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Daylight waiver 107.29

frli1031

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The FAA is refusing to grant me my waiver until I answer one question which I have no idea what more they want me to tell them. It's a question I have seen in other posts but have not seen the answer to the question. Here it is below. If anyone has been successful with this question, I would appreciate your assistance. I am only including the FAA's response.
The reply states “Prior to flying in the area of our operation, we will create a printed map or diagram of the area. The map will depict the positions of our Remote PIC and Visual Observers (VO), ensuring we have continuous VLOS of our sUA during its entire flight. The map will also show a highlight of our flight route, along with pre-selected emergency landing areas and alternative/emergency routes that are free from congested airspace or any departure or approach paths of other aircrafts to mitigate the risk of our sUA from
entering the path of another aircraft during a loss of communication link situation.”
  • - The reply mentions landing areas, alternate/emergency routes, and VLOS but none of these are a method that prevents (mitigates the risk) the sUA from entering the path of another aircraft (manned or unmanned) during Return to Home mode while in lost link communication operation. During lost link the RPIC has NO communication with the sUA so the sUA is uncontrolled; it can’t be maneuvered by anyone or commanded to land by anyone. With the sUA flying uncontrolled there is a chance it’s flight path, pre-programmed or not, could result in the sUA entering the path of another aircraft that has entered the operational area (or is near the operational area). Keep in mind manned and unmanned aircraft may be operating in or near your operational area at any altitude at any time without prior notice.

Please provide a method to satisfy the above mentioned concern.
 
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I have not filed a waiver for 107.29, but have you seen the UAS Facility Maps [1]? They dictate how high you may go near an airport. I recently got an airspace use authorization after promising that my aircraft will be allowed to go no higher than 300 ft. above ground (maximum allowed at the client's location) before commencing flight.

[1] UAS Facility Maps
 
The FAA is refusing to grant me my waiver until I answer one question which I have no idea what more they want me to tell them. It's a question I have seen in other posts but have not seen the answer to the question. Here it is below. If anyone has been successful with this question, I would appreciate your assistance. I am only including the FAA's response.
The reply states “Prior to flying in the area of our operation, we will create a printed map or diagram of the area. The map will depict the positions of our Remote PIC and Visual Observers (VO), ensuring we have continuous VLOS of our sUA during its entire flight. The map will also show a highlight of our flight route, along with pre-selected emergency landing areas and alternative/emergency routes that are free from congested airspace or any departure or approach paths of other aircrafts to mitigate the risk of our sUA from
entering the path of another aircraft during a loss of communication link situation.”
  • - The reply mentions landing areas, alternate/emergency routes, and VLOS but none of these are a method that prevents (mitigates the risk) the sUA from entering the path of another aircraft (manned or unmanned) during Return to Home mode while in lost link communication operation. During lost link the RPIC has NO communication with the sUA so the sUA is uncontrolled; it can’t be maneuvered by anyone or commanded to land by anyone. With the sUA flying uncontrolled there is a chance it’s flight path, pre-programmed or not, could result in the sUA entering the path of another aircraft that has entered the operational area (or is near the operational area). Keep in mind manned and unmanned aircraft may be operating in or near your operational area at any altitude at any time without prior notice.

Please provide a method to satisfy the above mentioned concern.

You can watch this webinar posted on the FAA website regarding how to obtain a daylight waiver: FAA Webinars
 
@frli1031 they are PROBABLY looking for a statement about geofencing. Such as the capabilities of DJI GEO 2.0 and the altitude restrictions in place.
 
Thank you for your response. I finally figured out what they were looking for. They don't want the drone to return home when it loses signal. They want the drone to be preset to go into its failsafe mode and land.
 
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