AMA's Response to the FAA's sUAS NPRM On February 23, 2015, the FAA published its proposed regulations for small unmanned aircraft systems (sUAS) as a notice of proposed rulemaking (NPRM). This began a 60-day period during which the public can comment on the proposed regulations. When finalized, the proposed rules would become the safety regulations for operating small, non-recreational, unmanned aircraft. In accordance with the Special Rule for Model Aircraft (the AMA amendment) established by Congress in the FAA Modernization and Reform Act of 2012 (P.L. 112-95), the new regulations would not apply to model aircraft operated within the safety programming of a nationwide community-based organization. This is good news for AMA members; however, the FAA has said that to be exempt from regulations, model aircraft operators must operate within the parameters of the Special Rule set out by Congress in 2012. The NPRM references FAA's June 2014 interpretation of the Special Rule. As indicated in detail in updates to our members last summer , the AMA has taken exception to several aspects of FAA's interpretation. The main areas of concern are that the FAA's interpretation: • Asserts model aircraft to be "aircraft" and effectively makes model airplanes subject to all regulations applicable to full-scale aircraft. • Makes model aircraft subject to airspace requirements that have never been applicable in the past and with which it is impossible or impractical to comply. • Effectively changes the criteria for operating within 5 miles of an airport from the requirement of providing prior "notification" to a requirement of obtaining prior permission. • Narrowly defines "hobby and recreation" and puts in question the activities of the supporting aeromodeling industry and AMA's educational programs. • Rigidly defines the requirement to operate within visual line of sight and targets the use of a specific aeromodeling technology/equipment, namely first-person view (FPV) goggles. Overall, the AMA views the proposed sUAS regulations as a positive step. With one exception that may impact model aircraft manufacturers, it essentially takes the language in the 2012 Special Rule for Model Aircraft (the AMA amendment) and places it in the federal aviation regulations. We encourage members to submit comments commending the FAA for appropriately separating model aviation from the new regulations. However, AMA would also encourage members to include in their comments the need to resolve the discrepancies stemming from the Interpretive Rule before finalizing the sUAS rule. In any case, it's important that our members provide their comments in support of the proposed rule. It's possible that there will be members of the public or aviation industry who will be opposed to a rule that protects the model aviation hobby, and we need to make sure that our voices are heard in support of continued community-based self-governance. Comments on the proposed sUAS rule can be made by clicking here. Read the proposed rule carefully, particularly the sections concerning "model aircraft," and submit comments on areas where you have a concern as well as thoughtful and productive comments in areas where you feel there could be improvement. AMA has created a suggested template for comments, which we strongly encourage you to edit and personalize. Unless extended, the deadline for submitting comments is 11:59 p.m., Friday, April 24, 2015.

AMA's Response to the FAA's sUAS NPRM On February 23, 2015, the FAA published its proposed regulations for small unmanned aircraft systems (sUAS) as a notice of proposed rulemaking (NPRM). This began a 60-day period during which the public can comment on the proposed regulations. When finalized, the proposed rules would become the safety regulations for operating small, non-recreational, unmanned aircraft. In accordance with the Special Rule for Model Aircraft (the AMA amendment) established by Congress in the FAA Modernization and Reform Act of 2012 (P.L. 112-95), the new regulations would not apply to model aircraft operated within the safety programming of a nationwide community-based organization. This is good news for AMA members; however, the FAA has said that to be exempt from regulations, model aircraft operators must operate within the parameters of the Special Rule set out by Congress in 2012. The NPRM references FAA's June 2014 interpretation of the Special Rule. As indicated in detail in updates to our members last summer , the AMA has taken exception to several aspects of FAA's interpretation. The main areas of concern are that the FAA's interpretation: • Asserts model aircraft to be "aircraft" and effectively makes model airplanes subject to all regulations applicable to full-scale aircraft. • Makes model aircraft subject to airspace requirements that have never been applicable in the past and with which it is impossible or impractical to comply. • Effectively changes the criteria for operating within 5 miles of an airport from the requirement of providing prior "notification" to a requirement of obtaining prior permission. • Narrowly defines "hobby and recreation" and puts in question the activities of the supporting aeromodeling industry and AMA's educational programs. • Rigidly defines the requirement to operate within visual line of sight and targets the use of a specific aeromodeling technology/equipment, namely first-person view (FPV) goggles. Overall, the AMA views the proposed sUAS regulations as a positive step. With one exception that may impact model aircraft manufacturers, it essentially takes the language in the 2012 Special Rule for Model Aircraft (the AMA amendment) and places it in the federal aviation regulations. We encourage members to submit comments commending the FAA for appropriately separating model aviation from the new regulations. However, AMA would also encourage members to include in their comments the need to resolve the discrepancies stemming from the Interpretive Rule before finalizing the sUAS rule. In any case, it's important that our members provide their comments in support of the proposed rule. It's possible that there will be members of the public or aviation industry who will be opposed to a rule that protects the model aviation hobby, and we need to make sure that our voices are heard in support of continued community-based self-governance. Comments on the proposed sUAS rule can be made by clicking here. Read the proposed rule carefully, particularly the sections concerning "model aircraft," and submit comments on areas where you have a concern as well as thoughtful and productive comments in areas where you feel there could be improvement. AMA has created a suggested template for comments, which we strongly encourage you to edit and personalize. Unless extended, the deadline for submitting comments is 11:59 p.m., Friday, April 24, 2015.