4.1.4
Category 4 Performance Standards
This category prescribes performance standards and operational restrictions for operations over
people that are conducted by UAS that present the same level of risk of “serious” injury as Category
3, but that involve sustained flight over people beyond what is permitted in Category 3, specifically
flight over crowds and/or dense gatherings of persons. Because an increased number of people on
the ground may be subjected to overhead flight of longer duration, the ARC recommends
prescribing additional operational mitigations for this category. Specifically, the ARC discussed the
various risk factors presented in the week-one presentations and determined that, along with other
factors, operator qualifications are an important mitigation in sustained operations of this category
UAS over crowds of people and should be included in a mission-appropriate manner through a risk
mitigation plan, similar in nature to already established FAA “Congested Area Plan” processes. As a
result, the ARC included this requirement in operational restrictions described below.
Category 4 includes operations conducted by UAS operators that present the same risk as UAS
conducting Category 3 operations over people, but without Category 3 operational limitations, and
therefore require a risk mitigation plan specific to the operation (discussed below in Section 4.3.4).
The industry consensus standards for this category are also the same as the standards for Category 3,
but with the addition of the risk mitigation plan, which may include coordination with the FAA or
event sponsor, municipality or local law enforcement, and pilot training, experience and certification
commensurate with the increased risk, as determined by an industry consensus standard.
In addition to safety of persons on the ground, the recommended addition of engagement with
appropriate third parties is intended to address concerns about the social acceptance of operating a
UAS over large gatherings or events. It is the ARC’s recommendation that this facilitation of local
engagement, while not intended as a delegation of jurisdiction over UAS operations, will be helpful
to address community concerns.
To facilitate the development of industry consensus standards for small UAS that qualify for
Category 4 operations over people that are acceptable to the FAA Administrator, the ARC
recommends that in addition to Category 3 requirements, the industry consensus standards must:
(1) Require a risk mitigation plan that addresses, at a minimum: (a) higher operator qualifications
than the proposed part 107; and (b) the method of compliance with the risk mitigation plan,
including the possibility of engagement with appropriate local entities.
(2) Consider materials and components of the UAS to determine if the materials pose additional
potential risk of collateral serious injury to people on the ground, in addition to injury caused
by initial impact.
April 1, 2016
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