Duane Brocious's Posts (49)

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Community Based Organization Standards






Now that the FAA regs are all but written in stone, many have argued that CBO's can provide their own regulations to circumvent the FAA regulations. What is uncertain is if there is any provision in the proposed regulations for CBOs at all.

The AMA has even pushed an ammendment to exempt only "nationwide" CBOs from FAA regulation through the Senate (but not the House).

There are three possibilities in this morass:

1. The provision for national CBOs in s.223 and other bills passes into law.

2. The FAA regulations provide for CBOs under OMB.119

3. No bill w/ammendment gets passed and there are no CBO provisions in the FAA regs.


To dispell much of what has been said about CBO's, I recommend reading the law governing CBO's as standards bodies.

That law is available here it is OMB.119 and defines what a Standards Body is as well as what they can and can't do.



" A voluntary consensus standards body is defined by the following attributes:
(i) Openness.
(ii) Balance of interest.
(iii) Due process.
(vi) An appeals process. "


I do not know of a single sUAV or Model Aircraft organization that meets a single one of those criteria.


As much as I hate to say it, I see no honest and legal way to get around the FAA in the recreational sector.

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FAA sUAS regulations milestone








According to the Federal Register, the FAA's sUAS regulations are to be submitted to the Secretary of Transportation today. Nothing for even the FAA to do about it now until the NPRM this summer. Just a couple months of rubber stamping the mystery envelope.


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In a newly created AMA safety rule, the AMA refers to themselves as a regulatory agency along with the FAA and FCC.

Quote (bolding mine):
"All pertinent regulations from the Federal Communications Commission (FCC), Federal
Aviation Administration (FAA) and Academy of Model Aeronautics (AMA) shall be


This new document allows AMA members to have aircraft upto 100 pounds and the AMA BoD already gave them permission to increase the regulated limit to 125 pounds. I bet other CBOs in the USA wish they could make up their own laws.


I will bet dollars to doughnuts that the AMA's nextstep will be to take over commercial sUAS regulations 

Never happen? That is what everyone said about recreational sUAS too.

AS soon as they rake in the $1B from S.223 you think they wont go after another $10B? and have the money to pay off the politicians?

Good luck with that.


Don't worry turbine users, if the FAA bans turbines just join the AMA, they are exempt from laws and allow turbines.


AMA safety rule cited is HERE

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Senate passes Bill S.223 with recreational sUAS amendment denying FAA authority!

Sponsored by OK Senator Inhofe:




(g) Special Rule for Model Aircraft.--

    (1) IN GENERAL.--Notwithstanding any other provision of law relating to the incorporation of unmanned

aircraft systems into FAA plans and policies,, including this section, the Administrator shall not promulgate any

rules or regulations regarding model aircraft or aircraft being developed as model aircraft if such aircraft is--

    (A) flown strictly for recreational, sport, competition, or academic purposes;

    (B) operated in accordance with a community-based set of safety guidelines and within the programming of a

nationwide community-based organization; and

    (C) limited to not more than 55 pounds unless otherwise certified through a design, construction, inspection,

flight test, and operational safety program currently administered by a community-based organization.

    (2) MODEL AIRCRAFT DEFINED.--For purposes of this subsection, the term ``model aircraft'' means a

nonhuman-carrying (unmanned) radio-controlled aircraft capable of sustained flight in the atmosphere, navigating

the airspace and flown within visual line-of-sight of the operator for the exclusive and intended use for sport,

recreation, competition, or academic purposes."


More HERE and HERE


Why didn't the AMA let anyone knw they were secretly working to get this passed without anyone knowing?

Sounds llike sneaky sleazy politics to me. But the AMA will instantly gain upto $100 Billion in dues!

No oversight over all that new money either!

I don't trust them and I am a member!


No AMA dues - no flying.

No autonomous systems period

Limited FPV, even an AR Parrot will be illegal to use because it doesn't meet AMA rules.

AMA can change rules at will to ban all FPV! 


This can only be stopped at the House of Representatives now.

Write and call your Representative now or say good buy to all your stuff.

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AMA retratcs (?) statements.







An Administrator (shawng) on the AMA forum posted that the recent AMA posted documents were incorrect.

Is the AMA backtracking or incompetent?

Publish stuff then tell people it is meaningless?

These guys want to run recreational sUAS regulation for the entire USA?

I hope the FAA realizes the current people running the AMA are incompetent and should be kept away from any position of control or regulation.


Here is the AMA's  retraction statement:


" Below is a message from Dave Mathewson concerning these documents:

On Friday February 4th several threads began appearing on Internet forums concerning two documents posted on the AMA Website. The documents being referred to were created, in part, as position papers to help our lobbyist when creating awareness for our cause with elected representatives. They were created in late October, early November and came right on the heels of what we feel was a low point for us in the process - the September 29th meeting with the FAA’s Unmanned Aircraft Program Office.

Since that time, things have somewhat improved, and what was heard at the AMA/FAA open forum held at the AMA Expo in early January is more reflective of where we are today, making these documents obsolete. We do believe that some of the concerns expressed in those papers may still be issues that could appear in the proposed (default) rule, but we are working to address those particular issues in our standards.

For the most current, up-to-date information please visit the Government Relations page on the AMA Website at www.modelaircraft.org/gov. More detailed information will also be contained in the next issue of Model Aviation magazine due out in the next couple of weeks."

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Academy Of Model Aeronautics Warns About Heavy Restrictions Coming From Washington

Academy-Model-Aeronautics-Logo-0211a_tn.jpg The Academy of Model Aeronautics tells ANN that the FAA is set to place "heavy restrictions" on the hobbyists who fly model aircraft. In a circular sent to ANN over the weekend, the AMA indicates that the agency is poised to impose severe restrictions on the model aviation hobby, sport and industry that will have a potentially devastating impact on a recreational and educational activity pursued by hundreds of thousands of enthusiasts, tens of thousands of employees and an industry that generates more than $1 billion in revenue.


Read much more HERE

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New AMA Documents shed light on NPRM

3689388164?profile=original3689388101?profile=originalThe AMA appears to have broken the silence over the coming NPRM. Full docs posted on Feb. 4, 2011 HERE and HERE.

In short they say:


"Although the exact language of the proposed regulation is not yet known, there are a number of conclusions that can be drawn from the ARC recommendations. The following are AMA’s areas of concern, the restrictions that are likely to be imposed and their effect on
the model aviation community:"


ALTITUDE: As proposed, the rule would impose a nationwide altitude ceiling of 400 feet.

SPEED: It is likely that the rule will attempt to limit model aircraft performance by
establishing a set speed limit such as 100 mph


WEIGHT: As proposed, the sUAS rule will limit small unmanned aircraft to 55 pounds
or less.


TURBINE BAN: The blanket prohibition of gas turbine engines.


AIRPORT PROXIMITY: It is understood that the FAA is considering going outside the ARC’s
recommendation and extending the “area of concern” around the nation’s 19,760 airports
beyond the current 3-mile radius to 5 miles.


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New discussion forum


I started a forum to keep some of my tangential discussions from taking up the space here.


FAA regulations - current and in process


Recreational autonomous systems

Recreational FPV systems


No censorship other than for abuse and profanity.

Free registration to post, only valid email required to register.

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From the released ARC document:

The AMA recommends removing section 3 in its entirety, leaving only the CBO (AMA) rules.

Note that FPV and atonomous systems are fully acceptable within LOS. The AMA prohibits all autonomous and FPV is allowed only with a budy box. "not operated in accordance with accepted standards" means nonAMA members.


"3. Model Aircraft Not Operated in Accordance with Accepted Set of Standards

3.1 Applicability
The following general requirements and limitations apply to Model Aircraft which are not perated in accordance with an FAA accepted set of standards, but are operated by hobbyists for the sole purpose of sport, recreation, and/or competition.

3.2 General Requirements
(1) Model Aircraft shall be flown in open spaces and in a manner that does not endanger the life and property of others.
(2) Model Aircraft shall yield the right of way to all manned aircraft.
(3) Model Aircraft shall not interfere with operations and traffic patterns at airports,heliports, and seaplane bases.
(4) Model Aircraft shall not be operated at locations where Model Aircraft activities are prohibited.
(5) Model Aircraft are limited to unaided visual line-of-sight operations. The Model Aircraft pilot must be able to see the aircraft throughout the entire flight well enough to maintain control, know its location, and watch the airspace it is operating in for other air traffic. Unaided visual line-of-sight does not preclude the use of prescribed corrective lenses.
(6) Model Aircraft shall be designed, equipped, maintained and/or operated in a manner in which the aircraft remains within the intended area of flight during all operations.
(7) Model Aircraft pilots may not intentionally drop any object from a Model Aircraft that creates a hazard to persons or property.
(8) Model Aircraft shall be operated in a manner that respects property rights and avoids the direct overflight of individuals, vessels, vehicles, or structures.
(9) Model Aircraft shall not be operated in a careless or reckless manner.
(10) Model Aircraft pilots shall not operate their aircraft while under the influence of alcohol or while using any drug that affects the person’s faculties in any way contrary to safety.
(11) Model fixed-wing and rotorcraft aircraft shall not use metal-blade propellers.
(12) Model Aircraft shall not use gaseous boosts.
(13) Model Aircraft shall not use fuels containing tetranitronmethane or hydrazine.
(14) Model Aircraft shall not use turbine-powered engines (e.g., turbo-fan, turbo-jet) as a propulsion source.

3.3 General Limitations
(1) Model Aircraft shall not exceed 55 pounds (lbs).
(2) Model Aircraft shall remain clear of clouds.
(3) Model Aircraft will not operate in Class B airspace without the permission of the ATC authority.
(4) Model Aircraft shall not be operated within 3 NM miles of an airport, heliport, or seaplane base without the permission of the ATC authority or airport manager.
(5) Model Aircraft shall operate in close proximity to the ground, at or below 400 feet (ALG) above ground level, and shall at all times remain below and well clear of all manned aircraft.
(6) Notwithstanding the above limitations, Model Aircraft weighing less than or equal to two lbs incapable of reaching speeds greater than 60 miles per hour (mph)
(52 knots), and powered by electric motor or mechanical stored energy (e.g.,rubber-band powered) may operate within 3 NM of a military or public-use airport or heliport; if they remain a safe distance from the airport or heliport, remain well clear of all manned aircraft, and remain below 400' AGL.
(7) Model Aircraft will not be flown at an airspeed that would cause the aircraft to
inadvertently leave the prescribed maneuvering area. !
(8) Model Aircraft cannot launch pyrotechnic devices which explode or burn.
(9) Excluding take-off and landing, no powered Model Aircraft may be flown closer than 25 feet to any individual, except for the pilot and the pilots helper located at the flight line.

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AMA Rules on FPV and Autonomous Aircraft

The AMA rules may well end up being the only FAA approved rules for recreational use of an sUAS (AMA membership may become mandatory as well).

This is the AMA rule for FPV:

"First Person View (FPV) Operations

1. An FPV-equipped model must be flown by two AMA members utilizing
a buddy-box system. The pilot in command must be on the primary
transmitter, maintain visual contact, and be prepared to assume
control in the event of a problem.

2. The operational range of the model is limited to the pilot in command’s
visual line of sight as defined in the Official AMA National Model
Aircraft Safety Code (see Radio Control, item 9).

3. The flight path of model operations shall be limited to the designated
flying site and approved overfly area.

4. The model weight and speed shall be limited to a maximum of 10
pounds and 60 miles per hour."


This is their official stance on autonomous and semi-autonomous flight:

"Autonomous flight, as it pertains to RC operations under AMA’s programs, infers usage of a navigational system that allows the model to fly a pre-determined mission from point A to point B, point C, etc.  Autonomous flight is navigating a model aircraft autonomously."


Note that the last sentence is a tautology and not a definition. Autonomous is autonomous? Big help there. Hopefully this kind of language will be a red flag to the FAA that the AMA does not  know how to write the proper documentation required by law for CBO standards. They do not even know the definition of the centuries old word "autonomous".

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FAA at AMA Expo. 1st hand report

"Mostly because I hate posting the same thing to multiple threads on multiple forums. But here is what I posted on RCGroups, Flying Giants, and RC Universe:

Here you go. SOme of it may not flow since I cut and pasted several remarks from another forum, but you should be able to get the general idea::

The presentation today was very interesting. The FAA had two people there. James Sizemore and a lady named Lynn. Mr. Sizemore was part of the FAA team early on and recently rejoined this group. Lynn is a recent addition. Mr. Sizemore is an active modeler in the DCRC club. He noted that a fair number of people in the UAPO (Unmanned Aircraft Program Office) are either active or past modelers. They both noted that the FAA fully recognizes the contribution of model aviation to the aviation industry.

As expected they were unable to address specific questions about the Rule. FAA policy prohibits them from doing so. Having said that, my overall impression is that I a bit more optimistic than I was when I woke up today.

A few high points for me were first hearing that the Rule is in fact written. It is undergoing a series of internal checks and reviews prior to being published as a NPRM sometime in June or perhaps July.

From there will be a comment period followed by a review and assessment of the comments and then the Rule may be modified based on those comments (or not) and then published in a final form. Final publication will likely be sometime in 2012.

They were very clear that the FAA is not interested in harming model aviation. They also clearly stated that the ONLY motivation for this was the explosive growth in the UAV world and the increasing number of commercial UAV folks trying to operate and calling themselves models. Since the FAA had no rules to regulate those uses, they decided to write these rules. It is a 100% air safety thing.

They very clearly stated that fears of terrorism and so on had absolutely nothing to do with the rules. They also said very clearly that there is no over riding concern about the past safety record of models or events that got us on their radar as it were. Again, it is the fact that in many cases we are indistinguishable from commercial UAS that they have to draw a line between us and them,

They laid out how the Safety Program that the AMA is writing will be reviewed and accepted (or accepted with modifications) for reference by the rule. The way it works is that if you want to be called a model you will operate in accordance with the accepted standards for models or you will have to operate as a regulated commercial sUAS.

They were clear that they are not prescribing any specific limits for altitude, speed, weight, propulsion, etc. At one point they said very clearly that they have not told the AMA to take turbines off the table for instance.

I expect that once an accepted set of operating standards is in place the way it will work is that the FAA will say go forth and enjoy. They will likely define places where you cannot operate regardless of compliance with the rules. This is sort of the same as saying ultra lights cannot operate in Class B airspace for instance.

The major challenge right now is to craft our safety program in a format and language that the FAA can accept. But they seemed genuinely interested in working with us to enable us to continue on in as close as possible to what we do now. They are also acutely aware of our concerns about altitude, speed, turbines, and so on.

While we are by no means out of the woods I can say that I am far more optimistic than I have been in the past. One really important thing I learned today was that when Dave Mathewson wrote his ominous article for the December MA it was right after a very disappointing meeting with the FAA. The AMA related their deep concerns and disappointment with the direction things were going. Shortly after that the FAA team was changed to the one that the AMA is working with now. For me the take away is that the FAA higher ups took the AMA concerns to heart and responded positively. That is huge in my mind.

So I am not dancing in the streets with joy, but I am also not thinking about selling everything either, for whatever that is worth to people.

Let me add that the impression I got is that they are working hard to help us to write safety standards that allow us to do what we do now in a manner that satisfies their need to demonstrate that they are protecting aviation safety.

Their concerns for us, as well as the commercial sUAS, focuses on things like what happens in a loss of control, pilot error, fly away and so on. They made positive statements about the things we do already, like checking battery packs prior to flight as a method of confirming that we will not lose battery power and control. Or selecting a field location that mitigates the risk from these events, and so on.

The only mention of AC 91-57 was during the explanation of why they are making the rule in the first place. There were a large number of commercial/public use users flying sUAS for hire who were doing so and saying that they were operating under AC 91-57. In 2007 the FAA issued a clarification of this saying that was not legal and then started moving towards writing these rules. That was the last time it was mentioned.

About the AMA working group doing the standards: Dave Mathewson and Rich Hanson have both stated very clearly that they are not "leaving anyone behind". There is no area of modeling they feel is worth sacrificing. So if the concern is that for instance the AMA will write a standard that says "No Turbines" or "No large planes" or "Nothing over 400 feet" I can more or less guarantee you that this is not going to happen.

The working group within the AMA has knowledgeable people from all parts of the hobby on it. Soaring, IMAC, pattern, jets, and so on all have solid representation there. Said simply, this is not a concern.

Bill Malvey
Leader Member
Distinguished Service Award (2007)
District Service Award (2010)
EX-AVP District X (Free Speech is Not Tolerated)
Orange County, CA "

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The official timeline has been officially extended.

NPRM publication is now due on July 21, 2011

The FAA has been granted extension for rulemaking process.

Federal documentation here.


"Popular Title: Small Unmanned Aircraft

RIN 2120-AJ60



Previous Stage:



limited portions of the national airspace system (NAS). This action is necessary because it

addresses the novel legal or policy issues about the minimum safety parameters for operating

recreational remote control model and toy aircraft in the NAS. The intended effect of this

action is to develop requirements and standards to ensure that risks are adequately mitigated,

such that safety is maintained for the entire aviation community.......

To OMB 02/03/2011 04/05/2011

OMB Clearance 03/07/2011 07/05/2011

Publication Date 03/10/2011 07/21/2011

End of Comment Period 07/14/2011 08/22/2011

This rulemaking would enable small unmanned aircraft to safely operate in


To OST 01/24/2011 03/03/2011

Explanation for any delay:

Unanticipated issues requiring further analysis

Federal Register

Citation for NPRM: None"
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JPO Hosts AMA Webinar on FAA Rulemaking

Here is where you can get the info and powerpoint from the recent webinar on the FAA RUlemaking. Seems the AMA is really pushing the "No rules for AMA members and no recreational use without the AMA" line. Seems to me they want to make everyone join the AMA whether they need it or not. The AMA has done nothing to "supervise" model aviation in its entire history so why should the FAA think they will do so if given that power? Sounds more like an AMA money grab to me. The AMA is doing nothing in this process for anyone but the AMA, this is not their NPO tax exempt stated purpose.

 I seriously hate this attitude from an NPO supposedly being the voice for "all model aviation". Guess they need a way to boost their falling membership numbers. Nothing like a monolpoly without rules to make that happen. I honestly hope the FAA will tell the AMA to stick it and give us reasonable rules for all recreational users. IMHO The AMA is little more than an insurance company looking to make more money.


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