sUAS NPRM Draft Advisory Circular (HIDDEN TREASURE)

Could there have been a sexier title? I don’t think so. For all those out there who have yet to see the draft AC for Part 107, let me say… it’s quite good. It can also be found here as part of the docket. Huzzah! If you haven’t read it yet, go read it now. It’s more important than this article. Then come back. I’ll wait here.



Let’s Begin.

Most operators and organizations I talk to and work with for Exemption 333 applications or CoA development, wonder what they require. Most are business people looking to apply this amazing new technology of drones to a real need. Using their business school degrees or their entrepreneurial spirit, they have found a true market niche and want to drive commerce. Whether that niche is using a drone to examine a heat signature of crops to determine parasitic invasion, using a fixed-wing mounted with a sonar pulse to determine densities in geolayering, or simply using a quadcopter to take pictures of dropping water levels in California, they all are hoping I will have the answer for what EXACTLY the FAA wants.

Most of their questions are the wrong ones. They want to know how long until they can fly legally. They want to know why their last safety case came out so poorly (before I got involved), or how they can do the bare minimum to get into the air. Some people want me to write their operating manual or their manufacturer’s manual since they built their quad copter themselves from parts at the local hobby store. Until recently, there hasn’t been a very good source that I could point them too. I could show them any number of industry based standards such as EUROCAE ED 78A, SAE ARP4754A, or SAE ARP4761. For some more organizational issues I could point them to internal Navy document OPSNAV 3500.39C or ICAOs 9859 AN/474. For maintenance and manual information I’d rely on FAA National Policy 8900.227 or FAA AC 120-92.

When people now ask me where to look, of course, we have the sUAS NPRM and soon to be rule (est. 2017) that has any number of delineations and answers to these questions. One source, however, that is being overlooked – probably because very few people know that is available online as part of the NPRM docket – is the Draft FAA Advisory Circular accompanying the NPRM. While of course the NPRM has to be issued first, this draft AC simplifies and clarifies all the information within the sUAS rule and makes using it much easier for operators, manufacturers, and operating organizations. Information provided in its Appendix includes what I’d like to mention a bit today – Operator checklist of themselves to aid conducting risk assessments and hazard identification. The table below is not directly from the document, so the terms may be slightly different.

Risk Scoring matrix

Most of us have seen the risk assessment matrix. For those that have not, you have the severity of a hazard and the likelihood that will occur. You put those in a matrix and determine if the hazard you are examining is acceptable in its associated risk or it needs to be mitigated. If it is red it requires mitigation, green requires little or no mitigation, and yellow requires more examination and likely results in a need for mitigation. A precursor, and probably the most important part of the risk assessment process, is successful hazard identification. The better the hazard identification, the more meaningful the risk examination becomes.

The sUAS rule offers a checklist and process for examining the operation and environment within which a flight is being planned. This will likely be missed unless an operator pays special attention to it (as it is nestled in the very last portion of the appendix)_, and should be seen for its elegance and applicability in flight planning. The Tool is called PAVE and IMSAFE. These acronyms are actually questions that an operator should ask before flight:


Personal – Am I healthy for flight and what are my personal minimums based upon my experience operating this small UAS?STEVE-sick

I’M SAFE Checklist Portion for PERSONAL

  • Illness – Am I suffering from any illness or symptom of an illness which might affect them in flight?
  • Medication – Am I currently taking any drugs (prescription or over-the counter)?
  • Stress – Am I experiencing any psychological or emotional factors which 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?

Aircraft – Have I conducted a preflight check of my small UAS (aircraft, controlstation, takeoff and landing equipment, etc.) and determined it to be in an aircraft prior to flight?condition for safe operation? Is the filming equipment properly secured to the

enViroment – What’s 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?

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?

Aside from the EnVironment acting as the V for PAVE, this acronym really makes a lot of sense in flight planning, but also in the risk assessment process. Risk Assessment and mitigation is not intended to be overly onerous. It is intended to get operators and flight planners thinking about the environment, the system, and stakeholders involved to avoid accidents or incidents. By following this simple acronym checklist, flights ops can be made much safer in a minimal amount of time.

Again, this comes directly from the Draft AC. It is not a comprehensive checklist by any means, but if every small drone operator went through this similar process, the airspace would be made safer even despite its complexities.

As a special treat I am also copying below a simple checklist that I encourage all my students go through when developing their own pre-flight risk assessment tool. This, again, is not comprehensive and does not address every problem that may arise or everything condition that may lead to failure. In fact, I have left specific things out so that – after reading through regulations – a student can add to this list and develop their own risk assessment tool. If you can honestly say that each item on the sheet is “in the green” or that you have sufficiently thought about that item and included mitigations for flight, you feel confident in your pr-flight condition.

As I try to instill in all students: Before you can prove to the FAA that you are safe, you must prove it to yourself. UAS Flight Risk Assessment

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