8-29 Note: For DOCs that are resubmitted, the same recordkeeping requirements will apply.
8.10.5 H olders of an FAA- Accepted DOC No Longer Supporting the Small Unmanned Aircraft Design. A DOC remains valid even in the case of discontinued models. Therefore, the small unmanned aircraft may still remain listed on the FAA website as eligible to operate over people in accordance with the original DOC. However, if an unsafe condition is identified, the FAA may rescind the DOC. Any applicant could submit a new DOC with design changes that rectify the unsafe condition, provided the requirements to submit a DOC in accordance with § 107.160 can be satisfied.
8.11 Pr oduct Labeling.
8.11.1 C ategory 1. The FAA does not require labeling of small unmanned aircraft eligible for Category 1 operations. Marking the retail packaging with the weight of the aircraft, or with a general statement that the aircraft weighs 0.55 pounds or less would be helpful to the consumer. The manufacturer may also provide information to assist the pilot in determining that the small unmanned aircraft does not have any exposed rotating parts that would lacerate human skin upon impact. This type of packaging would also serve to promote the aircraft to consumers wishing to buy a small unmanned aircraft that has minimal operating restrictions. The FAA expects applicants to provide this type of information on the packaging of a small unmanned aircraft for easy identification purposes; however, such packaging is not required. It is the responsibility of the remote pilot to ensure the small unmanned aircraft meets the applicable requirements. Before conducting Category 1 operations, the remote pilot must determine that the small unmanned aircraft weighs 0.55 pounds or less, including everything that is on board or otherwise attached to the aircraft at the time of takeoff and throughout the duration of each operation. Additionally, the remote pilot is responsible for determining the small unmanned aircraft does not contain any exposed rotating parts that would lacerate human skin upon impact.
8.11.2 Category 2 and Category 3. To be eligible for operations over people in accordance with Category 2 or Category 3, the small unmanned aircraft must display a label indicating the category or categories for which the small unmanned aircraft is eligible to conduct operations. Because operating limitations apply to operations under Category 3, the label on the small unmanned aircraft indicating eligibility for operations under Category 3 also serves to inform the remote pilot of the operating limitations that they are required to observe (§§ 107.120(b)(1) and 107.130(b)(1)).
8.11.2.1 T he FAA does not provide a prescriptive labeling requirement that specifies exactly how an applicant must label an aircraft, what size font to use, specific location, etc. Due to the large variety of small unmanned aircraft models that exist, a prescriptive requirement would be inappropriate. Instead, the FAA allows the small unmanned aircraft to be labeled by any means as long as the label is in English, legible, prominent, and permanently affixed to the aircraft before conducting any operations over people. For example, an applicant may use the following labels: “Category 2,” “Category 3,” “Cat. 2,” or “Cat. 3.”
8-30 The label could be painted, etched, or affixed to the aircraft by any permanent means. The label should be located externally, where it can easily be seen.
The FAA does not prescribe a specific location for label placement because of the design variations of small unmanned aircraft. In the case of very small unmanned aircraft, an applicant may need to exercise creativity in determining the location best suited to satisfying the labeling requirement. Locating a label on a non-critical surface will likely prevent wear and removal during normal operations.
8.11.2.2 If a Category 2 or Category 3 label affixed to a small unmanned aircraft is damaged, destroyed, or missing, a remote PIC must label the aircraft in English such that the label is legible, prominent, and will remain on the small unmanned aircraft for the duration of the operation before conducting operations over human beings. The label must correctly identify the category or categories of operation over human beings that the small unmanned aircraft is eligible to conduct.
8.11.2.3 In order to comply with labeling requirements, a remote pilot must ensure the small unmanned aircraft is properly labeled before conducting any operations over people. A clear and legible label enables a remote pilot, an inspector, or a member of the public to identify the types of operations a small unmanned aircraft is eligible to conduct. An aircraft without a clearly legible label would not be eligible to operate over people. If a label degrades and is no longer legible or attached to the aircraft, the remote pilot is responsible for providing a new label before operating over people. The labeling requirement applies regardless of whether a small unmanned aircraft is obtained directly from an applicant or as a subsequent transfer. No pilot may operate the small unmanned aircraft unless the pilot verifies that the label meets the requirements of §§ 107.120(b)(1) and 107.130(b)(1), as applicable. If the small unmanned aircraft was manufactured before the effective date of this rule, or the small unmanned aircraft was otherwise not labeled, the remote pilot is responsible for determining whether the small unmanned aircraft is listed on an FAA-accepted DOC. If the small unmanned aircraft is eligible to operate over people, the remote pilot is responsible for labeling the aircraft in accordance with § 107.135.
8.11.2.4 A label will need to be changed if a small unmanned aircraft is modified for operation in a different or additional category. If the small unmanned aircraft has been modified and is no longer eligible to operate in its previously labeled category, the label must identify the category the small unmanned aircraft is eligible to operate within. The person who performed the modification would have to remove or cover the previous label so only the label with the new eligible category is visible on the aircraft.
8.12 Remote Pilot Operating Instructions. 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
8-31 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.
8.12.1 The remote pilot operating instructions must include, at a minimum, the following information:
1. General information, system description, and system limitations, including the category or categories of operations over people that the small unmanned aircraft is eligible to conduct. This information must describe whether the small unmanned aircraft must include a specific component on the aircraft in order to fulfill the performance-based safety requirements of Category 2 or Category 3, or both, for which the small unmanned aircraft applicant has declared compliance. For example, if an applicant has designed the small unmanned aircraft to have a parachute system or other device affixed to the aircraft and that component is provided separately, the remote pilot operating instructions must clearly identify the component that must be attached. Similarly, the remote pilot operating instructions must list components that are eligible or necessary for inclusion on the aircraft.
2. A statement describing allowable modifications to the small unmanned aircraft.
a. If modifications are allowed, the remote pilot operating instructions must include a complete description of modifications the applicant has determined do not change the eligibility for the category or categories of operations over people for which the small unmanned aircraft has been declared compliant. Such descriptions of modifications include descriptions of the small unmanned aircraft itself as well as any payload that any person may include on the aircraft.
b. Modifications the applicant describes in the remote pilot operating instructions must be consistent with the basis for the FAA’s acceptance of the DOC. Any person, however, who modifies a small unmanned aircraft in a way that will affect the eligibility of the small unmanned aircraft to operate over people under Category 2 or Category 3 is required to submit a new DOC for FAA acceptance before the small unmanned aircraft is eligible to operate over people.
3. A statement regarding whether the small unmanned aircraft has variable modes or configurations.
a. For a small unmanned aircraft that has such variable modes or configurations, the instructions must describe how a remote pilot can verify what mode or configuration the small unmanned aircraft is in and how to switch between modes or configurations. This information assists the remote pilot in verifying that the small unmanned aircraft is in the correct mode or configuration to conduct a certain category of operations over people.
b. Similarly, if a remote pilot chooses to operate in a different category of operations over people, or in a mode or configuration that is not permitted for operations over people but is permitted under part 107, that person must be able to discern the necessary information from the remote pilot operating instructions. The remote pilot should not be able to inadvertently change the mode or configuration.
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8.12.2 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.
8-33 Figure 8-2. Sample Remote Pilot Operating Instructions.
[Small Unmanned Aircraft Make and Model]
TABLE OF CONTENTS
INTRODUCTION
GENERAL INFORMATION
SYSTEM DESCRIPTION Category 2 Category 3
REQUIRED COMPONENTS
OPTIONAL COMPONENTS
INTRODUCTION The [small unmanned aircraft make and model] is a high performance aerial imaging aircraft that the FAA has determined is eligible to operate over people. The system comes fully assembled and includes the aircraft, touch screen ground station and 3-axis gimbal camera capable of 16 megapixel still photos and full HD 60 FPS videos. Operating the [small unmanned aircraft make and model], will enable you to capture remarkable photographs and video footage for a wide variety of applications.
GENERAL INFORMATION IMPORTANT: This small unmanned aircraft is eligible to conduct operations over people in Category 2 and Category 3 provided the remote pilot complies with the modification instructions. Any modification to the small unmanned aircraft not provided for in the remote pilot operating instructions may affect eligibility for operations over people. Please take the time to read this entire instruction manual for more information on operating safety and according to the Federal Aviation Regulations.
NOTE: Before any person may conduct operations of the [small unmanned aircraft make and model], you should create an account online with [manufacturer’s name], at [manufacturer’s website]. This will enable you to receive important updates regarding the small unmanned aircraft and its eligibility to operate over people, as well as updates, bulletins, instructional videos and more.
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SYSTEM DESCRIPTION Selection of the FLIGHT MODE The [small unmanned aircraft make and model] is programmed with three (3) flight modes. The flight mode can be selected via the Flight Mode Control Selection Switch located just above the left-hand control stick. IMPORTANT: Selection of the flight mode determines the category of operations that the [small unmanned aircraft make and model] may conduct over people. The following selection options are available:
Flight Mode G: Any operation not conducted over people.
Flight Mode 2: Any operation conducted in accordance with category 2 operations over people.
Flight Mode 3: Any operation conducted in accordance with category 3 operations over people.
REQUIRED COMPONENTS Category 2 Required Components
1) The [small unmanned aircraft make and model] Airframe
2) Transmitter and Ground Station
3) USB to Micro USB Cable
4) USB Interface/Programmer
5) 3400mAh 9.1V LiPo Battery
6) 9.1V LiPo Balance Connector Charge Lead
7) AC to DC Adapter/Power Supply
8) 16GB microSD Card w/Adapter
9) CAT 2 Rotor Blades & Guards Category 3 Required Components
1) The [small unmanned aircraft make and model] Airframe
2) Transmitter and Ground Station
3) USB to Micro USB Cable
4) USB Interface/Programmer
5) 5600mAh 11.1V LiPo Battery
6) 11.1V LiPo Balance Connector Charge Lead
7) AC to DC Adapter/Power Supply
8) 16GB microSD Card w/Adapter
9) CAT 3 Rotor Blades & Guards
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OPTIONAL COMPONENTS The [small unmanned aircraft make and model] is already equipped with a high-definition camera. If you intend to conduct operations over people in accordance with Category 2 or Category 3, you may replace the camera only with a pre-approved camera listed in the remote pilot operating instructions, which may be found on the [manufacturer’s] website. Additionally, for operations over people in accordance with Category 2 or Category 3, you may not affix any other payload to the [small unmanned aircraft make and model] unless it is listed in the remote pilot operating instructions, which may be found on the [manufacturer’s] website. Any permissible payload you affix to the small unmanned aircraft must be securely attached throughout the duration of all operations that occur in accordance with Category 2 or Category 3.
Failure to adhere to these requirements will result in the ineligibility of the [small unmanned aircraft make and model] to operate over people in accordance with Category 2 or Category 3.
8.12.2.3 Additional Information. Part 107 currently requires remote pilots to conduct a preflight inspection and ensure that the small unmanned aircraft is in a condition for safe operation. These requirements do not change for operations over people. In fact, a preflight assessment for operations over people should be more complex to account for the additional risk inherent in those operations. For example, the remote PIC should consider:
• The location of the people over whom the small unmanned aircraft would fly.
• The weather and other factors that may play a role in the performance of the small unmanned aircraft.
• The environment and airspace in which the operation is being conducted.
• The remote pilot operating instructions to consider the characteristics of small unmanned aircraft, for example, the expected battery life of the small unmanned aircraft.
8.12.2.4 The FAA anticipates the remote pilot operating instructions, which are required for small unmanned aircraft eligible to operate in Category 2 or 3 of part 107 subpart D, will assist the remote pilot in conducting their preflight check and ensuring that the aircraft is in a condition for safe operation prior to conducting the operation.
8.12.2.5 Although the FAA does not require the remote pilot operating instructions to contain information in addition to the above enumerated items, the FAA encourages small unmanned aircraft manufacturers to provide additional operational information to remote pilots. This information will assist remote pilots in planning operations, decision making throughout the flight, and the overall safe conduct of operations of their small unmanned aircraft by providing valuable operating information about the specific small unmanned aircraft design and capabilities. Manufacturers may wish to develop voluntary
8-36 standards regarding the information provided in the remote pilot operating instructions. These would provide consistency across small unmanned aircraft remote pilot operating instructions, and the remote pilots would have a clearer understanding of what information would accompany a small unmanned aircraft. Information that a small unmanned aircraft manufacturer may wish to consider providing includes, but is not limited to, the factors in paragraphs 8.12.2.5.1 through 8.12.2.5.3 below.
8.12.2.5.1 P erformance, Limitations, and Operating Characteristics:
• Operating temperature limits (high and low limits);
• Weather limitations to include wind, precipitation, and maximum wind gusts;
• Altitude limitations to include maximum operating altitude;
• Range limitations;
• Power source to include endurance, power setting, and consumption levels appropriate to the type of propulsion system (fuel, battery, etc.);
• Airspeed limitations;
• Maximum weights;
• Prohibited maneuvers; and
• Other limitations necessary for safe operations over people.
8.12.2.5.2 N ormal, Abnormal, and Emergency Operating Procedures:
• Preflight inspection; and
• Emergency or abnormal procedures.
8.12.2.5.3 W eight and Balance (W&B). Information regarding the W&B of the small unmanned aircraft.
8.13 R emote Pilot Responsibilities When Conducting Operations Over People. 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 they are operating a small unmanned aircraft in the appropriate category for the type of operation they 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 this AC.
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
8-37 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).
Appendix A A-1 APPENDIX A. RISK ASSESSMENT TOOLS A.1 Purpose of This Appendix. The information in this appendix is a presentation of aeronautical decision-making (ADM), Crew Resource Management (CRM), and an example of a viable risk assessment process. This process is used to identify hazards and classify the potential risk that those hazards could present in an operation. It also provides examples of potential criteria for the severity of consequences and likelihood of occurrence that may be used by a small unmanned aircraft remote pilot in command (PIC).
A.2 Aeronautical Decision-Making (ADM). The ADM process addresses all aspects of decision making in a solo or crew environment and identifies the steps involved in good decision making. These steps for good decision making are as follows:
A.2.1 I dentifying Personal Attitudes Hazardous to Safe Flight . Hazardous attitudes can affect unmanned operations if the remote PIC is not aware of the hazards, leading to such things as: getting behind the aircraft/situation, operating without adequate fuel/battery reserve, loss of positional or situational awareness, operating outside the envelope, and failure to complete all flight planning tasks, preflight inspections, and checklists. Operational pressure is a contributor to becoming subject to these pitfalls.
A.2.2 Learning Behavior Modification Techniques. Continuing to utilize risk assessment procedures for the operation will assist in identifying risk associated with the operation.
Conducting an attitude assessment will identify situations where a hazardous attitude may be present.
A.2.3 Learning How to Recognize and Cope with Stress. Stress is ever present in our lives and you may already be familiar with situations that create stress in aviation. However, small UAS operations may create stressors that differ from manned aviation. Such examples may include: working with an inexperienced crewmember, lack of standard crewmember training, interacting with the public and city officials, and understanding new regulatory requirements. Proper planning for the operation can reduce or eliminate stress, allowing you to focus more clearly on the operation.
A.2.4 Developing Risk Assessment Skills. As with any aviation operation, identifying associated hazards is the first step. Analyzing the likelihood and severity of the hazards occurring establishes the probability of risk. In most cases, steps can be taken to mitigate, even eliminate, those risks. Actions such as using visual observers (VO), completing a thorough preflight inspection, planning for weather, familiarity with the airspace and operational area, proper aircraft loading, and performance planning can mitigate identified risks. Figure A-1, Hazard Identification and Risk Assessment Process Chart, is an example of a risk assessment tool. Others are also available for use.
A.2.5 Using All Available Resources with More Than One Crewmember (CRM). A characteristic of CRM is creating an environment where open communication is encouraged and expected, and involves the entire crew to maximize team performance.
Many of the same resources that are available to manned aircraft operations are available
Appendix A A-2 to unmanned aircraft operations. For example, remote PICs can take advantage of traditional CRM techniques by utilizing additional crewmembers, such as VOs and other ground crew. These crewmembers can provide information about traffic, airspace, weather, equipment, and aircraft loading and performance. If conducting operations over people or moving vehicles, crewmembers can also provide timely information regarding the presence of those not directly participating in the operation. Examples of good CRM include:
A .2.5.1 Communication Procedures. One way to accomplish this is for the VO to maintain visual contact with the small unmanned aircraft and maintain awareness of the surrounding airspace and operational area, and then communicate flight status and any hazards to the remote PIC and person manipulating the controls so that appropriate action can be taken. Then, as conditions change, the remote PIC should brief the crew on the changes and any needed adjustments to ensure a safe outcome of the operation.
A .2.5.2 Communication Methods. The remote PIC, person manipulating the controls, and VO must work out a method of communication, such as the use of a handheld radio or other effective means that would not create a distraction and allows them to understand each other. The remote PIC should evaluate which method is most appropriate for the operation and should make a determination prior to flight.
A .2.5.3 Task Management. Tasks vary depending on the complexity of the operation. Depending upon the area of the operations, additional crewmembers may be needed to operate the small unmanned aircraft safely.
The remote PIC should utilize sufficient crewmembers to ensure no one on the team becomes overloaded. Once a member of the team becomes overworked, a greater possibility of an incident/accident exists.
A .2.5.4 Other Resources. Take advantage of information from a weather briefing, air traffic control (ATC), the FAA, local pilots, and landowners. Technology can aid in decision making and improve situational awareness. Being able to collect the information from these resources and manage the information is key to situational awareness and could have a positive effect on your decision making.
A.2.6 Evaluating the Effectiveness of ADM Skills. Successful decision making is measured by a pilot’s consistent ability to keep themselves, any persons involved in the operation, and the aircraft in good condition regardless of the conditions of any given flight. As with manned operations, complacency and overconfidence can be risks. Several checklists and models exist to assist in the decision-making process. Use the IMSAFE checklist to ensure adequate mental and physical preparation for the flight. Use the DECIDE model to assist in continually evaluating each operation for hazards and analyzing risk.
Paragraph A.4.8 and AC 60-22, Aeronautical Decision Making, can provide additional information on these models and others.
Appendix A A-3 A.3 Hazard Identification. Hazards related to the small unmanned aircraft and its operating environment must be identified and controlled. The analysis process used to define hazards needs to consider all components of the system, based on the equipment being used and the environment in which it is operated. The key question to ask during analysis of the small unmanned aircraft and its operation is, “what if?” Small unmanned aircraft remote PICs are expected to exercise due diligence in identifying significant and reasonably foreseeable hazards related to their operations. It is recommended that remote pilots document small unmanned aircraft and operating environment hazards in accordance with the hazard identification process described in Figure A-1.
Figure A-1. Hazard Identification and Risk Assessment Process Chart A.
4 Safety Risk Assessment and Mitigation Steps. Before flight, the following Safety Risk Assessment and Mitigation steps should be taken. Figure A-2 in this paragraph is an example of a risk assessment plan in table format to accomplish this task. This example should not be considered a required format. It is designed simply to show one way to document a risk assessment and mitigation plan.