Model Aircraft Rules


Jonathan Rupprecht

Mr. Rupprecht is an aviation attorney who focuses on drones. Read more about his background as a commercial pilot, flight instructor, Embry-Riddle Aeronautical University grad, and legal author. He has had media appearances on Forbes, Newsweek, Politico, NPR, Marketwatch, The Independent, Motherboard, and other sources. Feel free to send Jonathan a message here.

Rupprecht Law’s Analysis of the FAA’s New Educational Use Exception for Drones

drone-law-education-teacher-professor-schoolUPDATE:  On August 29, 2016, Part 101 went into effect. Part 101 is essentially just a copy-paste of Section 336.  It is currently being challenged in a lawsuit up in the D.C. Circuit Court of Appeals.

The FAA announced on May 4, 2016 in a memorandum some helpful changes regarding the use of UAS in education.

The reason why this memo was created was that many universities were wanting to offer classes where students would be required to fly the aircraft. This brought up questions such as “does the university need a Section 333 Exemption?” or “does the student need a pilot license?” There were also spin-off questions such as “can we teach the local 4-H, Boy Scouts, etc. about drones?”

The FAA summed it up in three points:

  • A person may operate an unmanned aircraft for hobby or recreation in accordance with Section 336 of the FAA Modernization and Reform Act of 2012 (FMRA) at educational institutions and community-sponsored events[1] provided that the person is (1) not compensated or (2) any compensation received is neither directly or incidentally related to that person’s operation of the aircraft at such events;
  • A student may conduct model aircraft operations in accordance with Section 336 of the FMRA in furtherance of his or her aviation related education at an accredited educational institution;
  • Faculty teaching aviation-related courses at accredited education institutions may assist students who are operating a model aircraft under Section 336 and in common with a course that requires such operations, provided that the student maintains operational control of the model aircraft such that the faculty member’s manipulation of the model aircraft’s controls is incidental and secondary to the students (e.g. the faculty member steps in to regain control in the event the student begins to lose control, to terminate flight, etc.)

Section 336 of the FMRA says:

(1) the aircraft is flown strictly for hobby or recreational use;

(2) the aircraft is operated in accordance with a community-based set of safety guidelines and within the programming of a nationwide community-based organization;

(3) the aircraft is limited to not more than 55 pounds unless otherwise certified through a design, construction, inspection, flight test, and operational safety program administered by a community-based organization;

(4) the aircraft is operated in a manner that does not interfere with and gives way to any manned aircraft; and

(5) when flown within 5 miles of an airport, the operator of the aircraft provides the airport operator and the airport air traffic control tower (when an air traffic facility is located at the airport) with prior notice of the operation (model aircraft operators flying from a permanent location within 5 miles of an airport should establish a mutually-agreed upon operating procedure with the airport operator and the airport air traffic control tower (when an air traffic facility is located at the airport)).

 

There needs to be one point of clarification on this section in that Section 336 is focused on the FAA, not the public, and tells the FAA that they “may not promulgate any rule or regulation regarding a model aircraft, or an aircraft being developed as a model aircraft” if a model aircraft[2] is meeting all the 5 elements above. The FAA has misapplied this section repeatedly, most notoriously in the recent registration requirement which is currently being sued over by John Taylor and me in the D.C. Circuit. A lengthy blog post on 336 and the registration regulations is here.

The FAA is redefining its interpretation of “hobby or recreational use” as found in Section 336 as “to include operation of UAS to conduct demonstrations at accredited educational institutions or at other community-sponsored events provided the aircraft is not being operated for compensation, in furtherance of a business or incidental to a business.”[3]

UAS Demonstrations

Hobbyists or enthusiasts can fly at an “accredited educational institution or other community-sponsored events to promote the safe use of UAS and encourage students’ interest in aviation as a hobby or for recreational purposes provided the hobbyist receives no compensation of any kind (honorarium or reimbursement of costs), or any such compensation neither directly or indirectly furthers the hobbyists’ business or operation of the UAS.[4]

Keep in mind that the last portion is very broad. If you think this might apply to you, the work around is to just do demos inside a completely enclosed building and avoid all these legal gymnastic problems.

Student Use

The FAA went on to say that just because a student learns about the knowledge of flight does not make the flight not hobby and recreational when they will use that knowledge to get a degree.[5] The link between knowledge, to degree, to job is just “too attenuated” to be considered outside of hobby or recreational use.

The FAA concluded that UAS flying for “students at accredited educational institutions as a component of science, technology, and aviation-related educational curricula or other coursework such as television or film production or the arts more closely reflects and embodies the purposed of ‘hobby and recreation[.]’”[6]

If the student receives any reimbursement for costs or an honorarium then that is NOT hobby and recreational; however, a student may receive financial aid, participating in a work-study program, or being a paid research assistant to a faculty member teaching the course.[7]

Faculty Use

Faculty teaching a course or curricula that uses unmanned aircraft as a component of that course may provide limited assistance to students operating the unmanned aircraft” without changing the student’s hobby and recreational classification or the need for the faculty to obtain FAA authorization.[8]

This limited assistance exception is only where the UAS operation is secondary in the course; however, if UAS operations is the primary reason for the course, the faculty member would need authorization, but the student, as defined above, would not.

If you are an accredited institution interested in obtaining a flight instructing exemption, to date there has only been one exemption ever granted for public flight instructing. Keep in mind that if an educational institution obtains a Section 333 Exemption, they can flight instruct their own faculty because the new 333 Exemptions say, “All training operations must be conducted during dedicated training sessions and may or may not be for compensation or hire.”

It is NOT considered hobby and recreational for a faculty member or assistant to operate a drone as part of their professional duties. Additionally, a professor cannot do a “work around” and get the students to fly the drone for purposes of the faculty member’s professional research objectives.

When Does a University’s Class/Operations NOT Fall Into This Exception?

  • Faculty operating the drone for research and development
  • Faculty supervising students doing research and development using a drone
  • UAS flight instruction where the faculty instructor is actively involved in the operation (not incidental and secondary); however, just teaching without touching the controls would be fine. (Think of it like the faculty is the air traffic controller teaching the student how to land the aircraft.)

Problems I See:

Will the FAA continue to honor this Pre-Part 101 memo? 

Part 101 is really a copy-paste of 336. The FAA MAY continue to honor it but also might change their mind as time goes on. Interpretations are NOT the law, but the FAA’s view on how to follow the law. Nothing locks this interpretation in stone. They can easily switch it up on everyone tomorrow.

Does the Model Aircraft Have to Be Registered?

Nothing is said in the memo about whether the aircraft must be registered or not. This is most likely an oversight on the FAA’s part since they have been campaigning hard about the need for all aircraft 250 grams or above to be registered.

The FAA’s interpretation of Section 336 is that it prohibits the specific regulation of model aircraft, not the regulation of all aircraft as a whole like it is some sort of civil rights for drones equal protection clause which does not in any way work with the meaning of “special” in the title to Section 336. In other words, how are model aircraft special (as indicated in title of 336) if model aircraft are required to be treated like everyone else?

Are Model Aircraft Special or Not?

There is something seriously incongruous with the FAA’s view of Section 336 and how Section 336 actually reads. The FAA seems to view 336 as a means of allowing model aircraft flights without “authorization”[9] when in reality it is specifically addressed at the FAA telling them to not create any rule or regulation governing model aircraft.

Setting Educational Institutions Up for Failure?

The FAA said, “If an unmanned aircraft is operated as a model aircraft in accordance with the above, then it does not require FAA authorization.” Is there anything else they should do besides authorization? Any operating rules, etc.? This becomes problematic because some of the educational institutions are right NEXT TO AIRPORTS! Furthermore, some are in D.C. right smack dab in the SFRA or FRZ!  For example, Massachusetts Institute of Technology is within Logan’s Class B airspace and George Washington University is within the FRZ. Can MIT students merely notify Logan’s tower and manager in accord with 336 and fly? Wouldn’t that also violate the FAA’s current view that ALL regulations in Part 91 apply to unmanned aircraft such as the requirement to get clearance prior to entering Class B airspace?[10] If you are an educational institution reading this, you definitely need an aviation attorney on your team to help you navigate this area.

FPV Flying

The FAA in their 2014 policy interpretation on the model aircraft rules indicated that FPV racing would NOT fall within Section 336’s definition of model aircraft.[11] An interesting point here is the Federal Aviation Regulations require the pilot to “see and avoid” other aircraft[12] and Section 336 defines the model aircraft as being “flown within visual light of sight of the person flying the aircraft.”[13] This all logically follows that the FAA’s interpretation would be that FPV racing, while possibly permitted under this interpretation, would NOT be permitted under their model aircraft interpretation from 2014 since it would not be considered a “model aircraft” for purposes of Section 336.

Summary

If you an educational institution getting into this area, I would highly suggest you seek out competent aviation legal advice. I created a large article on drone law for educators which talks about Section 333, Part 101, and Part 107 with regards to educators, universities, etc.

When shopping around for legal help, consider the background of the attorney and if they have any experience because………Posers will keep your program grounded while an attorney who is a pilot will help it soar.

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[1] This would include “demonstrations at schools, Boy or Girl Scout meetings, Science Club, etc.” Page 1.

[2] (c) MODEL AIRCRAFT DEFINED.—In this section, the term ‘‘model

aircraft’’ means an unmanned aircraft that is—

  • capable of sustained flight in the atmosphere;

(2) flown within visual line of sight of the person operating

the aircraft; and

(3) flown for hobby or recreational purposes.

[3] Page 3.

[4] Page 3.

[5] Page 4.

[6] Page 4.

[7] Footnote 9 on page 4.

[8] Page 5.

[9] Page 3.

[10] 14 CFR 91.131.

[11] “The FAA is aware that at least one community-based organization permits “first person view” (FPV) operations during which the hobbyist controls the aircraft while wearing goggles that display images transmitted from a camera mounted in the front of the model aircraft. While the intent of FPV is to provide a simulation of what a pilot would see from the flight deck of a manned aircraft, the goggles may obstruct an operator’s vision, thereby preventing the operator from keeping the model aircraft within his or her visual line of sight at all times.” Footnote 2 on Page 8-9 of https://www.faa.gov/uas/media/model_aircraft_spec_rule.pdf

[12] 14 CFR 91.113.

[13] Pub. L. 112-95, Section 336(c).


Jonathan Rupprecht

Mr. Rupprecht is an aviation attorney who focuses on drones. Read more about his background as a commercial pilot, flight instructor, Embry-Riddle Aeronautical University grad, and legal author. He has had media appearances on Forbes, Newsweek, Politico, NPR, Marketwatch, The Independent, Motherboard, and other sources. Feel free to send Jonathan a message here.

Two Ways the FAA Can Immediately Help Promote Drone Safety in the National Airspace System

 

Since the House Subcommittee on Aviation is having a hearing on October 7th on “Ensuring Aviation Safety in the Era of Unmanned Aircraft Systems,” I was inspired to write about two things that the FAA can do to immediately promote drone safety.

The FAA can (1) put all the recreational aircraft guidance down in one place and (2)  get FAA certificated pilots involved in the industry.

 

(1) Put Everything Down in One Place.

The FAA has issued advisory circulars and guidance on small unmanned recreational aircraft since 1981.  Over the years the message has not been consistent and at times even contradictory. To illustrate the inconsistency and contradiction, I have compiled this chart on recreational aircraft guidelines. The FAA published their (1) Interpretation of the Special Rule for Model Aircraft, published (2) Law Enforcement Guidance for Suspected Unauthorized UAS Operations, partnered with (3) the Know Before You Fly campaign, published (4) the “What Can I Do With My Model Aircraft?” webpage on the FAA’s website, published (5) Advisory Circular 91-57,  and published (6) an Updated Advisory Circular 91-57 (“91-57A”).

 

Compilation of Recreational Aircraft Guidelines

The aircraft is flown strictly for hobby or recreational use. You can’t make money off the flying incidentally or directly. Sources:  (1),(2),(4),(6).
The aircraft is operated in accordance with a community-based set of safety guidelines and within the programming of a nationwide community-based organization. Sources: (1),(2),(3),(6).
The aircraft is limited to not more than 55 pounds [Take Off Weight] unless otherwise certified through a design, construction, inspection, flight test, and operational safety program administered by a community-based organization. Sources: (1),(2),(4),(6).
The aircraft is operated in a manner that does not interfere with and gives way to any manned aircraft. See also § 91.113. Sources: (1),(2),(3),(4),(5),(6).
When flown within 5 miles of an airport, the operator of the aircraft provides the airport operator and the airport air traffic control tower (when an air traffic facility is located at the airport) with prior notice of the operation (model aircraft operators flying from a permanent location within 5 miles of an airport should establish a mutually-agreed upon operating procedure with the airport operator and the airport air traffic control tower (when an air traffic facility is located at the airport)). AC 91-57 said 3 miles. Sources: (1),(2),(3),(4),(6).
Do not fly your model in a “careless or reckless manner so as to endanger the life or property of another.” Sources: (2); Section 336(c) of the FMRA; 14 C.F.R. § 91.13, (6).
Do not fly the aircraft beyond visual line-of-sight. Sources: (1),(3),(4),(6) FRMA § 336(c)(2).
“The aircraft must be visible at all times to the operator[.]”Source: (1).
“[T]he operator must use his or her own natural vision (which includes vision corrected by standard eyeglasses or contact lenses) to observe the aircraft.” You cannot use “vision-enhancing devices, such as binoculars, night vision goggles, powered vision magnifying devices, and goggles designed to provide a ‘first-person view’ from the model.” Source: (1).
“[P]eople other than the operator may not be used in lieu of the operator for maintaining visual line of sight.” No daisy chain. Source: (1).
The FAA mentioned in their Model Rule Interpretation § 91.119(c) which says do not operate the aircraft in a non-congested area “closer than 500 feet to any person, vessel, vehicle, or structure.” Model aircraft “may still pose a risk to persons and property on the ground warranting enforcement action when conducted unsafely.” However, in the Know Before You Fly campaign which the FAA partnered with, it says, “Do not intentionally fly over unprotected persons or moving vehicles, and remain at least 25 feet away from individuals and vulnerable property.” This distance requirement is unclear. Sources: (1) and/or? (3).
Fly no higher than 400 feet above ground level and remain below any surrounding obstacles when possible. Sources: (3),(5),(6).
The “operating site that is of sufficient distance from populated areas. The selected site should be away from noise sensitive areas such as parks, schools, hospitals, churches, etc.” Source: (5).
“Do not operate model aircraft in the presence of spectators until the aircraft is successfully flight tested and proven airworthy.” Source: (5).
“Do not fly in adverse weather conditions such as in high winds or reduced visibility.” Source: (3).
“Do not fly under the influence of alcohol or drugs.” Source: (3).
“Do not fly near or over sensitive infrastructure or property such as power stations, water treatment facilities, correctional facilities, heavily traveled roadways, government facilities, etc.” Source: (3).
“Check and follow all local laws and ordinances before flying over private property.” Source: (3).
“Do not conduct surveillance or photograph persons in areas where there is an expectation of privacy without the individual’s permission.” Source: (3).
“[M]ust comply with any Temporary Flight Restrictions (TFR).”(1),(6)
“Model aircraft must not operate in Prohibited Areas, Special Flight Rule Areas or, the Washington National Capital Region Flight Restricted Zone, without specific authorization.” (1),(6).

 

As you can see, the FAA has a patchwork of guidance on this area. We need to have all the information in one place and be done with it. The FAA needs to take the pieces and sew them all together so recreational flyers know what is exactly required of them as opposed to them having to piece together the hodgepodge guidance.

Furthermore, it would be helpful to include all the regulations that the FAA believes recreational operators are required to comply with in one place; otherwise, a guy who bought a Phantom off Amazon is going to have no clue about the regulations or even where to start!

 

(2) We Need to Get FAA Certificated Pilots Involved in the Industry

We can do this two ways: (A) take the pilot license suspension/revocation possibility off the table, for the time being, for individuals who have pilot licenses and (B) allow commercial flight operations for flight instructing.

(A) Removing the Possibility of a FAA Pilot License Suspension/Revocation

Pilots stand to lose a lot if they get in trouble with the FAA. Not only can they be fined, they can also get their pilot license suspended or revoked. This creates not a safer environment but actually decreases safety, because the most highly experienced and knowledgeable group of people who can operate safely in the national airspace are on the sidelines in fear of losing their licenses or in the worst case, their livelihood. This creates a “vacuum” of knowledge and also a vacuum in the culture of drone operators. You can still keep the licensed pilots in check with large civil penalties.

(B) Allow Commercial Flight Instruction Under the Section 333 Exemptions

Update: Kansas State University received an exemption to conduct flight instruction with drones.

One of my clients received this statement in their exemption from the FAA, “The petitioner also requested authority to conduct UAS training. At this time, the FAA is unable to authorize UAS operations for training until a further assessment is completed. When the FAA completes its review, we will proceed accordingly and no further action will be required by the petitioner. However, the petitioner is permitted to train its own pilot in commands and visual observers in accordance with condition no. 14 and the other conditions and limitations in this exemption.”  The FAA is not exempting individuals or businesses to do commercial flight instruction.

Furthermore, the FAA clarified in an opinion that public universities are prohibited from obtaining public COA’s for education because education is not considered a “core function” of government.

Since FAA certificated pilots are currently prohibited from commercially doing flight instruction of drones,  how do individuals or businesses get practical flight instruction? Are they expected to just go out and fly at some uninhabited baseball field and learn by trial and error (crash)? There is only one FAA approved flight school for drones in the US and the rest are just all illegally operating.


Jonathan Rupprecht

Mr. Rupprecht is an aviation attorney who focuses on drones. Read more about his background as a commercial pilot, flight instructor, Embry-Riddle Aeronautical University grad, and legal author. He has had media appearances on Forbes, Newsweek, Politico, NPR, Marketwatch, The Independent, Motherboard, and other sources. Feel free to send Jonathan a message here.

Advisory Circular 91-57 Canceled and Updated with AC 91-57A.

Advisory Circular 91-57  was originally published June 9, 1981 and had been current for 34 years, 2 months, 24 days. Interestingly, it was accidentally canceled on August 10, 2014 by the FAA. On September 2, 2015, the FAA canceled it and published Advisory Circular 91-57A.

Let’s get into the analysis.

Compare Background Sections

1981 AC 91-57

2015 AC 91-57A

Modelers, generally, are concerned about safety and do exercise good judgement when flying model aircraft. However, model aircraft can at times pose a hazard to full-scale aircraft in flight and to persons and property on the surface. Compliance with the following standards will help reduce the potential for that hazard and create a good neighbor environment with affected communities and airspace users.Model Aircraft Hazards in the NAS. While aero-modelers generally are concerned about safety and exercise good judgment when flying model aircraft for the hobby and recreational purposes for which they are intended, they may share the airspace in which manned aircraft are operating. Unmanned aircraft, including model aircraft, may pose a hazard to manned aircraft in flight and to persons and property on the surface if not operated safely. Model aircraft operations that endanger the safety of the National Airspace System, particularly careless or reckless operations or those that interfere with or fail to give way to any manned aircraft may be subject to FAA enforcement action.

 

 

Compare and Contrast Operational Restrictions

1981 AC 91-572015 AC 91-57A
Do not fly model aircraft higher than 400 feet above the surface.

 

Model aircraft operators should follow best practices including limiting operations to 400 feet above ground level (AGL).
When flying aircraft within 3 miles of an airport, notify the airport operator, or when an air traffic facility is located at the airport, notify the control tower, or flight service station.When flown within 5 miles of an airport, the operator of the model aircraft provides the airport operator or the airport air traffic control tower (when an air traffic facility is located at the airport) with prior notice of the operation. Model aircraft operators flying from a permanent location within 5 miles of an airport should establish a mutually agreed upon operating procedure with the airport operator and the airport air traffic control tower (when an air traffic facility is located at the airport).
Give right of way to, and avoid flying in the proximity of, full-scale aircraft. Use observers to help if possible.The aircraft operates in a manner that does not interfere with, and gives way to, any manned aircraft.
Nothing SimilarThe aircraft is limited to not more than 55 pounds, unless otherwise certified through a design, construction, inspection, flight test, and operational safety program administered by a CBO
Select an operating site that is of sufficient distance from populated areas. The selected site should be away from noise sensitive areas such as parks, schools, hospitals, churches, etc.

 

The aircraft operates in accordance with a community-based set of safety guidelines and within the programming of a nationwide community-based organization (CBO)
Do not operate model aircraft in the presence of spectators until the aircraft is successfully flight tested and proven airworthy

 

Nothing Similar
Nothing SimilarThe aircraft is flown strictly for hobby or recreational use

Compare Voluntary Compliance

1981 AC 91-57

2015 AC 91-57A

This advisory circular outlines, and encourages voluntary compliance with, safety standards for model aircraft operators.Public Law 112-95 recognizes the authority of the Administrator to pursue enforcement action against persons operating model aircraft who endanger the safety of the National Airspace System. Accordingly, model aircraft operators must comply with any Temporary Flight Restrictions (TFR). TFRs are issued over specific locations due to disasters, or for reasons of national security; or when determined necessary for the management of air traffic in the vicinity of aerial demonstrations or major sporting events. Do not operate model aircraft in designated areas until the TFR is no longer in force. Model aircraft must not operate in Prohibited Areas, Special Flight Rule Areas or, the Washington National Capital Region Flight Restricted Zone, without specific authorization.

 

The two big take-aways are that the airport notification radius was increased to 5 miles and that the FAA believes model aircraft must, not voluntarily, comply.

 

This advisory circular falls short by not fully explaining how model aircraft flyers can operate near an airport.

 

  • It says 5 miles but it is unclear as to nautical or statute miles.
  • It also does not define airport. This is important because there are many private airports all over the place. How do model aircraft flyers get in touch with these airports? Do I have to pull the property records and mail the owner a letter so I can plan a flight in a couple weeks? The airport facility directory does not list all the airports with a phone number for me to call. Furthermore, the AFD’s have the airport manager phone numbers in them so I can call them and ask to get the tower’s number. What happens if I’m wanting to fly after getting off of work and all I have is the airport manager’s phone number who left at 5PM? I can’t fly because I can’t notify the tower via phone. My only other choice is to get an aviation handheld transceiver which only has limited range and could sound horrible at 5 miles.
  • It does not clarify as to what the model aircraft operator must do if the tower tells them to not fly within their airspace. 14 C.F.R. § 91.123 (b) says, “Except in an emergency, no person may operate an aircraft contrary to an ATC instruction in an area in which air traffic control is exercised.” To get even more technical, Class B airports require clearances, while Class C and D airports require only two way radio contact. See 14 C.F.R §§ 91.131(a)(1); 91.129(c); 91.130(c). Do I have to get a “clearance” to fly in Class B? The FAA charged David Zablidowsky with flying in Class B without a clearance and he was a recreational flyer.   Since I have two flight instructor certificates and a commercial certificate, I’m totally not flying in a Class B until I get the tower telling me that I’m cleared. If I’m flying in a Class C or D airport, does the simple phone call suffice for two way radio contact?  After all, this is just an ADVISORY circular while I just referenced hard regulations with the force of law behind them and the FAA used one of them in a prosecution!
  • It does NOT clearly advise non-pilots of what they are required to comply with to safely operate in the national airspace. The new AC says, “Nothing in this AC changes the requirement to comply with the statute or any applicable regulations.” The regulations I just listed above were NOT clarified and this AC gives model aircraft operators a false sense of security.
  • It does not echo what was said in the 2014 Model Aircraft Rule Interpretation. For Example here is a list of what is said in the 2014 2014 Model Aircraft Interpretation but NOT in the new AC:
    • “The aircraft must be visible at all times to the operator[.]”
    • Do not fly the aircraft beyond visual line-of-sight.
    • “[T]he operator must use his or her own natural vision (which includes vision corrected by standard eyeglasses or contact lenses) to observe the aircraft.” You cannot use “vision-enhancing devices, such as binoculars, night vision goggles, powered vision magnifying devices, and goggles designed to provide a ‘first-person view’ from the model.”
    • “[P]eople other than the operator may not be used in lieu of the operator for maintaining visual line of sight.”
  • It did not clarify how close model aircraft flyers can fly to people. The FAA mentioned in their Model Rule Interpretation § 91.119(c) which says do not operate the aircraft in a non-congested area “closer than 500 feet to any person, vessel, vehicle, or structure.” Model aircraft “may still pose a risk to persons and property on the ground warranting enforcement action when conducted unsafely.” However, in the Know Before You Fly campaign which the FAA partnered with, it says, “Do not intentionally fly over unprotected persons or moving vehicles, and remain at least 25 feet away from individuals and vulnerable property.” This distance requirement is unclear.

In the back of my book, I had to compile everything into a chart that  the FAA said regarding model aircraft because the FAA has said certain things and not echoed them elsewhere. If we are going chronologically, is this the most up-to-date interpretation and we should just ignore the 2014 Model Aircraft Interpretation? If it is both/and, then how in the world is this even advisory?

 

Put it all down in one place.