maybe ARF (depending on the definition of ARF they wind up with)  toy will require a unique remote ID and registration with the FAA for it. I also expect that nearly no one in the market for RTF/ARF  toys will pay the slightest attention to that, fly it anyway, and thus be completely free of any difficulty that registration entails.

  My example follows the model of the last time the FAA's predecessor, the CAB (Civil Aviation Board) got involved, and again when the FCC got involved in RC. The first case, *all*, repeat *all*, "gas models" were supposed to be registered with the CAB, and the AMA number started as the CAB registration number. Of course everyone completely ignored that, and eventually - 25-30 years later! - that was quietly dropped.

     Second case was in the era of tube RC, where all operations were restricted to ham operators with some higher license, with hundreds of thousands of "sets" (which really pushes the definition of a set) sold and operated outside any allowed band. Eventually, they got to operate on the radio "garbage band" where there was no licensing, which quickly became unusable, and then shifted to other illegal frequencies. Finally, they got CB frequencies, those required "licensing" that consisted entirely of sending in a form - which was also roundly ignored even though all it cost you was 30 seconds and a stamp. The CB craze killed that, with similar universal lack of compliance, they got the 76 72 MHz band which still exists and still required a license, also universally ignored. I don't even know the law with respect to spread-spectrum, but it wouldn't surprise me if that, too required something that is also universally ignored.

   The point being that all that making up stupid rules does is screw a few people that were not the source of the problem in the first place,  and otherwise just raise the level of contempt for the law, while accomplishing none of the goals except for making it look like some social parasite politician has done something.

    Brett

[Dan McEntee]

   Probably right - but that ship sailed 5-6 years ago.

      Brett

    Yeah, I know. That was the same time that they were trying to bring the quad flyers "into the fold."  Those were the people that never had any intention of joining any organization and within 6 months had already moved on to whatever the next fad that caught their eye. Of all the millions of hobby grade drones that have been sold in the last 5 years, how many are still in operation or stuck at the top of a tree? I think the wave has past and all that is left to deal with is largely legitimate users and a few rogue operators that you get in any business.   This far down the line it really is much ado about nothing, I think, but there is no one in AMA leadership capable of arguing that point.  Now that the field has thinned out and become more defined with the regulations that they do have in place, I would think that it might e easier now to try and make a definitive definition of what we do and what the FAA really needs to be concerned about. I think the down turn in commercial aviation due to the Covid situation can be used to some advantage. Again, there just isn't anyone in charge that can think outside the box and address this thing. It all still sounds to me like something that will be very hard to enforce. I'm old enough to have been in on the last round of FCC licenses that we were required t o have for both CB radio and R/C model operation, voice and non voice it was called. After the CB craze hit and the FCC was inundated with millions of requests for the $25 dollar license for each, they said screw it and did away with the license requirement. We need someone that is a good enough wordsmith and/or lawyer that can work that same magic and put a Jedi mind trick on them. "These people aren't of any worry to you! They are not the droids you are looking for!"
   Type at you later,
    Dan McEntee

[Robert Zambelli]

Good message, Obi-Wan.

Bob Z.

[Pat Chewning]

Yeah, "Universally Ignored" is my plan..... and I fly R/C gliders too.