RMRC Responses to FAA and DOT Actions

I'm glad that someone is raising some legit questions in the name of the whole community 

  "November 2, 2015 - As many in the US are aware, the FAA and DOT are considering requiring registration of some sUAS and have created a task force to help develop that process.

The DOT and FAA have asked for public input on the issue and have identified 10 specific questions in the document titled "Clarification of the Applicability of Aircraft Registration Requirements for Unmanned Aircraft Systems (UAS) and Request for Information Regarding Electronic Registration for UAS" that can be found at www.regulations.gov/#!docketDetail;D=FAA-2015-4378.

It is our opinion that the rush to create these new rules violates the existing procedures for enacting new rules and also goes against the law set forth in the FAA Modernization and Reform Act of 2012 (Public Law 112-95). That statute included Section 336, “a special rule for model aircraft.”  This provision was specifically included to protect the model aircraft hobby and industry from any over-reaching and onerous regulation that might be created in the future by the FAA as the FAA set out to create new rules for large commercial unmanned aircraft.  The law exempts recreational model aircraft from any new regulation, instead preserving for our communities their existing historical role of offering safety guidance, pilot instruction, flying site establishment, and event supervision, while preserving the FAA’s limited taxpayer resources for other important regulatory functions.

In our opinion, the FAA and DOT are making new rules while trying to justify them both by saying they are “interpreting” existing rules and by claiming that they are justified under the language of the 2012 law stating that “Nothing in this section shall be construed to limit the authority of the Administrator to pursue enforcement action against persons operating model aircraft who endanger the safety of the national airspace system.” It is our opinion that the current rulemaking attempt of the FAA and DOT specifically violates the FAA Modernization and Reform Act of 2012 by applying new rules not previously required for model aircraft or an aircraft being developed as a model aircraft.

That said, and outside of any legal proceeding to verify our opinion, we feel it is in the best interest of our customers to review the questions and offer comments. It is our opinion that the government website used to allow the submission of comments is limited and cumbersome in its implementation, but we have offered a few suggested comments below that you as our customers are welcome to use as a guideline for your submissions. We suggest you offer your own civil and productive comments as well. We believe model aircraft can be operated safely in the US airspace by enforcing rules already in place. If you use our replies below, you will probably have to save your comments as a document and upload the document to the web site.

Responses must be submitted by November 6, 2015 to be officially considered by the DOT and FAA."....

Check whole press release here http://www.readymaderc.com/faa  

Views: 433

Comment by Gary McCray on November 2, 2015 at 11:13am

I Got this email from RMRC too and I think it is excellent.

Only have a few more days (November 6) to put in comments and I really encourage everybody to do so.

The FAA has chosen to use DOT to obfuscate that they are completely disregarding the FAA modernization and reform act 336 special rule for model aircraft which pretty clearly does not allow them to do what they are attempting to do at least insofar as "model aircraft" are concerned.

And at this point, pretty much anything that flies that is not covered by the commercial guidelines is a model aircraft.

FAA oversee'rs for this process have come and gone and it appears we are once again under attack (with renewed vigor by declaring it to be a pre-Christmas rush emergency) to basically try to make flying anything so difficult and onerous that most people won't even buy a quadcopter toy.

I find that completely reprehensible, these people are working against the people they work for - US!

Nonetheless, simply yelling at them or chastising them isn't going to do any good, so we need carefully crafted reasonable responses that indicate we know regulation is necessary, but that it needs to be minimal and to not destroy the hobby and toy market because it is important too.

Just my thoughts.

Best Regards,

Gary

Comment by Mark on November 3, 2015 at 3:17pm

Can anybody come-up with good statement that will make FAA to back-off?

It is all aimed at more Government control, less privacy for law abiding people and has nothing to do with safety. I do not see how registration will stop someone from buying a UAV on Craigslist locally for cash and do something stupid. Better yet, someone could bulk-purchase right now a few UAVs to use them later.

There is no amount of restrictions will stop any wrong doing. Restrictions only make normal people's life a living hell.

If someone buys a DJI online with credit card - serial number will match his/her credit card at anytime later and will take no effort to find the owner for the lost ship.

I personally fly my models with my address, email and phone number on-board. Why would I need an "N" number on it?

Don't we already overpay TSA that has many hick-ups just to say the least? We're talking billions of dollars as of right now and bureaucrats still want more..

How can we stop this hysteria widely promoted by the media?

The way it goes, next year we will have to register sling-shots, kitchen knifes and forks just to be safe!

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