An open letter to AMA leadership concerning FAA’s NPRM for Remote ID for Drones, in which professional drone pilot and photographer Vic Moss points out why it so important to write your own personal stories, feedback and concerns when you submit your comments to the FAA concerning their strict, overreaching, costly and privacy invading NPRM for Remote ID for Drones. Please do not copy/paste pre-written comments. Vic also points out that a large organization, such as the AMA could have a very strong voice in this debate when their members are instructed properly and are urged to take action. Please read this letter and make yourself heard! Thank you.

Open letter to AMA leadership concerning FAA’s NPRM for Remote ID for Drones

I’ll start this article by saying I wear many hats within the UAS community. And as such, there are times I need to qualify were I’m coming from. And for this article, I’m simply writing as myself, Vic Moss, a commercial drone pilot who is passionate about the UAS industry. And, as a former AMA member who did not renew their membership based on the very reason I’m going to write about. And to a lesser extent, a hobbyist.

Again, the following comments are mine and mine alone. They are not to be considered the opinion of any other group, private or gov’t, that I am associated with.

With that clearly stated, let’s get started…

According to the AMA’s own numbers, there are currently 195,000 members that, with a unified voice that counts, could be the major driving force behind making the changes necessary to protect this industry from the gross overreach contained in the FAA’s Remote Identification Notice of Proposed Rulemaking (RID NPRM).

The AMA has been around since 1936, and has a great history of keeping the skies safe when it comes to the use of model aircraft. And it’s known to all that they have an active role in crafting many aspects of any new regulation that comes from Washington, D.C. and affects their hobby. One simply has to look at the 2012 FMRA, Section 336, and the current H.R. 302, Section 349, to see their handiwork.

It’s even obvious in the current NPRM. The FAA-recognized identification area (FRIA) designation is of their making. Either directly or indirectly.

So it’s pretty obvious that Tyler Dobbs, AMA Director of Government Affairs, has the ear of many in Washington. So we must ask ourselves this, “Why have they shot themselves in the foot when it comes to yet another NPRM?” Once again, they’ve wasted an incredible opportunity.

But let’s back up just a bit.

I know many AMA members, and as mentioned, was one at one time myself. So this is not directed at the membership. As mentioned above, AMA has a long succesful history of advocating for their members. Additionally they have a stellar safety record at AMA events. Their safety programs are tops as well, and if you’re getting into radio controlled model aircraft (but not drones) I highly suggest joining the organization. There are many people at local AMA fields that love flying, and love teaching people about flying. So join, and then find a local flying field and ask for help. I’ll even make it easy, follow this link to join the AMA. If you want to fly r/c aircraft, it will be worth your while!

But don’t bother if you want to get into drones. AMA has made it quite clear in the past that they do not like drones. Although they may have offically softened that stance lately, all you have to do is go to a local field and pull out a DJI or other brand drone to see how many of the local AMA members still feel about us. Odds are great that you will not be welcomed with open arms. And God forbid you pull out an FPV racer. And this is not just my opinion, but one I’ve seen echoed time and time again by many in the drone community. In some cases, drone owners have even be told to pack up and go home. While this isn’t the case in all AMA fields, it is the case in many (if not most). So even as the AMA attempts to officially welcome the multi-rotor crowd, much of the rank and file haven’t subscribed to that stance. And it’s the local rank and file who are the face of the AMA to anyone who goes to a flying field for the first time.

This is even further confirmed if you take the time to go to the RID NPRM comment section here. Not only do you find a multitude of the pointless copy and paste comments already pushed out by the AMA, you’ll also find many probable AMA members (& some self proclaimed long-time members) telling the FAA that they need to separate drones from “real r/c aircraft”.

So what is my main complaint about AMA leadership? The apparent lack of respect for their membership, and their blasé attitude when confronted about this disregard for the NPRM process.

I say lack of respect, because that is the only theory I can come up with about why they continue to have their members simply copy and paste comments. Even after they know it’s completely ineffective. They were even told that this process was NOT recommended when the FAA put out two separate NPRMs on 2/13/19 . Yet they again took that indentical tack with the current NPRM. They seem to want to waste not only the time of their members, but the time of those who will read the comments as well.

And I say blasé attitude because even now the AMA is saying that the pushback they’re getting on social media is because people don’t understand their plan. Mr. Dobbs even heard this very thing last week in Washington. Ask yourselves this AMA, at what point will you accept that when the majority of people are trying to get you to change your tack, they’re actually trying to help? Believe it or not, that’s why I’m writing this article.

And if you don’t want to believe other industry groups telling you you’re wrong, would you be willing you listen to the official Federal Register docket language? If you look at the front page of the RID NPRM docket, you’ll see these very words: “This count refers to the total comment/submissions received on this docket, as of 11:59 PM yesterday. Note: Agencies review all submissions, however some agencies may choose to redact, or withhold, certain submissions (or portions thereof) such as those containing private or proprietary information, inappropriate language, or duplicate/near duplicate examples of a mass-mail campaign.”

That is straight from the RID NPRM Docket page. Maybe you’re relying on the “may choose to redact” part of that Federal Register language. But do you really think that’s in the best interest of the very members you’ve said you’re trying to speak for?

So rather than just b*tch and moan about what you’re doing, I have a suggestion. One I hope you consider. There is still time for many on your membership rolls to submit comments that will actually be counted.

Try this, instead of spoon feeding your members with some chosen words (which are well chosen indeed), just give them talking points. Let your members make personal and heart-felt comments that appeal to the human side of the equation. As I’ve mentioned, I know many members. And to a person, the ones I’ve met seem to be intelligent and passionate people. Let them speak that intelligence and passion into their comments.

And please have your members stick to the NPRM wording. Tell them to quit just telling Congress and the FAA that AMA members and/or fields should be excluded from the rules. That isn’t going to happen. You and I both know that. As does the FAA. The FRIAs are part of the current NPRM process. Claim victory for that, and have your members explain why they are way too limiting as written. Explain how they could work better, and ask why the ARC recommendations were ignored. Have them explain that if the Remote ID final rule comes out as written, it will kill any and all flights outside of FRIAs for the vast majority of your member’s aircraft. And have them ask what the FAA (& other Federal Agencies) were thinking when they said that no new CBO fields will be allowed 12 months after the Final Rule is published.

Trust your members. You have some great people on your membership rolls. Give them the info they need to know, some instructions on how to comment, and then set them free.

Release the voice of your 195,000 members, and let them know that they have it in them to literally save their hobby. And by the way, virtually every commercial drone operator I know also flies under hobby rules. And many commercial Remote Pilots I know are also AMA members. So when your members write stuff like, “Honestly yall can shove it! GPS guided drones and model aircraft are two totally different things!”, or “Model Aircraft need to be fully exempt from this new proposal.”(these are actual comments, obviously from r/c aviators, and likely AMA members), they are not only doing the entire industry wrong, they are also proving to those who will write the Final Rule that there is a great divide in this industry. Not to mention that many of those commenting in a like manner are also stigmatizing many of their fellow AMA members.

And as many historical figures have said, in one iteration or another, “United we stand, and divided we fall.”

AMA, please gather your troops and come alongside the FPV and Commercial/Hobby UAS communities to fight the onerous language in the Remote Identification Notice of Proposed Rulemaking. And please, feel free to cannibalize the Drone U/FPV Freedom Coalition’s RID NPRM comment guide. Read over DJI’s piece on the NPRM, they have some great things to say as well. Additionally,there is a great piece by Christopher Korody in his Dronin’ On blog. Pick and choose your talking points. Get them out to your members.

Because we need your voice. Desperately. Let’s speak as one, figuratively with personal comments, instead of literally with copy and paste comments.

Join us AMA.

Vic Moss

DroneDJ’s take

DroneDJ is pro Remote ID for drones, but not in the way it is currently proposed by the Department of Transportation and the FAA. The FAA’s NPRM for Remote ID for drones is overly restrictive, expensive, and invades the privacy of the drone pilot.

If you want to learn more about the FAA’s NPRM for Remote ID for drones, be sure to read these articles here as well as this Drone Advocacy Kit that has been developed by the Drone U and FPV FC.

And lastly, please be sure to submit your own original comments to the FAA on the Federal Register’s website. Explain to them how these new rules negatively impact your drone hobby and/or drone business before or on March 2, 2020, at the latest!

What do you think about the FAA denying a request to extend the commenting period of the NPRM for Remote ID for Drones? Let us know in the comments below.

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Photos: Vic Moss Photography


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