This question from a pilot came in through my ReportDroneAccident.com website. You can ask me questions here or here.

The Question

Hey Steve,

Just came across your website. It is very important to share this knowledge in the way you do. Thank you!

I was wondering if you have any info regarding the Matrice 300 RTK recently launched. I own one and after reviewing what you wrote about the Matrice 210 I am worried.

Could you please share your thoughts on this new model?

My Answer

Thank you so much for your question.

I’m a huge fan of facts. So this is just my opinion based on the facts that I know. I encourage everyone to use whatever sources of information and facts to make their own decisions.

The DJI Matrice 300 RTK looks like another step forward in the drones we’ve seen before.

DJI claims the following characteristics.

One source of information has been marketing and salespeople. They can be a good conduit of information but ultimately they are trying to sell units. That’s okay, that’s what they do.

But even trade associations have been a poor source of factual and balanced information about risks and issues pilots have experienced with nearly all drones.

I think the DJI Matrice 300 RTK falls into the same category that other drones have to deal with – it’s not built to any standard that has passed an FAA airworthiness inspection and found to be safe to fly.

There is a tremendous lack of testing and public data available to understand what the risks are. In the absence of that information, I think the DJI Matrice 300 RTK should be flown with the same care that other models that have not proven to be airworthy should be flown.

It should not be flown over any people or property that could be damaged if it falls out of the sky.
The flight should always be conducted within visual line of sight.

As you read the extensive airworthiness standards below, just ask yourself how your drone meets those standards.

For example:

If the DJI Matrice 300 RTK has a motor in flight will it continue to fly under control?
How is the Matrice 300 “designed to safeguard against inadvertent discontinuation of the flight and inadvertent release of cargo or external-load?
DJI says the Matrice 300 has an IP45 rating, but what does that really mean? What are the limits of tested weather the aircraft can safely fly in without failure? By the way, IP45 means “Protected from low-pressure water jets from any direction.” – Source
What are the critical parts on the Matrice 300 that can lead it to crash?
Most importantly, what are the maintenance, inspections, and/or life limits of those parts?
What is the rate of failure of DJI Matrice 300 RTK aircraft in any flight testing conducted by DJI?

I looked at the DJI Matrice 300 RTK specifications page and could not find the answers to those questions.

I’m Not Trying to Discourge You

I just want you to understand that the drone you are flying has not been found to be any safer to fly than a toy. It has not passed an aviation authority airworthiness standards test, and you should fly it like it is going to come out of the sky at any moment, no matter how few hours it has on it.

COA Agencies Should be Concerned

Now that we have airworthiness standards out from the FAA, they give COA agencies that are self-certifying their drone are airworthy, a standard to meet. The question is, how many really will, and then what is their risk exposure if they have no done so?

So What Do Airworthiness Standards Look Like

I would invite you to ask your sales representative for material DJI may have supplied on the following points so you can compare.

Just recently the FAA released the airworthiness criteria they are requiring the Percepto Robotics – Percepte System 2.4 to meet or exceed. So these would be a good guide to compare against the DJI Matrice 300 RTK engineering data.

While the Percepto System 2.4 is about twice as heavy, the same engineering standards apply.

In the public document, the FAA will publish tomorrow, they say, “The FAA considered the size of the proposed aircraft, its maximum airspeed and altitude, and operational limitations to address the number of unmanned aircraft per operator and to address operations in which the aircraft would operate beyond the visual line of sight of the pilot. These factors allowed the FAA to assess the potential risk the aircraft could pose to other aircraft and to human beings on the ground. Using these parameters, the FAA developed airworthiness criteria to address those potential risks to ensure the aircraft remains reliable, controllable, safe, and airworthy.”

The information below is a summary of what the FAAexpects an airworthy drone to meet or exceed to be safe to fly.

Proposed Airworthiness Criteria

The FAA proposes to establish the following airworthiness criteria for type certification of the Percepto Model Percepto System 2.4. The FAA proposes that compliance with the following would mitigate the risks associated with the proposed design and Concept of Operations appropriately and would provide an equivalent level of safety to existing rules:

GENERAL

UAS.001 Concept of Operations.

The applicant must define and submit to the FAA a concept of operations (CONOPS) proposal describing the Unmanned Aircraft System (UAS) operation in the National Airspace System for which certification is requested. The CONOPS proposal must include, at a minimum, a description of the following information.

(a) The intended type of operations;

(b) Unmanned aircraft (UA) specifications;

(d) Operators, pilots, and personnel responsibilities;

(e) Control station and support equipment;

(f) Command, control, and communication functions; and

(g) Operational parameters, such as population density, geographic operating boundaries, airspace classes, launch and recovery area, congestion of proposed operating area, communications with air traffic control, line of sight, and aircraft separation.

DESIGN AND CONSTRUCTION

UAS.100 Control Station.

The control station must be designed to provide the pilot with all information required for continued safe flight and operation. This information includes, at a minimum, the following:

(a) Alerts, such as an alert following the loss of the command and control (C2) link and function.

(b) The status of all critical parameters for all energy storage systems.

(d) Flight and navigation information as appropriate, such as airspeed, heading, altitude, and location.

(e) C2 link signal strength, quality, or status.

UAS.110 Software.

To minimize the existence of errors, the applicant must:

(a) Verify by test all software that may impact the safe operation of the UAS;

(b) Utilize a configuration management system that tracks, controls, and preserves changes made to software throughout the entire life cycle; and

UAS.115 Cyber Security.

(a) UAS equipment, systems, and networks, addressed separately and in relation to other systems, must be protected from intentional unauthorized electronic interactions that may result in an adverse effect on the security or airworthiness of the UAS. Protection must be ensured by showing that the security risks have been identified, assessed, and mitigated as necessary.

(b) When required by paragraph (a) of this section, procedures and instructions to ensure security protections are maintained must be included in the Instructions for Continued Airworthiness (ICA).

UAS.120 Contingency Planning.

(a) The UAS must be designed so that, in the event of a loss of the C2 link, the UA will automatically and immediately execute a safe predetermined flight, loiter, landing, or termination.

(b) The applicant must establish the predetermined action in the event of a loss of the C2 link and include it in the UAS Flight Manual.

(c) The UAS Flight Manual must include the minimum performance requirements for the C2 data link defining when the C2 link is degraded to a level where remote active control of the UA is no longer ensured. Takeoff when the C2 link is degraded below the minimum link performance requirements must be prevented by design or prohibited by an operating limitation in the UAS Flight Manual.

UAS.125 Lightning.

(a) Except as provided in paragraph (b) of this section, the UAS must have design characteristics that will protect the UAS from loss of flight or loss of control due to lightning.

(b) If the UAS has not been shown to protect against lightning, the UAS Flight Manual must include an operating limitation to prohibit flight into weather conditions conducive to lightning activity.

UAS.130 Adverse Weather Conditions.

(a) For purposes of this section, “adverse weather conditions” means rain, snow, and icing.

(b) Except as provided in paragraph (c) of this section, the UAS must have design characteristics that will allow the UAS to operate within the adverse weather conditions specified in the CONOPS without loss of flight or loss of control.

(c) For adverse weather conditions for which the UAS is not approved to operate, the applicant must develop operating limitations to prohibit flight into known adverse weather conditions and either:

(1) Develop operating limitations to prevent inadvertent flight into adverse weather conditions; or

(2) Provide a means to detect any adverse weather conditions for which the UAS is not certificated to operate and show the UAS’s ability to avoid or exit those conditions.

UAS.135 Critical Parts.

(a) A critical part is a part, the failure of which could result in a loss of flight or unrecoverable loss of UAS control.

(b) If the type design includes critical parts, the applicant must establish a critical parts list. The applicant must develop and define mandatory maintenance instructions or life limits, or a combination of both, to prevent failures of critical parts. Each of these mandatory actions must be included in the Airworthiness Limitations Section of the ICA.

OPERATING LIMITATIONS AND INFORMATION

UAS.200 Flight Manual.

The applicant must provide a UAS Flight Manual with each UAS.

(a) The UAS Flight Manual must contain the following information:

(1) UAS operating limitations;

(2) UAS normal and emergency operating procedures;

(3) Performance information;

(4) Loading information; and

(5) Other information that is necessary for safe operation because of design, operating, or handling characteristics.

(b) Those portions of the UAS Flight Manual containing the information specified in paragraphs (a)(1) through (4) of this section must be approved by the FAA.

UAS.205 Instructions for Continued Airworthiness.

The applicant must prepare ICA for the UAS in accordance with Appendix A to Part 23, as appropriate, that are acceptable to the FAA. The ICA may be incomplete at type certification if a program exists to ensure their completion prior to delivery of the first UAS or issuance of a standard airworthiness certificate, whichever occurs later.

TESTING

UAS.300 Durability and Reliability.

The UAS must be designed to be durable and reliable commensurate to the maximum population density specified in the operating limitations. The durability and reliability must be demonstrated by flight test in accordance with the requirements of this section and completed with no failures that result in a loss of flight, loss of control, loss of containment, or emergency landing outside the operator’s recovery area.

(a) Once a UAS has begun testing to show compliance with this section, all flights for that UA must be included in the flight test report.

(b) Tests must include an evaluation of the entire flight envelope across all phases of operation and must address, at a minimum, the following:

(1) Flight distances;

(2) Flight durations;

(3) Route complexity;

(4) Weight;

(5) Center of gravity;

(6) Density altitude;

(7) Outside air temperature;

(8) Airspeed;

(9) Wind;

(10) Weather;

(11) Operation at night, if requested;

(12) Energy storage system capacity; and

(13) Aircraft to pilot ratio.

(c) Tests must include the most adverse combinations of the conditions and configurations in paragraph (b) of this section.

(d) Tests must show a distribution of the different flight profiles and routes representative of the type of operations identified in the CONOPS.

(e) Tests must be conducted in conditions consistent with the expected environmental conditions identified in the CONOPS, including electromagnetic interference (EMI) and High Intensity Radiated Fields (HIRF).

(f) Tests must not require exceptional piloting skill or alertness.

(g) Any UAS used for testing must be subject to the same worst-case ground handling, shipping, and transportation loads as those allowed in service.

(h) Any UAS used for testing must be maintained and operated in accordance with the ICA and UAS Flight Manual. No maintenance beyond the intervals established in the ICA will be allowed to show compliance with this section.

(i) If cargo operations or external-load operations are requested, tests must show, throughout the flight envelope and with the cargo or external-load at the most critical combinations of weight and center of gravity, that—

(1) the UA is safely controllable and maneuverable; and

(2) the cargo or external-load are retainable and transportable.

UAS.305 Probable Failures.

The UAS must be designed such that a probable failure will not result in a loss of containment or control of the UA. This must be demonstrated by test.

(a) Probable failures related to the following equipment, at a minimum, must be addressed.

(1) Propulsion systems;

(2) C2 link;

(3) Global Positioning System (GPS);

(4) Critical flight control components with a single point of failure;

(5) Control station; and

(6) Any other equipment identified by the applicant.

(b) Any UAS used for testing must be operated in accordance with the UAS Flight Manual.

UAS.310 Capabilities and Functions.

(a) All of the following required UAS capabilities and functions must be demonstrated by test:

(1) Capability to regain command and control of the UA after the C2 link has been lost.

(2) Capability of the electrical system to power all UA systems and payloads.

(3) Ability for the pilot to safely discontinue the flight.

(4) Ability for the pilot to dynamically re-route the UA.

(5) Ability to safely abort a takeoff.

(6) Ability to safely abort a landing and initiate a go-around.

(b) The following UAS capabilities and functions, if requested for approval, must be demonstrated by test:

(1) Continued flight after degradation of the propulsion system.

(2) Geo-fencing that contains the UA within a designated area, in all operating conditions.

(3) Positive transfer of the UA between control stations that ensures only one control station can control the UA at a time.

(4) Capability to release an external cargo load to prevent loss of control of the UA.

(5) Capability to detect and avoid other aircraft and obstacles.

(c) The UAS must be designed to safeguard against inadvertent discontinuation of the flight and inadvertent release of cargo or external-load.

UAS.315 Fatigue.

The structure of the UA must be shown to be able to withstand the repeated loads expected during its service life without failure. A life limit for the airframe must be established, demonstrated by test, and included in the ICA.

UAS.320 Verification of Limits.

The performance, maneuverability, stability, and control of the UA within the flight envelope described in the UAS Flight Manual must be demonstrated at a minimum of 5% over maximum gross weight with no loss of control or loss of flight.

You can read the entire FAA document here.

Thank you for reaching out to me and asking your question.

Steve