Quoted:
Again, this rule is not about safety. There will be absolutely NO improvement in safety WHATSOEVER due to this registration requirement. It is absolutely about control. The FAA has, for decades, not required registration of hobby aircraft. Now that the UAS craze has caught on, their idiot legal team told them if they don't start regulating hobby drones, they simply won't be able to. Problem is, Congress already REVOKED their legal authority to regulate hobby/recreational sUAS. Period. It isn't a matter of interpretation, it's a matter of LAW, which the FAA is flagrantly violating. Further, the FAA may not charge a fee (otherwise known as a tax) until and unless Congress SPECIFICALLY gives them the authority to do so (because only Congress has the power to levy taxes). Congress have NOT given them the legal authority to charge such a fee.

As for the "risk" sUAS pose, there is precisely ZERO evidence of any kind that indicates what level of damage a 9oz. drone would cause. None. at. all. Further, my analysis of the so-called sighting/incident data indicates to me that over 95% of the so-called "sightings" were not sUAS at all. I've done the work that shows manned aircraft pilots are RARELY able to see sUAS, even under tightly controlled circumstances. The AMA did a good job on assessing these so-called incidents. They gave every benefit of the doubt to the manned aircraft pilot reporting it. Their conclusion was that only 3.5% of the reports actually indicated a possible conflict and most of those did not represent an actual hazard. In my estimation, over 95% of the "sightings" were not, in fact, drones but something else. Of the remaining, it is highly unlikely that the pilots were able to accurately gauge how close whatever the object was, something that even the FAA's own report indicates manned aircraft pilots are notoriously bad at (distance between moving objects).

I have been advocating for over 5 years now that NASA and the FAA conduct ACTUAL crash testing of sUAS of varying sizes into things like aircraft wings, windscreens, props, and jet engines. I've also advocated that tests be done to look at the damage a crashing vehicle might do to car windshields, rooftops, office building windows, and instrumented crash dummies. With that ACTUAL data, not fear and superstition, credible risk assessments can be made and defensible rules created based on actual engineering and science, not emotion.

In addition, the FAA needs to be "educated" about the fallacy of using penetrating injury data from ballistics and shrapnel to estimate lethality of sUAS. Think of it this way, I can hit you with a basketball or I can hit you with a throwing knife, point first. Which of those two do you think will cause more injury even if the kinetic energy imparted to both is the same? Since the answer is obvious, why does the FAA insist on using data that is clearly not applicable? To exaggerate the risk, of course. Why would they want to do that? Because Congress told them they could pursue enforcement action against "reckless" operators. So, by using bogus data, all operators become reckless by design. Once again, it's not about SAFETY, it's about CONTROL. They want to control ALL of the airspace, even that airspace the Supreme Court has already ruled belongs to the landowner underneath, and, that the airspace <as a whole> belongs to the public, not the FAA.

Quoted:
Again, this rule is not about safety. There will be absolutely NO improvement in safety WHATSOEVER due to this registration requirement. It is absolutely about control. The FAA has, for decades, not required registration of hobby aircraft. Now that the UAS craze has caught on, their idiot legal team told them if they don't start regulating hobby drones, they simply won't be able to. Problem is, Congress already REVOKED their legal authority to regulate hobby/recreational sUAS. Period. It isn't a matter of interpretation, it's a matter of LAW, which the FAA is flagrantly violating. Further, the FAA may not charge a fee (otherwise known as a tax) until and unless Congress SPECIFICALLY gives them the authority to do so (because only Congress has the power to levy taxes). Congress have NOT given them the legal authority to charge such a fee.

As for the "risk" sUAS pose, there is precisely ZERO evidence of any kind that indicates what level of damage a 9oz. drone would cause. None. at. all. Further, my analysis of the so-called sighting/incident data indicates to me that over 95% of the so-called "sightings" were not sUAS at all. I've done the work that shows manned aircraft pilots are RARELY able to see sUAS, even under tightly controlled circumstances. The AMA did a good job on assessing these so-called incidents. They gave every benefit of the doubt to the manned aircraft pilot reporting it. Their conclusion was that only 3.5% of the reports actually indicated a possible conflict and most of those did not represent an actual hazard. In my estimation, over 95% of the "sightings" were not, in fact, drones but something else. Of the remaining, it is highly unlikely that the pilots were able to accurately gauge how close whatever the object was, something that even the FAA's own report indicates manned aircraft pilots are notoriously bad at (distance between moving objects).

I have been advocating for over 5 years now that NASA and the FAA conduct ACTUAL crash testing of sUAS of varying sizes into things like aircraft wings, windscreens, props, and jet engines. I've also advocated that tests be done to look at the damage a crashing vehicle might do to car windshields, rooftops, office building windows, and instrumented crash dummies. With that ACTUAL data, not fear and superstition, credible risk assessments can be made and defensible rules created based on actual engineering and science, not emotion.

In addition, the FAA needs to be "educated" about the fallacy of using penetrating injury data from ballistics and shrapnel to estimate lethality of sUAS. Think of it this way, I can hit you with a basketball or I can hit you with a throwing knife, point first. Which of those two do you think will cause more injury even if the kinetic energy imparted to both is the same? Since the answer is obvious, why does the FAA insist on using data that is clearly not applicable? To exaggerate the risk, of course. Why would they want to do that? Because Congress told them they could pursue enforcement action against "reckless" operators. So, by using bogus data, all operators become reckless by design. Once again, it's not about SAFETY, it's about CONTROL. They want to control ALL of the airspace, even that airspace the Supreme Court has already ruled belongs to the landowner underneath, and, that the airspace <as a whole> belongs to the public, not the FAA.

Quoted:
If the FAA were serious about airport safety, they could use 2.4 GHz radio jammers around airport perimeters that have something like a 2500 ft range.

Quoted:
And how much do you figure this destructive testing of wings, windscreens, props, and jet engines would run?  Who do you propose should pay for it?

Quoted:

Education and accountability would work without registering everyone.

Just like with laser pointers,drop the hammer on those that get stupid.

Quoted:
I want all bicyclists registered because they might wander onto a highway.

Quoted:
Hilarious.

The R/C flyers can cripple the system in a week.  There are only so many Tail Numbers...

An N-Number can be in any of these formats
One to five numbers (N12345)
One to four numbers followed by one letter (N1234Z)
One to three numbers followed by two letters (N123AZ)
N-Numbers do not have
A zero (0) as the first number
The letters "I" or "O"

Register everything you have.  Now.

Quoted:


I have been advocating for over 5 years now that NASA and the FAA conduct ACTUAL crash testing of sUAS of varying sizes into things like aircraft wings, windscreens, props, and jet engines. I've also advocated that tests be done to look at the damage a crashing vehicle might do to car windshields, rooftops, office building windows, and instrumented crash dummies. With that ACTUAL data, not fear and superstition, credible risk assessments can be made and defensible rules created based on actual engineering and science, not emotion.



Plenty of data about what a 9oz pigeon (or other bird) does to an airplane, however...and it's not too much of a stretch to think that an RC aircraft of an identical weight with approximately the same collision speed would produce at least similar results.


Of course actual controlled testing is the best answer, but in the absence of that I still think you can make a reasonable assumption that these aircraft could cause actual (or under the wrong conditions, even catastrophic) damage. Especially larger ones with a DSLR camera strapped to them that weigh several pounds...or the weight of a red tailed hawk and other large birds.

Quoted:
A lot of posters in this thread seem to have the impression that you are in favor of it, despite your protestations. Maybe you should reread your own posts, recognize the echoes of anti-gun, statist arguments in them, and maybe you'll find a clue as to why.

Dear AMA Members,

Yesterday, the AMA Executive Council unanimously approved an action plan to relieve and further protect our members from unnecessary and burdensome regulations. This plan addresses the recently announced interim rule requiring federal registration of all model aircraft and unmanned aircraft systems (UAS) weighing between 0.55 and 55 pounds.

AMA has long used a similar registration system with our members, which we pointed out during the task force deliberations and in private conversations with the FAA. As you are aware, AMA's safety program instructs all members to place his or her AMA number or name and address on or within their model aircraft, effectively accomplishing the safety and accountability objectives of the interim rule. AMA has also argued that the new registration rule runs counter to Congress' intent in Section 336 of the FAA Modernization and Reform Act of 2012, otherwise known as the "Special Rule for Model Aircraft."

The Council is considering all legal and political remedies to address this issue. We believe that resolution to the unnecessary federal registration rule for our members rests with AMA's petition before the U.S. Court of Appeals for the District of Columbia. This petition, filed in August 2014, asks the court to review the FAA's interpretation of the "Special Rule for Model Aircraft." The central issue is whether the FAA has the authority to expand the definition of aircraft to include model aircraft; thus, allowing the agency to establish new standards and operating criteria to which model aircraft operators have never been subject to in the past.

In promulgating its interim rule for registration earlier this week, the FAA repeatedly stated that model aircraft are aircraft, despite the fact that litigation is pending on this very question. The Council believes the FAA's reliance on its interpretation of Section 336 for legal authority to compel our members to register warrants the Court's immediate attention to AMA's petition.  

While we continue to believe that registration makes sense at some threshold and for flyers operating outside of a community-based organization or flying for commercial purposes, we also strongly believe our members are not the problem and should not have to bear the burden of additional regulations.  Safety has been the cornerstone of our organization for 80 years and AMA's members strive to be a part of the solution.

As we proceed with this process, we suggest AMA members hold off on registering their model aircraft with the FAA until advised by the AMA or until February 19, the FAA's legal deadline for registering existing model aircraft.

Holding off on registration will allow AMA time to fully consider all possible options. On a parallel track, it also allows AMA to complete ongoing conversations with the FAA about how best to streamline the registration process for our members.

In the near future, we will also be asking our members to make their voices heard by submitting comments to the FAA's interim rule on registration. We will follow-up soon with more detailed information on how to do this.

Thank you for your continued support of AMA. We will provide you with more updates as they become available.

Kind regards,



The AMA Executive Council

On a parallel track, it also allows AMA to complete ongoing conversations with the FAA about how best to streamline the registration process for our members.

Quoted:
Mitigate your own risks. Don't limit what others are allowed to do based on what you choose to do.

Life's hard, get a helmet.