This document summarizes the purpose and activities of the Remote Control Aerial Photographers Association (RCAPA). In 3 sentences: RCAPA is an international organization with over 1,700 members that works to establish safety guidelines and best practices for the commercial drone industry. It provides resources like training, testing, and insurance access to members. The document outlines several challenges around integrating drones into national airspace systems, such as a lack of data to define safe operational limits and concerns that proposed regulations would severely limit small commercial drone operations.

2. We are a professional
association of dedicated
remote control aerial
photographers.
RCAPA provides operational
safety guidelines, business
best practices, international
networking opportunities and
new technology information.

3. History, purpose and affiliations
• RCAPA was founded 2004
• Has 1700 + members world wide
• We promulgate consensus based best
practices
• Conduct testing and continuing
education
• Produce safety based operational
guidelines
• Enable private liability insurance
• We are members of sUAS ARC and ICC

4. Global Integration issues
• Limited operational experience in the integration process
• Science “friction” emotion driven conclusions from
manned stakeholders
• Not utilizing available information and data
• Lack of non-military user involvement
• Lack of non-military operational understanding.
• Vendor business plans and agendas keep the issue open
ended. (resembles contract process, focused on what
they can get out of the regulation)
• Indifferent regulator reaction exacerbates current situation.
• No clear cut compliance process
• Lack of enforcement compels small operators not to be
involved.
• Understand similar issues in other countries

5. Unresolved Issues
Impeding Integration
• Confines of what is safe is yet to be scientifically defined
• Where is the empirical data that proves AC 91-57 type sUAS OPS
are unsafe?
• If we are to be held to the same level of safety as manned
aviation, what is the relative differential? (size/weight/speed how
does 10E-6 apply, if at all?)
• Required “data” yet to be identified/quantified
• Are these arbitrary operating envelopes viable ( e.g. 400’ AGL) for
empirical data gathering and business?
• Can a Data-set be captured in this small of an operating
envelope?
• Do we fit the definition of comp and hire? 14 CFR FAR Part 1.1 and
119?

6. Does this apply?
Definitions Title 14 Sec. 1.1 General definitions.
Commercial operator means a person who, for compensation or hire,
engages in the carriage by aircraft in air commerce of persons or
property, other than as an air carrier or foreign air carrier or under
the authority of Part 375 of this title. Where it is doubtful that an
operation is for ``compensation or hire'', the test applied is whether
the carriage by air is merely incidental to the person's other business
or is, in itself, a major enterprise for profit.

7. What about this?
Title 14 119.1 Applicability
Sec 6 (e) “...this part does not apply to—”
(4) Aerial work operations, including—
(i) Crop dusting, seeding, spraying, and bird chasing;
(ii) Banner towing;
(iii) Aerial photography or survey;
(iv) Fire fighting;
(v) Helicopter operations in construction or repair work (but it does
apply
to transportation to and from the site of operations); and
(vi) Powerline or pipeline patrol;

8. MTBF What does 10 - X mean?
The probability of failure (PF) or mishap is the expected number of mishaps
in a given amount of time (typically flight hours) usually expressed as an exponent.
Based on the type and quality of vehicle history or reliability data available, and accuracy
and/or conservatism required a rate is determined from:
• Actual vehicle mishap data
• Estimates based on reliability studies
• Comparison by similarity
• Worst case assumptions
• A combination of these approaches
For a new system, actual vehicle mishap data may be unavailable or have limited data points:
Hours flown without failure 95% Confidence that PF is equal or less than
10 3 X 10-1
30 1 X 10-1
100 3 X 10-2
300 1 X 10-2
Note that for a 1 X 10-9 failure rate with 95% confidence, over 3 BILLION hours will have to
be flown with no failures (342 years of solid flying)
*Source: Range Commanders Council document RCC 323 supplement
https://wsmrc2vger.wsmr.army.mil/rcc/manuals/323sup/323sup.doc

9. The next way would be to conduct an analysis of
the reliability of the vehicle
•Typical PFs for electronic components are 1 X 10-3 to 1 X 10-4, mechanical
rates are somewhat different
•For a 1 X 10-9 PF, this would require triple redundancy on ALL safety critical
electrical components, and redundancy on mechanical parts
• The operational reliability would suffer greatly as well as the usable payload
and cost
•Another approach would be to establish an equivalent level of safety (ELOS)
index such as PF times kinetic energy based on full size aircraft data and
apply it to UAS

10. An example….
• Current light aircraft PFs are on the order of 6.3 X 10-5 for relatively mature
aircraft/pilots and very mature operational procedures (see
http://www.aopa.org/asf/publications/07nall.pdf)
•A Cessna 172 weighs approximately 1000 kg (~2200 lbs) and cruises at 56 meters per
second (~125 MPH) with a kinetic energy of 1 X 10+6 (one million) joules
•A 45 kg (~100 lb.) UAS flying at 31 meters per second (~70 MPH) has a kinetic energy
of 2.2 X 10+4 joules
•A 11 kg (~25 lb.) UAS flying at 22 meters per second (50 MPH) has a kinetic energy of
2.6 X 10+3
•It would seem reasonable for a UAS to use the same 1 X 10-5 PF and then to allow a 1
X 10-2 reduction in reliability to account for the difference in kinetic energy
•This would permit a PF for UAS of 1 X 10-3, something that is analyzable and flight
hour verifiable
•Smaller UAS could be allowed an even higher PF

11. sUAS ARC Impressions
• No “data” or safety risk analysis going in
• Bins and boxes are a rehash of unacceptable RTCA work
• Those with operational experience were woefully
underrepresented
• Overall document lacks a comprehensive tone
• International Harmonization = Weights in kilo’s???
• Economic impact of recommendations are devastating
• All this will be compounded by use of standards groups

12. sUAS ARC Impressions
continued...
• Unwarranted and heavy-handed regulation of model
aviation.
• Type I operations leave little in the way of viability
• Operating greater than 3 NM of an airport
• System certification (what does it look like???)
• Manual flight control
• Type II operations put small operators in direct
competition with vendors (major enterprises for
profit)

13. sUAS ARC Impressions
continued...
• Type II and III operations shut out small operators
• Operating greater than 10 NM sometimes 30NM
from an airport
• System certification
• Required equipment takes most of payload
• Type IIII way beyond the reach of many.
• Type V LTA Lighter Than Air left out of
recommendation.

14. Affecting change
We need:
•Equivalent Level of Safety (ELOS) comparison
•Industry code of practice
•Formula for scale-able regulations (kinetic energy)
•Defined and capture-able data set
•Definable guidelines
•Aircraft certification plan
•Enforcement plan (comprehensive or otherwise)

15. FIN