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A couple of weeks ago, I submitted an operational waiver request to allow me to fly over people as I shot video for work here in Mountain View CA. I received their response this morning denying the request "because you did not describe interventions, for one or more hazards, to mitigate risk to an acceptable level. "
In the application, I wrote a short statement:
Operation over people (§107.39)
We may encounter a few instances where our flight path may be directly over people. We intend to minimize these instances by flying outside of non-crew personnel during the course of the operation, where it can be avoided
Apparently, that doesn't cut it, as they detail below:
"The FAA is unable to approve your request for a waiver to § 107.39 because the risk of injury to non participating or authorized human beings was not sufficiently addressed. Sufficiently addressing the risk of injury caused by an sUA when it impacts a human being includes— • The total amount of potential kinetic impact energy of the sUA; • A detailed list of how the sUA design affects the transfer of kinetic energy to a human being. For example— o Frangibility, energy absorption materials or design features; • The types of injuries caused by the sUA when it impacts a human being in normal and worst-case impact scenarios including—
o The severity of injuries caused in expected and unexpected failure scenarios;
o The likelihood of each type of injury caused when the sUA impacts a human being;
o The injuries caused by the rotating parts of the sUA; and • Operations limitations that are in place that may affect the safety of the operations..."
You can read the full document (attached below). There is a lot of work to do to get the data required, but if you have ever had this type of request approved, please share what you provided (if you can) to satisfy the requirements for the waiver. This was my first attempt and one of many learning opportunities as I move forward .
In the application, I wrote a short statement:
Operation over people (§107.39)
We may encounter a few instances where our flight path may be directly over people. We intend to minimize these instances by flying outside of non-crew personnel during the course of the operation, where it can be avoided
Apparently, that doesn't cut it, as they detail below:
"The FAA is unable to approve your request for a waiver to § 107.39 because the risk of injury to non participating or authorized human beings was not sufficiently addressed. Sufficiently addressing the risk of injury caused by an sUA when it impacts a human being includes— • The total amount of potential kinetic impact energy of the sUA; • A detailed list of how the sUA design affects the transfer of kinetic energy to a human being. For example— o Frangibility, energy absorption materials or design features; • The types of injuries caused by the sUA when it impacts a human being in normal and worst-case impact scenarios including—
o The severity of injuries caused in expected and unexpected failure scenarios;
o The likelihood of each type of injury caused when the sUA impacts a human being;
o The injuries caused by the rotating parts of the sUA; and • Operations limitations that are in place that may affect the safety of the operations..."
You can read the full document (attached below). There is a lot of work to do to get the data required, but if you have ever had this type of request approved, please share what you provided (if you can) to satisfy the requirements for the waiver. This was my first attempt and one of many learning opportunities as I move forward .
