[NSRCA-discussion] Update - UAS Registration Frequently Asked Questions | AMA Government Relations Blog

John Gayer jgghome at comcast.net
Fri Jan 15 20:17:07 AKST 2016


Dealing with the FAA on the 400 foot limit would appear to be a game of 
whack-a-mole.
AC 91-57A Change 1 does not appear to define "best practices" although 
staying below 400 feet would appear to be one of them. In fact, best 
practices for models does not appear to be defined for model aircraft 
anywhere on the FAA site.


I did however find the guidance for law enforcement to do with model 
aircraft. If you keep a copy of this in your flight box and insist the 
law enforcement person read it before proceeding, I doubt you will ever 
see them at the field again. The only good part is that 400 feet is not 
mentioned.
There is the odd rule that you must register any model purchased after 
12/21/15 even though you do not have to register yourself until next 
month. So I gather you will have to register early if you got a 
Christmas present and want to fly it soon. If you already flew it you 
should probably turn yourself in immediately and miss the playoffs this 
weekend.

http://www.faa.gov/uas/regulations_policies/media/faa_uas-po_lea_guidance.pdf

On 1/15/2016 8:48 PM, Ed Alt via NSRCA-discussion wrote:
> I haven't seen any lawyers weigh in yet, so the rank amateur opinions 
> continue on.  Mine included.  This is similar to what I was saying 
> about "shall" and "will" a couple of weeks ago.  There's a distinction 
> in what the words mean in a contract, but I don't think that it 
> guarantees that you won't find yourself in hot water that is expensive 
> to get out of if someone, somehow determines that you've violated an 
> "intent".  Don't get me wrong, this seems to be progress.
> ------------------------------------------------------------------------
> Date: Fri, 15 Jan 2016 19:27:37 -0800
> To: danamaenia at me.com; nsrca-discussion at lists.nsrca.org
> CC: jpavlick26 at att.net
> Subject: Re: [NSRCA-discussion] Update - UAS Registration Frequently 
> Asked Questions | AMA Government Relations Blog
> From: nsrca-discussion at lists.nsrca.org
>
> 6.e uses the word "should", not "must" and that's a very important 
> legal distinction, making that a guideline, not a requirement.  
> Further, as they said on Sunday, they are aware they got that wrong 
> and are working with the AMA to fix it.
>
> Peter+
>
> On Fri, Jan 15, 2016 at 7:10 PM, Dana Beaton via NSRCA-discussion 
> <nsrca-discussion at lists.nsrca.org 
> <mailto:nsrca-discussion at lists.nsrca.org>> wrote:
>
>     6.e is a real eye-opener, and a lot less ambiguous than 91-57 was
>     in its original form. Will be interesting to see what AMA gas to
>     say about it.  Thanks for the link!
>
>     Sent from my iPad
>
>     On Jan 15, 2016, at 7:59 PM, Mking via NSRCA-discussion
>     <nsrca-discussion at lists.nsrca.org
>     <mailto:nsrca-discussion at lists.nsrca.org>> wrote:
>
>         Has anyone from the AMA commented on the new FAA Advisory
>         Circular 91-57A Change 1?
>
>         http://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_91-57A_Ch_1.pdf
>
>         Marty King
>         A&P/IA
>         mking at kingaeroaviation.com <mailto:mking at kingaeroaviation.com>
>
>         King Aero Aviation, Inc.
>         574-304-5781
>
>         Shop:
>         24751 US 6
>         Nappanee, Indiana 46550
>
>         Office:
>         56632 Boss Blvd
>         Elkhart, Indiana 46516
>
>         www.kingaeroaviation.com <http://www.kingaeroaviation.com>
>
>
>         On Jan 15, 2016, at 8:32 PM, John Pavlick via NSRCA-discussion
>         <nsrca-discussion at lists.nsrca.org
>         <mailto:nsrca-discussion at lists.nsrca.org>> wrote:
>
>             And to that end I PROMISE not to shoot anyone unless they
>             actually break into my house. Now is it OK if I buy some
>             30 round mag’s for my AR-15? LOL
>
>             John Pavlick
>
>             Cell: 203-417-4971
>
>             <image001.png>
>
>             Integrated Development Services
>
>             *From:*NSRCA-discussion
>             [mailto:nsrca-discussion-bounces at lists.nsrca.org] *On
>             Behalf Of *Ed Alt via NSRCA-discussion
>             *Sent:* Friday, January 15, 2016 7:09 PM
>             *To:* Dave Lockhart
>             *Cc:* General pattern discussion
>             *Subject:* Re: [NSRCA-discussion] Update - UAS
>             Registration Frequently Asked Questions | AMA Government
>             Relations Blog
>
>             But Dave, did you like your doctor?  The promise was "if
>             you like your doctor, you can keep your doctor".
>
>
>             On Jan 15, 2016, at 7:06 PM, Dave Lockhart
>             <davel322 at comcast.net <mailto:davel322 at comcast.net>> wrote:
>
>                 I have lots of video promising I can keep my doctor……
>
>                 *From:*NSRCA-discussion
>                 [mailto:nsrca-discussion-bounces at lists.nsrca.org] *On
>                 Behalf Of *Ed Alt via NSRCA-discussion
>                 *Sent:* Friday, January 15, 2016 6:42 PM
>                 *To:* Peter Vogel <vogel.peter at gmail.com
>                 <mailto:vogel.peter at gmail.com>>; John Gayer
>                 <jgghome at comcast.net <mailto:jgghome at comcast.net>>;
>                 NSRCA List <nsrca-discussion at lists.nsrca.org
>                 <mailto:nsrca-discussion at lists.nsrca.org>>
>                 *Subject:* Re: [NSRCA-discussion] Update - UAS
>                 Registration Frequently Asked Questions | AMA
>                 Government Relations Blog
>
>                 Anyone get that on video?  It's just hearsay until
>                 they put it into their regulations.  Meanwhile, we're
>                 signing up to a promise not to exceed 400'.  It would
>                 be nice to have that video for the trial.  lol
>
>                 ------------------------------------------------------------------------
>
>                 Date: Fri, 15 Jan 2016 15:39:07 -0800
>                 To: jgghome at comcast.net <mailto:jgghome at comcast.net>;
>                 nsrca-discussion at lists.nsrca.org
>                 <mailto:nsrca-discussion at lists.nsrca.org>
>                 Subject: Re: [NSRCA-discussion] Update - UAS
>                 Registration Frequently Asked Questions | AMA
>                 Government Relations Blog
>                 From: nsrca-discussion at lists.nsrca.org
>                 <mailto:nsrca-discussion at lists.nsrca.org>
>
>                 Yep. This was brought up directly with the FAA guy at
>                 the AMA Expo, he indicated that they got the 400'
>                 thing wrong and will be working to clarify their
>                 guidance.  The guidance on the web site right now is
>                 for people not flying under an approved set of rules
>                 from a community based organization like the AMA.
>
>                 Peter+
>
>                 On Fri, Jan 15, 2016 at 3:32 PM, John Gayer via
>                 NSRCA-discussion <nsrca-discussion at lists.nsrca.org
>                 <mailto:nsrca-discussion at lists.nsrca.org>> wrote:
>
>                     This is what the AMA says about the 400 foot
>                     barrier on the FAQs page:
>
>
>
>
>                     *Q: Am I permitted to fly above 400 feet? What if
>                     I had to check a box saying otherwise on the
>                     federal registration website?*
>
>                     A: Yes. AMA members who abide by the AMA Safety
>                     Code, which permits flights above 400 feet under
>                     appropriate circumstances, and are protected by
>                     the Special Rule for Model Aircraft under the 2012
>                     FAA Modernization and Reform Act. Checking the box
>                     on the federal registration webpage signifies an
>                     understanding of the 400 foot guideline. This is
>                     an important safety principle that all UAS
>                     operators need to be aware of, and is the same
>                     guideline established in AC 91-57 published in
>                     1981. However, the placement of this guideline on
>                     the FAA website is intended as an educational
>                     piece and more specifically intended for those
>                     operating outside of AMA’s safey program. We have
>                     been in discussions with the FAA about this point
>                     and the agency has indicted that it will be
>                     updating its website in the next week to make
>                     clear that this altitude guideline is not intended
>                     to supplant the guidance and safety procedures
>                     established in AMA’s safety program.
>
>
>                     Sounds clear, right? No 400 foot barrier need apply.
>                     However, the following is what you have to "read,
>                     understand and follow", according to the FAA.
>
>
>                       Acknowledgement of Safety Guidance
>
>                       * I will fly below 400 feet
>                       * I will fly within visual line of sight
>                       * I will be aware of FAA airspace requirements:
>                         www.faa.gov/go/uastfr
>                         <http://www.faa.gov/go/uastfr>
>                       * I will not fly directly over people
>                       * I will not fly over stadiums and sports events
>                       * I will not fly near emergency response efforts
>                         such as fires
>                       * I will not fly near aircraft, especially near
>                         airports
>                       * I will not fly under the influence
>
>                     Learn More
>                     <http://www.faa.gov/uas/publications/model_aircraft_operators/>
>
>                     [ ] I have read, understand and intend to follow
>                     the safety guidance.
>
>
>                     Under the "learn more" link, we find the following:
>
>
>
>                         Model Aircraft Operations Limits
>
>                     According to the FAA Modernization and Reform Act
>                     of 2012 as (1) the aircraft is flown strictly for
>                     hobby or recreational use; (2) the aircraft is
>                     operated in accordance with a community-based set
>                     of safety guidelines and within the programming of
>                     a nationwide community-based organization; (3) the
>                     aircraft is limited to not more than 55 pounds
>                     unless otherwise certified through a design,
>                     construction, inspection, flight test, and
>                     operational safety program administered by a
>                     community-based organization; (4) the aircraft is
>                     operated in a manner that does not interfere with
>                     and gives way to any manned aircraft; (5) when
>                     flown within 5 miles of an airport, the operator
>                     of the aircraft provides the airport operator and
>                     the airport air traffic control tower…with prior
>                     notice of the operation; and (6) the aircraft is
>                     flown within visual line sight of the operator.
>
>                       * More information about safety and training
>                         guidelines
>                         <http://www.faa.gov/exit/?pageName=More%20information%20about%20safety%20and%20training%20guidelines&pgLnk=http://www.modelaircraft.org/>
>                       * Visit knowbeforeyoufly.org
>                         <http://www.faa.gov/exit/?pageName=Visit%20knowbeforeyoufly.org&pgLnk=http://www.knowbeforeyoufly.org/>
>
>                     This implies that the 400 foot barrier is not a
>                     limit for model aircraft and also refers you back
>                     to the AMA FAQs above.  Since the "learn more"
>                     link eventually refers you back to the AMA
>                     position on 400 feet under the "more info about
>                     safety"  link, it very fuzzily appears to be
>                     supporting the position that we can still fly
>                     pattern without lying to the FAA even though we
>                     appear to be agreeing to such a limit in the
>                     "Acknowledgement".
>
>                     Guess I'll register.
>
>                     On 1/15/2016 3:56 PM, Patternpilot One via
>                     NSRCA-discussion wrote:
>
>                         Here is what I got from Mark Radcliff just
>                         after  midnight Monday morning.
>
>                         He was at the Expo.  It has been posted all
>                         over Facebook.
>
>                         http://amablog.modelaircraft.org/amagov/2016/01/11/update-uas-registration-frequently-asked-questions/
>
>
>                         Sa.
>
>                         Sent from my Verizon Wireless 4G LTE smartphone
>
>
>
>
>                         _______________________________________________
>
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>
>                         NSRCA-discussion at lists.nsrca.org
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>
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>
>
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>
>
>
>                 -- 
>
>                 Director, Fixed Wing Flight Training
>
>                 Santa Clara County Model Aircraft Skypark
>
>                 Associate Vice President, Academy of Model Aeronautics
>                 District X
>
>                 Treasurer, National Society of Radio Control
>                 Aerobatics (NSRCA)
>
>                 <image001.jpg><image002.jpg>
>
>
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>
>
>
> -- 
> Director, Fixed Wing Flight Training
> Santa Clara County Model Aircraft Skypark
> Associate Vice President, Academy of Model Aeronautics District X
> Treasurer, National Society of Radio Control Aerobatics (NSRCA)
>
>
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