Welcome back, to our summer webinar series on operational waivers for unmanned aircraft systems.
I'm Kevin Morris, FAA Safety Inspector here, and today, we're on episode number 9, which is going to detail
operations over people, specifically going through the waiver process
to receive your permission to operate over people under Part 107.
A few things as we get started here, as throughout our entire webinar series,
we are recording this episode, which will be broadcast later,
and I'll get you that website information at the end.
The audio is through your computer speakers, and the Q&A pod is active at the bottom of the screen at this time.
We use that pod to give you access
directly to a room
full of subject matter experts on all things related to Part 107: That's legal. Air Traffic Control.
It's the Waiver Team. It's Flight Standard.
Communications. Anything that you have a question about for Part 107
Operations, put right into that pod there, at the bottom of the screen,
and that question will be submitted to our group of experts.
Following the content of the presentation
today, we will once again do our live Q&A, which will give you a chance to ask me a question
directly on the air, and if I can't answer it, we'll certainly make sure it does get answered later on.
So, why are we here today? While
operating over people is not our most often requested waiver,
I would bet that is probably the most often talked about waiver in Industry.
So, what I want to go through today, is a little bit on
operating over people, detailing the risk associated with that type of operation,
knowing what we, the FAA, expect in your waiver application,
and we're going to do that, as always, through discussing the Waiver Safety Explanation Guidelines.
So, let's start with the rule itself, because I don't know of many other rules in Part
107 that creates so much discussion for terms and what they mean.
So, let's talk about this. 107.39 is a rule that states:
No person may operate a small unmanned aircraft over human being, unless
that human being is directly
participating in the operation of your aircraft, or they're located under coverage structure, or inside a
stationary vehicle that can provide reasonable protection from a falling aircraft,
from your falling small unmanned aircraft.
Let me break down that first term. Directly participating.
Advisory circular 107-2, which is available
on the left side of your screen there, and our downloads if you want to get it, you can also find it online,
it defines directly participating as these individuals you see on the screen. We're talking about the remote pilot-in-command,
a visual observer, a person manipulating the controls of the aircraft, or
crew members that are necessary for the safety of your operation,
as assigned and briefed by the remote pilot-in-command.
So, those are the individuals with the rural references as directly participating.
Now, let's talk about crew members.
Crew members necessary for the safety of the operation.
These individuals do not include actors or actresses, or on-screen talent, a television reporter perhaps or,
and I've seen this a lot of times that people have asked me about it, people you've notified of your drone operation.
You can't simply put up a sign that says there is a drone flying over your head and consider those people
briefed, and crew members for your operation.
Remember, crew members are folks that are necessary for the safety of your operation.
So, let's move on to the big one, right.
What does operating over people mean?
Operating over people means an operation during which a small unmanned aircraft passes over any
part of a person who is not directly
participating in the operation.
Now, we've already talked about what directly participating in the operation means.
So, let's talk about over.
The simplest way to think about this, is to extend an imaginary
cylinder around a person, that extends vertically into the airspace.
If you're small unmanned aircraft were to pass through that cylinder, that surrounds that individual,
you have been considered to be
operating over that individual. Now, that cylinder can change shape, and change diameter a little bit,
so to speak. If you're
arms are to your side, if the person's arms are extended out wide, or if they're laying down on the ground,
obviously the cylinder is going to have some different diameters or shapes to it,
but regardless of what diameter shape, if you pass through that cylinder, that
imaginary cylinder extending above that person, you'll be considered to have been operating over that person.
So,
If you're not operating over somebody, that means you could fly five feet from that individual,
and not be over that person.
While that's true to meet the requirements of 107.39,
let's keep in mind that, as a remote pilot-in-command,
you also have to comply with 107.23 A,
which details hazardous operations.
107.23 A states: A small unmanned aircraft system may not be flown in a careless or reckless manner,
so as to endanger the life of another. So, what that means is, even though you may not be flying directly
over someone, as the rule references, you still must need to be aware of the direction
your UAS is flying. For example, Are you headed toward a group of people?
What speed are you flying towards that group of people?
Will the wind push your unmanned aircraft towards that group of people, and are you operating at an altitude,
whereas if the aircraft were to fail, there's a chance it could drift into those people?
Certainly, you could be in flying in all those conditions, and not be over people,
but if you're in a situation that's creating a careless or reckless operation,
you'd be in violation of 107.23 A.
So, there are certainly rules for operating over people, which we're going to focus on, but don't forget,
107.23 A, which details a hazardous operation.
So, our waiver policy in 107.200, grants the FAA permission, and states that we may issue a
deviation to 107.3,
operations over human beings, if the applicant provides a complete description of the proposed operation, and
justification that the operation can be safely conducted.
These are the same requirements you have for beyond visual on the site, or operating altitude, or daylight through waivers.
So, before we get into the actual Waiver Safety Explanation Guidelines,
let's talk a little bit about some of the risks that are inherent with operating over people.
Clearly, risk number one to be, we have an increased potential
to injure those people that are going to be below our aircraft.
There's also a possibility that humans may interfere with your operation, and that
malfunction or failures in your small unmanned aircraft,
become more critical, because now we're not talking about, perhaps,
crashing into a field,
we could be crashing into a group of people. So,
failures or mechanical issues are more critical when operating over people,
but let's talk about the number one issue here, and
that's making sure that people beneath your unmanned aircraft are going to remain safe.
That has a lot to do in terms of the severity of injuries you may cause
related to your sUAS design,
related to the blade construction. Is your unmanned aircraft plastic? Or is it made of
composites of fiberglass? Some sort of honeycomb material? Or is it metal?
Because the differences in
construction and design of the unmanned aircraft or blades, will affect the injury potential.
When we're talking about
rotating blades spinning somewhere in the neighborhood, on average
5,000 to 7,000 rpm, they can create severe lacerations, and if you look at the photo on the right,
that is some injuries that were caused by a blade on a small unmanned aircraft.
But, if you really want to see what kind of damages they do, and you've got a strong stomach,
you can google these images, and you will see a lot of human injuries related to unmanned aircraft.
So, the danger is real, and the injury potential is high.
So, finally, the actual weight of your unmanned aircraft,
and that includes, perhaps, any cargo or camera mounts on the bottom, will affect the injury potential,
and certainly, if we're flying at higher altitudes above people, the
velocity of the unmanned aircraft, when it comes out of the sky for a mechanical reason,
will increase versus flying at a lower altitude.
So, that will also affect injury potential. What about human interference?
When we're flying in rural areas, not over people, we don't really have to worry about human interference.
Sure,
there might be a person that may come into our area operation that we weren't planning on,
but we developed contingencies to avoid them.
Now, we're going to be conducting an operation, where we're flying directly over those people.
So, one thing to remember, is that human beings are not predictable.
You can't always know what they're going to do. So, filming over, perhaps, a
marathon race
versus a protest, or maybe a rock concert,
will guarantee that you have different results from those different people operating beneath your aircraft,
so they may reach up to grab it.
They may throw something at your unmanned aircraft. These are the things as, the remote pilot-in-command,
you're going to want to keep in mind, when you choose to operate over individuals, and
I touched on this earlier, and we'll talk about a little bit later in the presentation too,
but the malfunction or a failure of the unmanned aircraft, becomes more critical, because
what your aircraft may end up falling into. So, your command and control
links, or if you have life limited parts such as if the battery on your unmanned aircraft has a certain
lifespan or a certain amount of times it can be recharged before the manufacturer says the battery is not going to deliver 100%,
those are all pieces of information you, as the applicant for this waiver, are going to
need to understand, and mitigate in that application.
So, do you need to have a maintenance plan? We'll talk about that here too, a little bit.
So, the Waiver Safety Explanation Guidelines for operating over people are designed to help you with this process.
They're designed to help you get a start on observing the risks that your particular operation, remember each operation is
individualistic, you know your operation.
You know your aircraft best. What type of risks you're gonna pose. It helps you get started on the path
to do risk analysis and risk mitigation.
Remember, when you're looking at those questions, and the Waiver Safety Explanation Guidelines,
we at the FAA, need to know that you're going to ensure your operation remains safe at all times,
and then if unusual
circumstances develop, you have contingency plans or mitigations to help reduce the risk, and
avoid any serious injury to people or property on the ground.
Now, with operating over people, it's a complex waiver.
It's a higher risk environment, so that the Waiver Safety Explanation Guidelines should be viewed as a
starting point in your waiver application, not the answer to,
or not the questions that will give you answers to everything you need.
Because when you're talking about your operation, and your specific unmanned aircraft,
you will need to provide additional information.
Again, the Waiver Safety Explanation Guidelines, a good starting point, but don't stop there.
Make sure you're doing complete analysis of your proposed operation to fly over people.
So, let's talk about the Waiver Safety Explanation Guidelines,
and when we're talking about operating over people, there are four main data points
we want to talk about. One
Is that, when your unmanned aircraft
impacts a human, we don't want it to cause a serious injury, or worse, and that the data you're supplying to us,
not only addresses blunt trauma injuries, but also, laceration type injuries. Finally,
we would like to get some information on your operating data, and qualifications of the RPIC.
So, what type of conditions or limitations are you going to put on your operation to help mitigate the risk, and what type of
qualifications is a remote pilot-in-command going to need to hold.
What type of training will they need to hold, or the person manipulating controls in order to operate safely underneath your waiver?
So, let's get into our Waiver Safety Explanation Guidelines, and walk through that.
The big thing to remember, and if you saw our episode, I believe was episode 2, which was "Risky Business,"
we talked a lot about risk, risk analysis, risk mitigation, and we referenced this chart.
Well now, this chart is coming back to us here, in our last episode,
because it's critically important when we're talking about operating over people.
With this type of operatio, we are constantly
balancing the likelihood of a collision happening, against the severity, in terms of injury that
collision would cause, and it's a balance factor. So, if you want to look at this graph in the simplest terms,
we want to stay in the green area. For example, if the likelihood of you hitting somebody is
relatively occasional,
or may be remote, but the severity of injury is going to be negligible,
you may end up in a green,
acceptable risk area, or let's say that the injury that your unmanned aircraft may cause
would be very high on the injury scale,
but the chances of it happening, due to design considerations, are extremely improbable,
you also may end up in acceptable risk area.
So, keep this graph in mind, as we go through the next few slides, because I'll mentioned it a few different times as we move
along here.
So, the first Waiver Safety Explanation Guideline talks about, if
or when, the unmanned aircraft hits an individual, we want to make sure that does not cause a serious injury or worse.
So, we want to know, has your unmanned aircraft been tested to determine
what injury level might occur, if it were to hit a human?
We need to know this information to help determine the injury level. Again,
go back to that risk matrix, the injury level plays an important role in determining the acceptable risk level,
we're going to move forward with, in your waiver.
If it's a high injury level, a very severe injury, or very minor injury level, we need to know that your unmanned aircraft has been
tested to that information.
Now, I want to add in here, real quick, because a lot of folks put in their
applications that they will use the assure study, as their method of testing the injury level of their unmanned aircraft.
The problem with that is, what the assure study really showed us, is that we don't fully
understand impact injuries or
necessarily how to model them at this point.
That we may have made some wrong assumptions about unmanned aircraft, and that
results that we got back turned out, maybe, differently than we were anticipating.
So, we require further study on a lot of these issues,
but the reason I bring this up, is because a lot of
applications have Assure Study noted in their application, as they're testing for impact injuries,
and that does not work in their waiver application.
So, please don't submit a waiver application with Assure study as your method of testing impact injuries to human.
So, when you do provide us with some data, some testing data for impact injuries,
we want to know how, and when, the testing was performed, as well as, the data you got back from the testing.
We want to know that, because the impact injury, for most unmanned aircraft, posed to humans. It can be severe.
So, we need to know how you
perform this testing to determine an injury level. If you're gonna say that,
"My unmanned aircraft could cause nothing, but a couple of scratches on someone."
Okay, how did you come up with that data?
Because we need the data from you, not for reference, for our risk analysis of your application.
But we also may need to go on, and test and validate the data on our own.
So, we didn't know what you did, and how you did it, especially for higher risk operations. Operating over,
let's say, a lot of people, or operating a
heavier UAS over a lot of people. That information poses a higher risk.
So, we need to know how your testing data came about.
If you're not going to provide testing data, and that's a common myth out there, too
is that everyone must provide testing data for the unmanned aircraft.
That's not wholly true, because if you're not going to provide testing data,
you need to provide data that shows how your unmanned aircraft would not hit a human.
So, whether that's through design assurances and failure rates, or just the construction of your unmanned aircraft would prohibit it,
we need to know that information. So, certainly the most complete application would have both sets of data points in it.
But if you're providing testing data, or I should say if you're not providing testing data,
we need to know what information you're using to show us that your unmanned aircraft is not going to hit somebody.
So, the data you're providing, in terms of injuries, is important; not only for the rotating parts the rotor blades
that you have on your aircraft, but also the design of the unmanned aircraft itself.
How could that potentially injure somebody?
So, while most people think of rotor blades right away, is that that's what's going to cause the injury?
The actual design of your unmanned aircraft could cause injury as well.
The payload you're carrying, the shape of it, whether it's a rigid structure or something that's fragile,
that would break apart upon impact, provide that information to us.
So, we know how you're
determining your injury level, because we need to know whatever you're doing with your unmanned aircraft,
you're doing to reduce the potential for injury to humans. That's very, very important.
Some people have design built into the unmanned aircraft, or operating conditions, or
procedures that will also reduce the risk.
So, if your unmanned aircraft is going to incorporate safety related features that reduce the severity of impact:
What are they? How do they reduce that injury?
Parachute seems to be the answer a lot of people like to provide, and while that's definitely one mitigation,
it isn't exactly the answer for every situation,
because parachutes have different operating parameters associated with it.
Some people provide that the unmanned aircraft have features on it that would limit the transfer of energy
to human upon impact. Think fragile. The
unmanned aircraft would break apart, rather than transit transferring that energy directly to the human,
So, if you're gonna use something like design safety related features,
remember, your application must contain details on that.
How do those features reduce the injury level?
Do they have any operational limitations?
For example, we have parachute listed on this slide here,
does the parachute have a minimum deployment altitude?
So, if it's a minimum deployment altitude of 50 feet above ground level,
and you're proposing to operate at 30 feet above ground level,
those numbers don't work out. So, what type of limitations do you have on those design features?
And I mentioned this before, about if you're not going to provide
testing data for impact injury,
We need to know how you've determined that your unmanned aircraft is not going to hit somebody.
So, we get into something that we reference in the Waiver Safety Explanation Guidelines, as
determined level of reliability.
This is an assumption that your unmanned aircraft will not fail or crash.
If you're going to go down this route, where you're going to show us a determined level of reliability,
we need you to show us that you've got some sort of mean time failure testing data. That you've got a
reliability or a maintenance program that, if you have life limited parts,
you have a process to identify what parcels are, and a procedure to
correct anything that may be reaching its life limit.
What about the system architecture, are hardier a reliability analysis?
There are certain things, like software design,
assurances, control, anything that's operationally restricting or limiting your UAS,
which is going to enhance safety. We need to know,
particularly in the realm of determining your levels of reliability.
Now, a little bit of a note on terminal levels of reliability.
That list that I just gave you, which is in our Waiver Safety
Explanation Guidelines, is meant to be just a guide. Some examples for people to start the
reliability process in their application. So, it provides you, really, as the applicant,
areas to evaluate to include in your design assurance assessments.
But just like the Waiver Safety Explanation Guidelines themselves,
that list that I just went through, is NOT a complete list.
Certainly, because everyone's operation and everyone's aircraft is different.
Make sure your design
assurance list is complete, and telling us what it is you're doing:
How that's going to reduce the injury, and how you're going to incorporate that in your
operation, because we need information, and
every one of those design assurances to help you with determining the level of reliability.
A little bit about the remote pilot-in-command.
The remote pilot-in-command has to understand these design assurances.
If there are features that the UAS has,
or if there are procedures that you are incorporating in your operation that are going to reduce
the risk level, that will enhance safety,
please describe those restrictions, including: How did you determine that particular
restriction is going to reduce the likelihood. Think back, to that graph or the severity of your flight,
So, if you're going to fly, and it's got a hazard reducing or severely reducing component to it,
in terms of operational
qualifications or restrictions,
how did you determine that?
How will it prevent the injury?
Whether it's a serious injury or greater, if you were to hit a human,
what hazard is the design feature or restriction there to reduce?
If it's something very unique to the UAS,
don't assume that we understand exactly what you're talking about.
Be very detailed and specific.
We want to know how each of these operational restrictions or design hazards,
reduce the impact injury, or severity, or reduce the risk in your operation.
So, some things that that we have seen for operational restrictions that help enhance safety:
They limit the operation, itself, lowering the altitude to reduce the impact velocity.
Maybe, avoiding intentional operations over people.
You might be saying, "Well, if I'm avoiding intentional operations over people.
Why would I need a waiver?"
Well, perhaps you're doing some type of work, where you're flying, where once you're up on station in a mission,
you can't move the UAS from that spot, and if somebody were to walk underneath your unmanned aircraft,
you don't want to have to scrub the mission.
So, that is something that you could put into your application, that "Hey, as the norm,
I'm not going to be flying over people,
but I need to have my UAS stay on station, if somebody happens to walk underneath it."
What about an additional remote pilot training?
So, for example, if you're using an airbag or a tether, and there are certain
procedures that must be followed, or there are certain limitations associated with that operational restriction,
how are you ensuring that the remote pilot-in-command, or the person manipulating controls,
is trained on that equipment. Do they understand the
limitations? Do they know how to use it effectively, in a worst-case scenario,
to avoid that higher risk, or the more severe injury for operating over someone?
So, operating over people is not a simple waiver.
It falls into one of the more complex categories, similar to beyond visual line of sight,
but it's not an impossible waiver to get.
Remember, when you're applying for a waiver for operating over people,
you need to understand all the risks and provide enough mitigation to reduce those risks to an acceptable level.
That's the big key component with any waiver,
but in particular, with operating over people.
And then, don't forget all your responsibilities, as pilot-in-command.
Just because you were, let's say, to get approved to operate over individuals,
doesn't mean that you don't need to worry about 107. 23, the
hazardous operation. All the other restrictions are still in place, and
most importantly, on this page, make sure you include all
supporting testing, or all supporting data. That you're providing not only
WHAT the data is,
but HOW the data works to reduce the risk.
How you came to the conclusion that it reduced the risk to a particular level, and
provide enough information to the FAA that if we need to recreate the test that you did,
we have the data to move forward with that.
So, our website is still up and running, as always. It's your great one-stop shop for everything.
You may need our Drone Zone documents,
where you're going to find your Waiver Safety Explanation Guidelines and Waiver Application Instructions.
And then, this being our last episode in the series, number nine,
we will post it to our website, as soon as, we get it ready, as well as,
the questions that were asked in all previous sessions.
They're also posted up on YouTube,
but your one quick, stop shop for that, is our webinar series website,
and you can see the address on your screen below.
So, that is going to wrap up our summer webinar series.
It's been 9 episodes, that took us all through the summer.
The weather is getting colder here, where I live, which means that summer must be over,
and our summer webinar series must be over as well.
But do not worry, we have more information come to you folks.
Stay tuned. We are gonna stop this set.
Stop this summer webinar series,
and we're gonna go work on our next one here, to have it up to you, as soon as we can.
if you want to be advised of when that's happening, follow us on Twitter, follow us on Facebook.
Check to make sure you have a valid email address, and your registration profile, so that we can get the information out to you.
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