"The minimum impact energy you show for the parachute system fitting a DJI M300 is 26.81 ft-lbs at minimum TOW, but the FAA requirement for Category 3 (flying over people) says the impact force can not be greater than 25 ft-lbs of impact force. How can you meet that requirement?"
So, we reached out Josh Ogden of AVSS, the manufacturer to get the low down and here is what we learned:
(1) Means of Compliance – The Applicant Completes in Advance (e.g., Manufacturer, Modifier)
This is a test, analysis, inspection, or combination by the Applicant, which can be the manufacturer (e.g., DJI, FreeFly Systems, FLIR, Teal Drones) and/or modifier (e.g., AVSS, Indemnis, Mars Parachutes, Parazero), that can demonstrate key safety data points.
The Applicant will collect the data points (e.g., kinetic energy, descent rates, AIS Level 3 percentages, minimum deployment altitude) through an industry-accepted standard and/or custom testing method.
These can be through a pre-approved means of compliance or an acceptable means of compliance.
(2) Declaration of Compliance – Applicant Submits to the FAA
This is a document that the Applicant will submit to the FAA for approval.
This document will state how the Applicant met the FAA’s requirement in the event of a failure and that the drone will not exceed the kinetic energy allotment nor will rotating parts that are exposed result in a laceration.
Retain records of compliance and means of compliance that the FAA can review at a future date.
"Establish and maintain a process to notify the public and FAA of any safety defects that cause the small unmanned aircraft to no longer meet the requirements of Category 2 and Category 3”.
Why These New Rules Matter for Pilots & Manufacturers?
For Pilots, these new rules will be simpler for you to evaluate the business case of flight over people. It should also enable you to evaluate your current fleet of drones and determine which drone manufacturers and/or modifiers will enable you to legally expand your operations.
For Manufacturers, these new rules will matter if some of your clients will expect you to make a Declaration of Compliance. These clients may include operators who otherwise would have required extensive security to limit bystanders entering the flight areas, such as a bridge inspection over a walking trail or a thermal inspection of a downtown building. As well, your Public Safety clients who must fly among crowds and Industrial clients who are completing facility inspections over fellow employees.
Where to Go from Here
For Pilots, your first step should be to evaluate how flight over people could expand your operations. This may include (a) evaluating your current fleet of drones, (b) calling your local drone dealer to determine if they have drones or parachute recovery systems that meet the FAA’s Declaration of Compliance requirements, and (c) calling your clients/evaluating your internal use case to determine if there is clear value in meeting these new rules. Also, do not expect to see a solution relatively soon as the FAA has said this process will take Applications 9 to 12 months from the published date.
For Manufacturers, this will require some effort, a budget, and supply chain partners. To start with minimal costs, you can read through the new flight over people rules, ASTM F3322-18 for requirements of a parachute recovery system, and ASTM F3389-20 for “test methods to determine a drone’s blunt force trauma injury potential to the head or neck, or both, during a collision with a person on the ground”.