The FAA should halt the registration of sUAS (Small Unmanned Aerial Systems) pilots for hobbiest Model Aircraft operators.

The Federal Aviation Administration (FAA) is charged with creating and enforcing a regulatory framework for the National Airspace System (NAS) that protects its users. This has been the justification the FAA claimed in promulgating Registration and Marking Requirements for Small Unmanned Aircraft or the Interim Final Rule (IFR) on December 16th of 2015.  

Using public safety as a mantra the FAA has implemented the IFR in spite of 80 years of Academy of Model Aeronautics (AMA) members flying that has not generated significant data that indicates our flying has ever jeopardized the NAS. As such, the IFR seeks to impose legislation on a group of citizens where there is NO demonstrated need.

The IFR also completely ignores the Congressional mandate found in public law 112-95 section 336 that prohibits the administrator from promulgating ANY rule pertaining to Model Aircraft as long as those aircraft are operated per the guidance contained therein. The FAA is in clear violation of congressional direction.

The registration requirements as they stand today, require registrants to sign a document that forces them to consent to rules that have NEVER been part of any formal or legal rule making process e.g. flying below 400 feet.  This makes the FAA guilty of creative rule making by suggestion in violation of the Administrative Procedures Act (APA).

The FAA also violated the APA by failing make the case for need in doing away with formal APA procedures such as the “notice and comment” phase. The FAA's justification includes:

Federal Aviation Regulations (FARs) requiring aircraft registration
The need to educate registrants,  which has never been a function of aircraft registration
A guess as to how many Small Unmanned Aircraft Systems (sUAS) MAY be sold for Christmas 2015
Highly suspect data to show sUAS interference.

In NOT ONE case did the FAA's data demonstrate an example of AMA members involved in NAS interference. The FAA is guilty of overstating the threat and not recognizing those who as a group operate in a fashion that already protects the NAS. Again, the FAA has violated the APA with the IFR.

The FAA is also guilty of obfuscating the term aircraft registration. FAA claims federal precedents require aircraft to be registered. The process itself clearly is a pilot registration process. The FAA has denied this but the facts of the process belie their objections. We as a society recognize the foolishness of sUAS pilot registration for Model Aircraft and wish to craft a reasonable approach to regulating Model Aircraft that addresses their unique properties. We contend that at this point in time there is NO demonstrated need for Model Aircraft regulation.

We find the IFR to be a wholly unnecessary, and costly burden whose only real purpose is to give a public appearance of action on the part of the FAA with little to no value to the taxpayer, but all the attendant costs.

The FAA should halt the registration of sUAS (Small Unmanned Aerial Systems) pilots for hobbiest Model Aircraft operators.