Flying UAVs Over People: The Micro UAS ARC quick look

By Luke Geiver | April 14, 2016

There must be something about this time of year for major UAS announcements, policy updates or stories. Our team is currently taking an in-depth look at two regulatory-based storylines impacting the UAS industry: states vs. federal UAS laws and the Micro UAS ARC summary. (Last year around this time we were just delving into the FAA’s Pathfinder program). We are also staying on top of the ever changing effort to reauthorize the FAA. All of those efforts require several calls, emails and hours of research to produce a worthy print piece (most FAA-related stories are print worthy). 

While we are working on the print pieces, we’ve provided a quick synopsis usable for a information refresher or snapshot of the storylines mentioned above. For a look at the Micro UAS ARC summary, read on. For a look at the states vs. federal UAS law jurisdiction topic, check out Patrick C. Miller’s blog here

The Micro Unmanned Aircraft Systems Aviation Rulemaking Committee

Purpose: The ARC was supposed to “consider recommendations for a performance-based standard that would allow for micro UAS to be operated over people who are not directly participating in the operation of the UAS or under a covered structure.”

Participants: UAS industry reps and stakeholders. (As a side note, I talked with one of the most obvious choices for this committee that wasn’t added to the committee the day after this list was released. They thought they should be on the committee, but not surprised they were somehow left off). The members included:

3D Robotics; Academy of Model Aeronautics; American Institute of Aeronautics and Astronautics; Air Line Pilots Association; Aircraft Owners and Pilots Association; American Association of Airport Executives; Association for Unmanned Vehicle Systems International; Alliance for System Safety of UAS through Research Excellence; ASTM International; AT&T; Consumer Technology Association; DJI; Experimental Aircraft Association; General Aviation Manufacturers Association; GoogleX; GoPro Inc.; Helicopter Association International; Horizon Hobby; ICON Aircraft; Intel Corp; National Agricultural Aviation Association; National Association of REALTORS; National Association of State Aviation Officials; News Media Coalition; Professional Aerial Photographers Association International; Small UAV Coalition; Toy Industry Association.

In total, 25 members.

ARC Objectives:

 - Develop recommendations for a performance-based standard

- Means of compliance for UAS manufacturers

- Develop operational requirements for performance-based safety requirements.

 

Meetings:

6 days total (two separate 3-day sessions).

Presentations Delivered:

21 (ranging from insurance firms to aerospace experts to medical professionals)

Performance Standards, Categories Created:

4 category performance standards created, as follows:

Category 1: Flights over people are allowed with little to no regulation. Based on the UAV’s probability of a maximum risk impact threshold of a 1 percent chance of AIS level 3 or greater, UAV’s in this category can operate over people without being subjected to regulation beyond proposed part 107.

The abbreviated injury scale (AIS) is important here. The AIS is a scoring system developed by the Association for the Advancement of Automotive Medicine that scores and classifies certain bodily injuries created by an outside force or impact. The ARC used this system to differentiate between categories and/or types of UAVs and how much regulation should be placed on each platform based on size, type, footprint, speed, etc.

Category 2: Flights over people are allowed with some regulation and stipulation. UAVs that weigh more than 250 grams but present 1 percent or less chance of a serious injury (AIS level 3). To qualify for category 2, manufacturers must show the UAV doesn’t exceed a certain impact energy threshold.

Category 3: Limited operations over people are allowed. Flights over crowds not allowed. This category presents a risk that is “incrementally higher,” than categories 1 or 2 by roughly 30 percent.

Category 4: Similar to Category 3, only limited operations over people will be allowed. In addition, supplemental materials and requirements must be provided or met for this category such as a risk mitigation plan similar to an Congested Area Plan the FAA requires for certain manned flights.

Note: Both Categories 3 and 4 require much more of the manufacturer and potentially the FAA to determine energy impact thresholds and other risk associated with a UAV flying over people.

Recommendations for each Category:

Industry performance standards and compliance requirements:

Category 1: No

Category 2: Yes. Typical impact energy test required; platform manual provided to operator

Category 3: Yes. Typical impact energy test required; address impact of exposed rotating parts; platform manual provided to operator

Category 4: Yes. Typical impact energy test required; address impact of exposed rotating parts; platform manual provided to operator; study other materials that pose risk; develop risk mitigation plan

Requirements for manufacturers:

Category 1: label weight of product on external packaging or declare product weighs less than 250 grams

Category 2: Declare product meets industry consensus standards; submit declaration to FAA; label product in accordance to industry standards

Category 3: Declare product meets industry consensus standards; submit declaration to FAA; label product in accordance to industry standards

Category 4: Declare product meets industry consensus standards; submit declaration to FAA; label product in accordance to industry standards

Additional requirements outside of Part 107 rules:

Category 1: No

Category 2: Yes. Operator must maintain distance of 20 feet above and 10 feet away (laterally) from people and not create undue hazard to people.

Category 3: Yes. Flights over dense crowds never permitted. Operations over people only in closed or restricted access work site with permission of owner or operator. Set-off distance from Category 2 also applies.

Category 4: Yes. Category 2 set-off limitations apply. Risk mitigation plan also required.