Operations Over People Study Guide

ACS Area I, Task E — Operations Over People — sits inside Regulations, the single largest content area at 48% of the current FAA Part 107 knowledge test (UAG_Information_Bulletin.pdf, p. 4). It is also, by the FAA’s own measurement, the hardest thing on the exam: the ACS code at the center of this guide, UA.I.E.K13 (Declaration of Compliance), is the only UAG code the FAA’s quarterly report lists above a 70% miss rate. The full data trend lives on the most-missed page — this guide covers the regulation itself, in the depth that miss rate suggests it deserves.

The baseline rule, then the category system

Before subpart D existed, part 107 already allowed flight over people in two narrow cases: the person is directly participating in the operation, or the person is under a covered structure or inside a stationary vehicle that gives reasonable protection from a falling aircraft (14-cfr-107.txt, § 107.39(a)–(b)). Those two exceptions still apply to every operation, regardless of category.

Subpart D — Category 1 through Category 4 — is the additional pathway that lets a qualifying aircraft fly over people who are neither participating nor sheltered (14-cfr-107.txt, § 107.39(c), § 107.100). Every operation over a person who doesn’t fit the baseline exceptions must satisfy one of these four categories.

	Category 1	Category 2	Category 3	Category 4
Qualifying standard	≤ 0.55 lb. at takeoff (everything attached included); no exposed rotating parts that would lacerate skin	Impact injury ≤ a transfer of 11 ft-lb of kinetic energy from a rigid object; no lacerating rotating parts; no safety defects	Impact injury ≤ a transfer of 25 ft-lb of kinetic energy from a rigid object; no lacerating rotating parts; no safety defects	FAA airworthiness certificate under 14 CFR part 21
Needs a Declaration of Compliance?	No	Yes	Yes	No — type certification instead
Over open-air assemblies	Prohibited unless Remote ID–compliant (§ 89.110 or § 89.115(a))	Same	Always prohibited — no exception	Prohibited unless Remote ID–compliant
Over other non-participants	Permitted if the weight/parts standard is met	Permitted if listed on an accepted DoC and labeled accordingly	Only within a closed- or restricted-access site with notice, or without sustained flight over the person	Per the limitations in the approved Flight Manual

(14-cfr-107.txt, §§ 107.110, 107.115, 107.120, 107.125, 107.130, 107.140.)

Category 3’s “no sustained flight” option is the one most often misread. The AC defines sustained flight concretely: hovering above someone’s head, flying back and forth over them, or circling so the aircraft stays above some part of their body (AC_107-2A.txt § 8.3.6.7). A brief, incidental pass over a person while transiting elsewhere does not count — but lingering does, even without stopping.

Minimum distances from a person — there is no FAA number

ACS code UA.I.E.K5 asks about “minimum distances from a person,” and the honest answer trips people up because it isn’t a number at all: part 107 imposes no specific stand-off distance from people. The remote pilot must choose an appropriate distance by judgment, weighing the aircraft’s performance (course, speed, maneuverability), environmental conditions, the operational area, probable failure modes, and the pilot’s own skill — and must keep reassessing that distance as conditions change (AC_107-2A.txt § 8.3.1). Anyone expecting a fixed figure here — by analogy to the 500 ft./2,000 ft. cloud clearance numbers in § 107.51(d) — is importing a rule from a different section.

Operations over moving vehicles

A small UA may not fly over a person inside a moving vehicle unless the operation both qualifies under one of the four categories above and meets an extra condition specific to moving vehicles (14-cfr-107.txt, § 107.145):

• Category 1, 2, or 3: the aircraft must either stay within or over a closed- or restricted-access site (with everyone inside the vehicle on notice that a small UA may fly over them), or simply never sustain flight over moving vehicles.
• Category 4: must hold a part 21 airworthiness certificate and operate within Flight Manual limits that don’t prohibit flight over people in moving vehicles.

This is a narrower rule than the general over-people categories — it adds a vehicle-specific condition on top of, not instead of, the category requirement that already applies.

Required components, labeling, and modifications

Any aircraft operating under Category 2 or 3 must carry three things, all tied to the manufacturer’s (or modifier’s) declaration (14-cfr-107.txt, §§ 107.120(b), 107.130(b)):

1. A permanent, legible, English-language label on the aircraft stating its eligible category.
2. Remote pilot operating instructions covering the system description, allowed modifications, and how to verify/change modes if the aircraft supports more than one category.
3. A product support and notification process so the applicant can tell the FAA and the public about any defect that would make the aircraft no longer meet the category’s requirements.

If a label is damaged, destroyed, or missing, the remote pilot in command — not the manufacturer — must re-label the aircraft before flying over people again, correctly identifying its qualified category (14-cfr-107.txt, § 107.135).

Modifications are where DoC eligibility quietly breaks. The operating instructions list which modifications are allowed without affecting the aircraft’s category eligibility — replacing propellers with a part the instructions specifically permit, for example, doesn’t require anything new. But any modification not covered by those instructions makes the aircraft ineligible for the category it was declared under. If the person making that modification still wants to fly the modified aircraft over people, they personally become an “applicant”: they must demonstrate the modified configuration meets the Category 2 or 3 standard through an accepted means of compliance, and file a new declaration (AC_107-2A.txt §§ 8.4.4–8.4.5).

Declaration of Compliance (DoC) and Means of Compliance (MoC)

These two terms, and the relationship between them, are the center of the 78.58% miss rate. They are not the same document, and they are not filed by the same party for the same purpose.

Means of Compliance (MoC) is the method — the test, analysis, or inspection procedure that proves an aircraft design meets the Category 2 or 3 injury-energy and safety-defect standards (14-cfr-107.txt, § 107.155(a)). Anyone can submit a proposed MoC to the FAA for acceptance — an individual manufacturer, or a standards body like ASTM International or SAE (AC_107-2A.txt § 8.5). Once the FAA accepts an MoC, any applicant can rely on it. The FAA also publishes its own ready-to-use MoC for the kinetic-energy requirement: an applicant measures the aircraft’s maximum attainable forward airspeed and runs it through the FAA’s formula, rather than designing a custom test program (AC_107-2A.txt § 8.6).

Declaration of Compliance (DoC) is the filing — the record an applicant submits to the FAA certifying a specific aircraft (by make, model, and serial number or range) meets Category 2 or 3 requirements, identifying which accepted MoC it relied on (14-cfr-107.txt, § 107.160(a)). The required fields include the applicant’s name, address, and email; the aircraft’s make/model/series and serial number(s); whether the filing is an initial or amended declaration; the MoC used; and a certification that the applicant verified no safety defects exist and will allow FAA inspection on request.

Who files it. “Applicant” means anyone who designs, produces, or modifies a small UA (AC_107-2A.txt § 4.2.1) — ordinarily the manufacturer, but exactly as described above, a remote pilot who modifies their own aircraft outside the permitted-modifications list becomes an applicant too, with the same filing burden. The remote pilot in command’s day-to-day obligation is different and much lighter: use an aircraft that’s already listed on an FAA-accepted DoC and correctly labeled (§ 107.115(a), § 107.125(a)) — not to file anything themselves, unless they’ve also modified the aircraft.

What it covers, and what it doesn’t. A DoC only exists for Category 2 and Category 3. Category 1 needs no DoC because its 0.55 lb. weight limit is self-verifying. Category 4 needs no DoC either — it substitutes a part 21 airworthiness certificate and part 43/91 maintenance program for the entire performance-based framework (14-cfr-107.txt, § 107.140(d)). Confusing “needs a DoC” with “qualifies to fly over people” is one of the most common ways this topic gets missed: Categories 1 and 4 both permit the same kind of operation without ever touching § 107.160.

Rescission. The FAA can rescind an accepted DoC if the aircraft stops meeting its category’s requirements, the FAA finds the declaration in violation of § 107.5(a), or the Administrator determines a safety emergency exists. Outside an emergency, the FAA must first notify the holder of a safety issue and give 30 calendar days to respond before rescinding (14-cfr-107.txt, § 107.160(c)–(d)). No one may operate an aircraft under a rescinded DoC while it stays rescinded.

Why this sits inside the exam’s largest block

Task E is one task among six inside ACS Area I, and Area I alone is 48% of the scored questions — nearly half the exam (src/data/blueprint.json; see the full breakdown on What’s Actually on the Part 107 Test). A topic the FAA’s own data flags as its hardest-missed code isn’t a corner case to skim past; it’s inside the block most likely to decide a pass or fail. The most-missed page walks through exactly how the FAA measures that miss rate, and the multi-year trend showing it’s getting worse, not better.

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Drill this exact material with Operations Over People practice questions, or read the most-missed page for the FAA’s own data behind this topic.

Frequently asked questions

Do all four categories of operations over people require a Declaration of Compliance?

No. Only Category 2 and Category 3 aircraft need one. Category 1 qualifies by weight alone (0.55 lb. or less), and Category 4 substitutes a part 21 airworthiness certificate — neither needs a DoC (14-cfr-107.txt, §§ 107.110, 107.140).

See why DoC is the FAA's most-missed topic →

Is there a minimum distance I must keep from a person under part 107?

No specific number. Part 107 requires the remote pilot to use judgment — weighing the aircraft's performance, environment, and failure modes — rather than following a fixed stand-off distance (AC_107-2A.txt, § 8.3.1).

Drill operations-over-people questions →

What's the difference between a Means of Compliance and a Declaration of Compliance?

A Means of Compliance (MoC) is the test/analysis/inspection method that proves an aircraft design meets the injury-energy standard. A Declaration of Compliance (DoC) is the filing that certifies a specific aircraft meets that standard using an accepted MoC (14-cfr-107.txt, §§ 107.155, 107.160).

See why DoC is the FAA's most-missed topic →

If I modify my drone, do I need to file my own Declaration of Compliance?

Only if the modification isn't on the list of allowed modifications in the manufacturer's remote pilot operating instructions. In that case you become the 'applicant' and must requalify the modified aircraft and file a new DoC before flying it over people again (AC_107-2A.txt, §§ 8.4.4–8.4.5).

Drill operations-over-people questions →