I am a model aviator. Having just celebrated my 40th birthday, I have been flying, building, and designing model aircraft for over thirty years. I have experience with everything from simple hand launched gliders to complex composite airplanes capable of speeds in excess of 100 mph. I am a club flight instructor and introductory pilot for both fixed wing and rotary wing airplanes and am also a repair tech for model airplanes and helicopters at a local hobby shop. When called upon, I have volunteered for local schools to help with STEM education projects involving aviation and I am also the district ten representative for the Jet Pilots Association, a special interest group within the Academy of Model Aeronautics. (AMA) As a GED instructor in an adult probation program I use model aviation to help illustrate math and science concepts. To say that I am heavily involved in model aviation is a bit of an understatement.
Recently, the Federal Aviation Administration convinced the Department of Transportation to push through regulation requiring that all pilots of model aircraft (commonly incorrectly referred to as drones) be registered. It is important to note that the FAA has already been informed by two different court cases that model aviation is beyond the jurisdiction of the FAA. It is my opinion that this is why they chose to use the DOT as a proxy.
This new registration requirement is a textbook example of government overreach and waste. It is also a great way to continue the erosion of the trust of government as this is not the first time the FAA has gone against a previous decision on this issue that the AMA (an organization with over 140,000 members) has negotiated on in good faith.
It is also against a congressional ruling –
SEC. 336. SPECIAL RULE FOR MODEL AIRCRAFT.
(a) IN GENERAL
.—Notwithstanding any other provision of law
relating to the incorporation of unmanned aircraft systems into Federal Aviation Administration plans and policies, including this subtitle, the Administrator of the Federal Aviation Administration may
not promulgate any rule or regulation regarding a model aircraft,
or an aircraft being developed as a model aircraft, if—
(1) the aircraft is flown strictly for hobby or recreational
(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; and
(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 (when an air traffic facility is located at
the airport) with prior notice of the operation (model aircraft
operators flying from a permanent location within 5 miles of an
airport should establish a mutually-agreed upon operating procedure with the airport operator and the airport air traffic control tower (when an air traffic facility is located at the airport)).
(b) STATUTORY CONSTRUCTION
.—Nothing in this section shall be construed to limit the authority of the Administrator to pursue enforcement action against persons operating model aircraft who en-danger the safety of the national airspace system.
(c) MODEL AIRCRAFT DEFINED
.—In this section, the term ‘‘model
aircraft’’ means an unmanned aircraft that is—
(1) capable of sustained flight in the atmosphere;
(2) flown within visual line of sight of the person operating
the aircraft; and
(3) flown for hobby or recreational purposes.
The policy writers within the FAA will tell you that this regulation is in the name of safety. I would ask you to look into the safety record of model aviation that spans over 100 years. A quick internet search will show less than 100 reports of accidental deaths caused by model aircraft in the past ten years worldwide. By way of comparison, there have been over 1800 gun accidents in the United States this year alone. I give this statistic simply to illustrate the false urgency that the FAA is using to ram through this legislation.
The FAA likes to point to the many reports of interaction between full scale aviation and model aviation; further investigation of these claims show that the statistics used by the FAA are greatly inflated at best. Many of these “drone sightings” later turn out to be false.
Model aviation is not without its dangers. As with any other activity there are risks involved and people can and have been injured. If you look into these events it is frequently the participants that are injured. In the few cases where an airplane has injured spectators the pilot in question has been present to take responsibility. I do agree that there are some irresponsible people doing stupid things with model airplanes. Unfortunately, registering the responsible pilots does nothing to educate the small percentage of irresponsible joy riders.
While I understand the security risk, this also is a concern that has been blown out of proportion. The quadcopter that landed on the White House lawn is a great example of how useless this registration is. Every model aviator I know is very well aware that basically all of the capital is a no fly zone. Do you honestly think that a drunken government worker out for kicks at midnight is going to be aware of a registration requirement?
I do not think the FAA need be abolished as it does serve a very important role in keeping our air travel safe. However, I can’t help but point out that while the FAA has been tilting at the windmill of model aviation 787’s that have been approved for commercial use are catching fire and our air traffic control system continues to slip further and further in to disrepair.
I do ask that you look into containing a government agency that is spooked by imagined visions of hulking boogiemen lurking in dark corners. I also ask you to look into the importance of model aviation to this nation. Many of this nation’s pilots got started in model aviation. Some of our astronauts fulfilled their first dreams of flight with model aviation. Model aviation is the spark that ignites the passion to further the aerospace field that leads to the Moon, Mars, and beyond.
Perhaps it is time for the people within the FAA spend more time, energy, and resources to keep track of what they are actually supposed to keep track of rather than succumbing to their self generated fear.
Thank you for your time and attention in the matter
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