(Update 6/25/14 – Comments are now open! Use the links below. Share this as widely as you can!
Also, see the AMA’s response letter here)
The FAA has published yet another memo of dubious merit. I have questioned many of the FAA’s interpretations of the regulations since there are currently no regulations specifically for UAS, hobbyist, and other such drones. Now the FAA has attempted to clarify, but in doing so, they have destroyed work previously done by the American Model Association in the interest of hobbyist.
On FPV flying:
people other than the operator may not be used in lieu of the operator for maintaining visual line of sight
Why is this significant? FPV (First Person View) is the fastest growing segment of the hobby. The AMA (Academy of Model Aeronautics) recognizes this and has defined special rules for operating. AMA doc #550 says that the FPV pilot should have a spotter next to them, who will maintain visual line of sight while the pilot has the video goggles on. So essentially the FAA memo has just invalidated that.
On factory pilots, and paid model instructor pilots:
Not Hobby or Recreation :
Receiving money for demonstrating aerobatics with a model aircraft
Why is this significant? The AMA’s insurance policy specifically allows for instructors to be paid to teach how to fly model airplanes. See AMA Insurance Summary here, bullet point #6. In addition, every manufacturer of RC airplanes that goes to one of the several shows like Joe Nall, and flies a demo, is essentially being paid to be there and is a commercial interest. Not to mention to top factory pilots that compete and are compensated by their sponsors.
Link to the original memo (FAA’s site):
How to Comment to the FAA:
You may send comments identified by docket number FAA-2014-0396
using any of the following methods:
• Federal eRulemaking Portal: Go to http://www.regulations.gov and follow the
online instructions for sending your comments electronically. 2
• Mail: Send Comments to Docket Operations, M-30; US Department of
Transportation, 1200 New Jersey Avenue, SE., West Building Ground Floor,
Room W12-140, West Building Ground Floor, Washington, DC 20590-0001.
• Hand Delivery: Take comments to Docket Operations in Room W12-140 of the
West Building Ground Floor at 1200 New Jersey Avenue, SE., Washington, DC,
between 9 a.m. and 5 p.m., Monday through Friday, except Federal holidays.
• Fax: (202) 493-2251.
Example comments you can use:
Copy the below text, and follow this link, and paste it in the form. It will really help if you read through and make some changes to personalize it.
Re: Docket No. FAA-2014-0396
Interpretation of the Special Rule for Model Aircraft
To Whom It May Concern,
I am a model aviation enthusiast and would like to comment on your recent notice regarding flying ‘FPV’ first person view flying as well as the definition of commercial operation.
I am also a member of the AMA – Academy of Model Aeronautics, and follow their guidance for what is safe operation as they have published in previous years. The AMA does allow exchange of money for flight instruction, and I also enjoy seeing factory sponsored pilots perform demos at various conventions. Your notice claims these activities to be illegal.
I also enjoy operating my model aircraft by way of video goggles. The AMA has published their safety guidelines to allow this with use of a spotter that maintains visual line of sight. However, again your notice claims this to be illegal.
In the context of Federal Aviation Regulations, commercial operation of an aircraft should not exclude exchange of money as you have applied it to of model aeronautics. There are many valid reasons for money to be exchanged such as flight instruction (for models), demonstration by manufacturers, as well as simple non-profit compensation by clubs, educators, and similar small groups. This is not for the intent to make a profit, but can help offset costs of an expensive hobby.
FPV flying is an exciting way to enjoy model aviation, and contrary to the FAA’s belief, can enhance the safety of flight be allowing me to see and avoid obstacles such as trees and structures. Restricting flying to direct visual control causes me to judge distances incorrectly. FPV flying also allows me to fly my video camera around in a much more precise way.
I understand that the FAA is working on legislation for UAS and possibly hobbyists, however I feel your interpretation of the existing laws to be flawed, and creating more confusion than safety. I ask that the FAA rescind notice 2014-0396, and allow the AMA to set the standards for what is safe operation.