Receipt/Bill of Sale for Registering with FAA
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GadgetGuy
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This may help with some of the issues that are being faced, and an opportunity to weigh in on them, if anyone is interested:
November 2, 2015 - As many in the US are aware, the FAA and DOT are considering requiring registration of some sUAS and have created a task force to help develop that process.
The DOT and FAA have asked for public input on the issue and have identified 10 specific questions in the document titled "Clarification of the Applicability of Aircraft Registration Requirements for Unmanned Aircraft Systems (UAS) and Request for Information Regarding Electronic Registration for UAS" that can be found at www.regulations.gov/#!docketDetail;D=FAA-2015-4378.
It is our opinion that the rush to create these new rules violates the existing procedures for enacting new rules and also goes against the law set forth in the FAA Modernization and Reform Act of 2012 (Public Law 112-95). That statute included Section 336, “a special rule for model aircraft.” This provision was specifically included to protect the model aircraft hobby and industry from any over-reaching and onerous regulation that might be created in the future by the FAA as the FAA set out to create new rules for large commercial unmanned aircraft. The law exempts recreational model aircraft from any new regulation, instead preserving for our communities their existing historical role of offering safety guidance, pilot instruction, flying site establishment, and event supervision, while preserving the FAA’s limited taxpayer resources for other important regulatory functions.
In our opinion, the FAA and DOT are making new rules while trying to justify them both by saying they are “interpreting” existing rules and by claiming that they are justified under the language of the 2012 law stating that “Nothing in this section shall be construed to limit the authority of the Administrator to pursue enforcement action against persons operating model aircraft who endanger the safety of the national airspace system.” It is our opinion that the current rulemaking attempt of the FAA and DOT specifically violates the FAA Modernization and Reform Act of 2012 by applying new rules not previously required for model aircraft or an aircraft being developed as a model aircraft.
That said, and outside of any legal proceeding to verify our opinion, we feel it is in the best interest of our customers to review the questions and offer comments. It is our opinion that the government website used to allow the submission of comments is limited and cumbersome in its implementation, but we have offered a few suggested comments below that you as our customers are welcome to use as a guideline for your submissions. We suggest you offer your own civil and productive comments as well. We believe model aircraft can be operated safely in the US airspace by enforcing rules already in place. If you use our replies below, you will probably have to save your comments as a document and upload the document to the web site.
Responses must be submitted by November 6, 2015 to be officially considered by the DOT and FAA.
Q1: What methods are available for identifying individual products? Does every UAS sold have an individual serial number? Is there another method for identifying individual products sold without serial numbers or those built from kits?
Model aircraft range from scratch built models made from parts manufactured by the individual to fully ready to fly models manufactured and sold by large manufacturers. In addition, during testing and flying individual models, it is likely that major components will be changed throughout its use. It is unreasonable to expect all these models to have a serial number that will carry from one variation of the model to the next. It is our opinion that there is fundamentally no way to define any major component on a model aircraft that could reasonably be registered. Would a user be expected to serialize every single prototype created during the creative process of making a new model aircraft?
Q2: At what point should registration occur (e.g. point-of-sale or prior-to-operation)? How should transfers of ownership be addressed in registration?
Model aircraft and components are sold by vendors around the world, and international vendors have shown that they have no intention of following US regulations that currently exist. It will place an unreasonable burden on US vendors to expect them to offer any sort of point-of-sale registration for the buyers. Also, relating to the reply of question 1, as major components on a model aircraft are damaged and/or changed, what defines a specific model aircraft will be impossible to determine.
Q3: If registration occurs at point-of-sale, who should be responsible for submission of the data? What burdens would be placed on vendors of UAS if DOT required registration to occur at point-of-sale? What are the advantages of a point-of-sale approach relative to a prior-to-operation approach?
The reply for question 2 applies to this question as well. There is no advantage to asking vendors to have any responsibility for the registration of model aircraft, and any attempt to do so would have an immediate and drastic negative financial impact on all US vendors which have to adhere to any rules created as such.
Q4: Consistent with past practice of discretion, should certain UAS be excluded from registration based on performance capabilities or other characteristics that could be associated with safety risk, such as weight, speed, altitude operating limitations, duration of flight? If so, please submit information or data to help support the suggestions, and whether any other criteria should be considered.
According to the rules already set in place, the Academy of Model Aeronautics (AMA) has procedures in place for various model aircraft sizes and capabilities. Following the FAA Modernization and Reform Act of 2012, only model aircraft not being used or designed for amateur/hobby use and those model aircraft that do not fit into the existing rules set forth by the AMA should be considered for any possible registration requirements, including special provisions for model aircraft over specific weights. Outside if the existing AMA rules, the only other recommendation we have is that model aircraft should be over five pounds to institute any sort of labeling requirement.
Q5: How should a registration process be designed to minimize burdens and best protect innovation and encourage growth in the UAS industry?
It is our opinion that any registration requirements for model aircraft that are included in the current AMA rules and guidelines will violate the FAA Modernization and Reform Act of 2012, add unnecessary burden to the growing US industry surrounding model aircraft, and stifle innovation in the US relating to model aircraft and the sciences related to them. The AMA already has recommendations to place the AMA number on model aircraft. This requirement, which is consistent with the 2012 law, seems adequate.
Q6: Should the registration be electronic or web-based? Are there existing tools that could support an electronic registration process?
It is difficult to imagine any other method of registration given the technology available today. Any registration that would exist should be done electronically through a well-managed web interface.
Q7: What type of information should be collected during the registration process to positively identify the aircraft owner and aircraft?
To answer this question one must assume that the agencies have any right to the personal information of those people who want to operate model aircraft, even minors and those operating small toys. Although it is our opinion that the agencies do not have a right or justified need for this information, if forced to comply, the only information that should be required would be name and mailing address.
Q8: How should the registration data be stored? Who should have access to the registration data? How should the data be used?
This is a much larger question that probably needs to be answered by privacy advocates and attorneys. In our opinion, if the data is taken it should be securely saved on encrypted servers and should only be available to law enforcement under a judge's rule.
Q9: Should a registration fee be collected and if so, how will the registration fee be collected if registration occurs at point-of-sale? Are there payment services that can be leveraged to assist (e.g. PayPal)?
Requiring any fee to be collected for registration will reduce innovation and technological advancement in the US. This would place an unfair burden on those who may barely be able to afford to purchase model aircraft in the first place and may place barriers to continued education and technological advancement.
Q10: Are there additional means beyond aircraft registration to encourage accountability and responsible use of UAS?
We believe enforcing existing regulations and allowing individuals to operate under the guidelines of the AMA are sufficient to allow for safe operation of model aircraft in US airspace. As stated by the AMA, “Model aviation, operated within the safety programming of the Academy of Model Aeronautics (AMA), has an impeccable 80-year track record of operating safely and simply requiring AMA members to now register their aircraft would have no impact on that record.”
Registration of model aircraft would have had little to no effect on the few rogue pilots that have caused concern with the FAA and DOT and would only serve to prevent law abiding citizens from enjoying the freedom and liberty set forth by the US Constitution. Working with the model aircraft industry to help educate those on what defines safe operation rather than taking an adversarial approach to the industry would go a long way to helping to keep the US airspace safe, which is what all of us desire.
November 2, 2015 - As many in the US are aware, the FAA and DOT are considering requiring registration of some sUAS and have created a task force to help develop that process.
The DOT and FAA have asked for public input on the issue and have identified 10 specific questions in the document titled "Clarification of the Applicability of Aircraft Registration Requirements for Unmanned Aircraft Systems (UAS) and Request for Information Regarding Electronic Registration for UAS" that can be found at www.regulations.gov/#!docketDetail;D=FAA-2015-4378.
It is our opinion that the rush to create these new rules violates the existing procedures for enacting new rules and also goes against the law set forth in the FAA Modernization and Reform Act of 2012 (Public Law 112-95). That statute included Section 336, “a special rule for model aircraft.” This provision was specifically included to protect the model aircraft hobby and industry from any over-reaching and onerous regulation that might be created in the future by the FAA as the FAA set out to create new rules for large commercial unmanned aircraft. The law exempts recreational model aircraft from any new regulation, instead preserving for our communities their existing historical role of offering safety guidance, pilot instruction, flying site establishment, and event supervision, while preserving the FAA’s limited taxpayer resources for other important regulatory functions.
In our opinion, the FAA and DOT are making new rules while trying to justify them both by saying they are “interpreting” existing rules and by claiming that they are justified under the language of the 2012 law stating that “Nothing in this section shall be construed to limit the authority of the Administrator to pursue enforcement action against persons operating model aircraft who endanger the safety of the national airspace system.” It is our opinion that the current rulemaking attempt of the FAA and DOT specifically violates the FAA Modernization and Reform Act of 2012 by applying new rules not previously required for model aircraft or an aircraft being developed as a model aircraft.
That said, and outside of any legal proceeding to verify our opinion, we feel it is in the best interest of our customers to review the questions and offer comments. It is our opinion that the government website used to allow the submission of comments is limited and cumbersome in its implementation, but we have offered a few suggested comments below that you as our customers are welcome to use as a guideline for your submissions. We suggest you offer your own civil and productive comments as well. We believe model aircraft can be operated safely in the US airspace by enforcing rules already in place. If you use our replies below, you will probably have to save your comments as a document and upload the document to the web site.
Responses must be submitted by November 6, 2015 to be officially considered by the DOT and FAA.
Q1: What methods are available for identifying individual products? Does every UAS sold have an individual serial number? Is there another method for identifying individual products sold without serial numbers or those built from kits?
Model aircraft range from scratch built models made from parts manufactured by the individual to fully ready to fly models manufactured and sold by large manufacturers. In addition, during testing and flying individual models, it is likely that major components will be changed throughout its use. It is unreasonable to expect all these models to have a serial number that will carry from one variation of the model to the next. It is our opinion that there is fundamentally no way to define any major component on a model aircraft that could reasonably be registered. Would a user be expected to serialize every single prototype created during the creative process of making a new model aircraft?
Q2: At what point should registration occur (e.g. point-of-sale or prior-to-operation)? How should transfers of ownership be addressed in registration?
Model aircraft and components are sold by vendors around the world, and international vendors have shown that they have no intention of following US regulations that currently exist. It will place an unreasonable burden on US vendors to expect them to offer any sort of point-of-sale registration for the buyers. Also, relating to the reply of question 1, as major components on a model aircraft are damaged and/or changed, what defines a specific model aircraft will be impossible to determine.
Q3: If registration occurs at point-of-sale, who should be responsible for submission of the data? What burdens would be placed on vendors of UAS if DOT required registration to occur at point-of-sale? What are the advantages of a point-of-sale approach relative to a prior-to-operation approach?
The reply for question 2 applies to this question as well. There is no advantage to asking vendors to have any responsibility for the registration of model aircraft, and any attempt to do so would have an immediate and drastic negative financial impact on all US vendors which have to adhere to any rules created as such.
Q4: Consistent with past practice of discretion, should certain UAS be excluded from registration based on performance capabilities or other characteristics that could be associated with safety risk, such as weight, speed, altitude operating limitations, duration of flight? If so, please submit information or data to help support the suggestions, and whether any other criteria should be considered.
According to the rules already set in place, the Academy of Model Aeronautics (AMA) has procedures in place for various model aircraft sizes and capabilities. Following the FAA Modernization and Reform Act of 2012, only model aircraft not being used or designed for amateur/hobby use and those model aircraft that do not fit into the existing rules set forth by the AMA should be considered for any possible registration requirements, including special provisions for model aircraft over specific weights. Outside if the existing AMA rules, the only other recommendation we have is that model aircraft should be over five pounds to institute any sort of labeling requirement.
Q5: How should a registration process be designed to minimize burdens and best protect innovation and encourage growth in the UAS industry?
It is our opinion that any registration requirements for model aircraft that are included in the current AMA rules and guidelines will violate the FAA Modernization and Reform Act of 2012, add unnecessary burden to the growing US industry surrounding model aircraft, and stifle innovation in the US relating to model aircraft and the sciences related to them. The AMA already has recommendations to place the AMA number on model aircraft. This requirement, which is consistent with the 2012 law, seems adequate.
Q6: Should the registration be electronic or web-based? Are there existing tools that could support an electronic registration process?
It is difficult to imagine any other method of registration given the technology available today. Any registration that would exist should be done electronically through a well-managed web interface.
Q7: What type of information should be collected during the registration process to positively identify the aircraft owner and aircraft?
To answer this question one must assume that the agencies have any right to the personal information of those people who want to operate model aircraft, even minors and those operating small toys. Although it is our opinion that the agencies do not have a right or justified need for this information, if forced to comply, the only information that should be required would be name and mailing address.
Q8: How should the registration data be stored? Who should have access to the registration data? How should the data be used?
This is a much larger question that probably needs to be answered by privacy advocates and attorneys. In our opinion, if the data is taken it should be securely saved on encrypted servers and should only be available to law enforcement under a judge's rule.
Q9: Should a registration fee be collected and if so, how will the registration fee be collected if registration occurs at point-of-sale? Are there payment services that can be leveraged to assist (e.g. PayPal)?
Requiring any fee to be collected for registration will reduce innovation and technological advancement in the US. This would place an unfair burden on those who may barely be able to afford to purchase model aircraft in the first place and may place barriers to continued education and technological advancement.
Q10: Are there additional means beyond aircraft registration to encourage accountability and responsible use of UAS?
We believe enforcing existing regulations and allowing individuals to operate under the guidelines of the AMA are sufficient to allow for safe operation of model aircraft in US airspace. As stated by the AMA, “Model aviation, operated within the safety programming of the Academy of Model Aeronautics (AMA), has an impeccable 80-year track record of operating safely and simply requiring AMA members to now register their aircraft would have no impact on that record.”
Registration of model aircraft would have had little to no effect on the few rogue pilots that have caused concern with the FAA and DOT and would only serve to prevent law abiding citizens from enjoying the freedom and liberty set forth by the US Constitution. Working with the model aircraft industry to help educate those on what defines safe operation rather than taking an adversarial approach to the industry would go a long way to helping to keep the US airspace safe, which is what all of us desire.
GadgetGuy
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How are the "tips"?
I mean no offense, but you, and every other drone owner, all have the same pipe dream. Everyone with a camera is now a photographer, and everyone with a drone is now is an aerial photographer in their mind. If you, or any one else, is still giving the milk away for free, why should they buy the cow? It's hard to make a business out of something, when the bar to entry is so low, and the difference in your business results are the same or very similar to the other guys, now starting out where you did, shooting for free to promote the industry and their new company. It will all boil down to marketing and sales. Whoever is better at marketing and sales will be more successful than the best aerial photographers who lack those critical skills. However, I still don't see a real business opportunity here. For the cost of your services to any lucrative client, the client can afford to buy their own drone, and have their teenage, video-game-playing son/daughter fly, and shoot for them, for free. The supply is infinite and the paying demand minimal. That leads to prices well below your cost. However, if you or your spouse have a real job, you can write off your business losses against your W-2 income, and have Uncle Sam reimburse some 35% of your drone and equipment costs, while you try for two years!
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I bought my p3p directly from the dji.com website. The FAA considers it an import and requires that I contact the Civil Aviation Agency of China to obtain a certificate of non-registration. Has anyone else been as told they have to submit this documentation? How long did it take to get it back from China?
This is the only reason I'm going through with registration. If I didn't have a reason to do the 333 I wouldn't register, unless I had to. But at least I'll beat the flood of requests if the DO make it a requirement...
GadgetGuy
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This is the AMA boilerplate comment. An individual's personal comment goes a lot further than cut 'n paste comments.
GadgetGuy
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GadgetGuy
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Indeed. Mainly, I wanted to point out the 10 issues they are clearly struggling with. It's an overwhelming task!
I would imagine you will have to follow that guideline and get the information from them. I had to contact my DJI dealer (US Dealer) to have them send me a detailed invoice (including serial # etc). I then completed both forms , a notarized copy of the invoice, a notarized "Explanation" and all were accepted and approved first time through. Took just a hair under 2 weeks from the day I dropped it into the post office until I got the registration card in the mail.
GadgetGuy
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Thank goodness (for them) this isn't the same registration as the "hobbyist" registration. Keep in mind this is for Commercial/333 operations which is a bit more involved and cumbersome. I really REALLY hope that the hobby registration will be a web portal or something like that.Sounds like registering 2 million more will be no problem!
What's going to happen is the FAA is going to
We all hope it will be... I'm sure the people at the FAA are maxed out as it is... why not have it be a web registration and have the "real" people concentrate on other stuff...
We all hope it will be... I'm sure the people at the FAA are maxed out as it is... why not have it be a web registration and have the "real" people concentrate on other stuff...
GadgetGuy
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Well, we don't know that yet...
Could be a problem if they want the same information as this:
"I had to contact my DJI dealer (US Dealer) to have them send me a detailed invoice (including serial # etc). I then completed both forms , a notarized copy of the invoice, a notarized "Explanation" just to get a registration number...
Well, we don't know that yet...
Could be a problem if they want the same information as this:
"I had to contact my DJI dealer (US Dealer) to have them send me a detailed invoice (including serial # etc). I then completed both forms , a notarized copy of the invoice, a notarized "Explanation" just to get a registration number...
I already had the registration #(N#) that was another series of forms LOL! This was merely marrying the registration # (which was "reserved" weeks ago because I wanted a certain #) to the aircraft and issuing a "Registration Card" that has to be with the aircraft (not in it but can be shown upon inspection) at all times. Also my N# has to be displayed on the aircraft in the largest size as is reasonable on (2) sides. It sounds a lot more daunting that it really is but it IS a lot more daunting that it will need to be for hobbyist registration.
GadgetGuy
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Thanks for the clarification. How daunting it is for the hobbyists will largely depend upon whether the ulterior motive is to actually to "get us off the road" so to speak, or just educate us, as they claimed. It certainly won't help them "see" the pilots, as they also claimed!
Perhaps, but as someone who has worked as a mortgage loan officer for over 10 years, I have quite a lot of real estate friends who can't wait to hire me. I have already quoted rates and they are saying that I'm very reasonable. Many would already hire me now if I chose to overlook the guidelines. My goal is to pay off the cost of the drone while having fun. I could have already done that. I have had requests to do weddings and special events. I have been hired as a subcontractor for an online videographer and I have a friend in Florida who has a successful aerial photography company (he has a pilot's license).How are the "tips"?
I mean no offense, but you, and every other drone owner, all have the same pipe dream. Everyone with a camera is now a photographer, and everyone with a drone is now is an aerial photographer in their mind. If you, or any one else, is still giving the milk away for free, why should they buy the cow? It's hard to make a business out of something, when the bar to entry is so low, and the difference in your business results are the same or very similar to the other guys, now starting out where you did, shooting for free to promote the industry and their new company. It will all boil down to marketing and sales. Whoever is better at marketing and sales will be more successful than the best aerial photographers who lack those critical skills. However, I still don't see a real business opportunity here. For the cost of your services to any lucrative client, the client can afford to buy their own drone, and have their teenage, video-game-playing son/daughter fly, and shoot for them, for free. The supply is infinite and the paying demand minimal. That leads to prices well below your cost. However, if you or your spouse have a real job, you can write off your business losses against your W-2 income, and have Uncle Sam reimburse some 35% of your drone and equipment costs, while you try for two years!
I couldn't disagree with you more. Why would someone buy a drone for $1k or more just to get some aerial pics of his house for $50? Money is there to be made. I do this a hobby/side business but I will be able to earn money, as will many others.
GadgetGuy
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Who you know is part of marketing. If you are connected to that network, you have a headstart. Why not accept the work being offered you now? If they are friends, they aren't going to complain to anyone. No offense intended, but $50 for aerial pics of a house are not the lucrative clients I was referring to that would pay big bucks for aerial photography. Large surveying projects or commercial construction projects that could command thousands of dollars in lieu of a real helicopter are the one's I was talking about. As to your $50 for aerial house photos, even at that rate, your real estate friends will eventually decide to buy their own drone, and cut out the middle man. They are already doing that with their real estate listing photos. They just take them themselves, to keep their costs down, in case the listing doesn't sell. Take the money now, before their spouse buys them all a drone for Christmas!
