The notice of proposed rulemaking (NPRM) released on December 26, 2019 suggests three options for compliance with remote identification. The full 319-page rule can be downloaded and read here.

Standard Remote ID: This is how many UAS that are not model aircraft would comply with remote ID. The proposed requirement is for UAS to broadcast identification and location information directly from the aircraft and simultaneously transmit that same information to a Remote ID UAS service provider through an internet connection. This would be done through equipage on the UAS.

Limited Remote ID: This is another option to comply with remote ID for UAS flying no more than 400 feet from the control station and within visual line of sight. The proposed requirement is for UAS to transmit information through the internet only, with no broadcast requirements. This would be done through equipage on the UAS.

FAA-Recognized Identification Areas: This is how many traditional model aircraft will comply with remote ID. This does not require any equipage on the model aircraft. Under the proposal, models (and other UAS manufactured before the compliance date) would be permitted to fly at certain specific geographic areas established under this rule specifically to accommodate them. These locations would need to be submitted to the FAA for approval and renewed every four years.

In addition, to these three remote ID compliance options, the FAA has proposed to revise the existing UAS registration requirements to require all owners of unmanned aircraft to register each unmanned aircraft individually. Furthermore, the owners of standard or limited remote identification unmanned aircraft would have to provide the serial number of all unmanned aircraft registered. The serial number would establish the unique identity of the unmanned aircraft.

Detailed Summary of Major Provisions

(page 21 of the NPRM)

ISSUE PROPOSED REQUIREMENT

Registration Requirements

Individual registration of

unmanned aircraft and

conforming changes

Requires the individual registration of all unmanned aircraft registered

under part 48.

Requires each unmanned aircraft to be registered under a unique registration number. Eliminates existing option to allow multiple recreational unmanned aircraft to register under a single registration number.

Serial numbers for

unmanned aircraft

The unmanned aircraft serial number provided as part of an application for aircraft registration for a standard remote identification or limited remote identification unmanned aircraft would be the serial number issued by the manufacturer in accordance with the requirements of part 89.

The owner of a small unmanned aircraft would have to include the manufacturer and model name of the unmanned aircraft during the registration or registration renewal process, and for any standard or limited remote identification unmanned aircraft, the serial number issued by the manufacturer.

Adds clarifying language for existing registration requirements for part 107 operators.

Telephone number(s) for applicant for registration

Requires telephone number(s) of applicant at time of registration.

Operating Requirements

Applicability of operating requirements

The remote identification operating requirements would apply to: (1)

persons operating unmanned aircraft registered or required to be registered under parts 47 or 48; and (2) persons operating foreign civil unmanned aircraft in the United States.

Remote identification

requirements generally

No person would be allowed to operate a UAS within the airspace of the United States unless the operation is conducted under one of the following: (1) the UAS is a standard remote identification UAS and that person complies with the requirements of § 89.110; (2) the UAS is a limited remote identification UAS and that person complies with the requirements of § 89.115; or (3) the UAS does not have remote identification equipment and that person complies with the requirements of § 89.120.

Standard remote identification UAS Remote identification:

If the internet is available at takeoff, the UAS would have to do the following from takeoff to landing:

(1) connect to the internet and transmit the required remote identification message elements through that internet connection to a Remote ID USS; and

(2) broadcast the message elements directly from the unmanned aircraft.

If the internet is unavailable at takeoff, or if during the flight, the unmanned aircraft can no longer transmit through an internet connection to a Remote ID USS, the UAS would have to broadcast the message elements directly from the unmanned aircraft from takeoff to landing.

In-flight loss of broadcast capability:

A person manipulating the flight controls of a standard remote identification UAS that can no longer broadcast the message elements would have to land as soon as practicable.

Operation of standard remote identification UAS:

A person would be allowed to operate a standard remote identification UAS only if it meets the following requirements:

(1) its serial number is listed on an FAA-accepted declaration of compliance;

(2) its remote identification equipment is functional and complies with the requirements of proposed part 89 from takeoff to landing; and

(3) its remote dentification equipment and functionality have not been disabled.

Limited remote identification UAS Remote identification:

The UAS would have to do the following from takeoff to landing:

(1) connect to the internet and transmit the required remote identification message elements through that internet connection to a Remote ID USS; and

(2) be operated within visual line of sight.

In-flight loss of remote identification:

A person manipulating the flight controls of a limited remote identification UAS would have to land as soon as practicable when it cannot transmit the message elements through an internet connection to a Remote ID USS.

Operation of limited remote identification UAS:

A person would be allowed to operate a limited remote identification UAS only if it meets the following requirements:

(1) its serial number is listed on an FAA-accepted declaration of compliance;

(2) its remote identification equipment is functional and complies with the requirements of proposed part 89 from takeoff to landing; and

(3) its remote identification equipment and functionality have not been disabled.

UAS without remote identification

The limited number of UAS that do not have remote identification equipment would be allowed to operate within visual line of sight and within an FAA-recognized identification area.

With authorization from the Administrator, a person may operate a UAS that does not have remote identification for the purpose of aeronautical research or to show compliance with regulations.

FAA-recognized identification areas:

Applicability Prescribes procedural requirements to establish an FAA-recognized identification area.

Eligibility Only a community based organization (CBO) recognized by the Administrator would be allowed to apply for the establishment of an FAA-recognized identification area.

Requests for establishment Application:

A CBO requesting establishment of an FAA-recognized identification area would have to submit an application within 12 calendar months from the effective date of the final rule. The FAA will not consider any applications submitted after that date.

Required documentation:

A request for establishment of an FAA-recognized identification area would have to contain the following information:

· Name of the CBO making the request.

· Declaration that the person making the request has the authority to

act on behalf of the CBO.

· Name and contact information, including telephone number(s), of

the primary point of contact for communications with the FAA.

· Physical address of the proposed FAA-recognized identification

area.

· Latitude and longitude coordinates delineating the geographic

boundaries of the proposed FAA-recognized identification area.

· If applicable, a copy of any existing letter of agreement regarding

the flying site.

Approval of an FAA-recognized identification area:

FAA would approve or deny applications for FAA-recognized identification areas, and may take into consideration matters including but not limited to: the effects on existing or contemplated airspace capacity, critical infrastructure, existing or proposed manmade objects, natural objects, or the existing use of the land, within or close to the proposed FAA-recognized identification area; the safe and efficient use of airspace by other aircraft; and the safety and security of persons or property on the ground.

Amendment:

Any change to the information submitted in the application for establishment of an FAA-recognized identification area would have to be submitted to the FAA within ten calendar days of the change. Such information includes, but would not be limited to, a change to the point of contact for the FAA-recognized identification area, or a change to the community based organization’s affiliation with the FAA- recognized identification area.

If the community based organization wishes to change the geographic boundaries of the FAA-recognized identification area, the organization must submit the request to the FAA for review. The geographic boundaries of the FAA-recognized identification area will not change until they have been approved or denied in accordance with § 89.215.

Duration of an FAA-recognized identification area:

An FAA-recognized identification area would be in effect for 48 calendar months after the date the FAA approves the request for establishment of an FAA-recognized identification area.

Renewal:

A request for renewal would have to be submitted no later than 120 days prior to the expiration of the FAA-recognized identification area in a form and manner acceptable to the Administrator. The Administrator may deny requests submitted after that deadline or requests submitted after the expiration of the FAA-recognized identification area.

Expiration and termination Expiration:

Unless renewed, an FAA-recognized identification area would be automatically cancelled and have no further force or effect as of the day immediately after its expiration date.

Termination prior to expiration (by request):

A CBO may submit a request to the Administrator to terminate an FAA-recognized identification area. Once an FAA-recognized identification area is terminated, that CBO may not reapply to have that flying site established as an FAA-recognized identification area.

Termination by FAA:

FAA would be able to terminate an FAA-recognized identification area for cause or upon a finding that the FAA-recognized identification area could pose a risk to aviation safety, public safety, or national security or that the person who submitted a request for establishment of an FAA-recognized identification area provided false or misleading information during the submission process.

Once an FAA-recognized identification area is terminated, that CBO may not reapply to have that flying site reestablished as an FAA recognized identification area.

Petition to reconsider the FAA’s decision to terminate an FAA recognized identification area:

A CBO whose FAA-recognized identification area has been terminated by the FAA would be able to petition for reconsideration by submitting a request for reconsideration and establishing the grounds for such reconsideration within 30 calendar days of the date of issuance of the termination.

The FAA released its proposed rule on remote identification (remote ID) on December 26, 2019. AMA has been advocating for our hobby throughout the remote ID rule process to include voting privileges as a member of the Remote ID Aviation Rulemaking Committee. We are reviewing this notice of proposed rulemaking on remote ID, however, an early read indicates that some of our proposals were accepted, including not requiring onboard equipage for our members at our flying sites. Please look for future communications from AMA as we review the entire proposed rule. Because this is not a final rule, we will likely ask for our members to help us shape the ultimate regulation by participating and providing comments and feedback to the FAA.

Q: What is the email the FAA sent out about remote ID?

A: In 2016 the FAA announced plans to remotely track unmanned aircraft. On December 26, 2019, the FAA published its proposed rule on remote identification in the Federal Register. This is a proposed rule, not a final rule. Please continue to monitor AMA communication because we will likely encourage members to participate in the rulemaking process to comment and shape the final rule.

Q: What does this proposed rule say for recreational fliers and AMA members?

A: As we review the 319-page document, the initial read appears to show that AMA remains successful in advocating that our members will not require onboard equipage when at a flying field or approved location. The FAA gives flexibility for recognized community-based organizations (CBOs).

Q: What is AMA stance on remote ID?

A: AMA has long advocated for a common-sense approach to remote ID. Because our operations do not pose any new risk to the airspace, the burden of remote ID should apply to unmanned aircraft capable of navigating beyond visual line of sight of the operator or spotter or operations outside our safety programming. Some AMA proposals would allow recreational operators to meet the safety and security objectives of the rule without onboard equipage by operating at fixed flying sites or by using a software-based app solution.

Q: Has AMA had any say in the remote ID rulemaking?

A: AMA has been advocating on behalf of our members from the beginning on remote ID, to include as a voting member on the 2017 Remote ID Aviation Rulemaking Committee. AMA continues to serve on FAA advisory committees and safety teams addressing remote ID.

Q: I heard AMA mention fixed flying sites. What about members who are not flying at a fixed site?

A: For members not at a flying field, it’s unknown if members can use a ground-based solution such as an app to satisfy remote ID without onboard equipage. We will share more as we read and review the 319-page proposed rule.

Q: Where can I read the proposed rule?

A: You can read the entire proposed rule and FAA’s announcement at https://www.faa.gov/news/press_releases/news_story.cfm?newsId=24534.

Q: What Happens Next?

A: AMA will continue to shape the rule before it is finalized to include asking members to participate in the rulemaking process. Please monitor communication for more information. In March 2020, the FAA will begin reviewing comments and feedback to shape the final rule. This process could take days or years.

At the beginning of December, AMA participated in a safety risk management (SRM) panel at the national level, in Washington, DC, with the FAA and other stakeholders to address the 400’ altitude issue in controlled airspace. As a result of the national SRM panel, the FAA selected four AMA clubs in controlled airspace to participate in SRM panels at the local level.

The clubs were selected by the FAA because they had requested to operate at flights over 400’ AGL at their fixed site. These panels included the AMA club contacts, AMA HQ, FAA national, local Air Traffic Operations and other stakeholders. During these panels, safety data and air traffic patterns were looked at based on the location of the fixed site to the airport. Based on the analysis, mitigations were discussed to operate safely at higher altitudes. The four clubs that participated in these panels have each been granted flights over 400’ at their fixed site in controlled airspace.

Moving forward, the FAA will be working on a case by case scenario to select clubs to participate in local SRM panels to grant flights over 400’. This will be a slow, lengthy process but congress recognizes AMA’s longstanding safety record which is why the FAA has shown flexibility in working with our fixed flying sites.

If you have questions, please contact AMA Government Affairs at (765) 287-1256 or amagov@modelaircraft.org.

Last week, the AMA Government Affairs team had a promising meeting with FAA Deputy Administrator Dan Elwell to discuss the new regulations on recreational UAS that are negatively impacting the model aviation hobby. This meeting was an important milestone in our work to protect AMA members and model aviation as the agency implements Section 349 of the FAA Reauthorization Act of 2018.

The most pressing issue facing modelers right now is the FAA’s policy to limit modelers to an arbitrary 400-foot altitude limit in controlled airspace. Based on our meeting this week, we will likely have a solution to the altitude restriction issue soon.

We used this week’s meeting to explain to Deputy Administrator Elwell that, although most of the modeling community can operate safely under 400 feet AGL, there are some cases in which the altitude limit actually makes our operations less safe. The industry’s number one goal is to keep our airspace safe, therefore the FAA has agreed to work with AMA to find a solution to this problem. AMA has been participating in a Safety Risk and Management Panel, with the FAA and stakeholders, to address the altitude restriction issue and find a process to grant operations above 400 feet.

Importantly, we discussed with the FAA the process by which AMA will be officially recognized as a community-based organization (CBO). Although most already unofficially recognize AMA as a leading CBO, this official process will position our organization to more effectively comply with the regulatory requirements and ultimately serve AMA members better. It will also help AMA help others who may be new to the hobby and still need to learn how to fly safely and responsibly.

If you have any questions or concerns, please feel free to contact the government affairs team at 765-287-1256 ext. 236 or amagov@modelaircraft.org. We are always happy to chat with you.

The AMA Executive Council and the Government Affairs team took a trip to Washington, D.C. to advocate for our hobby. We had many productive and encouraging meetings with leaders at the FAA, members of Congress and several of our allies in the aviation community.

Throughout these meetings, we continued to emphasize AMA’s commitment to safety and education. We also highlighted examples of how flying model aircraft is a pathway to STEM-related to careers and the work we do to support local charities.

Importantly, we discussed the upcoming FAA rule-makings for recreational UAS, and we were encouraged by the positive tone of the dialogue. The FAA recognizes the importance of the model aviation community and wants to continue our longstanding partnership. On Capitol Hill, members of Congress pledged support to AMA and stand ready to weigh-in with the FAA on our behalf, as needed.

We also spoke with representatives from ATC to discuss the Letters of Agreement process. We’ll continue working closely with them to ensure that there is no disruption in our ability to fly. We’ve also learned that LAANC (the FAA’s low altitude authorization and notification capability system) will be available for recreational operators in controlled airspace on July 23, 2019. Currently, only Part 107 pilots have access to LAANC and recreational pilots are able to fly only at charted flying sites in controlled airspace. We will provide more information regarding LAANC as it becomes available.

Rest assured – we are taking a proactive approach in working with government officials to influence the new regulations for recreational UAS in a way that is favorable for AMA members.

Thank you for your continued support of AMA. As always, please reach out with any questions at amagov@modelaircraft.org.

Kind regards,
AMA Government Affairs Team

FAA Letter of Agreement Questionnaire Due June 16, 2019

Thank you to the club officers who have already participated in the FAA’s new process to establish letters of agreement between clubs in controlled airspace and Air Traffic Control for flying sites in controlled airspace, as required by the FAA Reauthorization Act of 2018.

In fact, thanks to your support, we have submitted information for over 200 clubs to the FAA to establish letters of agreement. We still have about 100 more clubs to go and will be working diligently to finish submitting those too.

Please know that we continue to work with the FAA to prioritize these letters of agreement and ensure that clubs can continue operating safely as they always have. As such, we have been told by the FAA that they will honor both verbal and written agreements with ATC for the continued safe operation of model aircraft clubs in controlled airspace. This should ensure that there is no interruption in your club’s ability to operate. (For the long-term, you will still need a written letter of agreement with ATC– this is what the new process mentioned above is designed to help with.)

Nevertheless, if for some reason you do have issues with a local tower or airport, please let us know so we can help resolve the situation. In fact, earlier this week we were able to help re-open two clubs in the Denver area that were previously shutdown due to misinformation.

If your club flying site is located in controlled airspace, please check with your club officers to ensure that your club’s questionnaire has been submitted.  All FAA questionnaire submissions will be due on June 16, 2019, any submission after this date could delay the LOA process for your club’s flying site.

As always, please contact us at (765) 287-1256 or amagov@modelaircraft.org with your questions and concerns.

We appreciate your support and cooperation.
Academy of Model Aeronautics

FAA Begins Letter of Agreement Process

The FAA Reauthorization Act of 2018 requires all flying sites within controlled airspace to have a letter of agreement (LOA) with air traffic control (ATC) facilities. AMA is working directly with the FAA to prioritize this work and ensure that you have the protections you need to continue to fly. However, we need some additional information to accomplish this.

Recently, emails have been sent to club officers to ensure correct completion of an FAA questionnaire to obtain the information needed for this LOA. Multiple submissions for the same flying site will delay the process of an LOA, so the email was sent only to club officers to coordinate this effort.

If your questionnaire is not submitted to AMA by Sunday, June 16, 2019, your flying site in controlled airspace my be impacted.

The FAA plans to have an airspace authorization system (LAANC) for recreational flights operational later this summer. Until then, the only path to fly legally in controlled airspace is at a flying site with an LOA in place. During this new LOA process, the FAA will honor any existing verbal or written agreement the club has with local ATC.

You can determine your airspace classification on the FAA’s UAS Data map.

Please contact us at (765) 287-1256 or amagov@modelaircraft with any questions. We appreciate your support and cooperation!

Sincerely,
Academy of Model Aeronautics

FAA Memorandum for Air Traffic Control Education

Recently an FAA Memorandum that addressed altitude and flying restrictions in controlled airspace was circulated around the internet. This memorandum was intended as FAA guidance to educate air traffic control facilities (ATC) on best methods to respond to recreational flyers seeking authorization, not as guidance to recreational operators.

Recent legislation under Section 349 (c) states operators in controlled airspace will be required to seek authorization from towered airports, unless flying from a charted flying site. We successfully championed that if you are flying at an AMA flying field or sanctioned event, you can continue flying by following AMA’s safety program and within the existing agreements your club or contest director has with nearby airports.

AMA has been in contact with the FAA regarding this memorandum, and we have been assured that our flying sites’ current agreements with air traffic control facilities (ATC) will be honored and our members can continue flying within AMA’s safety program, as usual. This memorandum was not intended for public distribution, and out of context can read as problematic or contradictory to previous messaging to protect our operations. The FAA clarified this memorandum is just one of many steps in the Section 349 implementation process.

Future steps in the implementation process will include the need for letters of agreements (LOA) between AMA flying sites in controlled airspace and nearby ATC. Updates and guidance on how clubs should proceed with LOAs will be provided to our members in the coming days.

Please monitor social media and www.modelaircraft.org/amagov for the latest information. You can reach our offices at 765-287-1256 or amagov@modelaircraft.org.

Letters of Agreement Between Clubs and Air Traffic Control

In the near future, hobbyists and drone operators will no longer have to notify every airport within a five mile radius before an operation. When this provision is removed, it will be replaced by a new requirement that operators in controlled airspace will be required to seek authorization from towered airports, unless flying from a charted flying site. We successfully championed that if you are flying at an AMA flying field or sanctioned event, you can continue flying as you always have following AMA’s safety program and within the existing agreements your club or contest director has with nearby airports.

The FAA has begun contacting clubs within controlled airspace to make certain they have a written letter of agreement in place. While we encourage our clubs to work towards this LOA, it’s important to remember that legislation states that recreational users and ATC establish a mutually agreed upon operating procedure, so input should be coming from both the club and ATC. Click here to view our LOA template.

You can read Section 349 of the FAA Reauthorization Act of 2018 here. The provision relating to the letter of agreement reads:

(c) OPERATIONS AT FIXED SITES.—

“(1) OPERATING PROCEDURE REQUIRED.—Persons operating unmanned aircraft under subsection (a) from a fixed site within Class B, Class C, or Class D airspace or within the lateral boundaries of the surface area of Class E airspace designated for an airport, or a community-based organization conducting a sanctioned event within such airspace, shall make the location of the fixed site known to the Administrator and shall establish a mutually agreed upon operating procedure with the air traffic control facility.

AMA encourages all clubs to contact AMA HQ before signing any agreement with the FAA or air traffic control facility. You can reach our offices at 765-287-1256 or amagov@modelaircraft.org. Please monitor social media and www.modelaircraft.org/amagov for the latest information.

FAA seeks comments on Safe & Secure Operations of UAS

Model aviation needs your help to ensure future regulations do not place unnecessary burdens on our community. Last month, the FAA issued an advanced notice of proposed rulemaking (ANPRM) regarding the safe and secure operations of small unmanned aircraft systems (UAS). In this ANPRM, the FAA is currently seeking comments on potential new rulemaking for operational and performance restrictions on UAS, including model aircraft. Some of the parameters being considered include altitude, airspeed, stand-off distances and unmanned aircraft traffic management.

AMA has long held that the hobby of model aviation has introduced no new risk into the airspace, and therefore should not be subject to any new regulations. AMA is in the process of submitting comments to the FAA to this effect, urging the agency to take into consideration the existing safety guidelines for modelers and the differences between model aircraft and commercial drones – the FAA cannot and should not take a one-size-fits-all approach to regulating them.

It is critical that we voice our support for the hobby by submitting a comment to the Federal Register regarding this ANPRM. Click here to submit a comment or visit www.regulations.gov and search for Docket No. FAA – 2018 – 1086; Notice No. 18-08. Below you’ll find a suggested template for comments, which you can customize with your personal story and then copy and paste into the comment field on the Federal Register website. The current deadline for submitting comments is 11:59 pm on April 15, 2019.

Rulemaking is a lengthy process but rest assured that AMA will continue to advocate for our members and keep you informed as it progresses. You can read FAQs regarding this ANPRM or reach out with any further questions or concerns at amagov@modelaircraft.org. As always, thank you for your continued support!

Thank you,

AMA Government Affairs

Template Comment for AMA Members: ANPRM Safe and Secure Operations

I am writing in response to the FAA’s advanced notice of proposed rulemaking on the safe and secure operations of small unmanned aircraft systems (UAS), including model aircraft. My position is simple: model aviation has introduced no new risk into the airspace, and therefore should not be subject to new regulations.

As the FAA considers new rules for UAS, I urge the agency to take into consideration the existing safety guidelines for modelers and account for the fact that model aircraft and commercial drones are not the same – the FAA cannot and should not take a one-size-fits-all approach to regulations. Not only would that approach run counter to the long-standing principles guiding both manned and unmanned aviation regulations, but it would also place an unnecessary burden on hobbyists like me who have been flying model aircraft for recreational and educational purposes safely for many years.

Hobbyists who fly model aircraft do not need to be included in new rules for drone operators because we already follow our own proven set of safety guidelines, often at remote fixed flying site locations. All AMA members fly according to the organization’s safety code, which has been recognized by Congress as an effective means for managing the modeling community. Our existing safety guidelines work – and there’s no reason to add new rules.

For example, AMA members always fly within visual line of sight of their aircraft, which allows model aircraft pilots to see and avoid anything that may be flying nearby. Also, AMA members must maintain a 25-foot distance between their aircraft and any individuals whenever they are flying. At competitions and events, spectators are required to stay behind a well-defined line, typically 50-100 feet away from the flight line where pilots are operating models, depending on the size of the event and aircraft.

Advanced drones, however, have created the possibility for new risk, and that’s why AMA has supported giving the FAA the authority it needs over sophisticated drones with advanced capabilities, such as those designed for sustained and controlled navigation beyond visual line of sight. The FAA could use the presence of a navigational system that utilizes multiple waypoints as a means of differentiation between model aircraft and sophisticated drones.

New restrictions on model aviation could have a detrimental impact on long-standing model aviation events and competitions that support local charities and non-profits. Beyond curtailing events and harming charities, new rules would have a chilling effect on youth involvement in the hobby and stifle the benefits of utilizing model aviation in STEM education, ultimately hindering efforts to attract youth to the aviation industry.

Again, I urge you to consider model aviation hobbyists separately from operators flying sophisticated drones as you work on new rules for UAS. Not all model aircraft and drones are the same, so the FAA cannot simply take a one-size-fits-all approach.

Respectfully,

[Name]

[City, State]

[Optional] AMA Member Number: _________