Highlights of the FPVFC’s Public Comments to the FAA

Responses to, “Safe and Secure Operations of Small UAS”

Stand-off distances.  The FAA asked for comments on an appropriate, required stand-off distance to fly Small UAS.  The FPVFC response was for Category 1, no stand-off distance should be required and for Categories 2 and 3, no stand-off distance should be required.  Instead, the kinetic energy limitations of 11 ft-lbs and 25 ft-lbs for Category 2 and 3 should provide sufficient safe operations.

Altitude, Airspeed and other Performance Limitations.  The FAA requested comments about establishing additional performance limitations.  The FPVFC responded the FAA should eliminate the maximum allowable speed of 87 knots for Category 2 and 3 SUAS under Part 107 as the kinetic energy limitations provide sufficient regulation.  For Category 1 SUAS, a speed limit of 87 knots is reasonable. In addition, FPVC requested no speed limit for recreational SUAS as the repeal of section 336, creates a gap of speed limits in SUAS regulations.

Unmanned Traffic Management (UTM) Operations.  The FAA requested public comments for SUAS Unmanned Traffic Management (UTM).  FPVFC recommended that any SUAS flying at a designated flying field should be excluded from UTM.  The FPVC recommends for recreational UAS and Category 1 SUAS operating under Part 107, LAANC should be used and no UTM should be required.  The FPVFC recommends Category 2 and 3 SUAS operate under a UTM.

Payload Restrictions.  The FAA requested public comment about rules on SUAS payloads.  The FPVFC responded that Hobbyists, Category 1, 2 and 3 UAS should all be able to carry a video camera without restrictions.  

Small UAS critical system design requirements.  The FAA requested public comment on any technology requirements for commercial SUAS operations beyond visual line of sight.  The FPVFC responded that BVLOS of a Hobbyist SUAS and Category 1 SUAS should require GPS with coordinates transmitted to the remote pilot and no redundancy of equipment should be required.  For Category 2 and 3, FPVFC recommends a Return to Home capability as a requirement.

Responses to, “SUAS Operations over People”

In the proposed rules, the FAA states anyone building or modifying a Small UAS is by definition a manufacturer.  There will be numerous requirements for a Small UAS manufacturer including gaining approval by the FAA to fly the SUAS as well as logs of changes, etc.  much like the requirements for manned aircraft. FPVFC requested the FAA waive the definition of manufacturer for SUAS which are intended for recreational use.

In a similar topic, the proposed rule states adding a camera to an existing SUAS renders the SUAS non-compliant with safety regulations and therefore not eligible to fly over people or at night.  The FPVFC requests the FAA waive this requirement for SUAS intended for recreational use.

The FAA proposes three Category of commercial SUAS:

Category 1

  • < 0.55 lbs AUW including cargo.

  • Props may be exposed.

  • May operate over people and at night with 107 certificate

Category 2

  • > 0.55 lbs

  • Limit of 11 ft-lbs of kinetic energy ref Section IV.B.4

  • No exposed props (no exposed rotating parts)

  • Manufacturer FAA certification required

  • May operate over people and at night with 107 certificate

Category 3

  • Limit of 25 ft-lbs of kinetic energy

  • No exposed props (no exposed rotating parts)

  • May not operate over people if the craft has a FAA-identified safety defect

  • Manufacturer FAA certification required

  • No operations over people.  If transiting through an area with people, no hovering

These categories are important to the FPV community if the FAA eventually determines all SUAS should fall into one of these categories.

The FPVFC’s response to this section was to copy text developed by, “Inside Unmanned Systems” where the authors dug into University research performed for the FAA where the FAA used a highly conservative interpretation of energy thresholds for category 2 and 3.  The statement copied and submitted to the FAA follows:

“The kinetic energy transfer figures in § 107.115 Category 2 operations (b) (1) (i) and § 107.120 Category 3 operations (b) (1) (i) are extremely conservative and will cripple the commercial UAS industry if adopted. The FAA should wait for the public release of the Task A14 Ground Collision Severity Study to allow the public and manufacturers to review the findings and make a public comment on the draft NPRM before proceeding. Valuable data will be available shortly that could guide the FAA and the public in addressing meaningful comments to the draft NPRM.

The FAA should remove § 107.105 Prohibition on operations over moving vehicles. No small UAS qualified for operations over people in category one, two and three would cause injury from collisions to occupants in moving vehicles. The FAA should not consider ground vehicle driver reaction to a small UAS collision. Collision with flying objects is a well-known driving hazard that all licenced drivers should be trained to encounter. Failure to remove § 107.105 will make the commercial UAS industry non-viable in this country. It is difficult to envision commercial UAS tasks that do not involve flying over moving vehicles in some manner.”