applicable to the category; (2) submit that declaration to the FAA in a form and manner acceptable
to the FAA; (3) label the product or product retail packaging in accordance with industry consensus
standards; and (4) provide an operating manual to the operator that includes operator instructions
for flight over people. The operator is responsible for knowing what category of operations his or
her UAS qualifies for, and what operational limitations he or she must follow.
4. ARC RECOMMENDATIONS
4.1 Recommendations for a Performance-Based Standard for the Classification of
UAS Operated Over People
The ARC began its discussion using traditional aviation risk models, considering: (1) risks to the
safety of people and property in the air; (2) risks to the safety of people and property on the ground;
(3) risks associated with aircraft integrity; and (4) risks associated with crew capability. After
considerable discussion, the ARC determined that the unique risk posed by flight over
people (unique in that the risk is not already addressed by proposed part 107) is injury or
death to persons on the ground.
The ARC then discussed to what extent the risk of injury to persons on the ground is acceptable and
what measurement to use to quantify the level of risk. Among others, the group referenced the
presentations of Paul Wilde from the FAA (Public Risk Criteria and Rationale for Commercial
Launch and Reentry), Joseph Pellettiere from the FAA (Historical Basis for FAA Occupant Safety),
and Dr. Narayan Yoganandan from the Medical College of Wisconsin (Human Injury Tolerance to
Impact: Biomechanical Studies), and discussed the work of Dr. Natasha Neogi from NASA
(Hazards Considerations for Micro-Unmanned Aerial Systems (µUAS) Overflight of Populated
Areas) and the traditional models of aviation risk continuum (from commercial aviation to micro
UAS) to couple risk of harm and societally acceptable risk levels.
The ARC also considered what flight “over people” means. With the guidance of FAA staff in the
room, the ARC came to understand that this term means flight of a UAS directly above one or more
persons. Any flight not directly over people already will be permitted under proposed part 107, with
certain proposed limitations. As noted above, what is the unique risk to operating over a person is
the increased risk that the UAS will strike that person when in failure mode, thus adding an
operational risk factor to be mitigated.
The ARC agreed to establish risk thresholds based on the probability that direct impact with a
person on the ground from a UAS would cause an injury that qualifies as level 3 and above on the
Abbreviated Injury Scale (AIS). 4 AIS level 3 injuries are classified as “serious.” 5 The working
The AIS was developed by the Association for the Advancement of Automotive Medicine (AAAM), which describes
the AIS as: “an anatomically based, consensus derived, global severity scoring system that classifies XX