President's Perspective - 2010/04
Model aviation has faced its share of challenges throughout the years.
Past challenges
- Urban sprawl threatening good, established flying sites.
- The scrutiny that model aviation, as well as a number of other activities, came under after the attacks of 9/11.
- The decades-long battle to obtain and retain frequencies set aside for aeromodeling.
AMA has risen to each of these challenges and continues to work diligently to ensure that these types of potential threats to model aviation remain minimal.
FAA rulemaking and the ARC
In the next few years, model aviation may be facing its greatest challenge. The proliferation of companies in the United States developing small unmanned aircraft systems (sUAS) has grown exponentially. The result of these companies' efforts to build sUAS for the public-use commercial environment has required the FAA to create regulations governing how sUAS will interface with the National Airspace System (NAS).
This regulatory process began in early 2008, when the FAA's Acting Administrator issued an Executive Order creating an Aviation Rulemaking Committee (ARC). The ARC comprised more than 20 members, and AMA's government affairs representative was selected to represent model aviation and the Academy.
The charge of the ARC, as outlined in the Executive Order, was to draft recommendations that would be used as a basis to regulate the use of commercial sUAS in the NAS. Additionally, in its only reference to model aviation, the order instructed the ARC to "define a model aircraft."
The ARC completed its work in March 2009 and submitted its recommendations to the FAA. Despite the straightforward directive established in the Executive Order, the administrative interpretation and execution of the order went well beyond simply defining model aircraft. The ARC report included recommendations that would potentially regulate the operation of model aircraft in the NAS.
At the January 2010 AMA Executive Council meeting in Muncie, Indiana, two representatives from the FAA attended to update the council on this ongoing process. Attending were James Sizemore, acting manager of the Unmanned Aircraft Program Office (UAPO), and Steve Glowacki, the sUAS rulemaking lead who also works out of the UAPO. They provided a lengthy overview of the regulatory effort and answered a number of questions from council members.
James and Steve sincerely want to integrate model aviation into the new regulations in a way that will have minimal impact on what we do as model aviation enthusiasts. They have a difficult job to do and it's apparent that, in some cases, there will be no easy answers.
A simple analogy that became evident during their presentation was that we may be trying to put the square peg of model aviation into the round hole of regulations intended for public-use commercial sUAS. This approach won't work. It could potentially harm aeromodeling and negatively affect a larger-than-perceived industry that is part of the model aviation community.
Key differences: model aviation vs. commercial sUAS
The primary visual flight rule under which all aircraft, including model aircraft, operate in the NAS is "see and avoid." This premise has worked well. Using this as our principal guideline, model aviation has an impeccable safety record. Based on the number of estimated flight hours flown by model aviation enthusiasts, model aviation is one of the safest, if not the safest, activities that take place in the NAS.
So what has changed? What has occurred that has now drawn attention to model aviation—a purely recreational activity? The answer is simple: public-use commercial sUAS. There are some huge differences between the two types of aircraft:
- Purpose: Modelers fly for recreation at flying fields, parks, soccer fields, or dedicated facilities. Commercial sUAS are often flown in metropolitan areas for purposes such as real estate photography, surveillance, or other revenue-generating activities.
- Operation: Modelers operate within established flying-field confines and community norms. Commercial operators may seek to fly beyond those confines to serve clients.
- Technology and flight rules: Public-use commercial sUAS are generally autonomous or remotely piloted for commercial missions and often are not designed to operate using "see and avoid" techniques. They may rely on "sense and avoid" technology, which is still being perfected and, even when mature, may not meet the standard set by see and avoid.
There's nothing wrong with commercial uses of sUAS; it's just not what model aviation does. We shouldn't be affected by the collateral impact of the FAA's need to regulate commercial sUAS.
AMA's response and next steps
AMA agrees that modelers have an obligation to operate safely in the NAS. AMA's safety guidelines have helped ensure the excellent track record we currently have. We will continue to work closely with the FAA to ensure that model aviation remains a safe activity, just as it has for more than the last seven decades. The best way to do that is to find a way to modify the round hole so that it fits the square peg, not the other way around.
As the regulatory process evolves, AMA will continue to keep our membership updated on its progress. For those who would like to learn more, we have created a section pertaining to this issue on the AMA website: www.modelaircraft.org/news/ama-faa.aspx.
During the last two-plus years, AMA has done much to improve its efforts to advocate for our members. We recently took another giant step in that endeavor: AMA has engaged the services of a political strategist in Washington, D.C.
AMA, as a non-profit, member-based organization, is allowed to lobby but must work within tight restrictions to maintain its 501(c)(3) status. The firm that we have contracted comes highly recommended and works for entities in the aviation and communications industries. This was important to AMA because much of our efforts focus on working with the FAA and FCC. The relationship we're building will help position us in the legislative arena and address any legislative issues that could impact model aviation in the future.
See you next time ...
Dave Mathewson AMA President [email protected]
Transcribed from original scans by AI. Minor OCR errors may remain.
