Dear FAA: Model Aircraft Are Not Drones

Dear Pilots: Speak up now!


Sometimes when you set out to fix one problem you create one (sometimes many) more. That’s what I think is happening now as the FAA has said it will not extend the comment period for a controversial program that, essentially, treats model aircraft as drones. As the EAA says, “The rule would require most [unmanned aircraft systems], no matter whether they are ‘drones’ or traditional model aircraft, to carry equipment that identifies the device and broadcasts its location. Additionally, many would be required to be equipped with ‘geofencing’ systems that autonomously contain the craft within a defined altitude and lateral boundary.” Does that sound as crazy to you as it does to me?
Actually, I’m getting ahead of myself.

Remote-controlled model airplane. Photo by John Miller Crawford – Own work, CC BY-SA 3.0.

If I asked for a show of hands among pilots asking how many got into aviation by building model airplanes, and then extending that hobby into flying radio-controlled model airplanes, I expect that well more than half the room would be extending limbs high into the air. I know, because I have asked this question at presentations and meetings all over the country. That, and the observation that just about every hangar or workshop I visit, has radio-controlled airplanes hanging from the walls or ceilings. Modeling is, and always has been, a gateway into full-scale aviation—just read any aviation biography and you’ll find that not only are future pilots born in a little farmhouse, but they got their start building balsa and tissue models.

A scene from KidVenture.

So there is little doubt in my mind that young model aircraft builders and flyers are the future of aviation—its where kids develop an interest and passion for aviation. And passion is important because aviation is not easy and it’s not cheap—you need motivation to get in, and to stay in. What starts as a passion for models becomes a passion for light aircraft, which then becomes a path into the military or the long road through instruction, charter and eventually airline flying. And without pilots flying airliners our entire economy falls off a cliff. The general public doesn’t know this, but they would probably understand if they were told.

That brings us back to the FAA, which has proposed a set of rules that essentially requires registration and ADS-B type installations on model aircraft across the country. This has developed out of work done to regulate Unmanned Aerial Systems (UAS), or drones, over the last decade. The FAA has tried a number of different initiatives to control and regulate drones, yet it is hard to see that much has changed except for a proliferation of rules proposals and some bureaucratic registration systems that have met with mixed results. Sure, many law-abiding citizens have registered their drones and gotten licenses to fly them, but most of the problem drone reports have been caused by those who didn’t. A “bad guy” with a drone simply isn’t going to bother registering it—that’s pretty simple to understand.

The latest proposed regulations are out for comment right now, with a 60-day comment period that started on January 1. So far, in one month, it has solicited 7000 comments—a huge number for a proposal that has hardly been publicized outside of aviation circles.

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It is a draconian proposal that has clearly raised a lot of ire. But it needs to raise more, so the EAA asked the FAA for an extension of the time period to allow more comments. The FAA very abruptly denied this request, saying that they will not allow an extension due to security concerns and the dire nature of the threat posed by drones.

Now folks, let’s take a step back. So far, in 10 years of drone awareness, there have been many reported suspicions of drone strikes on aircraft, yet only one or two that have been confirmed— worldwide. That is far below the number of bird strikes every week. Why do I bring up bird strikes? Well there is little that can be done about them. Yet we, as pilots, clearly accept the small risk because if we didn’t we wouldn’t fly at all. Drones are no different, unless you argue that there are malicious operators out there intentionally trying to hit airplanes with their drones. Sure, that is clearly a possible scenario, but let’s be honest—its pretty darn unlikely. You’d really have to have made an enemy for someone to make that sort of effort to take you out. And if you were going to do that, you certainly wouldn’t register it or let it transmit its ID and position.

So in a 10-year process in which little progress has been made, why suddenly do we need to close comments right now on a proposal that is clearly unpopular? I think I know: Because the longer you leave comments open, the more negative comments you get, and the more unpopular it obviously becomes. Yup, that’s the way it works in government—and as a former federal civil servant, I have a little insight.

This is not meant to paint the vast number of FAA personnel in a bad light—they are, by and large, great people doing good things for aviation. But they are directed by political forces beyond their control. Remember, policy is usually not created by civil servants, it is created by politicians; it’s just implemented by civil servants. When we see obvious bullying tactics by an agency toward the public, that is generally a sign of political pressure not civil servants run amuck. Civil servants aren’t allowed to run the mucks anyway…. (It’s above their pay grade.)

Regardless of your opinions on how drones and model airplanes should be regulated, the bottom line is that if you want to have a say in how your government regulates them, it is time to go make your comments and let your voice be heard! (There are instructions for submitting comments on this page, via email, regular mail, hand delivery, courier and, yes, fax.) Comments are due by March 2, 2020.

No matter how you do it, do it soon. You’re not getting an extension. That has been made abundantly clear.

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Paul Dye
Paul Dye, KITPLANES® Editor at Large, retired as a Lead Flight Director for NASA’s Human Space Flight program, with 40 years of aerospace experience on everything from Cubs to the Space Shuttle. An avid homebuilder, he began flying and working on airplanes as a teen, and has experience with a wide range of construction techniques and materials. He flies an RV-8 that he built, an RV-3 that he built with his pilot wife, as well as a Dream Tundra they completed. Currently, they are building a Xenos motorglider. A commercially licensed pilot, he has logged over 5000 hours in many different types of aircraft and is an A&P, EAA Tech Counselor and Flight Advisor, as well as a member of the Homebuilder’s Council. He consults and collaborates in aerospace operations and flight-testing projects across the country.


  1. Like many of you, I built radio control airplanes back when you had to build them or buy them from someone who had. So much gratification and pride in seeing your hard work take to the air. Not so much like the ARF’s of today’s world. But regardless of what generation you come from, model aviation is History, it is Present, and with all our help it can continue to be in our Future. It is a wholesome rewarding enjoyable hobby spent with good folks of the same interest. What you are witnessing here is the government’s attempt to put yet another nail in your freedom coffin. I understand the FAA’s concern in this matter but they are quick to destroy a good thing that will ultimately result in retaliation instead of cooperation. Not to mention the industry as a whole will ultimately fail. Drones and airplanes are two separate interest groups with different ideals and goals. The FAA must see them as such. Voice your concerns to put a stop to this action.

  2. It’s all about the big money that wants to put last delivery vehicles and air taxis in the air and wants to have the space below 400 feet without any obstacles.

  3. I too enjoyed model aviation prior to my career in aviation. I returned to it a couple of years ago. I can tell you this really is about making the threat bigger than it is so a few rich people can get richer.
    1. R/C airplanes have not been involved in any incident I have read about. It is not a Beyond line of sight vehicle.
    2. There is an alliance of commercial drone operators who want to legally take everyone’s airspace for their own profit.
    3. After years of working with external load operations that require FAA site by site approval you cannot tell me commercial drone operations are safe or that they will get that type of approval for every delivery site.
    4. ALL EXTERNAL LOAD SYSTEMS FAIL AT SOME TIME. A 90lb box is what is approved.
    5. Do you really want a drone landing in your yard with kids playing outside. Be sure they will organize to be insulated from liability.

  4. “but most of the problem drone reports have been caused by those who didn’t.”

    Actually this statement is not true. Most proble. Drone reports are caused by either certificated (the FAA does not issue licenses) and/or registered owners/operators. The problem lies in the fact that there has been excessive effort of oppressive and meaningless regulation and near zero effort in providing standards and opportunities in actual (meaningful) education and training. The Part 107 certificate is and continues to be one of the most failed and problematic things the FAA has ever done.

    Bad people with bad intentions exist in all things… and oddly they are not the problem here. But you are absolutely right, remote ID helps no one and is a violation of everything this country stands for.

    The only acceptable solution is less regulation and more standardized and applicable training and education on a national level.


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