Freefall, safety concerns, overflight proposals

[Meta4]

If your subject is a marching band on a field and you’re imaging a -90 gimbal the entire time I would think those below are participating.

It's obvious that you think that.
But are the performers participating directly in the operation?
Operation is the key word.
When the FAA says participating directly in the operation, does that mean operation of the drone or the performance?
If I was you, I'd want to be certain about that and not just assume it means what you want it to mean.

 

[Meta4]

But, that's based on a pure gravitational free-fall. What's the drag of a falling drone like. I'd wager longer than 3.7 seconds at that altitude. That means an even lower wind limitation should be used.

In freefall, drones reach a terminal velocity that varies between approx 15-18 m/s as the drone falls.

And what about a 1/4 failure? What would happen then?

The drone spirals to the ground.

 

[Wade L.]

If your subject is a marching band on a field and you’re imaging a -90 gimbal the entire time I would think those below are participating. And a clear path to move over the field would satisfy that.

In this particular event there aren’t any courses of action other than a top down angle to view. It’s just expressly for the directors to evaluate their rank and file.

It’s not for compensation so it costs me nothing to not do it.

I agree that options can massage an opportunity into existence.

Given that it could be done with no legal prohibition, the onus is on me to satisfy the concerns of the venue that matter most to them.

I don’t wish for tenacity to be confused with obstinance here.
Between chutes, signed waivers, insurance and assurances, I think there is room to build a safe model here. When the contrary begins to outnumber ways to ensure a safe outcome—the risk assessment is over.

Look, the band members are not considered direct participants of your flight operation. See Ultimate Guide to Over People Waivers & Section 107.39.

Therefore, contrary to the claim you previously made, it is not a legal operation without a waiver that is extremely difficult to get. You can continue to argue the point as to why you should be able to execute your plan, but, as I said, it is not legal without a waiver and carries considerable risk. What you do with that information is up to you, and you accept the consequences if you decide to go through with it. But there’s no point continuing to argue it. Period.

 

[MAvic_South_Oz]

FAA rules for OOP, this seems current ?

https://www.faa.gov/uas/commercial_operators/operations_over_people/

For sub 250gm . . . cat 1.

Even a mini / mini 2 does not comply.
Maybe small FPV type nano / micro drones with ducted motor etc

• 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.

For larger Mavics etc

• • Category 2 and Category 3 provide performance-based eligibility and operating requirements when conducting operations over people using unmanned aircraft that weigh more than .55 pounds but do not have an airworthiness certificate under part 21.
  • In addition, for Category 2 operations, no remote pilot in command may operate a small unmanned aircraft in sustained flight over open-air assemblies unless the operation is compliant with RID.
  • Category 3 small UAS have further operating restrictions. A remote pilot in command may not operate a small unmanned aircraft over open-air assemblies of human beings. Additionally, a remote pilot in command may only operate a small unmanned aircraft over people if:
    • The operation is within or over a closed- or restricted-access site and all people on site are on notice that a small UAS may fly over them; or
    • The small unmanned aircraft does not maintain sustained flight over any person unless that person is participating directly in the operation or located under a covered structure or inside a stationary vehicle that can provide reasonable protection from a falling small unmanned aircraft.
  • Category 4 operations is an addition from the NPRM. This category allows small unmanned aircraft issued an airworthiness certificate under part 21 to operate over people, so long as the operating limitations specified in the approved Flight Manual or as otherwise specified by the Administrator, do not prohibit operations over people. Additionally, no remote pilot in command may operate a small unmanned aircraft in sustained flight over open-air assemblies unless the operation is compliant with Remote ID. To preserve the continued airworthiness of the small unmanned aircraft and continue to meet a level of reliability that the FAA finds acceptable for operating over people in accordance with Category 4, additional requirements apply.
• Note: 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.

Cat 3, all depends what the terms closed - restricted site means, and how the people are notified ?
Is a public arena during a public performance a closed site ?

Participating directly ?
I thought it had been discussed a lot here, and that means participating in the drone operation ?
Pilot, spotter, film crew, etc.

 

[BigAl07]

You originally stated:

"Given that my flight is from the track (at the end zone) straight to centerfield (at altitude) and back, there is no overflight of spectators except for the band itself and any staff security on the track at that area."

That is 100% an OOP flight regardless how you try to change how you "think" it means. They are NOT part of the Flight Crew so therefore each and every person on the field would be OOP and require 107.39 of you flying under Cat 1 rules. That's the only way your aircraft can be over anyone on the field other than you and your FLIGHT CREW.

 

[MAvic_South_Oz]

On a lighter note, it's good the OP is really doing their homework on this proposal, including throwing it out here for some input.
Everyone can learn from others investigations into such matters.

 

[Wade L.]

FAA rules for OOP, this seems current ?

https://www.faa.gov/uas/commercial_operators/operations_over_people/

For sub 250gm . . . cat 1.

Even a mini / mini 2 does not comply.
Maybe small FPV type nano / micro drones with ducted motor etc

• 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.

For larger Mavics etc

• • Category 2 and Category 3 provide performance-based eligibility and operating requirements when conducting operations over people using unmanned aircraft that weigh more than .55 pounds but do not have an airworthiness certificate under part 21.
  • In addition, for Category 2 operations, no remote pilot in command may operate a small unmanned aircraft in sustained flight over open-air assemblies unless the operation is compliant with RID.
  • Category 3 small UAS have further operating restrictions. A remote pilot in command may not operate a small unmanned aircraft over open-air assemblies of human beings. Additionally, a remote pilot in command may only operate a small unmanned aircraft over people if:
    • The operation is within or over a closed- or restricted-access site and all people on site are on notice that a small UAS may fly over them; or
    • The small unmanned aircraft does not maintain sustained flight over any person unless that person is participating directly in the operation or located under a covered structure or inside a stationary vehicle that can provide reasonable protection from a falling small unmanned aircraft.
  • Category 4 operations is an addition from the NPRM. This category allows small unmanned aircraft issued an airworthiness certificate under part 21 to operate over people, so long as the operating limitations specified in the approved Flight Manual or as otherwise specified by the Administrator, do not prohibit operations over people. Additionally, no remote pilot in command may operate a small unmanned aircraft in sustained flight over open-air assemblies unless the operation is compliant with Remote ID. To preserve the continued airworthiness of the small unmanned aircraft and continue to meet a level of reliability that the FAA finds acceptable for operating over people in accordance with Category 4, additional requirements apply.
• Note: 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.

Cat 3, all depends what the terms closed - restricted site means, and how the people are notified ?
Is a public arena during a public performance a closed site ?

Participating directly ?
I thought it had been discussed a lot here, and that means participating in the drone operation ?
Pilot, spotter, film crew, etc.

All of this relies on the certification by the FAA of Category 2 and Category 3 drones. So far, the FAA has made no such certifications. The vast majority of sub-250g consumer drones (including the Mini models) weigh over 250g once prop guards are installed, which is a requirement for Category 1 drones, and therefore excludes them as Category 1 drones.

 

[MAvic_South_Oz]

The vast majority of sub-250g consumer drones (including the Mini models) weigh over 250g once prop guards are installed, which is a requirement for Category 1 drones, and therefore excludes them as Category 1 drones.

Weight aside (one could use a Japanese battery to be sub 200gm before guards), the prop guards for a mini / mini 2 don't meet the design criteria either.
More of a cage is necessary to stop any ingress of flesh into props.

 

[ThirtyWest]

Look, the band members are not considered direct participants of your flight operation. See Ultimate Guide to Over People Waivers & Section 107.39.

Therefore, contrary to the claim you previously made, it is not a legal operation without a waiver that is extremely difficult to get. You can continue to argue the point as to why you should be able to execute your plan, but, as I said, it is not legal without a waiver and carries considerable risk. What you do with that information is up to you, and you accept the consequences if you decide to go through with it. But there’s no point continuing to argue it. Period.

I wasn't arguing, regardless of your usage of that word. I didn't intend for discussing possibilities to make a flight safer in light of a definition to offend you. Even reading the federal register is not the easiest way to find the definition of participant. I'm not doubting you, but it's not obvious in the ECFR that I can see. You didn't have to waste your time chastising. Switch to the orange handle next time.

 

[eEridani]

This entire OOP issue comes down to making a drone that can crash into a person at full uncontrolled speed and not hurt anyone; and then there's that minor detail of not having any point of the propellers accessible to a even a finger.

A propeller guard sufficient to keep a finger away from the propellers is going to have some significant flight constraints. But here's one design that sets the tone: and I doubt they'd hold up to scrutiny in cases of a crash.

 

[MAvic_South_Oz]

I recall a news service in the US a while ago (several years I think), received FAA approvals for drone OOP using a Vantage Robotics Snap drone.
The drone was held together with magnets (!), and designed to break into pieces in the event of an impact, apparently mitigating significant injury to persons on the ground if unlucky enough to be in the way.

It seems now that the drone didn't become a long term item.

An article from (I think) circa 2015 . . .

The Snap Drone Might Be The Easiest 4K Video Drone on the Market

And (a bit of a mixed up code) website page on Vantage Robotics site . . .

Specs for Snap 4K flying camera from Vantage Robotics

”We borrowed a trick from F1 racecars and enabled Snap to break apart on impact. This distributes the kinetic energy of impact across more components, which lets us make everything both lighter AND more durable. It also absorbs 75% of the energy on impact to make it radically safer. We know you don’t have an F1 sized budget, so it also snaps back together in seconds using our patent pending magnetic connectors.”

Clever idea that may make a come back one day, when drones with such design might become more needed.

 

[Dbez1]

Looking at it from a different perspective…As a retired HS band director, if I wanted that video bad enough, I’d schedule a dress rehearsal when there’d be no one in the stands and the participants and parents would all be put on notice. Personally, I think you’re a little ahead of technology/107 laws. We may have to wait until closer to your date and see if an Air2 is declared a Cat. 2 with the safety equipment and RID attachments. Best wishes to you but I personally would stay away from this project. JMO

 

[EsaT]

Not 100% sure how these chutes work, could be tilt, could be fall rate, worth a read to see if that suits a loss of battery, loss of gps, some sort of imu / compass discrepancy etc, other that might causing a fly away.

VectorSave uses detection of free fall and excessive tilt.
Though chute deployment is based on spring loaded mechanism and then airflow opening the chute.
So unlike some compressed gas/pyrotechnic charge using systems it needs some distance from ground.
(but that also makes it safe to carry when travelling)

 

[BigAl07]

I wasn't arguing, regardless of your usage of that word. I didn't intend for discussing possibilities to make a flight safer in light of a definition to offend you. Even reading the federal register is not the easiest way to find the definition of participant. I'm not doubting you, but it's not obvious in the ECFR that I can see. You didn't have to waste your time chastising. Switch to the orange handle next time.

Well let's take this and be a little more blunt (without being chastising of course):

Federal Register :: Request Access

§ 107.39 Operation over human beings.​

No person may operate a small unmanned aircraft over a human being unless -


(a) That human being is directly participating in the operation of the small unmanned aircraft;

(b) That human being is located under a covered structure or inside a stationary vehicle that can provide reasonable protection from a falling small unmanned aircraft; or

(c) The operation meets the requirements of at least one of the operational categories specified in

The above is a DIRECT QUOTATION from the eCFR with no editing, ad libing, or anything. If you can determine and prove the band, director, other staff/people on the field are part of the OPERATION OF THE SMALL UNMANNED AIRCRAFT you would be good to go... (not happening).

 

[BigAl07]

Looking at it from a different perspective…As a retired HS band director, if I wanted that video bad enough, I’d schedule a dress rehearsal when there’d be no one in the stands and the participants and parents would all be put on notice. Personally, I think you’re a little ahead of technology/107 laws. We may have to wait until closer to your date and see if an Air2 is declared a Cat. 2 with the safety equipment and RID attachments. Best wishes to you but I personally would stay away from this project. JMO

It's very unlikely there will be any approved DoC by the time the OP wants to try this feat. The window for submitting the manufacturers request isn't even open yet. We don't know how long the approval process could take once they begin.

In regards to OOP Category 2 & 3:

Slide 15
•Implementation date is dependent on when manufacturers can get their Declaration of Compliance approved.
•They can start submitting them 9-12 months after 4/16/21.

 

[Clintoops]

Have you even talked to a lawyer to see how far you will be hanging out
The risk you are taking on.
It might be a good idea .
Just a thought.

 

[Vic Moss]

If you fly over the band, it's an illegal flight unless you have a 107.39 Waiver, which you don't.

You say band members count as participants, but they don't.

The FAA states the only ones who qualify are (1) the remote pilot in command, (2) visual observer, (3) person manipulating the controls, and (4) a person necessary for the safety of the flight.

So your band members aren't part of the operation.

Best bet is to fly from the endzones or track, with someone from your crew walking directly under the drone. Even better would be to cordon off a 20'x20' section in the end zone and fly from there, and hover over that area only. You will not be able to legally fly over the band.

Sorry.

 

[rstyles]

How about a camera on a boom? Safer and you can mimic a close in drone shot. So many less hassles and you could probably do this at any game(s) and combine the best shots. Seems like the one take drone shot is an all or nothing. Spend your energy on having some others on the field taking video from different angles. Look at the insta cameras to get 360 that you can edit exactly what you want after the shoot.

 

[baddog]

It's an Air 2, and it may have come across poorly but I never indicated I was doing OOP. The 107.41 authorization was based on a lat/lon, max altitude, and a nautical mile radius of operation--because I didn't seek to overfly non-participants.

I'm 9 months out from this--going through all the different safety aspects (systems, planning, insurance, etc) to measure viability.

I agree it is difficult to measure falling parameters. My operation would be stationary. Both the school and music director are on board, but I could see a parental waiver possibly going out to certify the students are participants.

The marching band and coaching staff are not considered participants, they are the POI (Point of Interest) of your mission/shoot. Your flight crew would be considered participants, (Remote Pilot, Visual Observer, Pilot at the controls)

 

[smashse]

Was going to say the band is not considered a participant, but so many others have.

I really like the suggestion from @Dbez1 , I was going to suggest if someone else hadn't. Schedule a night time dress rehearsal (or whenever it would be). Maybe even have the football team involved on the opposite sideline, and don't fly directly over, but say at 30 degrees and then circle in front of them at a distance. Just because it is a drone, doesn't mean you have to be at 68m. You could do this at say 20m AGL and still get fantastic shots. Then dronie away from them, which wouldn't be possible with a crowd. I'd have a couple people keeping lookie lous away too.

Crowd noise, video of the stadium full, etc can all be added in post from ground based or boom cameras.