"Flying over people" Drone Classifications

[Theoriginalgregtoo]

"Over" is "over, no matter the circumstances.

You just have to ask yourself if it's safe. Technically it's your fault if someone walks or drives under your drone. However, unless it falls out of the sky and lands on someone, it's impossible to determine if you flew over individuals.

Honestly, if anyone has flown in urban environments for more than a year or two, they're lying to themselves if they say they know they've never flown over a person. I know I can't say it with 100% certainty. We all try and avoid it, and should to the best of our ability.

Just be safe.

Thanks Vic, always appreciate your insight.

 

[striperseeker]

There ARE NO ROTORY wing OOP Compliant sUAS (up to 55lbs). IMO none will be due to kinetic energy ratings, speeds and weights all be too variable. Read Any 107 certified pilot knowns you can transit people (brief crossing). FAA is all about safety (and collecting data to use against us, but that's another issue). There is no way a sUAS with blades and top speeds of 87knots will be allowed over people without each person consent or in the flight group. Wording like "sparely popluated" and "minimal harm" cause issues because they are not defined by everyone the same way. Just remember, it's all about injury. If you injure someone with your sUAS and you were OOP, then the SWHTF, otherwise use common sense, stay to the periphery and fly on. Read these links:
Virginia Tech Mid-Atlantic Aviation Prtnership
First Drone passes Testing

 

[Vic Moss]

There ARE NO ROTORY wing OOP Compliant sUAS (up to 55lbs). IMO none will be due to kinetic energy ratings, speeds and weights all be too variable. Read Any 107 certified pilot knowns you can transit people (brief crossing). FAA is all about safety (and collecting data to use against us, but that's another issue). There is no way a sUAS with blades and top speeds of 87knots will be allowed over people without each person consent or in the flight group. Wording like "sparely popluated" and "minimal harm" cause issues because they are not defined by everyone the same way. Just remember, it's all about injury. If you injure someone with your sUAS and you were OOP, then the SWHTF, otherwise use common sense, stay to the periphery and fly on. Read these links:
Virginia Tech Mid-Atlantic Aviation Prtnership
First Drone passes Testing

Actually there are plenty of Category 1 OOP compliant drones. I have three.

 

[striperseeker]

Actually there are plenty of Category 1 OOP compliant drones. I have three.

I'd like to know which ones you are flying, since there are NO rotory sUAS on the FAA website with DoCs. The fact they all have exposed rotating parts.

• Category 1 small unmanned aircraft are permitted to operate over people, provided the small unmanned aircraft:
  • Weigh 0.55 pounds or less, including everything that is on board or otherwise attached to the aircraft at the time of takeoff and throughout the duration of each operation.
  • Contain no exposed rotating parts that would cause lacerations.

 

[Vic Moss]

I'd like to know which ones you are flying, since there are NO rotory sUAS on the FAA website with DoCs. The fact they all have exposed rotating parts.

• Category 1 small unmanned aircraft are permitted to operate over people, provided the small unmanned aircraft:
  • Weigh 0.55 pounds or less, including everything that is on board or otherwise attached to the aircraft at the time of takeoff and throughout the duration of each operation.
  • Contain no exposed rotating parts that would cause lacerations.

Category 1 drones do not require an FAA DOC. They are "certified" by the RPIC.

I have one Mini 2 w/ Japanese batteries, and a trimmed prop cage. I wrote an article about it: Category 1-OOP Compliant-DJI Mini 2 - Drone Service Providers Alliance

The other two are BETA FPV 95Xv2 with naked GoPros on them.

 

[striperseeker]

Category 1 drones do not require an FAA DOC. They are "certified" by the RPIC.

I have one Mini 2 w/ Japanese batteries, and a trimmed prop cage. I wrote an article about it: Category 1-OOP Compliant-DJI Mini 2 - Drone Service Providers Alliance

The other two are BETA FPV 95Xv2 with naked GoPros on them.

Well, all I have to say is, I hope you never get into a situation where a person is injured. Modifying the Mini 2 to skirt the issue at hand would probably go against you. And searching the DoC website, the Mini 2 doesn't show up as Remote ID compliant. I'm no expert but it seems it's still not compliant.

 

[Vic Moss]

Well, all I have to say is, I hope you never get into a situation where a person is injured. Modifying the Mini 2 to skirt the issue at hand would probably go against you. And searching the DoC website, the Mini 2 doesn't show up as Remote ID compliant. I'm no expert but it seems it's still not compliant.

It skirts nothing at all. It is 100% compliant. It doesn't need the DOC from the FAA.

And you don't need RID to be OOP compliant. You only need RID if you plan on flying "sustained flight over open-air assemblies of human beings", as per § 107.110 (c). If I were to put an RID module on it, it would not comply (over 250g). It's very unlikely I would be able to fly it under § 107.110 (c) conditions.

If you look at the OOP Final Rule (pg 70-72 here: https://www.govinfo.gov/content/pkg/FR-2021-01-15/pdf/2020-28947.pdf), you'll find the actual wording for OOP compliance. Categories 2 & 3 require that the drone "Is listed on an FAA-accepted declaration of compliance as eligible for Category 2 operations in accordance with § 107.160;", and Category 4 drones must "Have an airworthiness certificate issued under part 21 of this chapter.".

There is no FAA requirement like either of those for Category 1 OOP drones. It is up to the RPIC to determine its eligibility.

BTW, I am an expert, so I can promise you it does comply except for flights under § 107.110 (c).

 

[striperseeker]

It skirts nothing at all. It is 100% compliant. It doesn't need the DOC from the FAA.

And you don't need RID to be OOP compliant. You only need RID if you plan on flying "sustained flight over open-air assemblies of human beings", as per § 107.110 (c). If I were to put an RID module on it, it would not comply (over 250g). It's very unlikely I would be able to fly it under § 107.110 (c) conditions.

If you look at the OOP Final Rule (pg 70-72 here: https://www.govinfo.gov/content/pkg/FR-2021-01-15/pdf/2020-28947.pdf), you'll find the actual wording for OOP compliance. Categories 2 & 3 require that the drone "Is listed on an FAA-accepted declaration of compliance as eligible for Category 2 operations in accordance with § 107.160;", and Category 4 drones must "Have an airworthiness certificate issued under part 21 of this chapter.".

There is no FAA requirement like either of those for Category 1 OOP drones. It is up to the RPIC to determine its eligibility.

BTW, I am an expert, so I can promise you it does comply except for flights under § 107.110 (c).

Since transiant flights over people do not constitute OOP, what else is there? But, seeing as how your and expert and all, everyone else must be wrong.
Have a great day!

 

[Vic Moss]

Since transiant flights over people do not constitute OOP, what else is there? But, seeing as how your and expert and all, everyone else must be wrong.
Have a great day!

"sustiained flights over open-air assemblies", not individuals. Ands yes, Google is your friend, I am an expert.

Otherwise I wouldn't be having my quarterly meeting with the FAA next week in DC. And no, not everyone else is wrong, just you. At least in this thread.

I helped the FAA roll out this rule, it was sent to me so me and my team could put together videos about the rules.

And don't take my word for it, reach out to [email protected]. Mention this conversation. You may even get an email back today. Because I know for a fact that the person monitoring it today is keeping an eye on this inbox. Steve already emailed me about something else this morning.

Don't dismiss this conversation, use it as a learning moment. Maybe even @BigAl07 could pipe in and help you understand why you're wrong.

 

[Vic Moss]

Since transiant flights over people do not constitute OOP, what else is there? But, seeing as how your and expert and all, everyone else must be wrong.
Have a great day!

Maybe this will help you understand the difference too.

This is from the OOP Final Rule, page 2, "Sustained flight over an open-air assembly includes hovering above the heads of persons gathered in an open-air assembly, flying back and forth over an open-air assembly, or circling above the assembly in such a way that the small unmanned aircraft remains above some part the assembly. ‘Sustained flight’ over an open-air assembly of people in a Category 1, 2, or 4 operation does not include a brief, one-time transiting over a portion of the assembled gathering, where the transit is merely incidental to a point-to-point operation unrelated to the assembly"

You can find that here: https://www.govinfo.gov/content/pkg/FR-2021-01-15/pdf/2020-28947.pdf

Actual language from § 107.110 Category 1 operations:

To conduct Category 1 operations—
(a) A remote pilot in command must use a small unmanned aircraft that—
(1) Weighs 0.55 pounds or less on takeoff and throughout the duration of each operation under Category 1, including everything that is on board or otherwise attached to the aircraft; and
(b) Does not contain any exposed rotating parts that would lacerate human skin upon impact with a human being.
(c) No remote pilot in command may operate a small unmanned aircraft in sustained flight over open-air assemblies of human beings unless the operation meets the requirements of either § 89.110 or § 89.115(a) of this chapter.

Again, use this conversation as a learning opportunity. We're all here to help each other, and you don't understand the actual rules. So this is a good chance for you to learn them.

 

[striperseeker]

"sustiained flights over open-air assemblies", not individuals. Ands yes, Google is your friend, I am an expert.

Otherwise I wouldn't be having my quarterly meeting with the FAA next week in DC. And no, not everyone else is wrong, just you. At least in this thread.

I helped the FAA roll out this rule, it was sent to me so me and my team could put together videos about the rules.

And don't take my word for it, reach out to [email protected]. Mention this conversation. You may even get an email back today. Because I know for a fact that the person monitoring it today is keeping an eye on this inbox. Steve already emailed me about something else this morning.

Don't dismiss this conversation, use it as a learning moment. Maybe even @BigAl07 could pipe in and help you understand why you're wrong.

It's not a questions of right vs wrong with me. It's interpretting rules and regs that the FAA put out consistently and clearly. Obviously they didn't do that as many individuals interpret them like I do. The sematical games played in regs like these (which I've dealt with my entire adult life) doesn't help. What's an "open-are assembly" what's "sparsely populated" what's "a severe injury". I don't rely on Google other than to find the relevent authoritative website (in this case, FAA.GOV). In the end, the FAA's goals are to reduce injury or the chance of injury. Lesser educated pilots that aren't experts like you will read this post and interrpret it as a license to mod and skirt that intent. Just this uneducated persons POV.
Thanks.

 

[striperseeker]

Maybe this will help you understand the difference too.

This is from the OOP Final Rule, page 2, "Sustained flight over an open-air assembly includes hovering above the heads of persons gathered in an open-air assembly, flying back and forth over an open-air assembly, or circling above the assembly in such a way that the small unmanned aircraft remains above some part the assembly. ‘Sustained flight’ over an open-air assembly of people in a Category 1, 2, or 4 operation does not include a brief, one-time transiting over a portion of the assembled gathering, where the transit is merely incidental to a point-to-point operation unrelated to the assembly"

You can find that here: https://www.govinfo.gov/content/pkg/FR-2021-01-15/pdf/2020-28947.pdf

Actual language from § 107.110 Category 1 operations:

To conduct Category 1 operations—
(a) A remote pilot in command must use a small unmanned aircraft that—
(1) Weighs 0.55 pounds or less on takeoff and throughout the duration of each operation under Category 1, including everything that is on board or otherwise attached to the aircraft; and
(b) Does not contain any exposed rotating parts that would lacerate human skin upon impact with a human being.
(c) No remote pilot in command may operate a small unmanned aircraft in sustained flight over open-air assemblies of human beings unless the operation meets the requirements of either § 89.110 or § 89.115(a) of this chapter.

Again, use this conversation as a learning opportunity. We're all here to help each other, and you don't understand the actual rules. So this is a good chance for you to learn them.

maybe you can help understand what OOP actually means then. If transient flying over crowds is permitted without meeting any categories, and you state "open-air assembly" what other types of OOP are there?

 

[Vic Moss]

maybe you can help understand what OOP actually means then. If transient flying over crowds is permitted without meeting any categories, and you state "open-air assembly" what other types of OOP are there?

This is a classic example of "you can lead a horse to water, but you can't make it drink".

You can't "transit over crowds" w/o meeting one of the 4 categories. You can transit over crowds with what is currently a Category 1 or one of the Category 3 drones. But without RID you can't fly "sustained flights over open-air assemblies".

I already provided the links for this language.

And again, reach out to the FAA at the email I provided. Steve was monitoring the inbox over coffee, he may still be.

You need to be open to what people are telling you. I've explained everything already.

There is no interpretation here, it is black and white. The OOP language is very clear, either in the actual rules, or in the preamble. The OOP Final Rule is 74 pages long. That's why I'm giving you the page numbers and language for each of the FAA's clarification.

You're wrong, I'm right, and that's just how it is. Ask the FAA. They'll tell you the same thing.

 

[BigAl07]

I'll absolutely chime in here.

@Vic Moss is 100% accurate in his replies. Vic has been deeply involved in not only interpreting FAA UAS regulations but has also been deeply involved in meetings and discussions relating directly to their changes with the FAA. Vic has had a place "at the table" with the FAA in many occasions and he has a direct line with FAA as a FAASTeam Representative.

FAA Regulations are written in such a way as to try and be flexible yet also address the needed safety areas. It's not uncommon for many of us, even those who have been deeply involved with them for decades to misunderstand the finite details but I can tell you first hand that Vic is without a doubt a recognized subject matter expert on these issues. He's done a TON to help the UAS operators in the US in his dealings with the FAA.

 

[striperseeker]

I'll absolutely chime in here.

@Vic Moss is 100% accurate in his replies. Vic has been deeply involved in not only interpreting FAA UAS regulations but has also been deeply involved in meetings and discussions relating directly to their changes with the FAA. Vic has had a place "at the table" with the FAA in many occasions and he has a direct line with FAA as a FAASTeam Representative.

FAA Regulations are written in such a way as to try and be flexible yet also address the needed safety areas. It's not uncommon for many of us, even those who have been deeply involved with them for decades to misunderstand the finite details but I can tell you first hand that Vic is without a doubt a recognized subject matter expert on these issues. He's done a TON to help the UAS operators in the US in his dealings with the FAA.

I'm sure he has. His arrogance and condesending attitudes towards counter comments clearly shows that.
I do understand I am no expert and I'm learning all the time. When I read the reg and how I (and many of my fellow pilots that I converse with) understand them needs adjusting. Clarification in the form of an FAQ might be a useful tool. For example, I read the reg to state moving from one side to another (transiting over people) does not require any RiD or DoC for OOP (or RPIC cert). And if I'm flying over a trail with 5 hikers on it, is that an assembly in open-air? Or is it just a football game bleacher full of people? I appreciate all the clarifications, just not the "I'm smarter than you so [Comment removed by ADMIN] attitude".

 

[BigAl07]

I'm sure he has. His arrogance and condesending attitudes towards counter comments clearly shows that.
I do understand I am no expert and I'm learning all the time. When I read the reg and how I (and many of my fellow pilots that I converse with) understand them needs adjusting. Clarification in the form of an FAQ might be a useful tool. For example, I read the reg to state moving from one side to another (transiting over people) does not require any RiD or DoC for OOP (or RPIC cert). And if I'm flying over a trail with 5 hikers on it, is that an assembly in open-air? Or is it just a football game bleacher full of people? I appreciate all the clarifications, just not the "I'm smarter than you so [Comment removed by ADMIN] attitude".

Just because someone doesn't sugar coat their response to you doesn't mean they are condescending etc. It can get VERY tiresome to answer the same questions over and over again yet many of us continue to do so and sometimes in a very matter-of-fact way. Vic has answered your questions very abundantly and with great detail. The rest is up to you to dig in and figure it out.

If you have a problem with Vic or any other member on the forum use the REPORT button and let Staff work it out. When you start throwing snarky remarks and crude abbreviations it's going to come back to haunt you and serves NO purpose on the forum.

 

[striperseeker]

Just because someone doesn't sugar coat their response to you doesn't mean they are condescending etc. It can get VERY tiresome to answer the same questions over and over again yet many of us continue to do so and sometimes in a very matter-of-fact way. Vic has answered your questions very abundantly and with great detail. The rest is up to you to dig in and figure it out.

If you have a problem with Vic or any other member on the forum use the REPORT button and let Staff work it out. When you start throwing snarky remarks and crude abbreviations it's going to come back to haunt you and serves NO purpose on the forum.

I don't need sugar coating. I was writing how I took the responses. I'm sorry if I offended.
If you read my original posting to this section of replies, I stated "there are NO rotary drones with FAA DoCs". I didn't say anything about categories or RPIC self-certification. If you go back and read some of Vic's other replies, they are simiar to my comments regarding what exactly flying over people means.
I meant nothing more than to vent my feelings towards to comments made to my replies.
I'll shut up now.

 

[Vic Moss]

I'm sure he has. His arrogance and condesending attitudes towards counter comments clearly shows that.
I do understand I am no expert and I'm learning all the time. When I read the reg and how I (and many of my fellow pilots that I converse with) understand them needs adjusting. Clarification in the form of an FAQ might be a useful tool. For example, I read the reg to state moving from one side to another (transiting over people) does not require any RiD or DoC for OOP (or RPIC cert). And if I'm flying over a trail with 5 hikers on it, is that an assembly in open-air? Or is it just a football game bleacher full of people? I appreciate all the clarifications, just not the "I'm smarter than you so [Comment removed by ADMIN] attitude".

There was nothing condescending or arrogant intended in my replies. I'm simply being succinct. If you took them the wrong way, that was not my intent. For that I apologize.

I gave you the answers, and you seemed not to want to read them. If you had, you would understand the rules better.

I strongly encourage you to utilize that email ([email protected]) for any UAS questions you have. The gents there are very knowledgeable and if they don't have the answer right away, they can get you in front of the folks who do.

You're right in not taking the word of someone on the internet, but when that person gives you the verbatim wording for the actual rules, along with links as reference, take advantage of that. UAS regs are sometimes difficult to understand, so questions are natural. Being open to verifiable answers should be just as natural.

If you have time next Wednesday, I encourage you to watch the AAAC meeting. It's not terribly long (3.5 hours), and will be broadcast over the FAA's social media pages. You'll get a better understanding of how the process works. It can be boring, but it will be enlightening too.

The FAA hasn't released the public book yet, which surprises me. But hopefully they will tomorrow. I'll post links to the actual meeting and public book when I have it. For all to see. It will also be uploaded to those same channels a few days after for those not able to watch it live. I'll post those as well.

Enjoy the rest of your Sunday.

 

[finity]

Actually we can't fly over the people in moving vehciles. We can fly over the moving vehicles themselves, as long as we don't fly over the people in them.

I'm sorry to ask but I think that confused me even more.

Can you please try to explain this?

 

[striperseeker]

There was nothing condescending or arrogant intended in my replies. I'm simply being succinct. If you took them the wrong way, that was not my intent. For that I apologize.

I gave you the answers, and you seemed not to want to read them. If you had, you would understand the rules better.

I strongly encourage you to utilize that email ([email protected]) for any UAS questions you have. The gents there are very knowledgeable and if they don't have the answer right away, they can get you in front of the folks who do.

You're right in not taking the word of someone on the internet, but when that person gives you the verbatim wording for the actual rules, along with links as reference, take advantage of that. UAS regs are sometimes difficult to understand, so questions are natural. Being open to verifiable answers should be just as natural.

If you have time next Wednesday, I encourage you to watch the AAAC meeting. It's not terribly long (3.5 hours), and will be broadcast over the FAA's social media pages. You'll get a better understanding of how the process works. It can be boring, but it will be enlightening too.

The FAA hasn't released the public book yet, which surprises me. But hopefully they will tomorrow. I'll post links to the actual meeting and public book when I have it. For all to see. It will also be uploaded to those same channels a few days after for those not able to watch it live. I'll post those as well.

Enjoy the rest of your Sunday.

I appreciate the advice, I really do. But sending links and telling me to read the info doesn't help when questions arise and they aren't answered. I have read the CFRs, the summaries, the NPRMs, etc. several times - both prior and after my 107 cert test. It's like telling someone to read the manual or text book without a professor or tutor around. If I told someone to read a Python coding book or CISCO configuration manual without network or coding experience and no one around to answer questions, I'm sure they would make lots of mistakes or at least not be very efficient or proficient in their work. I'm sure I'll get a better understanding of the rules and apply them as they were intended (with safety in mind first and foremost). I'll never get to your level because I have way to many other interests to be an expert in this one (according to the "definition" of an expert...lol). Thanks for your tutelage.