UA.V.F.K7: Manufacturer's Declaration of Compliance for Category 2 and 3 operations.
ACS Area V — Operations Task F: Maintenance and Inspection Procedures References: A-7
Key Concepts
Eligibility and what a “Declaration of Compliance” must cover (Category 2 and 3)
For a small UAS to be used in Category 2 operations over people, the aircraft must be designed, produced, or modified so that it will not cause injury equivalent to or greater than 11 foot-pounds of kinetic energy on impact, has no exposed rotating parts that would lacerate human skin, and contains no safety defects. These are the baseline technical thresholds the manufacturer must meet before declaring compliance for Category 2 use. The applicant must also provide a Category 2 label that is English, legible, prominent, and permanently affixed; and provide remote pilot operating instructions made available upon sale/transfer or when used by someone other than the applicant. Those instructions must include at least: a system description (required components, limitations, and declared categories), permitted modifications that do not change eligibility, and instructions for how to verify and change the mode or configuration. These elements are integral to the manufacturer’s declaration and to your operational compliance as a pilot.[3]
Category 3 has its own eligibility standard in §107.130(a) (not reproduced here). However, the declaration and supporting materials for Category 3 must similarly address how the aircraft and its configurations meet the Category 3 requirements.[1]
FAA-accepted means of compliance: how manufacturers show it, and ongoing oversight
To establish that a Category 2 or Category 3 aircraft meets its eligibility requirements, the accepted “means of compliance” must consist of test, analysis, or inspection. The applicant submits procedures describing the applicable tests/analyses/inspections, including conditions, environments, and methods, and explains how applying those methods fulfills §107.120(a) (Cat 2) or §107.130(a) (Cat 3). The FAA notifies the applicant when it has accepted the means of compliance. Importantly, acceptance is not permanent: the FAA may rescind an accepted means of compliance upon ongoing review and will publish a notice of rescission in the Federal Register. Practically, if a means of compliance is rescinded, the basis supporting a declaration can be undermined, and operators must track manufacturer and FAA notices that may affect the aircraft’s eligibility for Category 2 or 3 operations.[1]
Many small UAS can be produced for multiple categories. That’s permitted, but configuration control is critical: the aircraft may be eligible for one or more categories only if the remote PIC cannot inadvertently switch between modes or configurations. This drives both manufacturer design and your preflight verification: you must know which mode/configuration is active and ensure it cannot be changed unintentionally during flight.[1]
Labels, instructions, and the pilot’s maintenance/inspection role
Two labeling duties matter for exams and real-world compliance:
- Manufacturer/applicant duty: The Category 2 label must be English, legible, prominent, and permanently affixed to the aircraft.[3]
- Pilot duty if a label is damaged, destroyed, or missing: Before conducting operations over people, the remote PIC must affix an English label that is legible, prominent, will remain on the aircraft for the duration of the operation, and correctly identifies the eligible category(ies). This ensures traceability of the aircraft’s declared capability during each operation.[2]
Your preflight inspection must actively use the manufacturer’s operating instructions provided with the declaration. Verify:
- The aircraft is in the declared Category 2 or 3 configuration per the instructions (and that you can verify and, if necessary, change the mode/configuration as described).[3]
- No modifications beyond those listed as not changing eligibility have been made.[3]
- There are no exposed rotating parts that would lacerate skin (Category 2) and no safety defects.[3]
- The mode/configuration cannot be inadvertently switched in flight (configuration control).[^^1]
Operationally, remember that operations over people and moving vehicles are category-dependent. Part 107 restricts operations over people to Categories 1–4; you must operate under the applicable category and its limitations.[7] For moving vehicles outside a closed- or restricted-access site, Category 2 and 3 operations are “transit only, no sustained flight.” Within a closed- or restricted-access site, persons not directly participating must be “on notice.” These constraints inform mission planning and risk mitigations you’ll list in your preflight and maintenance/inspection checklists.[5] With respect to open-air assemblies, Category 3 aircraft must not operate over open-air assemblies, and Category 2 operations are prohibited in sustained flight over open-air assemblies unless the operation meets the requirements of §89.110 or §89.115(a). Know these limits when determining whether the declared category actually permits the intended operation.[8]
Bottom line for the test and for safe operations: memorize the Category 2 technical threshold of 11 foot-pounds, the labeling and instruction requirements tied to the manufacturer’s declaration, the “test, analysis, or inspection” means of compliance, and your role in configuration control and labeling if a label is missing. These are frequent exam targets and everyday compliance checks.
Test Yourself
UA.V.F.K7No practice questions are currently available for this specific knowledge element.