Task E. Operations Over People

UA.I.E.K1 Remote pilot responsibilities when operating over people (AC 107-2A 8.13) 

The remote pilot has additional responsibilities when conducting small unmanned aircraft operations over people. In addition to the other operational requirements in part 107, the pilot is responsible for determining he or she is operating a small unmanned aircraft in the appropriate category for the type of operation he or she will conduct. The remote pilot is also responsible for verifying the small unmanned aircraft is properly labeled and listed on an FAA-accepted DOC. The remote pilot should perform all of the recommended preflight actions for all flights described in previous chapters and appendices of  AC 107-2A.

UA.I.E.K2 Operations over people at night (AC 107-2A 8.14 & 8.14.1)

8.14 Operations Over People at Night. The categories and their respective restrictions for operations over people do not change due to conditions of night. The test methods, analyses, or manner of inspection an applicant uses for determining that a small unmanned aircraft meets the performance-based safety requirements are time-of-day neutral. The risk mitigation measures apply equally to day and night operations when operating over people, with specific requirements for both the manufacturer of the small unmanned aircraft and the remote pilot.

8.14.1 If the small unmanned aircraft used in an operation at night is eligible to operate in any category for operations over people listed in part 107 subpart D, then the remote pilot may operate the small unmanned aircraft over human beings at night pursuant to the requirements of §§ 107.29 and 107.39. In declaring any small unmanned aircraft as eligible for operations in Category 2 or 3, manufacturers who produce small unmanned aircraft eligible to operate over people at night will most likely need to consider the mass of an anti-collision light in declaring the small unmanned aircraft fulfills the safety requirements set forth in either §§ 107.120(a) or 107.130(a).

UA.I.E.K3 Category of operations, including: 

UA.I.E.K3a Category 1 (AC 107-2A 8.3.4, 8.3.4.1, & 8.3.4.2)

Category 1 Operations. Part 107 establishes a category of operations over people using small unmanned aircraft that weigh 0.55 pounds (250 grams) or less on takeoff and throughout the duration of flight, including everything that is on board or otherwise attached to the aircraft. In addition to weight limits, Category 1 small unmanned aircraft must not contain any exposed rotating parts that would lacerate human skin upon impact. Remote pilots are prohibited from operating as a Category 1 operation in sustained flight over open-air assemblies unless the operation meets the requirements of § 89.110 or § 89.115(a). This prohibition is subject to waiver.

8.3.4.1 The remote pilot is responsible for determining that the small unmanned aircraft does not exceed the weight threshold and must ensure that the small unmanned aircraft does not contain any exposed rotating parts that would lacerate human skin. These requirements are in addition to the already existing pilot requirements of part 107, such as the preflight responsibilities listed in § 107.49 (see paragraph 8.11.1).

8.3.4.2 There are no applicant requirements for Category 1.

UA.I.E.K3b Category 2 (AC 107-2A 8.3.5, 8.3.5.1, 8.3.5.2, & 8.3.5.3)

Category 2 Operations. To conduct Category 2 operations over people, the small unmanned aircraft must meet the requirements of § 107.120. To confirm such eligibility, the small unmanned aircraft must be listed on an FAA-accepted declaration of compliance (DOC).

8.3.5.1  It is the remote pilot’s responsibility to ensure that the small unmanned aircraft is listed on an FAA-accepted DOC as eligible for Category 2 operations and labeled as eligible to conduct Category 2 operations. A remote pilot can accomplish these things by checking online at https://uasdoc.faa.gov to see if the DOC is valid and by visually inspecting the aircraft to ensure a label identifying the aircraft as Category 2 is affixed to the aircraft. These requirements are in addition to the already existing pilot requirements of part 107, such as the preflight responsibilities listed in § 107.49.

8.3.5.2 Additionally, the small unmanned aircraft must display a label indicating eligibility to conduct Category 2 operations; have current remote pilot operating instructions that apply to the operation of the small unmanned aircraft; and be subject to a product support and notification process. (The applicant must submit the DOC containing specific information to affirm that the aircraft meets the safety requirements through an FAA-accepted means of compliance (MOC).

8.3.5.3 Remote pilots are prohibited from operating as a Category 2 operation in sustained flight over open-air assemblies unless the operation meets the requirements of § 89.110 or § 89.115(a). This prohibition is subject to waiver.

UA.I.E.K3c Category 3 (AC 107-2A 8.3.6, 8.3.6.1 8.3.6.2, 8.3.6.3,  8.3.6.4)

Category 3 Operations. To conduct Category 3 operations over people, a small unmanned aircraft must meet the safety requirements of § 107.130. To confirm such eligibility, the small unmanned aircraft must be listed on an FAA-accepted DOC.

8.3.6.1 It is the remote pilot’s responsibility to ensure the small unmanned aircraft is listed on an FAA-accepted DOC and labeled as eligible to conduct Category 3 operations. A remote pilot can accomplish these things by checking online at https://uasdoc.faa.gov to see if the DOC is valid and by visually inspecting the aircraft to ensure a label identifying the aircraft as Category 3 is affixed to the aircraft. These requirements are in addition to the already existing pilot requirements of part 107, such as the preflight responsibilities listed in § 107.49.

8.3.6.2  Additionally, the small unmanned aircraft must display a label identifying eligibility to conduct Category 3 operations; have current remote pilot operating instructions that apply to the operation of the small unmanned aircraft  and be subject to a product support and notification process. (The applicant must submit the DOC containing specific information to affirm that the aircraft meets the safety requirements through an FAA-accepted MOC.

8.3.6.3 Location Requirements and Restrictions. Category 3 operations are allowed under the following conditions:

• The operation is conducted over a closed- or restricted-access site and everyone located within the site must be on notice that a small unmanned aircraft may fly over them.

• The operation is not conducted within a closed- or restricted-access site, and the small unmanned aircraft does not sustain flight over any person unless that person is directly participating in the operation or located under a covered structure or inside a stationary vehicle that can provide reasonable protection from a falling small unmanned aircraft.

8.3.6.4 No Operations Over Open-Air Assemblies of People. Category 3 operations are not allowed over an open-air assembly of persons. While the FAA does not define open-air assembly by regulation, it employs a case-by-case approach in determining how to apply the term. Open-air assembly has to do with the density of people who are not directly participating in the operation of the small unmanned aircraft and the size of the operational area. An open-air assembly is generally understood as dense gatherings of people in the open, usually associated with concert venues, sporting events, parks, and beaches during certain events. Such assemblies are usually associated with public spaces. The FAA considers that some potential examples of open-air assemblies may include sporting events, concerts, parades, protests, political rallies, community festivals, or parks and beaches during certain events. Some potential examples that are less likely to be considered open-air assemblies include individual persons or families exiting a shopping center, persons participating in casual sports in an open area without spectators, individuals or small groups taking leisure in a park or on a beach, or individuals walking or riding a bike along a bike path. Whether an open-air assembly exists depends on a case-by-case determination based on the facts and circumstances of each case. The remote pilot must assess whether the operational area would be considered an open-air assembly prior to conducting flight operations.

UA.I.E.K3d Category 4 (AC 107-2A 8.3.7)

Certification is how the FAA manages risk through safety assurance. It provides the FAA confidence that a proposed product or operation will meet FAA safety expectations to protect the public. Eligible Category 4 small unmanned aircraft must have an airworthiness certificate issued by the FAA under part 21 and must be operated in accordance with the operating limitations specified in the FAA-approved Flight Manual or as otherwise specified by the Administrator. The airworthiness certificate allows small unmanned aircraft operations for compensation and hire.

8.3.7.1 The remote pilot conducting Category 4 operations over people must use an eligible small unmanned aircraft. To operate over people in accordance with §107.140 and over moving vehicles in accordance with § 107.145(c), the remote pilot must operate the small unmanned aircraft in accordance with all operating limitations that apply to the small unmanned aircraft, as specified by the Administrator. These operating limitations must not prohibit operations over people.

8.3.7.2 Remote pilots are prohibited from operating as a Category 4 operation in sustained flight over open-air assemblies unless the operation meets the requirements of § 89.110 or § 89.115(a). This prohibition is subject to waiver.

8.3.7.3 Category 4 Maintenance. In order to preserve the continued airworthiness of the small unmanned aircraft and continue to meet a level of reliability that the FAA finds acceptable for flying over people in accordance with Category 4, the requirements of § 107.140(c) apply. Eligible Category 4 small unmanned aircraft must have maintenance, preventive maintenance, or alterations performed in a manner using the methods, techniques, and practices prescribed in the manufacturer’s current maintenance manual or instructions for continued airworthiness (ICA) prepared by its manufacturer, or other methods, techniques, and practices acceptable to the Administrator. Additionally, Category 4 small unmanned aircraft must be inspected in accordance with the manufacturer’s instructions or other instructions acceptable to the Administrator and have maintenance, preventive maintenance, or alterations performed using parts of such a quality that the condition of the aircraft will be at least equal to its original or properly altered condition.

8.3.7.3.1 The person performing any maintenance, preventive maintenance, or alterations must use the methods, techniques, and practices prescribed in the manufacturer’s current maintenance manual or ICA that are acceptable to the Administrator, or other methods, techniques, and practices acceptable to the Administrator. The person who inspects the small unmanned aircraft must do so in accordance with the manufacturer’s instructions or other instructions acceptable to the Administrator. Additionally, the person must have the knowledge, skill, and appropriate equipment to perform the work. The person performing the maintenance, preventive maintenance, or alterations must use parts of such a quality that the condition of the aircraft will be at least equal to its original or properly altered condition.

8.3.7.3.2 The owner or operator must maintain records of maintenance performed on the aircraft as well as records documenting the status of life-limited parts, compliance with Airworthiness Directives (AD), and inspection compliance of the small unmanned aircraft. Owner and operator responsibilities are discussed in paragraph 8.3.7.4.1.

8.3.7.4 Applicability of Maintenance and Record Retention Requirements. When a remote pilot operates a small unmanned aircraft in accordance with part 107, having an FAA-issued airworthiness certificate under part 21, the requirements of parts 43 and 91 do not apply. However, a small unmanned aircraft issued an airworthiness certificate may be eligible to operate under part 91, under certain circumstances. Part 107 contains necessary updates to the regulatory text to reflect the applicability of operating rules. Category 4 does not prescribe as many maintenance and record retention requirements as are required by parts 43 and 91, respectively. Therefore, it may be difficult for an owner or operator to switch between operating rules. A small unmanned aircraft operated and maintained in accordance with part 107 may find it difficult to show compliance with the requirements of part 43 and 91. To address this concern, an owner or operator can elect to comply with the relevant parts 43 and 91 requirements, even while operating in accordance with part 107. Under these circumstances, electing to comply with the relevant parts 43 and 91 requirements may help facilitate moving back and forth between operational parts, if desired, because the requirements of parts 43 and 91 are more stringent than those of § 107.140 with regard to maintenance and airworthiness.

8.3.7.4.1 Consistent with other regulatory frameworks, such as parts 91 and 135, the owner is responsible for maintaining the small unmanned aircraft in accordance with the requirements of § 107.140(c). However, if the owner enters into an agreement with another entity to operate the small unmanned aircraft, the operator is responsible for the maintenance and records retention requirements for small unmanned aircraft operated in accordance with Category 4 under part 107. The FAA expects most operators of Category 4 small unmanned aircraft operating under part 107 will also be the owner, or operating under direction of the owner. In this case, the owner is responsible for compliance with the Category 4 small unmanned aircraft maintenance and records retention requirements. To maintain flexibility for those owners of Category 4 small unmanned aircraft who wish to enter into an agreement with another entity for the operation of their small unmanned aircraft without the owner’s intervention or control, § 107.140(c) provides the means for the responsibility of maintenance requirements and retention of records to be clearly defined in such an agreement. If so specified in the agreement, the FAA would hold the operator responsible for compliance with the Category 4 small unmanned aircraft maintenance and records retention requirements. An agreement between an owner and an operator may be in the form of a written lease or contract, verbal agreement, or other agreement. If any agreement is found invalid or unenforceable, then the owner has the responsibility to meet these requirements. The provisions of any agreement should address, at a minimum, the requirements of § 107.140(c).

UA.I.E.K4 Selecting an operational area (AC 107-2A 8.3.1)

Operational area conditions such as the location and movement of people, vessels, or vehicles, as well as terrain features, including structures or any other item that could affect the operational area where the small unmanned aircraft is being maneuvered.

UA.I.E.K5 Minimum distances from a person (AC 107-2A 8.3.1) 

Part 107 does not impose a specific stand-off distance requirement from people when operating a small unmanned aircraft. The remote pilot may elect to observe a minimum stand-off distance to ensure the safety of the operation. When determining an appropriate stand-off distance, the remote pilot should consider the following factors:

• The small unmanned aircraft’s performance, to include course, speed, trajectory, and maneuverability.

• Environmental conditions such as wind, including gusts, precipitation, and visibility.

• Operational area conditions such as the location and movement of people, vessels, or vehicles, as well as terrain features, including structures or any other item that could affect the operational area where the small unmanned aircraft is being maneuvered.

• Probable failures and the ability to perform emergency maneuvers, including emergency landings.

• The remote pilot’s familiarity with and ability to maneuver the small unmanned aircraft.

Note: When conducting the small unmanned aircraft operation, the remote pilot should evaluate and make adjustments to this minimum distance from people as conditions change.

UA.I.E.K6 Operations over moving vehicles (AC 107-2A 8.3.3) 

8.3.3 Operations Over Moving Vehicles. Part 107 allows small unmanned aircraft operations over people inside moving vehicles with a small unmanned aircraft that meets the eligibility requirements for a Category 1, 2, 3, or 4 operation subject to one of the following conditions:

8.3.3.1 For Categories 1, 2, and 3 small unmanned aircraft, the operation must be conducted within or over a closed- or restricted-access site. Any person located inside a moving vehicle within the closed- or restricted-access site must be on notice that a small unmanned aircraft may fly over them; or

8.3.3.2  If the operation is not conducted within or over a closed- or restricted-access site, the small unmanned aircraft must not maintain sustained flight over any moving vehicle.

Note: Category 4 small unmanned aircraft may be eligible to operate over moving vehicles as long as the operating limitations specified in the FAA-approved Flight Manual, or as otherwise specified by the Administrator, do not prohibit such operation.

Operations Over Moving Vehicles – Over or Within a Closed/Restricted Access Site

* Category 4 eligible small unmanned aircraft may conduct operations over human beings and moving vehicles if not prohibited by the operating limitations specified in the FAA-approved Flight Manual or as otherwise prescribed by the Administrator.

Operations Over Moving Vehicles – Not Over or Within a Closed/Restricted Access Site

* Category 4 eligible small unmanned aircraft may conduct operations over human beings and moving vehicles if not prohibited by the operating limitations specified in the FAA-approved Flight Manual or as otherwise prescribed by the Administrator.

UA.I.E.K7 Modifications to an sUAS (AC 107-2A 8.3.6.5)

Modifications. The remote pilot operating instructions may contain details concerning allowable modifications of the small unmanned aircraft. Modifications not allowed by the remote pilot operating instructions may render the small unmanned aircraft ineligible for operations over people. Such modifications would require submission of a new DOC. Additionally, the small unmanned aircraft may need to be relabeled to reflect the category of operations it is eligible to conduct. In the case of the sale or transfer of the small unmanned aircraft, or use of the aircraft by someone other than the applicant, the applicant must provide remote pilot operating instructions that reflect the aircraft’s eligible category and acceptable modifications. Therefore, the FAA encourages manufacturers of small unmanned aircraft to keep track of modifications that would require an update to the remote pilot operating instructions.

UA.I.E.K8 Closed and restricted access sites (AC 107-2A 8.3.6.6)

Closed- or Restricted-Access Sites. Category 3 operations may take place over or within closed- or restricted-access sites where everyone located within the site must be on notice that a small unmanned aircraft may fly over them, as long as the operational area is not considered an open-air assembly. People who are not directly participating in the operation of the small unmanned aircraft but who are performing functions at the closed- or restricted-access site must be on notice of potential small unmanned aircraft operations, and should be advised of precautions or other recommended actions to take, if necessary. Remote pilots are responsible for ensuring no inadvertent or unauthorized access to the site occur. Adequate assurance could include physical barriers such as barricading and fencing or monitoring personnel to ensure inadvertent or unauthorized access to the site does not occur. Geographical boundaries, such as rivers, canals, cliffs, and heavily wooded areas may serve as effective barriers to restrict access.

UA.I.E.K9 Remote Pilot operating instructions (AC 107-2A 8.12)

The FAA requires applicants to provide remote pilot operating instructions for a small unmanned aircraft eligible to conduct Category 2 or Category 3 operations upon sale or transfer of the small unmanned aircraft, or use of the small unmanned aircraft by someone other than the applicant. In addition, the applicant should keep the instructions up-to-date to account for any changes it makes to a small unmanned aircraft.

UA.I.E.K10 Required components and Category declaration (AC 107-2A 8.12.2, 8.12.2.1, & 8.12.2.2)

The remote pilot operating instructions must be specific to the particular small unmanned aircraft design. An applicant may update existing instructions to include the required information with the small unmanned aircraft, or the applicant may create a new set of instructions that are specific to operations over people.

8.12.2.1 The FAA does not require the applicant to provide the remote pilot operating instructions in a particular format. An applicant could choose to provide the operating instructions as part of the packaging of a small unmanned aircraft, make them available electronically, or by any other means. Regardless of the manner in which the applicant transmits the instructions to remote pilots, the applicant should ensure the instructions remain up-to-date. Remote PICs should be able to discern clearly the set of operating instructions that are in effect at the time of the intended operation of the small unmanned aircraft over people.

8.12.2.2 Information contained in the remote pilot operating instructions should provide enough detail to enable remote pilots to understand clearly how to configure the small unmanned aircraft to ensure compliance with applicable requirements for operating over people. This information informs the remote pilot and aids in decision making. While the remote pilot operating instructions can aid a remote pilot in operating safely, it is ultimately the responsibility of the remote PIC to determine the safe operational parameters for the operation. A description of each of the elements the FAA requires in remote pilot operating instructions follows.

UA.I.E.K11 Optional components (AC 107-2A  8.12.2.2)

UA.I.E.K12 Applicant produced, designed, or modified sUAS for operations over people (AC 107-2A 8.4, 8.4.1, 8.4.2, 8.4.3, 8.4.4, & 8.4.5)

Applicant. An applicant includes any person who produces, designs, or modifies a small unmanned aircraft eligible to operate over people within the United States. An applicant may produce many small unmanned aircraft, sell kits from which to build small unmanned aircraft, or modify a small unmanned aircraft in a way that affects the eligibility of the small unmanned aircraft to conduct a different category of operations over people than it was previously eligible.

8.4.1 An applicant who manufactures and sells a kit that contains all the components and parts from which to build an operable small unmanned aircraft must comply with the requirements of part 107 subpart D, if the aircraft is intended for operations over people. The kit must contain all the components necessary to build an operable small unmanned aircraft, and would not require the owner to purchase any additional materials. Before the kit is sold, the applicant must ensure that the completely assembled small unmanned aircraft, not only its individual component parts, complies with the performance-based safety requirements to determine eligibility using an FAA-accepted MOC and declare compliance. This will ensure that the small unmanned aircraft meets the requirements of part 107 subpart D.

8.4.2 Someone who builds a small unmanned aircraft from separate components and parts not from a kit is an applicant. For example, someone may purchase the parts of a small unmanned aircraft separately, and build the small unmanned aircraft. An applicant is required to submit a DOC in order to conduct Category 2 or 3 operations.

8.4.3 An applicant may be a person who modifies a small unmanned aircraft listed on an existing DOC, resulting in noncompliance with the original declaration. A noncompliance means the small unmanned aircraft has been altered and is no longer in the same configuration as originally declared. If the small unmanned aircraft is changed so that it is no longer eligible for operations over people, a new DOC must be submitted prior to conducting operations over people or moving vehicles within that category. An applicant should specify allowable modifications in the remote pilot operating instructions. This ensures a remote pilot who may replace parts or otherwise modify the small unmanned aircraft is aware of which modifications would be allowable for the category of operation. An applicant may develop updates for a small unmanned aircraft after the remote pilot takes possession of it, such as a software update or hardware update. To communicate these updates to the remote pilots, the manufacturer should make operating instructions for the new capabilities of the small unmanned aircraft available.

8.4.4 Any person who makes a modification not permissible by the remote pilot operating instructions to a small unmanned aircraft eligible for Category 2 or Category 3 operations over people renders that small unmanned aircraft ineligible. If the person making the modification intends to conduct Category 2 or Category 3 operations over people with the modified small unmanned aircraft, that person is required to take on the responsibilities of an applicant. In this case, the applicant is required to determine the modified small unmanned aircraft meets the performance-based safety requirements for either Category 2 or Category 3, or both, using an FAA-accepted MOC and submit a new DOC. This principle applies to any person who modifies an existing ineligible small unmanned aircraft with the intention of conducting Category 2 or Category 3, or both, operations over people.

8.4.5 Maintenance actions performed on an eligible Category 2 or Category 3 aircraft that do not change the configuration or characteristics of the aircraft would not require a new DOC to be submitted. For example, if replacing propellers is listed as an allowed modification in the remote pilot operating instructions, a new DOC would not be required. However, replacing propellers not covered in the remote pilot operating instructions requires submission of a new DOC to conduct Category 2 or Category 3 operations over people. Remote pilot operating instructions should include a list of allowed modifications for the small unmanned aircraft to remain eligible.

UA.I.E.K13 Declaration of Compliance (DoC) (AC 107-2A 8.9)

Declarations of Compliance. For a small unmanned aircraft to be eligible to conduct Category 2 or 3 operations over people, the person who designs, produces, or modifies the small unmanned aircraft must declare compliance with the appropriate performance-based safety requirements through use of an FAA-accepted MOC. The FAA will receive such DOCs via an electronic form available on the FAA’s website https://uasdoc.faa.gov. Submission of a DOC involves the applicant declaring the following information:

• The applicant has demonstrated that the small unmanned aircraft meets the performance-based safety requirements for the category or categories of operation through an FAA-accepted MOC;

• The applicant maintains a process to notify owners of small unmanned aircraft and the FAA of any unsafe conditions that render those small unmanned aircraft noncompliant with part 107 subpart D;

• The applicant verifies that the small unmanned aircraft does not contain any safety defects; and

• The applicant will allow the FAA access to its facilities and technical documents, records, or reports required or witness any test necessary to determine compliance with the DOC.

UA.I.E.K14 Maintenance of an sUAS that is eligible for operations over people (AC 107-2A 8.3.74)

Applicability of Maintenance and Record Retention Requirements. When a remote pilot operates a small unmanned aircraft in accordance with part 107, having an FAA-issued airworthiness certificate under part 21, the requirements of parts 43 and 91 do not apply. However, a small unmanned aircraft issued an airworthiness certificate may be eligible to operate under part 91, under certain circumstances. Part 107 contains necessary updates to the regulatory text to reflect the applicability of operating rules. Category 4 does not prescribe as many maintenance and record retention requirements as are required by parts 43 and 91, respectively. Therefore, it may be difficult for an owner or operator to switch between operating rules. A small unmanned aircraft operated and maintained in accordance with part 107 may find it difficult to show compliance with the requirements of part 43 and 91. To address this concern, an owner or operator can elect to comply with the relevant parts 43 and 91 requirements, even while operating in accordance with part 107. Under these circumstances, electing to comply with the relevant parts 43 and 91 requirements may help facilitate moving back and forth between operational parts, if desired, because the requirements of parts 43 and 91 are more stringent than those of § 107.140 with regard to maintenance and airworthiness.

UA.I.E.K15 Means of Compliance (MoC) (AC 107-2A 8.5.1 & 8.5.1)

8.5 Means of Compliance—General Information. An MOC is a method to show that a small unmanned aircraft does not exceed the applicable injury severity limit upon impact with a human being, does not contain any exposed rotating parts that would lacerate human skin, and does not contain any safety defects. An MOC must be accepted by the FAA before an applicant can rely on it to declare compliance with the safety requirements for operations over people. Anyone may submit an MOC to the FAA for acceptance if it fulfills Category 2 or Category 3 safety requirements. An individual or a voluntary consensus standards body (e.g., ASTM International or SAE) could develop an acceptable MOC. The MOC must demonstrate through test, analysis, or inspection that the small unmanned aircraft is eligible for operations over people in Category 2, Category 3, or both. The MOC may include consensus standards. Once the FAA accepts an MOC, any person submitting a DOC could use it to establish that a small unmanned aircraft fulfills the requirements of the rule. An applicant requesting FAA acceptance of an MOC must submit certain information to the FAA in a manner the Administrator specifies. When reviewing an MOC, the FAA will utilize a comprehensive set of criteria. The FAA will determine whether the testing, analysis, or inspection described in the MOC demonstrates that a small unmanned aircraft meets the appropriate regulatory requirements. An MOC must address the injury severity limits, the prohibition on exposed rotating parts that would cause lacerations, and verification that there are no safety defects. The FAA will determine whether the proposed MOC aligns with accepted methods used by the medical industry, consumer safety groups, or other peer-reviewed test methods. In addition, the FAA will consider whether the proposed MOC relies on mitigations that require exceptional remote pilot skill or excessive workload to satisfy the requirements.

8.5.1 The FAA must accept an MOC before an applicant can rely on it to demonstrate compliance with the performance-based safety requirements for operations over human beings. An FAA-accepted MOC is subject to an ongoing review by the FAA to ensure the MOC remains valid. If the FAA determines the MOC no longer meets any or all of the requirements to demonstrate compliance with part 107 subpart D, the FAA may rescind acceptance of an MOC. If the FAA elects to rescind an MOC, it will publish a notice of rescission in the Federal Register.

8.5.2 The MOC options an applicant may use are:

1. The FAA-provided MOC, discussed in this AC.

2. An FAA-accepted MOC developed by a voluntary consensus standards body or other entity, or an FAA-accepted MOC developed independent of the FAA. An MOC developed by an individual applicant requires the same level of FAA review as an MOC developed by a voluntary consensus standards body. The FAA generally works with voluntary consensus standards bodies in the development of these standards. As a result, any MOC based on these standards will already have gone through a comprehensive review process during development.

UA.I.E.K16 Impact kinetic energy (AC 107-2A 8.6, 8.6.1 – 8.6.10)

8.6 FAA-Provided MOC. Without prejudice to any other MOC that an applicant may propose and the FAA may accept, the FAA offers one already accepted MOC for both the impact kinetic energy and exposed rotating parts requirements provided at § 107.120(a)(1) and (2) (Category 2) and § 107.130(a)(1) and (2) (Category 3). The FAA-provided MOC for the injury severity limitations is developed through an applicant’s calculation of the small unmanned aircraft’s maximum kinetic energy. This MOC does not account for impact dynamics or other factors, but consists of using only the formula the FAA describes to calculate the small unmanned aircraft’s maximum kinetic energy. This FAA-accepted MOC provides manufacturers with at least one method to demonstrate their small unmanned aircraft would meet the requirements to operate over people. As a result, the MOC involves confirming (1) the impact of a small unmanned aircraft does not exceed a certain kinetic energy limit, (2) the small unmanned aircraft does not contain any exposed rotating parts, and (3) does not contain any safety defects.

8.6.1 Impact Kinetic Energy. An applicant may use the FAA-provided MOC to satisfy the impact kinetic energy requirements by confirming the impact of the small unmanned aircraft does not exceed the applicable injury severity limits during a typical failure mode at the aircraft’s maximum performance capabilities. To test a small unmanned aircraft using this MOC, an applicant would first determine the maximum forward airspeed that the small unmanned aircraft is capable of attaining at full power in level flight. This would be done using a reliable and accurate airspeed measurement method under typical environmental conditions. For example, an applicant could measure the maximum speed using a Global Positioning System (GPS) groundspeed indicator, a radar gun, or tape measure and stop watch. Note that small unmanned aircraft operated under part 107 may not exceed the speed limitations in part 107 unless authorized under a Certificate of Waiver (CoW) or an exemption (§ 107.51(a)).

8.6.1.1 Next, an applicant would determine the ground impact speed resulting from an unpowered free-fall from the highest altitude the small unmanned aircraft is capable of attaining at full power. Note that aircraft operating under part 107 may not exceed the altitude limitations of that rule unless authorized under a CoW or an exemption (§ 107.51(b)). The ground impact speed could be determined by performing a drop test from the altitude determined in the previous step using a reliable and accurate vertical speed measurement method under typical environmental conditions.

8.6.1.2 If an applicant determines it is unreasonable to perform a drop test from the highest attainable altitude, then the applicant can perform a drop test from a lower altitude. The lower altitude must be sufficient to determine the small unmanned aircraft free-fall aerodynamic characteristics, such as the coefficient of drag and terminal velocity, to accurately calculate the ground impact speed from a free-fall from the highest attainable altitude. The manufacturer would state in the supporting data the applicant submits pursuant to the environmental conditions under which the applicant determined the maximum speeds. The applicant would also describe any unique test conditions for both the level flight and free-fall scenarios.

8.6.1.3 The above tests account for speeds a small unmanned aircraft could reach prior to or during a typical failure mode, such as losing power and falling with both a vertical and horizontal speed component. The tests do not take into account small unmanned aircraft failure modes or pilot actions that would cause the small unmanned aircraft to exceed the speeds determined in the previous steps. One example is a powered descent in which the ground impact speed of the small unmanned aircraft exceeds its unpowered free-fall ground impact speed. The FAA assumes these types of failure modes or pilot actions are not typical, and while possible, have a low likelihood of occurring. If an applicant determines these types of failure modes or pilot actions could typically occur and result in speeds greater than those determined in the previous steps, then the applicant should use the higher speeds to determine the maximum impact kinetic energy.

8.6.1.4 Once the applicant determines the maximum speeds associated with a horizontal and vertical impact, the applicant would determine the highest combination of these speeds the aircraft could achieve as a result of a typical failure in order to determine the maximum impact kinetic energy. The applicant should identify and assess typical failures caused by system or equipment loss of function or malfunction as well as those that could be caused by pilot error.

8..16.5 In consideration of the maximum speeds and typical failures described above, the applicant should determine the maximum impact kinetic energy using the following equation:

KEimpact = 0.0155 × w × v2

Where KEimpact is the maximum impact kinetic energy in ft-lbs, w is the weight of the small unmanned aircraft measured in pounds, and v is the maximum impact speed measured in feet per second (ft/s).

1. For example, a small unmanned aircraft that weighs 1.0 pound and has a maximum impact speed of 26 ft/s has a maximum impact kinetic energy of:

KEimpact = 0.0155 × 1.0 × (26)2 = 10.5 ft-lbs

2. Similarly, a small unmanned aircraft that weighs 1.0 pound and has a maximum impact speed of 40 ft/s has an impact kinetic energy of:

KEimpact = 0.0155 × 1.0 × (40)2 = 24.8 ft-lbs 

8.6.1.6 The two tables below provide examples of maximum impact speeds, rounded to whole numbers, associated with the impact kinetic energy thresholds of the different categories and the weight of the small unmanned aircraft. One table provides speeds in feet per second and the other table provides speeds in miles per hour (mph). Applicants may use these tables when following this MOC based on the maximum performance of the small unmanned aircraft. These tables do not consider any energy absorbing characteristics of a small unmanned aircraft that may reduce the amount of energy that is transferred to a person during a collision.

Maximum Impact Speeds (ft/sec) for a Given Weight and Impact Kinetic Energy Under FAA-Provided MOC

Maximum Impact Speeds (mph) for a Given Weight and Impact Kinetic Energy Under FAA-Provided MOC

8.6.1.7 If the small unmanned aircraft incorporates airspeed or altitude limiting systems or equipment that, when installed or enabled, restrict its forward airspeed or altitude in order to meet an impact kinetic energy requirement, then those systems or equipment should be installed or enabled when performing the tests described above. If compliance with the impact kinetic energy requirement depends on the proper function of those systems or equipment, then the applicant should provide in the remote pilot operating instructions information on the proper use of those systems or equipment, as well as any restrictions. The FAA anticipates applicants will implement these types of systems or equipment through hardware, software, or a combination of both. If the small unmanned aircraft can be operated with or without these systems or equipment enabled or installed, such as in a variable-mode small unmanned aircraft, then the applicant should provide information in the remote pilot operating instructions to ensure pilots understand any restrictions or limitations associated with the different modes.

8.6.1.8 This MOC does not account for the use or testing of design features such as parachutes, ballistic recovery systems, or other deployable devices that once deployed, reduce impact velocity. Such features can establish that a small unmanned aircraft would impact a person with a reduced amount of kinetic energy. Such design features will require the FAA’s review to determine whether they assist in achieving compliance with injury severity limitations. Outside the scope of the FAA-provided MOC, an applicant may choose to demonstrate compliance with the injury severity limitations using deployable devices, as long as the applicant describes how the devices are used to meet the safety requirements in the proposed MOC.

8.6.1.9 The MOC detailed above does not take into account the effect of the small unmanned aircraft’s structural configuration or materials of construction during an impact with a person. It assumes that the total kinetic energy of the small unmanned aircraft would be transferred to the person upon impact. In reality, a small unmanned aircraft’s structural configuration, materials of construction, or other design features may reduce the amount of the total kinetic energy that is transferred to a person during an impact. The use of energy absorbing materials, or an energy absorbing protective cage, may reduce the transfer of kinetic energy during an impact with a person. Under these circumstances, an applicant may wish to establish the amount of kinetic energy transferred to a person during an impact based on the impact absorbing characteristics of the small unmanned aircraft. If an applicant shows the aircraft does not transfer more than the kinetic energy limit to a person upon impact, the aircraft may be eligible for Category 2 or 3 operations over people. This demonstration would require an MOC that is not provided in this AC.

8.6.1.10 The FAA acknowledges limitations associated with the FAA-provided MOC. The FAA intended with this FAA-provided MOC to provide a test method that applicants could use to show compliance with the injury severity limitations, with the anticipation that industry can and will develop more flexible MOC through a voluntary consensus standards body or otherwise. The FAA expects these industry standards to consider that small unmanned aircraft often have non-rigid structures, which can reduce the kinetic energy transferred to a person upon impact. The FAA encourages the development of such MOC. .

UA.I.E.K17 Exposed rotating parts (AC 107-2A 8.6.2)

Exposed Rotating Parts.

One means, but not the only means, of complying with the requirement would be to manufacture the small unmanned aircraft so that it does not contain any exposed rotating parts. For example, if the propellers that provide lift and thrust for the small unmanned aircraft are internal to the unmanned aircraft, such as in a ducted fan configuration, and would not make contact with a person as a result of a typical impact, then the parts would not be exposed. Therefore, the small unmanned aircraft would satisfy this requirement. Testing and analysis may be required to determine that the rotating parts could not become exposed as a result of a typical impact with a person. If the forces on the small unmanned aircraft during an impact with a person are likely to cause structural failures that cause the rotating parts to become exposed, then that design would not satisfy this requirement.