Links to the sites you should submit to:
Please be thoughtful, respectful, and well researched when commenting on these forms.
"United States should be a leader, not a laggard, in adopting [drone] technology." -Washington Post Editorial
It is possible to have completely safe and incredibly useful FPV technology as a hobby and a service.
What is happening?
Why is the FAA disturbing the way the hobby is regulated when it has worked fairly well at no cost to them until now? Technology has changed the radio control hobby to the point that the FAA feels that the AMA is no longer sufficient to enforce the safety of FPV flight. However their stated reason is safety.
"Such devices would limit the operator’s field of view thereby reducing his or her ability to see-and-avoid other aircraft in the area"
How many incidents have their been involving an FPV operator and full scale aircraft?
Why is the FAA disturbing the way the hobby is regulated when it has worked fairly well at no cost to them until now? Technology has changed the radio control hobby to the point that the FAA feels that the AMA is no longer sufficient to enforce the safety of FPV flight. However their stated reason is safety.
"Such devices would limit the operator’s field of view thereby reducing his or her ability to see-and-avoid other aircraft in the area"
How many incidents have their been involving an FPV operator and full scale aircraft?
Changes by the FPV don't address the real problem, which is safety. Someone not using FPV but flying an out of the box multi rotor over a crowd of people or into a building in a major city are the real problem.
Why should this matter to you?
-Other countries will follow
-Other countries will follow
-Other classes of model flying will follow
-Enforcement will be mostly YouTube driven we would guess. Your average FPV flier is perfectly safe, rural, and doesn't publish flights online so this won't be the target. People who do publish FPV flights online will be prime for enforcement.
What can you do about it?
We are not opposed to having some rules and guidelines, we just want ones that make sense for the hobby. We believe in win-wins not lose-lose regulations.
-Enforcement will be mostly YouTube driven we would guess. Your average FPV flier is perfectly safe, rural, and doesn't publish flights online so this won't be the target. People who do publish FPV flights online will be prime for enforcement.
What can you do about it?
We are not opposed to having some rules and guidelines, we just want ones that make sense for the hobby. We believe in win-wins not lose-lose regulations.
They are going to be instrumental in dealing with the FAA on this matter. They are worth your support for that reason alone. Click here to get 50% off a membership.
-> Submit a thoughtful, respectful, well researched and well reasoned comment to the FAA through regulations.gov and the FAA Facebook page.
· Federal eRulemaking Portal: Go to Regulations.gov and follow the online instructions for sending your comments electronically.
· Mail: Send comments to Docket Operations, M-30; U.S. Department of Transportation, 1200 New Jersey Avenue, SE., Room W12-140, West Building Ground Floor, Washington, DC 20590-0001
· Hand Delivery or Courier: Bring comments to Docket Operations in Room W12-140 of the West Building Ground Floor at 1200 New Jersey Avenue, SE., Washington, DC
· Fax: Fax comments to Docket Operations at 202-493-2251.
-> Sign a popular petition
· Mail: Send comments to Docket Operations, M-30; U.S. Department of Transportation, 1200 New Jersey Avenue, SE., Room W12-140, West Building Ground Floor, Washington, DC 20590-0001
· Hand Delivery or Courier: Bring comments to Docket Operations in Room W12-140 of the West Building Ground Floor at 1200 New Jersey Avenue, SE., Washington, DC
· Fax: Fax comments to Docket Operations at 202-493-2251.
-> Sign a popular petition
Links to the sites you should submit to:
www.Change.org
AMA Response:
The AMA believes the Interpretive Rule as a whole is in essence a backdoor approach to enacting new regulatory requirements without complying with the congressionally mandated Administrative Procedures Act.
It is an abuse of the provision for Interpretive Rule under 5 U.S. Code § 553, and is contrary to Public Law 112-95, Sec. 336 which states, “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… the aircraft is operated in accordance with a community-based set of safety guidelines and within the programming of a nationwide community-based organization.”
The Interpretive Rule specifically addresses model aircraft operated within the safety programming of a nationwide community-based organization, AMA, and it effectively establishes new rules to which model aircraft were not previously subjected, i.e. model aircraft must meet the regulatory requirements for operating in particular classes of airspace.
More specifically:
1 – Throughout the rule the FAA takes great latitude in determining Congress’ intentions and in placing tightly worded restrictions through its “plain-language” interpretation of the text.
For instance, the definition of model aircraft in the Public Law requires that a model aircraft be flown within visual line of sight of the person operating the aircraft. From a safety perspective this would mean that the model aircraft must remain in sight so that the operator can maintain situational awareness, control the aircraft and see and avoid other aircraft and obstacles. There appears to be no ambiguity in the language provided by Congress, and no need for interpretation.
am on the side of convincing the FAA to not pass any draconian regulations affecting FPV be it for hobby or commercial purposes, I am also convinced the only way to get there is by making our voices heard and to be heard we need to follow the proper procedures.
Now you can raise all the Jolly Rogers you want and sign petitions all day long, but all that is going to result in is being ignored by the FAA, wasting your time and the time of others who may decide to follow you down that path.
For what it is worth this is the correct procedure to submit comments, from the agency that oversees the FAA, note nowhere in the proper procedure is mentioned the raising of pirate flags and signing petitions.
Now you can raise all the Jolly Rogers you want and sign petitions all day long, but all that is going to result in is being ignored by the FAA, wasting your time and the time of others who may decide to follow you down that path.
For what it is worth this is the correct procedure to submit comments, from the agency that oversees the FAA, note nowhere in the proper procedure is mentioned the raising of pirate flags and signing petitions.
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