FAA Webinar: Operations Over People

Overview                                                                                                                                                   If you are someone that is interested in flying a sUAS over people, use the following as an outline to help you understand what considerations need to be made. In an effort to improve my knowledge of the administrative requirements for waivers, I figured I’d share my takeaways from an FAA webinar that addresses 107.39- Operations over people. To view the video in its entirety, click on it below.                                                                     

Understand 107.39 and 107.23
In the first part, an understanding of Part 107.39 is reviewed. Key takeaways include: 

• Crew members directly participating in the sUAS mission. 
• Defining directly participating  crew members in the context of a sUAS 
• Defining crew crew members that are not included in a sUAS mission 

According to AC 107-2, Crew members directly participating in a sUAS mission are defined having involvement necessary for the safe operation of the sUAS. These include 

• The remote Pilot In Command (PIC)
• The Visual Observers (VOs)
• The Sensor Operator
• Anyone safety related official. For example this can be a police officer closing off a road so that you can fly a sUAS over it without any traffic interference

On the other hand, crew members do not include 

• Public that is made aware of sUAS presence but not apart the operation
• Newscasters/Reporters
• Actors 

Next, Operating over people is defined as the action of a sUA passing over any part of a person:

This Includes people not directly participating in the operation. The parameters defining the word "over" are depicted as an imaginary cylinder that extends from a person up to the UAS as shown in Figure 1. If the diameter of the cylinder changes and you fly over a part of it, you will have flown

over the person.                                                                                                                                                                                                                                              . 107.23a which defines Hazardous operations of a UAS is explained to show that although you might be conducting a flight near people, you must not fly in a way that can endanger someones life. Therefore it is important to know:

• How to control the flight direction of the sUA at all times
• The ground speed of the sUA
• The wind
• Altitude

After having an understanding of how both 107.29 and 107.39 interact interact with each other, An overview of how waivers may be issued from the FAA was introduced emphasizing that applicants for a waiver

• Must have a complete description of the operation that they want to complete
• Provide a detailed description of how the operation will be conducted safely                                                                                                 

Inventory the sUAS

Since there are several risks associated with operating over people, providing a detailed inventory of your sUA and a description of the components that are on board the sUA will help the FAA better understand the level of consequences that a sUA could have if an incident flying over people were to occur. Given the fact that humans have the potential to interfere with the aircraft, the FAA is highly concerned about how people beneath the unmanned aircraft will remain safe. Therefore they want to know that you are aware of the extent injury your sUA can potentially inflect on someone. Specific items that an applicant must look into include but are not limited to:

• Make up of the sUA blades
• Material of the aircraft
• RPM on the aircraft blades
• Weight of the Aircraft
• Operation Altitude
• Velocity of Aircraft
• Life Limited Components 

At the very minimum, the FAA wants to know that in the event an emergency were to occur, that an applicant has detailed contingency plans in place  ideal for the specific missions that the sUA will engage in. For information about how to further adjust your mission to ensure that key safety requirements are met. Visit the Waiver Operation Safety Guidelines from the FAA website. More importantly, it is emphasized in the video that the Waiver Operation Safety Guidelines are a starting point and a complete analysis of a proposed flight is expected in the waiver application.

Mitigate the Risk . 

There are 4 main topics that the waiver operation safety guidelines want to explain. These are taken directly from 11:41 of the FAA video. 

1. When the sUA impacts a human, the sUA the sUA will not cause a serious injury or worse
2. Data addresses not only blunt trauma injuries, but also laceration injuries
3. Operating conditions, limitations or procedures that must be followed to ensure safe operations
4.  Qualifications of the Pilot in Command or the person manipulating the controls 

Shown in Figure 2 is the Safety Risk Matrix posted by the FAA. It is best practice to do everything possible to stay in the green. 

Figure 2: Safety Risk Matrix taken from the FAA Video

Questions to Consider 

• How do you know what injury level a sUA can inflict upon a person? 
• How was testing data performed?
• When was testing data performed?
• Alternatively to testing data, how can you ensure that a sUA will not hit a human? 
• What other safety related features will also reduce  risk?  
• Are there are limitations of safety features?
• How do safety related features work? 
• Do you have a maintenance program?
• Do you have a procedure to correct older components?
• How do you track software updates?
• Is the Remote Pilot in Command aware of the safety measures in place?
• Is the Remote Pilot in Command experienced in using emergency equipment? 
• What is the estimated time of the operation?  

Conclusion
As stated in the video, flying over people is not an easy waiver to get. However, according to recent UAS initiatives, there are proposed rules that will allow certain sUAS to fly over people without having to obtain a waiver. Furthermore, obtaining a waiver may become easier depending if the installation of a Parachute could be applicable to your UAS. Nevertheless, a thorough analysis of focusing on the safety of the people the sUAS flys over is key to the success of getting the FAA to grant approval to your waiver.