FAA UAS Registration Rule
My 2 Cent Take As An RC Aviator

FAA sUAS Registration - No Drone Zone

Well, I just muddled through the FAA UAS Registration 211 page document in hopes of understanding this nonsense a bit better.

It was far from an easy read and there were lots of "proposed" suggestions that the task force had to consider; many of which were border line insanity, so we can at least be thankful many of the silly suggestions were not adopted and the democratic process was followed with a "smattering" of reason thrown in for good measure.

The 100 mile up view of the FAA UAS registration that went into full effect December 21st 2015 is all sUAS (small unmanned aerial systems - which include all RC aircraft) between the weight of 0.55 lbs and 55 lbs (unless only flown indoors) will require mandatory registration and require the unique registration number to be on the RC model in an easily accessible/view-able area.

You as the RC flier are responsible to obtain registration and the number before ever flying your RC aircraft outdoors. If you are caught flying without registration, FAA may assess civil penalties up to $27,500. Criminal penalties include fines of up to $250,000 and/or imprisonment for up to three years.

This registration applies to all recreational RC aircraft (that fall within the weight range) you own before or after the 21st of December 2015. If you have a vintage RC helicopter or airplane that is 20 years old and you still fly it; yep, you must include your shiny new FAA registration number on it! 

The registration is done on-line. You will get a registration number that is good for all your present and future RC aircraft. The cost is $5.00 USD and every 3 years, you will have to renew your registration (if you are still flying any RC models) and pay another $5.00. Of course, we all know that fee will go up, but at least the FAA is waving the fee until January 20th, 2016 to entice your first time registration. 

This just covers the broad questions I've been getting so far from my visitors. I have a more in-depth Q&A direct from FAA's site at the end of this page. 

FAA UAV Registration

What Caused This?

It's always easy to nay-say any new regulation without all the facts in hand. In other words, I came at this with an open mind.

Yes, like many RC fliers who oppose registration; while I certainly don't like the idea, I wasn't naive enough to think things could continue the way they have been given the level of fear mongering by many in combination with the actions of some very bad RC fliers.

I feel if done right, accountability makes sense, pragmatically at least...

I have been worried about this for the past few years now as more and more newbies take to the sky, some who have absolutely no business being there thanks to electronic flight stabilization help & GPS autopilot enabled flight.

In my RC Drone rant article, I mention exactly why I and others feel this way, and how some of these folks have cast a very negative light on all RC aviation of which most of us "true" RC aviation hobbyists are very responsible folks - many who also fly full size aircraft.

So before going any further, I would like to send a big thank-you out to the irresponsible RC fliers of the world for finally wrecking it for the rest of us! I'm not saying such folks are the one & only cause, but they certainly are very visible catalysts.

There are countless videos I see with self stabilizing mid size or larger qaud or multi rotors with GPS autopilot, going on hero missions, flying well over 1000 feet AGL and more times than not, over high density population areas.

I then see many of them falling out of the sky at terminal velocity when they get caught in a thermal or high level wind and don't have the battery power to safely get back home and land. I also see lots of them crashing into people's yards, houses, and cars for the simple reason the person controlling the thing didn't know what they were even doing.

Now, perhaps those videos realistically represent less than 10% (I sure hope so) of what most quad & multi rotor fliers are actually doing; but with yearly sales in the millions worldwide, that is still a potentially very large number of people doing stuff they absolutely shouldn't be.

I fly one GPS enabled multi-rotor by way of FPV as well (enabling beyond line of sight flight - which by definition is also illegal), but I would never dream of flying it over people or houses. Moreover, I have my hand held aviation radio with me at all times tuned to our local frequency in the rare event a full size aircraft is in the area.

I also would not be upset in the least if I eventually have to register it for a nominal fee. I know the risks involved and I for one appreciate what the FAA is attempting to do.

Where to put the registration number?

Now, please remember, I live in Canada so I'm not directly affected by this new FAA UAS registration rule like all USA RC aviators are; but you know full well, Transport Canada and other aviation governing bodies world wide will very likely adopt similar RC aircraft registration processes in the coming years.

Before going any further with this dry topic, lets watch an entertaining video...

Fear Prompts Legislation
Legislation Generates Confirmation Bias

Perhaps my single largest gripe with this entire process is the fact that certain special interest groups were able to gain enough support through the use of fear mongering and bullying; backing up their positions with nothing but anecdotal evidence, appeals to probability, and rhetoric.

This in my opinion was caused by the continuous and inaccurate use of the word drone, along with main stream media looking to sensationalize any report they get on an incident involving a recreational RC aircraft. Most if not all being easy to fly quad & multi rotors as they best fit what the general public identify as "drones" which of course they are not.

So now RC usage gets regulated and that gives these groups even more power & creditably in the eyes of the general public because they can state things like "RC aircraft obviously pose a threat, otherwise the FAA would not require them to be registered".

This has happened many times when other questionable legislation is hastily pushed through. While the initial idea is good on the surface and seems sound, it can then later be used to give the proponents of the legislation even more of a voice & power by twisting it in their favor. Most likely in this case the inevitable charge that RC aircraft pose a real threat to the general public now that the FAA says registration is required; despite the fact there is no hard data to support such a claim. 

FAA Won't Recognize AMA Membership

AMA Already Doing What The FAA Is Trying To Do

They don't recognize AMA membership at all!?

Yep, even if you only fly your plane, helicopter, glider, or multi-rotor at a sanctioned RC flying field, following all the very common sense aviation rules the AMA has already painstaking adopted, have your AMA # and/or name & address affixed to your aircraft, and are covered by their liability insurance; you still need to pay your 5 bucks and register your RC model with the FAA.

You pay your yearly AMA & club fees, you took the time to learn how to fly correctly, you have a basic understanding of aeronautical physics, you have and can show an understanding of all the systems onboard your aircraft, you have a basic understanding of meteorology, and you fully understand and appreciate the responsibility that comes with the privilege of flying an RC aircraft.

Yet the FAA groups you in with the "unskilled masses" of which many don't even understand the basic principles of lift. What a slap in the face!

Traditional RC airplane and helicopter pilots are not the problem here FAA. We have been flying our aircraft for over 70 years and it has never been an issue for the simple reason we never fly beyond line of sight, and the moment we stop actively piloting our plane, helicopter, or glider - they crash. They have never posed any real threat; past, present, or future!

Only because of advancements in electronics that fully stabilize the aircraft so it can fly well beyond line of site without any input from the pilot, use of GPS for fully autonomous flight, or the use of FPV flying methods, has the line of sight and lack of skill safety net been broken .

How Real Is The RC Aircraft Risk?

RC AS350 RC Helicopter In Wide Open Area & No Spectators Around = No Risk

Speaking of safety nets, just what is the risk here - if any?

There have still been no reported full size aircraft collisions with RC models other than at an actual small RC airshow event where a scale RC airplane (flown by a highly skilled pilot no less only several feet above the ground) was hit by a full size sport bi-plane. The event was being held at a small airport where both RC and full size airplanes were present. Moreover, this had nothing to do with the RC model flying beyond line of site, over 400 feet high, or any special stabilization technology.

Poor communication between the event planner/s is the general consensus of the mishap, and there is no mention (at least none I can find) if there ever was a NOTAM filed for the event. That again falls into the responsibility of the event planners. I suspect there wasn't a NOTAM issued, because the FAA ultimately ruled the RC airplane pilot was the one responsible even though he had full permission to be flying there at the time. The report states he was not maintaining situational awareness. Something I talk about in my FPV writeup.   

Most news and even pilot reports of "near drone misses" are also grossly exaggerated. Near misses reported by the media are almost always distant RC multi-rotor sightings by pilots. In fact, what used to be reported "UFO" sightings are more likely these days to be classified as "drone sightings".

The lack of any evidence (even a simple photo in this day and age where we all have cameras in our phones), is disturbing to say the least. We now live in a fear driven environment where anything seen by a pilot is more than likely reported as a "drone sighting" when there is no evidence whatsoever to back up the claim. It's pathetic!

Worse is the hysteria that follows; to the point several airports have been shut down over conflicting and zero evidence drone sightings.

Of course, with the growing number of quad & multi-rotors taking to the sky every year; eventually a near miss will be exactly that, and no question a few full on collisions will eventually occur based on the law of averages and the irresponsible actions of others.

Still, the numbers will pale in comparison to the many thousands of bird strikes every year, many of which will do much more damage than the vast majority of consumer based ready to fly quad copters that weigh in at under 2 kg.  

That said, I don't recognize the argument that birds cause more damage and collisions and therefore the vast majority of RC aircraft pose little to no threat. While that is most certainly true, I also hope humans that are flying RC models are a little bit smarter than birds when it comes to avoiding full size aircraft.

Yep, I know, some people are obviously not as smart as birds and will go out of their way to cause mischief. Like I said before - a big thanks goes out those that have finally wrecked it for the rest of us!  

Will FAA UAS Registration Really Help The Underlying Problem?

First off, what is the underlying problem?

No matter how it's spun, FAA's primary reason for RC sUAS regulation is to have in place a system to identify, find, and prosecute any irresponsible nut that flies his/her RC aircraft into a manned aircraft or anything else causing property damage, injury, death, or mischief.

In other words, a way to hold someone accountable if they do something stupid. A good idea and I full well agree.

I however don't see that as the primary problem that has surfaced with easy to fly RC aircraft for the masses. What I see to be the single biggest problem is a total lack of education and understanding when it comes to flying an RC model.

In all honestly, I believe the vast majority of newcomers to the hobby simply don't understand the many risks RC Aircraft can pose to others or even to themselves.

Not only that, they may not realize that any time you are up in the air, things can and will fail that will bring down your aircraft. My own personal adage regarding RC flight is...

"When do you know your RC model might crash? Any time it's flying."

Think that way while you are flying, and you really start paying attention to what you are flying near or over. Most also don't understand air currents and what can be going on up there, even when things on the ground are perfectly benign.

I know for a fact, most people who approach me when I'm flying my RC helicopters have no idea at first how complex this hobby can be; they still think in many ways we are flying "toys". That same mindset no doubt is then mirrored as they take to the sky with their own out of box easy to fly quad copter.

If you are in that same "newbie boat", I encourage you to spend some time on the Know Before You Fly website. It's a  great resource and even has a neat little test you can take to see just how much you know about the do's and don'ts of RC flying.

“Make no mistake: unmanned aircraft enthusiast are aviators, and with that title comes a great deal of responsibility,” said U.S. Transportation Secretary Anthony Foxx. “

If this mandatory registration requires the passing of a simple exam like the one above before anyone new to the hobby takes to the sky, then as far as I'm concerned, more than half the battle has just been won.

Informed users will then become your informers, educators, and policing tour de force; just as I have been trying to do on this website & while out flying/instructing for many years now.  

Now what about these Registration numbers on the aircraft? Will having a registration number on a little sub 55 pound RC aircraft that brings down an Airbus A320 (not that it could) really help identify the owner responsible? 

  • 1st - I don't think it's likely that any full ID number will be left on a small RC aircraft after it get disintegrated into hundreds of little pieces after it collides with a full size aircraft traveling at over 200 MPH or is ingested through a turbo fan, propeller, or rotor. No question some will survive lower energy impacts, but even finding the RC aircraft debris would be highly unlikely. 
  • 2nd - Does the FAA really think the bad apples & mischief makers out there that purposely want to cause issues are going to put a registration number on their model - not bloody likely! It is them after-all that have caused all this BS for the rest of us and no way will they ever comply with this FAA UAS registration rule.
  • 3rd, what happens when registration numbers are being falsified and/or stolen? Of course it's going to happen. So your number is stolen somehow by some moron who then flies a qaud copter on a suicide mission bearing your registration number. It's then traced back to you - nice! So anytime you post a picture of your airplane, helicopter, glider, or multi-rotor on-line somewhere, better make sure that registration number is hidden. 
  • Lastly, who will police all this, administer fines, press charges, etc? I'm assuming the idea is any bylaw enforcement or police officer who sees someone outside flying an RC aircraft will have the right to stop and ask to see their FAA registration, and then weigh the craft to see if it's over the 0.55 lb (250g) limit... Ya right! It's not like they have anything better to do with the real problems facing our world right now.  There is simply no practical way to police or enforce this.

These are just a few problems I thought of while reading through the regulations - I'm sure many more will surface.

So what's my suggestion to Transport Canada if they ever blindly adopt a similar RC aircraft registration process, or to the FAA if they ever update and amend theirs?

My first suggestion is obvious - DON'T DO IT! We don't need registration, we need more "real" education.

That suggestion will no doubt be laughed at and there are people out there that will go out of there way to cause negative feedback, so what registration method makes sense, if any?

To me, something like what Transport Canada has in place for Pleasure Water Craft (PWC) operators would work equally well for RC Aircraft operators.  

1. Keep it simple... Go On-line, pay a minimal fee, take the small online course, write and pass your basic RC Aircraft Competency Exam (RC-ACE - love it!), get your certificate card to keep with you, or in your RC Field box, any time you are flying.

It would be nice if your certificate was good for life (again like the PWC example), but perhaps a 3 to 5 year renewal process is a good idea. After all, for many, this is nothing but a year long (or less) passing fad and it makes sense to keep the data base up to date & clean. 

It however might be worthwhile to have an option to pay a "moderately" higher "one time forever fee" for us true RC aviation hobbyists that intend to be buried along side our fleet of RC aircraft.

2. No aircraft numbering required. It's pointless on small RC models because the vast majority don't last long, the numbers can't be seen from the ground or from other aircraft, parts which might have the number are often changed out, and in the event of a collision, the number will likely be rendered unreadable regardless.

Education alone, along with a certificate stating you are competent to operate an RC model, will do way more good than any little onboard registration number ever will. Those who choose to fly in restricted airspace or areas they shouldn't to cause mischief, won't register anyways or will use stolen registration numbers to get others in hot water.

3. Recognize AMA or MAAC membership numbers as equally suitable alternatives to your registration number. Better yet, if the AMA or MAAC wishes, build the price of the FAA or Transport Canada UAS registration fee into your membership, and then let the "all knowing" feds deal with the administrative nightmare of assigning UAS registration & numbers to all your members and their aircraft, freeing your administrator's time up immensely ;-)

Anyways, I'm sure people an order of magnitude smarter than I am already suggested such simple ideas to the FAA and were ultimately shot down. I have no doubt the "language" of this new FAA UAS registration rule will change and evolve as they experiment with how it works/doesn't work over the next several years and start to realize the administrate workload involved.

I just hope it doesn't make it easier for special interest groups to further restrict our benign fun, by twisting and cherry picking this now existing legislation to support their cause.

I personally think registration should only apply to any RC model that has automated flight stabilization, GPS, waypoint, or is flown by means of FPV. Basically any technology that allows sustained beyond line of sight RC flight. Problem is, that cool stuff can all be added or removed afterward to most hobby grade model aircraft, so there is no practical way to monitor it.

Like it or not, RC aircraft registration is here. Now more than ever, it's RC pilot's world wide responsibility to educate both newcomers to the hobby & the general public; while promoting the hobby in a safe, responsible, and professional way.

Like I mentioned before, there were some real wacky ideas proposed to the FAA regarding recreational RC flight. Now that this legislation is in effect, those same insane ideas will be that much easier to amend additional restrictions.

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