[AlaskaRC] FW: Guidance on Submitting Comments to the FAA

Marty Hall mjhall at alaskarcs.com
Mon Dec 28 11:05:33 AKST 2015



From: AMA Government Relations [mailto:amagov at modelaircraft.org] 
Sent: Monday, December 28, 2015 8:29 AM
To: mjhall at alaskarcs.com
Subject: Guidance on Submitting Comments to the FAA


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Member Communication


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Monday, December 28, 2015 spacer

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The AMA has recommended that our members hold off on registering their model
aircraft with the FAA until advised by the AMA or until the FAA's legal
deadline of February 19. Holding off on registration will allow time for AMA
to fully consider all possible legal and political options for alleviating
this unnecessary regulatory burden on our members. 

In the meantime, you can help by making your voice heard with the FAA.
Specifically we are asking all AMA members to submit comments on the FAA's
interim rule on registration. The deadline to submit comments is January 15,
2016. All comments can be submitted at http://1.usa.gov/1Jegj0C
3b8c3938308f> . 

Below are recommended messages to convey in your comments:  

*	Express your disappointment with the registration rule. As a member
of the Academy of Model Aeronautics (AMA), I am disappointed with the new
rule for UAS registration. I am a long time model aircraft flyer, who has
operated under the guidance of the largest community-based organization
(CBO) in the world for many years. 
*	Highlight AMA's history and safety record. Since 1936, AMA has
published safety standards and offered training programs for our members -
more than 20 years before the FAA was created. Our National Model Aircraft
Safety Code has been recognized by Congress as well as by state legislatures
as a safe and effective means of managing model aircraft enthusiasts like me
*	Note that you already register with AMA. Additionally, AMA's safety
program already instructs me to place my AMA number or name and address on
or within my model aircraft(s), effectively accomplishing the safety and
accountability objectives of the interim rule. 
*	Make it clear this rule is contrary to the intent of Congress. The
new rule is contrary to the intent of Congress in Section 336 of the 2012
FAA Modernization and Reform Act. Section 336, also referred to as the
"Special Rule for Model Aircraft," clearly prohibits the FAA from
promulgating any new rules for recreational users operating within the
safety guidelines of a CBO. In addition, the FAA's contention that model
aircraft should be considered aircraft is currently the subject of pending
*	Affirm that as an AMA member you should be exempt from federal
registration. The registration process is an unnecessary burden for me and
the more than 185,000 other AMA members. AMA members should not be required
to register with the FAA.

Thank you,

AMA Government and Regulatory Affairs Team

amagov at modeliarcraft.org
<mailto:amagov at modeliarcraft.org?subject=Guidance%20on%20Submitting%20Commen


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