Says Overall, Rule Is A 'Positive First Step' But Says Model Aircraft Should Be Exempt From Part 107

The Academy of Model Aeronautics (AMA) has submitted formal comments to the FAA on the NPRM for FAR Part 107, which would regulate unmanned aerial vehicles (UAVs).

"Overall, the AMA views the proposed sUAS regulations as a positive first step. And, the Academy believes the proposed rules in the new Part 107 are an important and appropriate approach to enabling the rapidly emerging and highly beneficial unmanned aircraft industry," the advocacy group said in its formal written comments.

"It’s important to note that the integration of sUAS into the National Airspace System (NAS) should be seamless and should not impede existing manned aircraft operations or create additional requirements for position source and/or navigational equipment. Manned aircraft associations such as the Experimental Aircraft Association (EAA) have made significant strides with the FAA regarding their “Equip 2020” ADS-B Out mandate. This cooperative effort has recently allowed new and affordable options for FAA-compliant ADS-B equipment to be introduced into the marketplace. The introduction of sUAS does not justify further equipment requirements for GA aircraft. AMA shares the views of the manned aviation community in terms of equipage and stresses the importance of maintaining the current timeline and requirements for ADS-B."

The AMA said it supports the exemption of model aircraft from the regulation for unmanned aircraft systems. "As Congress recognized in its Special Rule for Model Aircraft, self-governance under community-based safety guidelines has worked exceptionally well for decades, and should remain in place. However, in the preamble to the proposed rule, the FAA has repeated its June 2014 statement that model aircraft are "aircraft" subject to all existing aviation regulations. The Academy has taken exception to this stance as well as several other elements of FAA’s interpretation of the "Special Rule for Model Aircraft."

But the Academy says that the FAA "must revise this interpretation so that it is in agreement with what Congress directed in 2012, specifically that recreational model aircraft are subject to community-based safety guidelines, not aviation regulations."

The Academy also says that limiting use of model aircraft and UAVs and to individuals age 17 and older leaves out the vast majority of the youth in the K-12 educational system. "FAA must make it clear that model aircraft and recreational UAS can be used under the hobby rules as a tool for teaching STEM curriculum," they said.

(Images from file)

FMI: Full Comments document