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Written by Tyler Dobbs
AMA comments on the ruling
AMA In Action Advocating For Members
As seen in the May 2019 issue of
Model Aviation.


external marking requirement

external marking requirement

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See how to mark your aircraft by visiting amablog.modelaircraft.org/amagov/2019/02/27/faa-registration-renewal-and-marking-your-aircrafts.

ON FEBRUARY 15, 2019, the FAA posted a rule in the Federal Register requiring all unmanned aircraft owners to display their FAA registration number on the outside of an aircraft. UAS operators may no longer place registration numbers in an interior compartment of the aircraft. The rule went into effect on February 25, 2019. In response to this Interim Final Rule, AMA submitted the following public comment:

"The Academy of Model Aeronautics (AMA) represents nearly 200,000 model aircraft hobbyists across the country. Founded in 1936, we are the nation’s largest organization representing those who fly model aircraft for recreational and educational purposes. For years, our National Model Aircraft Safety Code has been recognized by Congress, as well as state legislatures, as a safe and effective means of managing model aircraft hobbyists. Our members know where, when, and how to fly safely and they do not pose any new risk to the airspace.

"Since 2015, we have participated in the Federal Aviation Administration’s (FAA) efforts to establish a registration rule for small unmanned aircraft systems (UAS). We have long held that federal registration of UAS makes sense at an appropriate threshold of weight, capability, and other safety-related characteristics. However, we continue to believe that federal registration should not apply at such a low threshold that it includes toys. Most importantly, it should not burden model aircraft hobbyists who have operated safely and harmoniously in our nation’s skies for decades.

"AMA members already comply with AMA’s own registration system. When joining AMA, members provide personal identification and contact information, and affirm that they will abide by AMA’s safety guidelines. Members are instructed to place their membership number or their name and address on or within their aircraft. Over the years, this has proven to be an effective means of linking and identifying the owner-operator of a model aircraft to his or her platform.

"Our members know where, when, and how to fly safely and they do not pose any new risk to the airspace."

faa to consider a waiver process

"Although the interim final registration rule is duplicative for AMA members, we have complied. Most AMA members already have their FAA registration number posted on the outside of their aircraft. Unfortunately, for some of our members, including the small percentage of AMA members who fly scale replica model aircraft, the interim final registration rule creates a significant burden. For these AMA members, affixing an FAA registration number on the external surface of the aircraft diminishes the accuracy of the scale replica model. The accuracy of the model is critical because it is the primary factor by which these models are judged in competitions nationally and globally.

"AMA understands and appreciates the intent behind the interim registration rule’s requirement to affix the FAA number on the outside of the aircraft. In no way do we want to create safety risks for law enforcement officials or first responders who might be tasked with opening a compartment on a model aircraft to find a registration number. However, we do not believe that model aircraft create any new risk.

"… we urge the FAA to consider a waiver process for our niche community of responsible hobbyists who have been flying safely for years."

"Given the relatively small number of scale replica in the airspace today, we urge the FAA to consider a waiver process for our niche community of responsible hobbyists who have been flying safely for years. Just as in the full-scale aviation community, there are exceptions to exterior aircraft marking. A waiver process will ensure that passionate and law-abiding scale replica modelers have an opportunity to continue their beloved hobby without interference.

"We look forward to continuing to work closely with the FAA regarding recreational small UAS operating requirements. As always, we are committed to ensuring the safety of our nation’s skies for all."

New Requirements for Recreational Users

AMA continues to work closely with the FAA to implement Section 349, the new operating requirements for recreational users. Although no new requirements had been put in place at the time that this article was written, we do expect the FAA to begin implementing portions of the new requirements soon.

AMA will continue to work on solutions that we hope will minimalize the impact that Section 349 has on our members. We will be sure to update our members with any new changes.

AMA’s most recent meetings on Capitol Hill focused on updating various committees and legislators on the implementation process and the impact burdensome regulations would have on our members and the hobby. When the new operating requirements were passed, the FAA assured AMA that the new rules would not prove overly burdensome for our community. Because of these assurances, AMA will continue to update Congress throughout the process.


12 comments

As I interpret the regulation, the FAA number on a model only needs to be affixed when flying the UAS. Perhaps an easily mountable / removable id tag would suffice for scale aircraft static judging, or a duplicate part that can be substituted on the aircraft (even a tire/wheel would work) when flying. Alternatively, since the impact on judging is the main concern for scale competition events, perhaps the FAA would accept the owner/flyer of the aircraft in question putting the FAA information on a sanctioned event application form and a copy being retained or forwarded to the FAA.
Again, the FAA number is only required for flight, not just ownership or display, so there are ways around the rule for those concerned about the negative impact of having the number on the aircraft. Personally, I use a label printer to print both my AMA and FAA number in the smallest type available and affix it to an inconspicuous place on the aircraft (usually under the horizontal stabilizer - where full scale id plates can often be found). It meets the requirements of the rule and I never see it unless I look for it.

Your link: air.modelaircraft.org/updated-faaregulations. doesn't work.

It would be convenient to publish on the step by step process of FAA Model Registration, as I have been asked if the AMA Registration is sufficient, which is not, also another question, is it necessary to register each model owned to have its exclusive registration number so a printed guideline would be convenient for most all the membership.

Exactly where does an AMA member get an FAA registration number?

Hi William. You receive your FAA registration number with you register with the FAA. You can do this at www.faa.gov/uas.

I hate to sound pessimistic. However, has the FAA made any concessions, other than recognizing our organization? It seems to me that every time we suggest or request a concession from the FAA, the answer is either no or some off the wall response. If I display my AMA number and contact info, why is displaying my FAA number on the exterior of my aircraft necessary. What is the FAA's reasoning for such a requirement?

I have several planes that I have built and because of AMA membership I chose to make my AMA number a part of my aircraft. I post the number on the outside near the tail to look like a registration number inside our club had posted the number, name and address of owner. why can't the FAA. just use our AMA number? Not a problem for me even on scale war birds I just post it on the outside near tail to look like a buro number.

And this new external I.D. requirement, does what exactly? How does this add any real "security" in any way? In the event that a first responder was really in harms way, do you think any criminal would really put his/her real information outside that would identify themselves?

What are your thoughts on this Circular released on 5/31/2019?

"Starting July 19, 2000, the Commission will begin implementing the Commission Registration System (CORES). CORES is a registration system for entities filing applications or making payments with the Commission. CORES will assign a unique 10-digit FCC Registration Number (FRN) which can be obtained both on-line and manually. Over time, the FRN will be used by all Commission systems that handle financial, authorization of service, and enforcement activities. The use of the registration number is voluntary, although the Commission will consider making it mandatory in the future."

The above paragraph, which starts the explanatory text of a Federal Communications Commission announcement entitled "NEW COMMISSION REGISTRATION SYSTEM (CORES)
TO BE IMPLEMENTED JULY 19" and bearing FCC "document no.DA00-1596", marked the initial presence of a "registration system" pre-dating the FAA's own by some 15 years, that could have been required by a Federal agency dealing with aeromodelers - one for every single FCC radio service licensee.

As I'm an FCC Amateur Radio Service licensee of just over four decades of time, a so-called "FRN", or "FCC Registration Number", of ten digits long (no letters!) exists on my Amateur Radio Service license in its lower-left corner. The paragraph starting this reply DOES contain a provision (as its concluding sentence) that: "The use of the registration number is voluntary, although the Commission will consider making it mandatory in the future."...

...something that DOES sound exactly what the FAA's already asking us to do, BUT...the FCC beat them to it by over a decade's worth of time, for its OWN licensees, which can include any AMA members flying RC aircraft on either six meters (50.8-51 MHz VHF) on fixed frequencies; or on the low-UHF 70 cm/433 MHz band, which fly within an already-well-established Amateur Radio Spread Spectrum radio technology environment in the 70 cm UHF band only.

As I want to "primarily" be known on ANY such "FAA-mandated" placard of any sort as a Ham-licensed RCer through the FCC above all else, my planned five-line placard for FAA ID needs on RC model aircraft has its quintet of lines of text reading thusly:

1st line: The words "AMATEUR RADIO SERVICE"
2nd line: My amateur radio callsign
3rd line: My ten-digit FCC Registration number (beginning with "FRN", then the 10 digits)
4th line: The license class of my FCC Amateur Radio Service license
5th line: The ten-character FAA "registration number", only AFTER the FCC info has been given.

In addition, the FCC's logo is shown prominently at extreme left, as a three-line high sized logo, with only the first line's text above it, and the (Aux ID) status of the FAA registration being "below" it (as the placard's fifth line), as being less of a firm determinant when compared to the given FCC information in the previous four lines of text on the placard.

This placard only has text that's 1/8", or 3.2mm high, with a placard that only measures 2-9/16" long by a hair over 15/16" high, and which for RC Scale models I'll be building in time, can be placed on an open cockpit's "pilot platform" and plainly visible from an exterior view, WITHOUT having to open anything.

The main goal of prioritizing the display of the info connected with my FCC Amateur Radio Service license is that; as an FCC Amateur Radio Service licensee under FCC Part 97.215, RC flying is legally undertaken by FCC-licensed Hams on Amateur Radio Service bands; that the FCC already HAS a "registration number" system established for eventual "mandatory" use and has had this system in existence since the very beginning of the 21st century; and that I'd most likely be strictly sticking to using the FCC's Ham bands for all (or as much of it as possible) of my own RC flying as, per FCC Part 97.113, is strictly for recreational purposes, exactly as Amateur Radio itself, even when aeromodeling is not involved in any way, is itself intended to be.

i am an 82 year old modeler who has ben flying model planes for fifty years and i have NEVER
INJURED OR DAMAGED ANYONES PROPERTY except my own (a few crashes here and there), if a modeler puts his faa number inside of his plane he would have to open the hatch, canopy or inspection plate to show his number there by being the first person to receive any damage
from an existing hazard such as an explosive device (i assume that this is what the faa is afraid of). further more, techenally we could fly at ANY airport since we are considered an airplane with an fcc number.

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