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Make your comments to the FAA before April 24th
1397 1 2015-4-9
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United States

I recieved this from the AMA and I am passing it on here because it affects DJI pilots also. It explains the good and bad of the FAA rule change proposal and gives you a template (in bold at the bottom ) with some key points so you can make your comments to the FAA. Be sure to customize the stuff in red to fit you.

If youhave not commented on the FAA's sUAS NPRM, the AMA hopes you will take actionduring the next few days to send your comments to the FAA. We have provided youthe key points on AMA's position and an easy to follow comment template withinstructions. Thank you for your comments.
On February23, 2015, the FAA published its proposed regulations for small unmannedaircraft systems (sUAS) as a notice of proposed rulemaking (NPRM). This began a60-day period during which the public can comment on the proposed regulations.When finalized, the proposed rules would become the safety regulations foroperating 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 newregulations would not apply to model aircraft operated within the safetyprogramming of a nationwide community-based organization.This is good news for AMA members Moreover, the FAA has said that to be exemptfrom regulations, model aircraft operators must operate completely within theparameters of the Special Rule set out by Congress in 2012.

The NPRM references the June 2014 Interpretive Rule in which the FAA assertsits interpretation of the Special Rule for Model Aircraft. As indicated indetail in updatesto our members last summer, the AMA has taken exception to several aspectsof FAA's interpretation. The main areas of concern are that the interpretation:

• Asserts model aircraft to be "aircraft" and effectively makes modelairplanes subject to all regulations applicable to full-scale manned aircraft.
• Makes model aircraft subject to airspace requirements that have never beenapplicable in the past and with which it is impossible or impractical tocomply.
• Effectively changes the criteria for operating within 5 miles of an airportfrom the requirement of providing prior "notification" to arequirement of obtaining prior permission.
• Narrowly defines "hobby and recreation" and puts in question theactivities of the supporting aeromodeling industry and AMA's educationalprograms.
• Rigidly defines the requirement to operate within visual line of sight andtargets the use of a specific aeromodeling technology/equipment, namelyfirst-person view (FPV) goggles.

Overall, the AMA views the proposed sUAS regulations as a positive step. Withone key exception that may impact model aircraft manufacturers, it essentiallytakes the language in the 2012 Special Rule for Model Aircraft and places it inthe federal aviation regulations.

We encourage members tosubmit comments commending the FAA for appropriately separating model aviationfrom the new regulations. However, AMA would also encourage members to includein their comments the need to resolve the discrepancies stemming from theInterpretive Rule before finalizing the sUAS rule.Inany case, it's important that our members provide their comments in support ofexcluding model aviation from the proposed rule. It's possible that there willbe members of the public or aviation industry who will be opposed to a rulethat protects the model aviation hobby, and we need to make sure that ourvoices are heard in support of continued community-based self-governance.

Comments on the proposed sUAS rule can be made by clickinghere. Read the proposed rule carefully, particularly the sectionsconcerning "model aircraft," and submit comments on areas where youhave a concern as well as thoughtful and productive comments in areas where youfeel there could be improvement. AMA has created a suggested template for comments,which we strongly encourage you to edit and personalize. Unless extended, thedeadline for submitting comments is 11:59 p.m., Friday, April 24, 2015.

Template Comment for AMA Members
(copy the template, click the comment now button below, and paste into thecomment field)

I  am writing in response to the FAA's proposal to regulate small unmanned  aircraft systems, including model aircraft. [Insert  personal introduction details such as: I am a [job/profession], a member of  the Academy of Model Aeronautics, and have been safely and responsibly flying  model aircraft for ___ years. I am also a model aircraft club  officer/educator/designer, etc.]

  I support the exemption of recreational model aircraft from the regulation of  unmanned aircraft systems. As Congress recognized, self-governance under  community-based safety guidelines has worked exceptionally well for decades,  and should remain in place. However, I have the following concerns about the  FAA's proposal: [choose all that you  feel apply, and feel free to add other comments]

  The FAA has repeated its June 2014 statement that model aircraft are  "aircraft" subject to all existing aviation regulations. The FAA  must revise this interpretation so that it is in agreement with what Congress  directed in 2012, which is that recreational model aircraft are subject to  community-based safety guidelines, not aviation regulations. Similarly, the  regulatory proposal excludes ultralight vehicles, moored balloons, kites,  amateur rockets, and unmanned free balloons from the FAA's aircraft operating  regulations but neglects to expressly exclude model aircraft. The proposed  regulation should make it clear that model aircraft meeting the criteria  established by Congress are not subject to aviation regulations.

  Also, the proposal leaves out the part of the statute that excludes "an  aircraft being developed as a model aircraft" from aviation regulations.  This exclusion must be added to the regulations. Companies in the model  aircraft industry should not be regulated as if they are aircraft  manufacturers.

  The FAA bases its proposal on its June 2014 interpretation of the law  concerning model aircraft. There were 33,000 comments submitted last summer  concerning that interpretation [including  mine]. The future regulations for model aircraft should not be based  on incorrect interpretations of what Congress wrote. Some of the  interpretations that should be changed to the extent they form the basis for  any current or future regulation include:

  • Making model aircraft subject to airspace requirements such as air traffic  control clearance, that have never been applicable in the past and with which  it is impossible or impractical to comply. Congress indicated the maximum  obligation, which is actually stricter than what the FAA's guidance has been  for the past 34 years: notifying the airport when operating within five  miles. That is the most that model aircraft hobbyists should have to do.

  • Rigidly defining a requirement to operate within visual line of sight and  that calls into question the use of a specific technology or equipment,  namely first-person view (FPV) goggles. The language of the 2012 statute  concerning "within visual line of sight" indicates how far away a  person should fly the model aircraft, not what method of control may be used  for the recreational experience. The proposal for commercial unmanned  aircraft acknowledges that an observer (spotter) can be used to ensure  airspace safety, just as the AMA's community-based safety guidelines do.

  • Narrowly interpreting the words "hobby or recreational use." You  should not regulate people who are flying model aircraft in connection with  the hobby just because they receive payments. For decades, enthusiasts have  participated in contests and competitions that have cash prizes, have been  paid to instruct others on how to safely fly models, and have received  compensation for aerobatic displays. These payments incidental to the hobby  do not change the underlying recreational purpose of the activity or make the  hobby any less safe, and regulating these activities would be highly  disruptive to the hobby without any benefit.

  [Optional] AMA Member Number: _________

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