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Category 3 classification for sustained flight over people and moving vehicles

jburtonRTK

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I'm wondering if anyone has successfully gotten their Evo 2 V3 to qualify for FAA's Category 3? https://www.faa.gov/uas/commercial_operators/operations_over_people

Here is the definition: Category 3 eligible small unmanned aircraft must not cause injury to a human being that is equivalent to or greater than the severity of injury caused by a transfer of 25 foot-pounds of kinetic energy upon impact from a rigid object, does not contain any exposed rotating parts that could lacerate human skin upon impact with a human being, and does not contain any safety defects. Requires FAA-accepted means of compliance and FAA-accepted declaration of compliance.

I know the Evo 2 has the declaration of compliance for remote ID, and you could attach a parachute to reduce the kinetic energy (links at bottom), then add some prop guards and you should be good to go I would think. Is it worth it?

 
I'm wondering if anyone has successfully gotten their Evo 2 V3 to qualify for FAA's Category 3? https://www.faa.gov/uas/commercial_operators/operations_over_people

Here is the definition: Category 3 eligible small unmanned aircraft must not cause injury to a human being that is equivalent to or greater than the severity of injury caused by a transfer of 25 foot-pounds of kinetic energy upon impact from a rigid object, does not contain any exposed rotating parts that could lacerate human skin upon impact with a human being, and does not contain any safety defects. Requires FAA-accepted means of compliance and FAA-accepted declaration of compliance.

I know the Evo 2 has the declaration of compliance for remote ID, and you could attach a parachute to reduce the kinetic energy (links at bottom), then add some prop guards and you should be good to go I would think. Is it worth it?

Kinetic energy is Ek=mV^2/2, which for m=1.191 kg EVO 2 Pro V3 flying at 12 m/s max horizontal speed equals 85.752 J or 63.247 ft-lb. Also, if EVO 2 Pro V3 hovers at h=400 ft=121.92 m, loses battery energy, and falls to the ground by converting the potential into kinetic energy, it delivers Ep=mgh=1424 J. Air drag force during the fall was not accounted for. To meet 25 foot-pounds of kinetic energy (=33.89 J) upon impact from a rigid object, EVO 2 Pro V3 should fly at a speed below 3.5 m/s or fall from an altitude not higher than h=9.5 ft. None of the above estimates meet 25 ft-lb (33.89 J) requirements in most EVO 2 Pro V3 flight scenarios. So, EVO 2 Pro V3 is unlikely to to qualify for FAA's Category 3.
It looks like flying a drone high over people's heads with old or almost drained batteries is the most dangerous scenario to potentially injure someone.

Consequently, a 249 g drone flying horizontally at a speed equal to or below 16.5 m/s will meet the requirement of 25 ft-lb of kinetic energy upon impact from a rigid object (a human body), but not if falls from an altitude higher than 45.5 ft.
 
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Unfortunately, the specific parachute model would have to be ASTM (I believe) tested on the specific drone model and if approved, be added to the list. Unfortunately, none of the Autel have been added with any parachute models, last time I checked.

How about not sustaining flight directly over a person, just transversing briefly while on a mapping mission, etc? Then there’s 107.19 to heed, ensuring no undue hazard if there’s a loss of control, etc. That’s where, in my opinion, a parachute, even if not ASTM approved, is still a good mitigation technique. The page below has a good graphic explanation of this.

Ultimate Guide to Over People Waivers & Section 107.39

I’m sure the official testing is expensive, but it would be nice to see companies like ParaZero testing on more models, ours included. I was digging, hoping to find a solution for my Evo 2 pro to comfortably map over parking lots with activity, but finally accepted that there’s nothing currently available to help with the waiver. I hope to be wrong on that some day.

https://parazero.com/products/astm-professional-kit/
 
Unfortunately, the specific parachute model would have to be ASTM (I believe) tested on the specific drone model and if approved, be added to the list. Unfortunately, none of the Autel have been added with any parachute models, last time I checked.

How about not sustaining flight directly over a person, just transversing briefly while on a mapping mission, etc? Then there’s 107.19 to heed, ensuring no undue hazard if there’s a loss of control, etc. That’s where, in my opinion, a parachute, even if not ASTM approved, is still a good mitigation technique. The page below has a good graphic explanation of this.

Ultimate Guide to Over People Waivers & Section 107.39

I’m sure the official testing is expensive, but it would be nice to see companies like ParaZero testing on more models, ours included. I was digging, hoping to find a solution for my Evo 2 pro to comfortably map over parking lots with activity, but finally accepted that there’s nothing currently available to help with the waiver. I hope to be wrong on that some day.

https://parazero.com/products/astm-professional-kit/
Thanks for the reply Dfly. You got to the root of my question there, does a mapping mission in a grid pattern count as sustained flight? I guess not, but I've just been getting into the weeds about the definition of sustained flight. I think having a parachute for times when we couldn't ensure no undue hazard will be a good option for us.
 
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Autel does not have a declaration of compliance for any of their drones to meet the requirements of any category. The declaration of compliance for RID has nothing to do with the declaration of compliance for flight over people categories. So, no you cannot lawfully use any Autel drone in a manner that is prohibited by the final rule on flight over people. Adding a parachute does not cut it for compliance with the rule. The bit about "sustained flight" is also irrelevant since your drone does not meet the category 3 requirements for any flight at all over people, sustained or not.

Remember, this whole thing starts off with operation over people was established as one in which a small unmanned aircraft passes over any part of any person who is not directly participating in the operation and who is not located under a covered structure or inside a stationary vehicle. All flight over any people anywhere is prohibited. The categories provide defined exception criteria. If you don't meet the equipment requirements for one of the categories (which you don't), then none of the described exceptions apply to you.

does a mapping mission in a grid pattern count as sustained flight?.
The sections of the rule that provide exceptions for not sustained flight over people only apply if your aircraft meets category 3 requirements and you're operating under all the rules and requirements of category 3, which you won't be doing with an Autel Evo 2.
 
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Autel does not have a declaration of compliance for any of their drones to meet the requirements of any category. The declaration of compliance for RID has nothing to do with the declaration of compliance for flight over people categories. So, no you cannot lawfully use any Autel drone in a manner that is prohibited by the final rule on flight over people. Adding a parachute does not cut it for compliance with the rule. The bit about "sustained flight" is also irrelevant since your drone does not meet the category 3 requirements for any flight at all over people, sustained or not.

Remember, this whole thing starts off with operation over people was established as one in which a small unmanned aircraft passes over any part of any person who is not directly participating in the operation and who is not located under a covered structure or inside a stationary vehicle. All flight over any people anywhere is prohibited. The categories provide defined exception criteria. If you don't meet the equipment requirements for one of the categories (which you don't), then none of the described exceptions apply to you.


The sections of the rule that provide exceptions for not sustained flight over people only apply if your aircraft meets category 3 requirements and you're operating under all the rules and requirements of category 3, which you won't be doing with an Autel Evo 2.
So tell me this then, what non DJI or Autel drone could be purchased right now that does comply with Cat 2 or 3? Is there any sort of authoritative list from the FAA? I can't find one.
 
So tell me this then, what non DJI or Autel drone could be purchased right now that does comply with Cat 2 or 3? Is there any sort of authoritative list from the FAA? I can't find one.
There are no category 2 UAS in existence today from anyone. The only category 3 UAS are AgEagle fixed wings. Nobody else has made anything. I doubt any quad copter will ever meet the category 3 requirements due to the catastrophic loss of control that happens when one motor fails.

If you really need to fly over people, doing so with a small UAS that meets category 1 weight requirements and with category 1 propeller guards installed. There is no certification. You (the RPIC) self certify that you're safely flying in accordance with category one.
 
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