The RCAPA Proposed Guidelines

Patrick Egan

These guidelines have been referenced numerous times in stories and commentary across the web and here as recently as part of the 2011 year wrap up. They are posted here as both a reference for what has been done not just as far as written down, but what was a baseline for small business viability and a fraction of what had already transpiring safely in the NAS prior to 2007.

These Proposed Guidelines are not to be taken lightly as they are the most comprehensive set of community based standards yet seen heretofore and can stand on their own as immediately implementable backed up by procedures, a pilot testing program and liability insurance.

The historical significance of the guidelines speaks volumes. Over the years, the community has had to endure the frustration of hearing “I don’t know”, and glaring blank stares as responses to a myriad of relevant questions or suggestions for a common sense NAS integration solution. Much hand wringing and calls for data and a litany of other sorry excuses have been throwing up and out road blocking and sandbagging the process. (The process is so dysfunctional that it can easily justify and support two superlatives.)

These Guidelines where brought into the sUAS ARC as a starting point. The only other group that had anything on paper was MITRE. Which, by the way, contained information that was gathered from RCAPA. Nothing comprehensive or offering a common sense solution to this situation and beyond that theirs was a contracted piece where as the RCAPA guidelines where given to the government free, with no charge to the taxpayer. As far as we know the Guidelines where not incorporated into the ARC recommendation.

Another iteration of these guidelines exists that were reformatted for the ASTM consensus standards process. However, to the best of my knowledge they have fallen into the black hole of Calcutta and not seen since. 

27 May, 2008

This is document was produced by RCAPA to assist the FAA in developing regulatory guidance

for the safe integration of small and very small UAS into the NAS. As a member of the ASTM

committee and the RTCA SC-203, RCAPA has contributed data from a very early stage. The

following Proposed Operational Guidelines and Definitions for Ultra Light Class (A), Mini Class

(B) and Small Class (C), incorporates knowledge gained through involvement in this process.

The most important factor in this process is the insertion of empirical data gathered from the

operational experience of the RCAPA membership. This type of data has obvious inherent

advantages to modeling the hypothetical.

The goal of RCAPA has always been three fold. First is to insure safety of other aviation interests

and the general public. Second is to achieve and maintain that level of safety with minimal

regulatory burden. Third is to promote professionalism and excellence in the field of small UAS

operations. This proposal intends to incorporate these goals to achieve a safe and simple

guidance that will allow small individual business owners to resume commercial operations with

the least impact to the NAS. The resumption of those operations would allow data collection to

continue providing input to this dynamic situation.

This proposal addresses the concerns as presented from the general aviation community and

other potential UAS stakeholders. Those reoccurring concerns that are addressed are as follows:

  1. Airspace conflicts.

  2. See and Avoid/ Sense and Avoid

  1. Safety of those on the ground

  2. Aircraft/pilot certification

  1. Radio interference

The prospect of integrating UAS into the NAS, when viewed in its entirety, is daunting. There are

enormous challenges to overcome, both technical and regulatory. It is only sensible to progress

in incremental “baby steps” and to begin with the segment of UAS activity that poses minimal

risks. Those are risks that are the simplest to mitigate and will require little or no action or

accommodation from existing aviation interests. Expedient implementation in this area would

provide the cornerstone for the continuance of an enviable safety record in the operation of small

UAS in the national airspace.

As the sponsors of this “DRAFT” document we invite comments and suggestions.



The RCAPA board



Proposed Operational Guidelines and Definitions for Ultra Light

Class (A), Mini Class (B) and Small Class (C) UAS


Proposed operational guidelines to define the basic aircraft type specifications and

operational limitations for class (A) ultra light UAS to be operated with specific

restrictions within the national airspace in developed areas for commercial purposes.

  1. Section 1. Aircraft Definitions and Restrictions. The following shall apply to Class

(A) Ultra Light UAS:

(a) CLASS (A) ULTRA LIGHT UAS shall be defined as being no more than 4 pounds AUW (all up weight).

(b) POWER SYSTEM-Such aircraft shall be electrically powered and carry no flammable liquid type fuel.

  1. MAXIMUM SPEED- The aircraft shall have a normal operating speed of less than 40 knots in level flight.

  1. PROHIBITIONS-Aircraft shall not be equipped to drop any object or to spray or disperse any liquid or substance.

    (e) MARKINGS-Aircraft shall be clearly labeled with the operator’s business

name and contact information as well as any required FAA registration


(f) CONSTRUCTION-The aircrafts frontal areas and wing leading edges

should be made of soft materials such as foam to the extent that is

practical and consistent with airworthiness.

(g) AIRFRAME IDENTIFICATION- Upon being constructed by the operator

or by a manufacturer, each airframe shall be permanently marked with an

identifying number.

  1. Section 2. Aircraft Operational Limitations.

Aircraft may operate in urban or developed areas within the limitations

described herein.

(a) Aircraft shall not be operated within 150 yards of an open air assembly of

large numbers of persons such as public events.

(b) Aircraft shall not be operated within 3 miles of an airport without prior

approval of, and establishing a line of communication for the duration of the

flight operation with, the controlling authority of that airport.

(c) Aircraft shall be operated at an altitude no higher than 400ft AGL (above

ground level).

(d) Aircraft shall avoid areas where manned aircraft can be expected to be

descending through 400ft.

(e) Aircraft shall not be flown in airspace restricted to manned aircraft or in a

Flight Restricted Zone (FRZ) without specific prior authorization of each

flight from the controlling authority of that airspace.

(f) Aircraft shall maintain a minimum horizontal separation of no less than

2000yds from all other manned or unmanned airborne aircraft unless that

other aircraft is maintaining level flight or climbing at an altitude above

8000ft AGL.

(g) Aircraft shall be flown during daylight hours (civil twilight) only, under

direct visual control (DVC) and within visual line of sight (VLOS) and “pilot

in command” (PIC) at all times. The operator shall “see and avoid” as well as

hear and avoid” all other aircraft and hazards. Avoidance of airspace conflict

shall take precedence over all other aspects of operation and shall be the full

responsibility of the operator.

(h) If at any time the operator see or hears another aircraft and it appears that

aircraft may enter the area in which the operator’s system is airborne as

defined in PART 1, Sec. 2, (f), or it is questionable whether or not it will do

so, the operator shall immediately descend the system to 200 ft. AGL or less

and direct the system on a heading toward it’s designated landing area, or

alternate landing area if necessary, until the system has landed or it is

determined the other aircraft has cleared the area in a way that is compliant

with PART 1, Sec. II (f).

(i) Aircraft shall be kept within the limits of the operators unaided vision at

all times, with the exceptions to unaided vision being sunglasses and /or

prescription eyewear. The operator MAY be assisted by an observer. If an

observer is assisting the operator, the observer may use binoculars or other

vision aids to assist the operator in detecting potential conflicts of airspace and

in maintaining visual contact with the system being operated. This shall in no

way relieve the operator (PIC) of his/her responsibility for keeping the aircraft

at all times within the limits of his/her unaided vision.

(j) The operator shall keep the aircraft within 500yds of his/her position in the

horizontal plane to assure the aircraft remains well within range of the radio

control system as well as to assure maintaining visual contact.

(k) The aircraft/system shall be controlled by an interference tolerant radio

control system and a system range check shall be done before each flight or

series of flights.

(l) Aircraft shall implement fail safe features of the radio control system set

to reduce throttle to a setting for slow decent and induce a slight turn to

prevent a fly off in addition to providing the highest chance of re-acquisition

in the event of a radio control system failure or “loss of link.” Passive fail

safe measures such as trimming the aircraft to make a slight turn when in

powered flight without operator intervention may also be implemented.

(m) Only one airborne system shall be controlled by one operator at any given

time and only one operator may operate the flight controls of a particular

system while it is airborne. The only exception to this being for flight training

purposes which are not to be conducted in developed areas.

(n) IN AN EMERGENCY ONLY, the operator shall be allowed to diverge

from any part of PART 1, Sec. 2 if good judgment indicates it is specifically

necessary to do so to avoid an immediate hazard but such divergence shall be

made only to the minimum extent necessary to avoid such hazard. The

operator shall immediately return to operation within the requirements of

Section 2 once the immediate hazard is avoided.

(o) If absolutely necessary to avoid a hazard to persons, property, conflict of

airspace with another aircraft or any other significant hazard, the operator

may, as a last resort, terminate the flight operation with a controlled flight into

a safe area of the ground or body of water. Potential sites for this type of

emergency flight termination shall be selected at the start of each flight. The

operator shall always consider safety of persons and avoidance of conflict of

airspace to take precedence even if that requires that the system being

operated be made expendable.

(p) After every five hours of total flight time or 25 take off and landing

cycles, whichever occurs first, or if the aircraft suffers any significant damage

that requires repair, the aircraft shall be removed from service and given a

detailed mechanical inspection and any mechanical issues noted and repaired

before it is placed back in service.

(q) After any significant repairs or modifications to the aircraft a minimum of

20 flight minutes of flight test time shall be flown in an undeveloped area and

shall include a minimum of 2 take off and landing cycles.

(r) Prior to each flight the operator shall make a careful pre- flight inspection

of the aircraft that includes all potential points of mechanical failure that could

lead to malfunction or loss of control of the aircraft. All systems shall be test

functioned in the manner that they are used by the UAS in operation.

III Section 3 DOCUMENTATION- The operator of a commercial UAS shall

document aircraft operation as follows:

(a) The operator shall maintain a log of each flight and note any accidents or

incidents involving persons or property as well as erratic or errant function of

any part of the aircraft or support equipment. Log shall be prefaced with a

detailed description of the aircraft that includes any manufactured equipment

and/or parts installed. Entries shall be made of any damage to the aircraft as

well as repairs and subsequent testing of repairs. Log entries shall also be

made of any divergence as outlined in PART 1, Sec. II. (n)

(b) Log details for each flight shall as a minimum include date, time, general

location, purpose for and nature of the flight activity, and total flight time.

  1. Notes and all other relevant data resulting from compliance with Sec. 2

including documentation for manufactured replacement parts shall be attached

to the aircrafts log.

(d) The operator shall inform the FAA in writing within 24 hours of any

incident involving harm to a person or any damage to property that exceeds


(e) Operators shall inform the FAA in writing or by online registration

if/when that option is made available, of their intention to engage in

commercial operations.

(f) Copies of all aircraft flight logs and related documentation shall be kept

with the operator during all flight operations and shall be made available to

the FAA immediately upon request.


(a) AIRCRAFT SAFTY PROVISIONS-All aircraft shall meet the applicable

general and radio control portions of the Academy of Model Aeronautics

National Model Aircraft Safety Code with the exception that the provisions of

Part 1, Sections I and II (a) above shall take precedence.

(b) SELF-CERTIFICATION- If more than 51% of the aircraft is built and/or

assembled by the operator, the builder/operator shall “self certify” the aircraft

being used and be responsible fo r assuring the aircraft is in a safe and

airworthy condition prior to any flight In accordance with 14 CFR 91.7.


(See below **)

(d) INITIAL CERTIFICATION- Upon initial construction, the aircraft shall

be test flown by the intended operator, in an undeveloped area, for a

cumulative time of at least one hour and perform at least 2 take off and

landing cycles prior to being used for commercial purposes to assure operator

familiarity and system reliability.



shall be the person directly operating and/or managing the aircrafts flight

controls and shall do so at all times while the aircraft is airborne. The operator

shall bear the full responsibility for the safe operation of the aircraft and

compliance with all applicable rules and regulations.

(b) ADDITIONAL OPERATORS-Additional persons may operate onboard

systems such as, for example, cameras or imaging equipment but only if such

operation and equipment does not adversely alter the flight characteristics of

the aircraft.


operator shall be both physically and mentally capable of holding a valid

drivers license and shall in fact have a lega lly issued driver’s license from one

of the 50 states or a US territory.

(d) OPERATOR LACK OF CRIMINAL RECORD-The operator must not be

a fugitive from justice for any crime.


responsible for exercising due diligence and good judgment regarding their

level of experience and level of experience with any particular aircraft/system

being used prior to engaging in commercial activity.

(f) AREA FAMILIARIZATION- The operator shall make themselves aware

of any airports, airstrips or established heliports in the general area in which

they intend to conduct operations.

(g) ENGLISH FLUENCY- The operator must be able to speak, understand

and read the English language.

(h) AGE- An operator must be at least 18 years of age to engage in

commercial UAS activity.

(i) All operators must affirm to the FAA that they are aware of and

understands these regulations.

(i) UNIMPAIRED OPERATION-In accordance with 14 CFR 91.17, Aircraft

of this type shall never be flown while the operator is under the influence of

alcohol or any drugs whether prescription or non prescription that would

impair the operator in any way or if the operator is in any other way impaired

in such a way to limit or restrict his/her ability to operate the aircraft safely.


(a) It shall be considered unlawful to knowingly and/or intentionally threaten,

intimidate, interfere with, attempt to distract or harasses any operator of any

UAS while they are in control of a system that is in the air or under that

operator’s control on the ground.



(a) All the definitions for a ULTRALIGHT CLASS (A) UAS apply with the

exception that a MINI CLASS (B) UAS may weigh up to 12 pounds and have

a normal operating speed of less than 40 knots in level flight.

(b) Aircraft shall have a data logging device installed that records length of

flight time, altitude and positional data throughout the duration of each flight.

II Sec. 2 Aircraft Operational Limitations.

All the operational limitations and requirements detailed for ULTRALIGHT

CLASS (A) UAS shall apply to MINI CLASS (B) UAS with the following


(a) The operator SHALL be assisted by an observer at all times. Observer

duties shall include acting as a back up to the operator in maintaining visual

contact with the UAS as well as monitoring of the airspace around the UAS

for other aircraft, potential conflicts of airspace and/or other hazards.

(b) Aircraft may be operated at a maximum altitude of 1000 ft AGL.

(c) Aircraft may be operated at a maximum distance from the operator of


(d) Aircraft shall avoid operating within 300yds in the horizontal plane of

such things as residential structures, places of business that serve large

numbers of people and heavily trafficked roadways with the specific

exception being structures and roadways associated with agricultural activity.

(e) The vehicle shall be constructed in a robust manner to prevent structural


(f) If the system is to be operated outside the parameters of the Class (A)

ULTRALIGHT UAS requirements listed above regarding distance from

operator and altitude, the system shall have a dedicated “loss of link”

capability to return to a designated point and orbit. This system shall be

checked for proper function prior to and enabled for the duration of each


(g) The aircraft shall be clearly equipped with high visibility markings to

assist in control of the system and long range visibility of the system by other




The definitions and restrictions for CLASS (A) AND CLASS (B)

UAS shall apply with the following exceptions.

(a) A CLASS (C) UAS may weigh up to 25 pounds.

(b) Aircraft may be powered electrically or by an internal combustion engine

but if powered by an internal combustion engine may carry no more than 1/2

gallon of liquid fuel.

(c)) The aircraft shall have a normal operating speed of less than 45 knots in

level flight.

(d)Aircraft shall be equipped with a dedicated flight termination system that

operates independently of the aircrafts’ normal flight controls and radio

control link. The flight termination system shall render the aircraft incapable

of aerodynamic flight.

II Sec. 2 AIRCRAFT OPERATIONAL LIMITS. The operational limitations of a

CLASS (A) and CLASS (B) UAS shall apply with the following exceptions:

a. The aircraft shall be operated only in undeveloped areas and not within

500yds in the horizontal plane of such things as residential structures, heavily

trafficked roadways or business that serve large numbers of people with the

specific exception of low population structures and roadways associated with

agricultural activity.

b. Aircraft may be operated at an altitude up to 1200ft. AGL but may exceed

400ft. AGL only if terrain and weather conditions allow the operator clear

visibility to a distance of not less than 2000yds from all points at which the

system will be airborne to facilitate compliance with Part 1, Sec. 2 (h).

c. If the aircraft suffers a “loss of link” and/or the operator is unable to

assume manual control of the aircrafts flight control system, the operator shall

immediately prepare to engage the flight termination system and shall do so to

terminate the flight before the aircraft exceeds the distance from the operator

as detailed in Part 2, Sec. 2, (c) and/or before the aircraft is in conflict with

Part 3, Sec. 2, (a) or sooner if it becomes apparent it is necessary to do so to

avoid any other hazard.

* RCAPA is currently revising its written and video testing program to reflect recent

developments and feedback from various FAA sources. Additional feedback from the

FAA and industry is expected to be produced by the upcoming ARC (Advisory

Rulemaking Committee) in which RCAPA will participate. If regulators accept the

program, RCAPA will release the updated version as soon after incorporating this

additional information as possible.

** There are currently no recognized manufactures of systems of this class of UAS.

As the markets served by systems of this type develops that will likely change.

Manufacturer certification standards will need to be developed based on data gathered

as a result of the commercial activities allowed and generated as the result of

implementation of this body of regulations.