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
Appendix A A-8 operations. It is really a simple process: I must consider the hazards presented during this particular operation, determine the risk severity, and then develop a plan to lessen (or mitigate) the risk to an acceptable level. By documenting and compiling these processes, I can build a collection of safety practices that will add to the safety and success of future operations. The following are some proven methods that can help a new remote PIC along the way:
A.4.8.2 Hazard Identification. Using the Personal Minimums (PAVE) Checklist for Risk Management, I will set personal minimums based upon my specific flight experience, health habits, and tolerance for stress, just to name a few.
After identifying hazards, I will then input them into the Hazard Identification and Risk Assessment Process Chart (see Figure A-1).
1. Personal: Am I healthy for flight and what are my personal minimums based upon my experience operating this small unmanned aircraft? During this step, I will often use the IMSAFE checklist in order to perform a more in-depth evaluation:
• Illness – Am I suffering from any illness or symptom of an illness which might affect me in flight?
• Medication – Am I currently taking any drugs (prescription or over-the-counter)?
• Stress – Am I experiencing any psychological or emotional factors that might affect my performance?
• Alcohol – Have I consumed alcohol within the last 8 to 24 hours?
• Fatigue – Have I received sufficient sleep and rest in the recent past?
• Eating – Am I sufficiently nourished?
2. Aircraft: Have I conducted a preflight check of my small UAS (aircraft, control station (CS), takeoff and landing equipment, anti-collision light for night operations, etc.)? Has it been determined to be in a condition for safe operation? Is the payload properly secured to the aircraft prior to flight?
3. Environment: What is the weather like? Am I comfortable and experienced enough to fly in the forecast weather conditions? Have I considered all of my options and left myself an “out?” Have I determined alternative landing spots in case of an emergency? Will I be flying at night and how may that change the way I operate? What are my associated risks when operating at night? Will I have the ability to see the anti-collision light for at least 3 sm? Will other aircraft that may be operating in the area have the ability to see the anti-collision light for at least 3 sm, considering weather and terrain (certain weather phenomena, such as fog, terrain features, and other phenomena, and obstacles such as hills, mountains, and manmade structures, may affect the ability for me and other aircraft to see the anti-collision light for at least 3 sm)? Is the flash rate sufficient to avoid a collision? Will I be operating over people, and if so, how will I
Appendix A A-9 ensure I do not create any hazards to persons not directly participating in the operation? Can my operational area be considered an open-air assembly of persons? Will I be operating over moving vehicles, and if so, how will I ensure I do not create any hazards to vehicles? Will my operations (landing spots) need to be relocated due to the people?
4. External Pressures: Am I stressed or anxious? Is this a flight that will cause me to be stressed or anxious? Is there pressure to complete the flight operation quickly? Am I dealing with an unhealthy safety culture? Am I being honest with myself and others about my personal operational abilities and limitations?
A.4.9 Controlling Risk. After hazards and risks are fully understood through the preceding steps, risk controls must be designed and implemented. These may be additional or changed procedures, additional or modified equipment, the addition of VOs, or any of a number of other changes.
A.4.10 R esidual and Substitute Risk . Residual risk is the risk remaining after mitigation has been completed. Often, this is a multistep process, continuing until risk has been mitigated to an acceptable level necessary to begin or continue operation. After these controls are designed but before the operation begins or continues, an assessment must be made of whether the controls are likely to be effective and/or whether they introduce new hazards to the operation. The latter condition, introduction of new hazards, is referred to as substitute risk, a situation in which the resolution is worse than the original issue. The loop seen in Figure A-1 that returns back to the top of the diagram depicts the use of the preceding hazard identification, risk analysis, and risk assessment processes to determine whether the modified operation is acceptable.
A.4.11 S tarting the Operation . Once a remote PIC develops and implements appropriate risk controls, the operation can begin.
Appendix B B-1 APPENDIX B. SUPPLEMENTAL OPERATIONAL INFORMATION B.1 Determining Operational Performance. The manufacturer may provide operational and performance information that contains the operational performance data for the aircraft such as data pertaining to takeoff, climb, range, endurance, descent, and landing. To be able to make practical use of the aircraft’s capabilities and limitations, it is essential to understand the significance of the operational data. The use of this data in flying operations is essential for safe and efficient operation. It should be emphasized that manufacturers’ information regarding performance data is not standardized. If manufacturer-published performance data is unavailable, it is advisable to seek out performance data that may have already been determined and published by other users of the same small UAS manufacturer model and use that data as a starting point.
B.2 Small Unmanned Aircraft Loading and Its Effects on Performance.
B.2.1 W eight and Balance (W&B) . Before any flight, the remote PIC should verify the aircraft is correctly loaded by determining the W&B condition of the aircraft. An aircraft’s W&B restrictions established by the manufacturer or the builder should be closely followed.
Compliance with the manufacturer’s W&B limits is critical to flight safety. The remote PIC must consider the consequences of an overweight aircraft, as it may result in an unsafe condition.
B.2.1.1 A lthough a maximum gross takeoff weight may be specified, the aircraft may not always safely take off with this load under all conditions. Conditions that affect takeoff and climb performance, such as high elevations, high air temperatures, and high humidity (high density altitudes) may require a reduction in weight before flight is attempted. Other factors to consider prior to takeoff are runway/launch area length, surface, slope, surface wind, and the presence of obstacles. These factors may require a reduction in weight prior to flight.
B.2.1.2 Weight changes during flight also have a direct effect on aircraft performance.
Fuel burn is the most common weight change that takes place during flight.
As fuel is used, the aircraft becomes lighter and performance is improved, but this could have a negative effect on balance. In UAS operations, weight change during flight may occur when expendable items are used on board
(e.g., a jettisonable load).
B.2.2 B alance, Stability, and Center of Gravity (CG). Adverse balance conditions (i.e., weight distribution) may affect flight characteristics in much the same manner as those mentioned for an excess weight condition. Limits for the location of the CG may be established by the manufacturer. The CG is not a fixed point marked on the aircraft; its location depends on the distribution of aircraft weight. As variable load items are shifted or expended, there may be a resultant shift in CG location. The remote PIC should determine how the CG will shift and the resultant effects on the aircraft. If the CG is not within the allowable limits after loading or does not remain within the allowable limits
Appendix B B-2 for safe flight, it will be necessary to relocate or shed some weight before flight is attempted.
B.3 Sources of Weather Information for Small Unmanned Aircraft Operations. Remote PICs are encouraged to obtain weather information prior to flight from Flight Service by using the website https://www.1800wxbrief.com. Remote PICs can create a free account in order to use the briefing service. While Flight Service does offer a telephone-based service, it is intended for manned aircraft pilots only.
B.3.1 N ational Weather Service (NWS). Remote PICs are also encouraged t o visit the NWS’s Aviation Weather Center (AWC) at https://www.aviationweather.gov. This free, web-based service does not require registration and offers all of the weather products important to a remote PIC, such as Aviation Routine Weather Reports (METAR) and Terminal Aerodrome Forecast (TAF). While reviewing the weather for your intended operation, it is also critical that the remote PIC review any TFRs at the FAA’s TFR website, which can be found at https://tfr.faa.gov.
B.4 Weather and the Effects on Performance. Weather is an important factor that influences aircraft performance and flying safety. Atmospheric pressure and density, wind, and uneven surface heating are factors that affect small unmanned aircraft performance and must be considered prior to flight.
B.4.1 Wind. Wind speed and direction are important as they affect takeoff, landing, and cruise of flight operations. Geological features, trees, structures, and other anomalies can affect the wind direction and speed close to the ground. In particular, ground topography, trees, and buildings can break up the flow of the wind and create wind gusts that change rapidly in direction and speed. The remote PIC should be vigilant when operating small unmanned aircraft near large buildings or other man-made structures and natural obstructions, such as mountains, bluffs, or canyons. The intensity of the turbulence associated with ground obstructions depends on the size of the obstacle and the primary velocity of the wind. This same condition is even more noticeable when flying in mountainous regions. While the wind flows smoothly up the windward side of the mountain and the upward currents help to carry an aircraft over the peak of the mountain, the wind on the leeward side does not act in a similar manner. As the air flows down the leeward side of the mountain, the air follows the contour of the terrain and is increasingly turbulent. This tends to push an aircraft into the side of a mountain. The stronger the wind, the greater the downward pressure and turbulence become. Due to the effect terrain has on the wind in valleys or canyons, downdrafts can be severe.
B.4.2 S urface Heat . Different surfaces radiate heat in varying amounts. Plowed ground, rocks, sand, and barren land give off a larger amount of heat, whereas water, trees, and other areas of vegetation tend to absorb and retain heat. The resulting uneven heating of the air creates small areas of local circulation called convective currents, which creates bumpy, turbulent air. Convective currents, with their rising and sinking air can adversely affect the controllability of the small unmanned aircraft.
Appendix B B-3 B.5 Battery Fires. Lithium-based batteries are highly flammable and capable of ignition. A battery fire could cause an in-flight emergency by causing a LOC of the small unmanned aircraft. Lithium battery fires can be caused when a battery short-circuits, is improperly charged, is heated to extreme temperatures, is damaged as a result of a crash, is mishandled, or is simply defective. The remote PIC should consider following the manufacturer’s recommendations, when available, to help ensure safe battery handling and usage.
B.6 Small UAS Frequency Utilization. A small UAS typically uses RFs for the communication link between the CS and the small unmanned aircraft.
B.6.1 Frequency Spectrum (RF) Basics. The 2.4 GHz and 5.8 GHz systems are the unlicensed band RFs that most small UAS use for the connection between the CS and the small unmanned aircraft. Note the frequencies are also used for computer wireless networks and the interference can cause problems when operating an unmanned aircraft in an area
(e.g., dense housing and office buildings) that has many wireless signals. LOC and flyaways are some of the reported problems with small UAS frequency implications.
B.6.1.1 To avoid frequency interference, many modern small UAS operate using a
5.8 GHz system to control the small unmanned aircraft and a 2.4 GHz system to transmit video and photos to the ground. Consult the small UAS operating manual and manufacturer’s recommended procedures before conducting small UAS operations.
B.6.1.2 It should be noted that both RF bands (2.4 GHz and 5.8 GHz) are considered line of sight and the command and control link between the CS and the small unmanned aircraft will not work properly when barriers are between the CS and the unmanned aircraft. Part 107 requires the remote PIC or person manipulating the controls to be able to see the unmanned aircraft at all times, which should also help prevent obstructions from interfering with the line of sight frequency spectrum.
B.6.2 Spectrum Authorization. Frequency spectrum used for small unmanned aircraft operations are regulated by the Federal Communications Commission (FCC). Radio transmissions, such as those used to control an unmanned aircraft and to downlink real-time video, must use frequency bands that are approved for use by the operating agency. The FCC authorizes civil operations. Some operating frequencies are unlicensed and can be used freely (e.g., 900 MHz, 2.4 GHz, and 5.8 GHz) without FCC approval.
All other frequencies require a user-specific license for all civil users, except Federal agencies, to be obtained from the FCC. For further information, visit https://www.fcc.gov/licensing-databases/licensing.
Appendix C C-1 APPENDIX C. SMALL UAS MAINTENANCE AND INSPECTION BEST PRACTICES C.1 In the interest of assisting operators with varying background levels of small UAS knowledge and skill, below is a chart offering conditions that, if noticed during a preflight inspection or check, may support a determination that the small unmanned aircraft is not in a condition for safe operation. Further inspection to identify the scope of damage and extent of possible repair needed to remedy the unsafe condition may be necessary prior to flight.
C.2 For Category 4 maintenance requirements for operating in accordance with 14 CFR part 107, see Chapter 8, paragraph 8.3.7.4.
C.3 For Category 4 record retention requirements, see Chapter 8, paragraph 8.3.7.4.1.
Table C-1. Small UAS Condition Chart Conditions that may result in the small unmanned aircraft not being in a condition for safe operation include, but are not limited to, the following:
Condition Action
1. Structural or skin cracking Further inspect to determine scope of damage and existence of possible hidden damage that may compromise structural integrity. Assess the need and extent of repairs that may be needed for continued safe flight operations.
2. Delamination of bonded surfaces Further inspect to determine scope of damage and existence of possible hidden damage that may compromise structural integrity. Assess the need and extent of repairs that may be needed for continued safe flight operations.
3. Liquid or gel leakage Further inspect to determine source of the leakage. This condition may pose a risk of fire resulting in extreme heat negatively impacting aircraft structures, aircraft performance characteristics, and flight duration. Assess the need and extent of repairs that may be needed for continued safe flight operations.