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.
Appendix A A-4 Figure A-2. Sample Safety Risk Assessment and Mitigation Steps Before Flight Risk Management – Example of Identified Potential Hazard Hazard Cause Effect Likelihood (1) Severity (2) Risk (3) Mitigation Emergency or Contingency Procedures (4) Describe “what might happen?”
Example:
Loss of control link over people Describe the “why might it happen?”
Example:
Loss of power supply from control station, small UAS out of range, signal interference from another device (Wi-Fi, Bluetooth, etc.)
Describe the effect.
Example:
Ground impact, injury to people, damage to small unmanned aircraft.
Describe the chances of the hazard occurring.
Example:
Occasional Describe the consequences if the event does occur.
Example:
Injury to people (possibly including death) State the overall risk.
Example:
High Describe how the risk is minimized.
Example (partial): The remote PIC must conduct a control link check prior to operations over people.
The preflight briefing must include control link loss procedures.
Describe what will be done if the hazard occurs.
Example: Try to reestablish control link connection with the small unmanned aircraft. If connection cannot be reestablished, start emergency or contingency procedures for loss of control link.
Notes:
(1) Likelihood: Likelihood the risk will occur – Improbable, Remote, Occasional, Probable, or Frequent.
(2) Severity: Consequence if the hazard occurs – No safety effect, Minor, Major, Hazardous, or Catastrophic.
(3) Risk: Combination of Likelihood and Severity – Low, Medium, High, or Avoid (i.e., changes to operation are required for mitigation or the operation should not be conducted). These definitions are used to assign the level of risk prior to consideration of risk mitigation effects.
Appendix A A-5
(4) Emergency or Contingency Procedures: This column is your plan of action if the event still occurs.
(a) In order to identify effectively all potential hazards and their associated risks, you should first begin with a thorough description of the operational environment. This should include (but is not limited to):
1. Current and forecasted weather conditions.
2. Condition of the equipment to be used and associated operational limitations.
3. Remote pilot, observer, and other participants’ fatigue and awareness levels.
4. Terrain and obstacles (such as proximity to power lines, buildings, etc.) in the planned and emergency/contingency flightpath.
5. Identify the hazard(s) associated with flying over people (hazard column above).
6. If the operation will occur at night, identify hazards of flying at night, to include those operations whose mission duration includes portions of day, twilight, and night. Such potential hazards include night vision adaptation when unlit towers and buildings are present in the area of operation. Other potential hazards include current and forecast weather conditions and terrain features that may affect the ability for other aircraft operating in the area to see the anti-collision light for at least 3 statute miles (sm).
7. Identify other hazard(s) present during all small unmanned aircraft flights, such as schedule pressure, health issues, lack of familiarity with equipment, etc. (hazard column above).
(b) Once you have identified the potential hazards, complete the following steps for each hazard.
(c) List the cause(s) of each hazard (cause column above).
(d) List the effect(s) of each hazard (effect column above).
(e) Perform a qualitative risk assessment by:
1. Estimating the likelihood of each hazard occurring (probability column (1) above).
2. Estimating the severity of each hazard, if it occurs (severity column (2) above).
3. Defining the risk of each hazard as a combination of the probability and severity (risk column (3) above).
Appendix A A-6
(f) Describe the mitigation steps for each hazard (mitigation column above). Develop controls to mitigate all risks to an acceptable level. If such development is not possible, the operator should not operate the small unmanned aircraft until the operator can accomplish this.
(g) Describe any procedures to accomplish, including emergency and contingency procedures, should the hazard occur (emergency or contingency procedure column (4) above).
A.4.1 In-Flight Mitigations. During the flight, the following safety risk assessment and mitigation steps should be taken:
1. Properly use the assessment and inspection checklists, including briefing of appropriate safety risk assessment and mitigation steps.
2. Maintain proper configuration of the small unmanned aircraft for the category of the operation.
3. Constantly re-assess risk.
4. Have and follow procedures for making changes to the flight profile, including crewmember notification.
A.4.2 Post-Flight. After the flight, the following steps should be taken:
1. Perform a thorough debriefing.
2. Capture lessons learned and recommendations.
A.4.3 Contributors to Consider When Performing Risk Assessments. The following list contains examples of factors to consider in assigning a risk rating to a specific identified hazard. This is not a comprehensive list, but an initial list of items to consider:
• Workload.
• Configuration (gross weight, center of gravity (CG), etc.).
• Environment (weather, ATC, particular airport conditions, turbulence, etc.).
• Specific small unmanned aircraft limitations as stated by the manufacturer.
• Consequence of failure in technique, system, or structure.
A.4.4 Formulating Mitigations. Mitigate all risks to an acceptable level. Mitigations are actions to minimize, understand, prepare, or respond to causes of the hazards. They are actions the remote pilot, crewmember(s), or other team member(s) have control over. Mitigations will address reducing either the probability of a cause, the severity of the effect, or both.
Mitigations should be detailed and specific in nature. The following items should be considered when formulating mitigations. This is not a comprehensive list, but an initial list of items to consider:
Appendix A A-7
• Set limits on flight conditions (e.g., minimum weather, altitude, minimum/maximum speed, etc.).
• Clearly define and brief criteria that could cause the discontinuation of the flight
(e.g., items that affect safety of flight) and who will make and execute decisions.
• Review hazards and specify steps to reduce the associated risk(s).
• Review Weight and Balance (W&B) computations.
A.4.5 Emergency and Contingency Procedures. Describe any emergency and contingency procedures to accomplish if the hazard occurs, despite mitigation steps (emergency or contingency procedure column (4) in Figure A-2 above).
A.4.6 Other Risk Assessment Tools for Flight and Operational Risk Management. Other tools can also be used for flight or operational risk assessments and can be developed by the remote PICs themselves. The key consideration is ensuring all potential hazards and risks are identified and appropriate actions are taken to reduce the risk to persons and property not associated with the operations.
A.4.7 R educing Risk. Risk analyses should concentrate not only on assigning levels of severity and likelihood, but on determining why these particular levels were selected. This is referred to as root cause analysis, and is the first step in developing effective controls to reduce risk to lower levels. In many cases, simple brainstorming sessions among crewmembers is the most effective and affordable method of finding ways to reduce risk.
This also has the advantage of involving people who will ultimately be required to implement the controls developed.
A.4.7.1 It is very easy to get quite bogged down in trying to identify all hazards and risks. That is not the purpose of a risk assessment. The focus should be upon those hazards which pose the greatest risks. As stated earlier, by documenting and compiling these processes, a remote PIC can build an arsenal of safety practices that will add to the safety and success of future operations.
A.4.8 Sample Hazard Identification and Risk Assessment.
A.4.8.1 Example. I am the remote PIC of a small unmanned aircraft in the proximity of an accident scene shooting aerial footage. Much like pilots in manned aircraft must adhere to preflight action (14 CFR part 91, § 91.103), I must adhere to preflight familiarization, inspection, and aircraft operations (14 CFR part 107, § 107.49). Let’s say there is an obvious takeoff and landing site that I intend to use. What if, while I am operating, a manned aircraft (emergency medical services (EMS) helicopter) requires use of the same area and I am not left with a suitable landing site? Furthermore, I am running low on power. If I consider this situation prior to flight, I can use the Basic Hazard Identification and Mitigation Process. Through this process, I might determine that an acceptable level of risk can be achieved by also having an alternate landing site and possibly additional sites at which I can sacrifice the small unmanned aircraft to avoid imposing risks to people on the ground or to manned aircraft