Dear FAA, I need clarification to how these recent redefinition by the FAA on the model aircraft usage applies to my business activities. faa.gov/about/initiatives/uas/media/model_aircraft_spec_rule.pdf Im the owner of a small business in Colorado selling model aircraft kits and parts to the hobby industry for the past 7 years. If I understand the new definitions correctly, every time I fly RC anything I am violating the definition of commercial use of my models because I sometimes profit from my association with the hobby. Who can I contact to clarify these rules pertaining to my business? How do I legally test fly models that I intend to produce and sell? How do I legally demonstrate models I have for sale? Does unpaid flying in organized model aircraft events with models that have my business logo displayed constitute commercial use? Does posting videos of model flights that are using the product Im selling constitute a violation of these new definitions? If I fly inside a building for commercial use, do I need to worry about the FAA regulations? If a third party individual posts a review of my product can they be prosecuted under these new definitions for unauthorized commercial use? Are news reporting agencies that report on drone stories not using the flight records and video for commercial use and thus would need FAA approval before posting the stories? Is it even possible to operate a business in the US in the hobby industry and not violate these new commercial use definitions? How does the FAA plan to regulate commercial use operators based outside the US but selling and promoting inside the US through the internet? It would be unfair to US based businesses if foreign businesses can operate under different rules. If my actions do fall under commercial use how to I get the proper license for me and my customers that promote my products? Theres hundreds of us and we will gladly file paperwork but expect timely response to not hinder the enjoyment of our activities unnecessarily or cause financial losses to the business. When do you want us to start the application process? We are eager to be in compliance to these new definitions. I assume all financial loss associated with commercial operation of models in any form can now be declared as business expenses with the IRS. The IRS rules defining a hobby vs. business will have to be updated to match the FAAs new definitions or it will confuse taxpayers that are hobbyists to no end. Ill make sure all my customers know they should be declaring their hobby expenses on their tax returns if they have flown for commercial use during the year. How does accepting compensation directly or indirectly from model aircraft operation constitute a safety concern vs a flight without compensation deemed as recreation? The publication was unclear on this point but spent several paragraphs trying to explain how our models are Aircraft and under the FAA regulations. This is in despite the Congresss 2012 clarifications that the FAA has no mandate to regulate model aircraft or the recent court cases ruled in the favor of citizens rights to operate a model aircraft without FAA interference. Where do I report the 10s of thousands of individuals and business that are in violations of these rules in Colorado? I can quickly create and automated reporting system with my programming background. I have thousands and thousand of names in my contact lists to report that are in violation of these new definitions. Can you please provide a link to the reporting website so I can start building my Iphone and android reporting apps right away? Im sure my fellow law abiding modellers will be glad to pay a dollar for it so they can report these safety violators more efficiently. I bet we can get a million or more of those violators reported in the next couple of weeks as we will have lots of free time now that we wont be flying while we wait for the license applications to be processed. Maybe selling the app will replace my lost income from the hobby business. Oh, I could also create an app that monitors all the social network sites to find violators to report as well as social network users are compensated for advertising clicks traffic. I wouldnt want anyone profiting from unauthorized commercial use and endanger the airspace . The FAA is going to make a killing with all these $10,000 fines from former law abiding hobbyists that are now violating federal law by FAA declaration. As a good citizen of Colorado Im assuming the FAA provide monetary reward for providing violation tips just like the IRS. To help investigate these violations you will need to hire many new agents. All the out of work hobbyists will be ideal employees as they are experts in the hobby industry and will quickly identify violators. Now that I rethink this, thanks for the great new rules definitions. My new business idea is going to make bank!!! Thanks FAA! Andrew Williams Canuck Engineering Owner
Posted on: Thu, 17 Jul 2014 06:39:55 +0000
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