UA.I.E.K7: Modifications to an sUAS.

ACS Area I — Regulations Task E: Operations Over People References: 14 CFRCode of Federal RegulationsCloseThe federal rulebook where Part 107, Part 89, Part 48, and other aviation rules live. parts 89 and 107; ACAdvisory CircularCloseFAA guidance that explains acceptable ways to comply with rules or understand FAA procedures. 107-2; FAAFederal Aviation AdministrationCloseThe U.S. aviation regulator responsible for Part 107 rules, airspace, and pilot certification processes.-H-8083-25; FAAFederal Aviation AdministrationCloseThe U.S. aviation regulator responsible for Part 107 rules, airspace, and pilot certification processes.-G-8082-22

Key Concepts

Why modifications matter for Operations Over People (OOP)

• Part 107 permits OOPOperations Over PeopleClosePart 107 rules for flying over people, open-air assemblies, and related scenarios. only when the aircraft and operation meet category-specific requirements in Subpart D, with §107.39 otherwise prohibiting flight over people who are not under safe cover. Category 1 aircraft must weigh no more than 0.55 pounds (250 grams) and have no exposed rotating parts that would lacerate human skin; Category 4 requires an airworthiness certificate under 14 CFRCode of Federal RegulationsCloseThe federal rulebook where Part 107, Part 89, Part 48, and other aviation rules live. part 21 with Flight Manual limits. Any change that alters these characteristics can change OOPOperations Over PeopleClosePart 107 rules for flying over people, open-air assemblies, and related scenarios. eligibility and what you may legally do over people^[6].
• The remote pilot is responsible for ensuring the aircraft is in the correct category for the intended operation, and that it is properly labeled and listed on an FAAFederal Aviation AdministrationCloseThe U.S. aviation regulator responsible for Part 107 rules, airspace, and pilot certification processes.‑accepted Declaration of Compliance (DOCDeclaration of ComplianceCloseManufacturer compliance document that matters for some Operations Over People categories.). If a modification changes eligibility, the labeling and DOCDeclaration of ComplianceCloseManufacturer compliance document that matters for some Operations Over People categories. must match before you fly OOPOperations Over PeopleClosePart 107 rules for flying over people, open-air assemblies, and related scenarios.^[3].

What counts as an “allowable” modification—and the DOC/labeling impacts

• The Remote Pilot Operating Instructions (RPOIResponsible Person of InterestCloseAn FAA contact or responsible-party role used in some operational and compliance contexts.) identify allowable modifications. A modification not allowed by the RPOIResponsible Person of InterestCloseAn FAA contact or responsible-party role used in some operational and compliance contexts. can render the aircraft ineligible for OOPOperations Over PeopleClosePart 107 rules for flying over people, open-air assemblies, and related scenarios., trigger the need to submit a new DOCDeclaration of ComplianceCloseManufacturer compliance document that matters for some Operations Over People categories., and may require relabeling to reflect the new eligible category. When the aircraft is sold, transferred, or used by someone other than the original applicant, the applicant must provide RPOIResponsible Person of InterestCloseAn FAA contact or responsible-party role used in some operational and compliance contexts. that reflect the aircraft’s eligible category and acceptable modifications^[1].
• RPOIResponsible Person of InterestCloseAn FAA contact or responsible-party role used in some operational and compliance contexts. should be current and clear so the PICPilot in CommandCloseThe person responsible for the flight. Under Part 107, this is usually the remote pilot in command. understands how to configure the aircraft to comply with OOPOperations Over PeopleClosePart 107 rules for flying over people, open-air assemblies, and related scenarios. requirements. Some models are eligible for Category 2 and Category 3 only if the remote pilot follows the modification instructions; any modification not provided for in those instructions voids that eligibility^[2].
• Practical tip: Treat any changes to components, configurations, or attachments as potentially eligibility‑affecting unless the RPOIResponsible Person of InterestCloseAn FAA contact or responsible-party role used in some operational and compliance contexts. explicitly authorizes them for the intended category. If in doubt, do not conduct OOPOperations Over PeopleClosePart 107 rules for flying over people, open-air assemblies, and related scenarios. until the DOCDeclaration of ComplianceCloseManufacturer compliance document that matters for some Operations Over People categories., labeling, and RPOIResponsible Person of InterestCloseAn FAA contact or responsible-party role used in some operational and compliance contexts. all align with the modified configuration^[1][2][3].

Category limits you must preserve after modification

• Open‑air assemblies: Category 1 and Category 2 operations are prohibited from sustained flight over open‑air assemblies unless the operation meets §89.110 or §89.115(a); this prohibition is waiverable. Category 3 aircraft must not operate over open‑air assemblies. Category 4 aircraft may operate over people if not prohibited by FAAFederal Aviation AdministrationCloseThe U.S. aviation regulator responsible for Part 107 rules, airspace, and pilot certification processes.‑approved Flight Manual limitations, but are also prohibited from sustained flight over open‑air assemblies unless §§89.110 or 89.115(a) are met (also waiverable). If a modification shifts your aircraft’s category, these permissions and prohibitions can change immediately^[7].
• Moving vehicles: Outside a closed- or restricted‑access site, Category 1, 2, and 3 operations are “Transit Only, No Sustained Flight” over moving vehicles. Within a closed/restricted site, operations may occur when persons not directly participating are “on notice.” Category 4 operations follow Flight Manual/Administrator‑specified operating limitations. A modification that changes category or operating limitations affects what you can do over moving vehicles^[5].
• Direct participants may be overflown in all categories; ensure any modification doesn’t push the aircraft out of the intended category before using that allowance^[6][5].

Preflight, night operations, and modification examples to watch

• Preflight: Verify all manufacturer‑required components are present and operating as designed, and review the RPOIResponsible Person of InterestCloseAn FAA contact or responsible-party role used in some operational and compliance contexts.. This is your last chance to catch unapproved modifications or configuration errors that would invalidate your OOPOperations Over PeopleClosePart 107 rules for flying over people, open-air assemblies, and related scenarios. eligibility^[8][3].
• Night: OOPOperations Over PeopleClosePart 107 rules for flying over people, open-air assemblies, and related scenarios. categories do not change at night, and eligible aircraft may operate over people at night in accordance with §§107.29 and 107.39. Manufacturers declaring Category 2 or 3 eligibility may need to consider the mass of an anti‑collision light in their compliance basis—adding such a light could affect the aircraft’s declared configuration if not accounted for in the RPOI/DOCResponsible Person of Interest / Declaration of ComplianceCloseOperations Over People shorthand tying a declared aircraft configuration to its compliance record.^[4].
• Category 1 sensitivity: Exceeding 0.55 pounds (250 grams) or introducing exposed rotating parts that could lacerate skin eliminates Category 1 eligibility—common pitfalls when adding or swapping parts^[6].

Know your aircraft’s category, labeling, DOCDeclaration of ComplianceCloseManufacturer compliance document that matters for some Operations Over People categories., and RPOIResponsible Person of InterestCloseAn FAA contact or responsible-party role used in some operational and compliance contexts. before and after any change. If a modification is not explicitly allowed, do not fly OOPOperations Over PeopleClosePart 107 rules for flying over people, open-air assemblies, and related scenarios. until eligibility, labeling, and documentation are corrected^[1][2][3].