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Small Unmanned Aircraft System
Aviation Rulemaking Committee
Comprehensive Set of Recommendations
for UAS Regulatory
April 1, 2009
The Small Unmanned Aircraft System (UAS)
Aviation Rulemaking Committee (ARC) was focused on making
recommendations for Federal regulations for the operation of civil
(commercial) UAS. However it was understood by the members of the ARC
that a public entity could fly under the provisions of any rule that
might result from these recommendations in lieu of flying under the
provisions of a Certificate of Authorization (COA) or in restricted,
prohibited, or warning areas. In formulating the recommendations
contained in this document, UAS ARC used the following guiding
1. Enable the operation of UAS by mitigating, to an acceptable level of
hazards posed to manned aircraft and other
airborne objects operating in the National
Airspace System (NAS) as well as the public on
2. The development of regulations authorizing specific operations of
could provide a means for operators to request
a waiver(s) from such a rule. Such an
option is not available to operators today.
3. Visual .see and avoidance. will be used by the UAS flight crew to
mitigate the risk
of collision with other aircraft and airborne
4. The primary burden of maneuvering for potential collision risk
avoidance should be
on the UAS flight crew.
5. All other aircraft have the right-of-way over UAS.
6. The above two principles do not relieve burden upon any pilot to see
and avoid other
7. Operating limitations will be defined to reduce or minimize potential
between manned and unmanned aircraft and reduce
vulnerability of those on the
8. a formal Federal Aviation Administration (FAA) safety risk assessment
will be used
to determine whether proposed regulations are
acceptable to the FAA from a safety
perspective. If a specific recommendation is
not acceptable from a safety perspective
then the FAA may require additional mitigations
9. Mitigations and controls should be tied to the level of risk to avoid
burdensome on the application of UAS
technology. If a specific recommendation is
overly excessive or burdensome then the FAA may
elect to modify the
recommendation in developing proposed
10. The recommended regulations should not be overly complex to
facilitate analysis by
the FAA and other stakeholders.
11. Recommendations will leverage existing standards and regulations
which govern the
operation of small unmanned and Model Aircraft.
Where feasible, the ARC will use existing definitions and regulations to
13. UAS ARC recommendations for an Special Federal Airworthiness
Are intended to enable some initial UAS operations
Are not intended to cover all potential applications or aircraft
- Existing processes such as COAs for public-use aircraft and Special
Airworthiness Certificate will
- Recommendations are directed at UAS not necessarily all unmanned
Overall the committee was focused on a layered
approach to ensuring that the potential risks associated with mid-air
collisions and/or injury to persons and property is within acceptable
levels. Many of the committee.s recommendations were made based upon
experience with existing aviation operations and regulations and
perceptions of risk. Overall, the committee was equally focused on
protecting existing air traffic and persons/property on the surface. In
general, the philosophy was to minimize encounters, keep UAS separated
from other aircraft and surface risks, avoid collisions, and minimize
the impact of collisions that may happen. See Figure 1.
The committee perceives that the
recommendations in this document combine together to enable UAS
operations at an acceptable level of risk. As more experience with UAS
is gained and more data generated, these recommendations should be
The following definitions apply to all small
unmanned aircraft systems (UAS) referred to in this regulation.
Auto Flight Management:
Pilot-in-Command (PIC) is able to maintain stable
flight without constant direct intervention. To at least some degree,
control surface movements result from sensors and software automation
on-board the aircraft.
Considered a last resort maneuver of an aircraft
to avoid an imminent collision. Without the maneuver a collision might
Activity which seeks to ensure that aircraft
remain safely separated and well clear of each other as to not present a
Equipment, not on the aircraft, used to maintain
control, communicate, guide, or otherwise operate an unmanned aircraft.
Data Communications Links:
All links between the unmanned aircraft and the
Control Station which includes the command, status, communications, and
Equipment, not on-board the aircraft, used to
launch and recover an unmanned aircraft which could also include unique
navigation and differential positioning equipment used for autonomous
a UAS used by hobbyists and flown within visual
line-of-sight under direct control from the pilot, which can navigate
the airspace, and which is manufactured or assembled, and operated for
the purposes of sport, recreation and/or competition.
Mode C Veil:
The airspace within 30 nautical miles (NM) of an airport listed in
Appendix D, Section 1 of 14 Code of Federal Regulations (CFR) Part 91
(generally primary airports within Class B airspace areas), from the
surface upward to 10,000 feet mean sea level (MSL). Unless otherwise
authorized by Air Traffic Control (ATC), aircraft operating within this
airspace must be equipped with automatic pressure altitude reporting
equipment having Mode C capability. However, an aircraft that was not
originally certificated with an engine-driven electrical system or which
has not subsequently been certified with a system installed may conduct
operations within a Mode C veil provided the aircraft remains outside
Class a, B, or C airspace; and below the altitude of the ceiling of a
Class B or Class C airspace area designated for an airport or 10,000
feet MSL, whichever is lower. [Directly quoted from the Federal Aviation
Administration.s (FAA.s) Aeronautical Information Manual: Official Guide
to Basic Flight Information and ATC Procedures, February 14, 2008].
Same as 14 CFR 1.1
Manual Flight Control:
PIC is able to directly control the aircraft such
that control inputs made at the Control Station are translated directly
into corresponding control surface positions. Augmentations which help
maintain flight stability are permitted.
UAS Flight Crewmember:
a pilot, visual observer, payload operator or
other person assigned duties for a UAS for the purpose of flight.
UAS Pilot: a
person exercising control over an unmanned aircraft during flight.
An aircraft (as defined by 14
CFR 1.1) that is intended to navigate in the air without an onboard
Unmanned Aircraft System (UAS):
An unmanned aircraft and its associated elements
related to flight operation which may include Control Stations, data
communications links, support equipment, payloads, flight termination
systems, and launch/recovery equipment.
Unaided (corrective lenses and/or sunglasses
exempted) visual contact with aircraft sufficient to be able to maintain
operational control of the aircraft, know its location, and be able to
scan the airspace in which it is operating to decisively see and avoid
other air traffic or objects.
a UAS flight crew member who assists the UAS PIC
in the duties associated with collision avoidance. This includes, but is
not limited to, avoidance of othertraffic, airborne objects, clouds,
obstructions, and terrain.
Subpart a. Model Aircraft
2. Model Aircraft Operated in
FAA Accepted Standards
Model Aircraft operations that are conducted in
accordance with an FAA accepted set of standards established and
administered by a community based association as discussed in Section
2.2, shall otherwise be exempt from the requirements of any Special
Federal Airworthiness Regulation (SFAR) that results from this
recommendation as long as they are operated by:
- Hobbyist for the sole purpose of sport,
recreation and/or competition under the conditions of such an FAA
- Manufacturers which are flight testing
aircraft intended to be operated for the sole purpose of sport,
recreation, and/or competition and they are tested at an approved
field as defined by and in accordance with an FAA accepted program
with the approval of the community-based association responsible for
- Educational institutions and/or students
for the sole purpose of education or research and they are operated
at an approved field as defined by and in accordance with an FAA
accepted program with the approval of the community-based
association responsible for the location
- Manufacturers which are flight testing
aircraft intended to be operated for other than sport, recreation,
and/or competition and they are tested at an approved field as
defined by and in accordance with an FAA accepted program with the
approval of the community-based association responsible for the
Reflects FAA.s concept of regulating model aviation by exempting Model
Aircraft from regulation. Under this approach, modelers participating
within an aeromodeling structure/organization such as the Academy of
Model Aeronautics (AMA) may operate their Model Aircraft in accordance
with an accepted set of standards and operating procedures. Based on a
more rigorous attention to safety, risk assessment, and risk mitigation,
the accepted standards may provide greater latitude in the Model
Aircraft operations. Modelers not participating in the additional safety
programming established in an accepted set of standards shall comply
with the requirements of Section 3.
It is important that
manufacturers of Model Aircraft are able to test fly their aircraft as
they do today without having to adhere to UAS regulations. In order to
give educational institutions (e.g.,universities) the flexibility to
provide "hands on" instruction and training to students preparing for
careers in the UAS and aviation industries they are allowed to fly these
systems under the requirements for Model Aircraft. For consistency,
manufacturers who develop UAS that are functionally similar to Model
Aircraft, are allowed to test at a location following a community-based
and FAA-accepted program.
2.2 Accepted Model Aircraft Standards and Procedures
Accepted Model Aircraft Standards and
Procedures may be established and administered by a community-based
association. An accepted set of standards shall be based upon accepted
and recognized safety principles and will include but not be limited to
Community based organizations, such as the AMA, that have credibility
within the Model Aircraft community and that have an established safety
record and have demonstrated the ability to influence participant
compliance shall be afforded the opportunity to establish a set of
safety standards that are more comprehensive than the requirements and
limitations given for non participating modelers, and use these
standards as an alternative means of compliance with any regulations
which may results from these recommendations. Since such standards are
more comprehensive, operations under such standards shall allow for a
broad spectrum of operations and greater latitude in the AMA operations.
(1) Prescribed safety program entailing
oversight, assessment, risk mitigation, and accident/incident reporting.
(2) General safety guidelines and operating
(3) Operating guidelines specific to the
location and to the type, size, performance, and propulsion of the
various Model Aircraft.
(4) Comprehensive programming addressing Model
Aircraft having non standard weight, or identified as having unusual
propulsion types or extraordinary flight characteristics.
(5) Programming to facilitate Model Aircraft
events, competition, national and international record attempts,
gatherings, and Model Aircraft demonstrations and exhibitions.
(6) Educational programming that assures
participants are provided relevant safety information and validates the
(7) Educational programming that addresses
essential piloting issues including:
Safe and cooperative operation with other
Transitioning to higher performance and
more complex models
- Recognition and avoidance of manned
- Safe operation near spectators and other
(8) Methodology for establishing and
designating dedicated Model Aircraft flying sites providing:
- Guidelines for flying site location,
configuration and design layout applicable to its intended use and
the type(s) of Model Aircraft flown, and which ensures Model
Aircraft operations do not interfere with manned flight operations
- Safety guidelines that ensure the safety
of the public and provide adequate separation of persons and
property from the Model Aircraft operations
- Guidelines for coordinating and reviewing
operating policies and procedures with the airspace controlling
authority for those flying sites located within controlled airspace
- Guidelines for coordinating and reviewing
operating policies and procedures with the airport and applicable
airspace control authority for those flying sites located within 3
NM of a military or public-use airport, heliport, or seaplane base.
- Guidelines for establishing and
disseminating flying site operating procedures, limitations and
safety guidelines including the following:
- Hours of Operation
- Flying site operating procedures
- Frequency control procedures (if
- Traffic pattern and flight operations
- Cooperation with other modelers
- Applicable altitude restrictions
- Applicable No-Fly zones and operating
- Flight line and pit area safety
- Spectator and public access policies
- Emergency Procedures (e.g., Fire,
3. Model Aircraft Not Operated in
Accepted Set of Standards
The following general requirements and
limitations apply to Model Aircraft which are not operated in accordance
with an FAA accepted set of standards, but are operated by hobbyistsfor
the sole purpose of sport, recreation, and/or competition.
Eliminate Section 3.0 in its
AMA believes this approach is flawed in that it
fails to recognize the substantial diversity of the hobby, establishes
unrealistic and unenforceable restrictions, and leaves absent a safety
surveillance program to oversee the activities of those modelers who
choose not to participate in a formal aeromodeling
structure/organization More importantly, as a baseline set of standards,
these limitations have the inherent potential of imposing a devastating
impact on the aeromodeling activity and the hobby industry.
3.2 General Requirements
(1) Model Aircraft shall be flown in open
spaces and in a manner that does not endanger the life and property of
(2) Model Aircraft shall yield the right of way
to all manned aircraft.
(3) Model Aircraft shall not interfere with
operations and traffic patterns at airports, heliports, and seaplane
(4) Model Aircraft shall not be operated at
locations where Model Aircraft activities are prohibited.
(5) Model Aircraft are limited to unaided
visual line-of-sight operations. The Model Aircraft pilot must be able
to see the aircraft throughout the entire flight well enough to maintain
control, know its location, and watch the airspace it is operating in
for other air traffic. Unaided visual line-of-sight does not preclude
the use of prescribed corrective lenses.
(6) Model Aircraft shall be designed, equipped,
maintained and/or operated in a manner in which the aircraft remains
within the intended area of flight during all operations.
(7) Model Aircraft pilots may not intentionally
drop any object from a Model Aircraft that creates a hazard to persons
(8) Model Aircraft shall be operated in a
manner that respects property rights and avoids the direct overflight of
individuals, vessels, vehicles, or structures.
(9) Model Aircraft shall not be operated in a
careless or reckless manner.
(10) Model Aircraft pilots shall not operate
their aircraft while under the influence of alcohol or while using any
drug that affects the persons faculties in any way contrary to safety.
(11) Model fixed-wing and rotorcraft aircraft
shall not use metal-blade propellers.
(12) Model Aircraft shall not use gaseous
(13) Model Aircraft shall not use fuels
containing tetranitronmethane or hydrazine.
(14) Model Aircraft shall not use
turbine-powered engines (e.g., turbo-fan, turbo-jet) as a propulsion
Turbine powered aircraft are
perceived by many members of the UAS Aviation Rulemaking Committee
(ARC) as being a higher risk.
Eliminate the limitation.
The blanket prohibition of turbine engines does
not take into consideration the various and diverse turbine engines
currently produced and impose an unjustified economic impact on the
3.3 General Limitations
(1) Model Aircraft shall not exceed 55 pounds
(2) Model Aircraft shall remain clear of
(3) Model Aircraft will not operate in Class B
airspace without the permission of the ATC authority.
(4) Model Aircraft shall not be operated within
3 NM miles of an airport, heliport, or seaplane base without the
permission of the ATC authority or airport manager.
(5) Model Aircraft shall operate in close
proximity to the ground, at or below 400 feet (.) above ground level (AGL),
and shall at all times remain below and well clear of all manned
keeping Model Aircraft at or below 400. encounters with manned aircraft
are reduced. This recommended general limitation is consistent with the
current Model Aircraft guidance contained in AC91-57.
ALTERNATIVE VIEW: Replace (5) with the
Model Aircraft shall operate in close proximity
to the ground, shall stay at or below 400. AGL when within 3 NM of an
airport, and shall at all times remain below and well clear of all
Though it is agreed that there needs to be some
altitude limit on the modelers that are not participating in a
structured safety program such as AMA.s, AMA also knows from their
experience that creating a hard and fast across the board altitude
limit, such as 400. is unnecessarily restrictive, unrealistic, and
arguably poses a greater risk to personnel on the ground. AMA.s
experience has shown that the greatest risk to other participants in the
NAS and perhaps the only significant risk posed by model aviation is
when Model Aircraft are operated within three miles of an airport. The
language in the ATERNATIVE VIEW mirrors the current guidelines in the
AMA Safety Code.
(6) Notwithstanding the above limitations,
Model Aircraft weighing less than or equal to two lbs incapable of
reaching speeds greater than 60 miles per hour (mph) (52 knots), and
powered by electric motor or mechanical stored energy (e.g., rubber-band
powered) may operate within 3 NM of a military or public-use airport or
heliport; if they remain a safe distance from the airport or heliport,
remain well clear of all manned aircraft, and remain below 400. AGL.
RATIONALE for the above limitations:
(1) Currently accepted domestic weight limit
and has international precedent as well.
(2) Is consistent with the concept of visual
(3) Class B is positive control. All aircraft
are required to operate on a clearance. Gaining permission from ATC is
equivalent to receiving a clearance.
(4) Model Aircraft permitted to operate within
3 NM of the airport will be provided applicable operating limitations.
(5) 400. is appropriate for Model Aircraft
operations in Class C airspace without coordinating with ATC and is
consistent with the intention of current domestic policy and with the
UK, CASA, and Canada.
(6) This is consistent with the guidelines
currently established by AC91-57.
(7) Makes a blanket exception for models
weighing two lbs or less. This is an appropriate allowance for .Park
Flier. and .toy. type models and allows them to use parks and small
fields closer to airports.
(7) Model Aircraft will not be flown at an
airspeed that would cause the aircraft to inadvertently leave the
prescribed maneuvering area.
pilot will be responsible for limiting their speed so that they can
remain within the prescribed maneuvering area.
ALTERNATIVE VIEW: Replace (7) with the
Model Aircraft cannot be operated at airspeeds
which exceed 100 mph (87 knots).
Restricting the speed of Model Aircraft not
participating in an FAA-accepted safety program will mean that high
performance aircraft will not be operated by individuals that are not
being scrutinized by their peers. Eliminating high-performance aircraft
will also help to ensure that the operator will be able to keep their
aircraft within the defined operational area (line-of-sight and below
400. AGL). Limiting the speed also will reduce the likelihood of turbine
powered aircraft being operated without the guidance of an FAA-accepted
safety program. Turbine powered aircraft are perceived by many members
of the ARC as being a higher risk.
(8) Model Aircraft cannot launch pyrotechnic devices which explode or
(9) Excluding take-off and landing, no powered
Model Aircraft may be flown closer than 25 feet to any individual,
except for the pilot and the pilots helper located at the flight line.
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