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USA A vexing problem re Part 107.

Discussion in 'Certified UAV Pilots' started by William Gaddy, Sep 7, 2016.

  1. William Gaddy

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    So a hypothetical scenario popped into my head, and after going through the Part 107 AC, the part 107 rules themselves, and even the entire Federal Register discussion with respondent notes, I am still terribly vexed on this one.

    Let's say I'm an owner/operator (in the aircraft sense), with a fleet of various drones, but for this scenario let's just assume I have 2 Inspire 1 RAW, and that as owner/operator, I am also a certificate 107 remote pilot.

    I've been asked to do aerial promotional cinematography at a State Park, and I have the authorization of the State DEP, Parks, etc. However, I only have 3 hours to conduct whatever authorized flights I can as the Park Rangers have to cordon off the flight line areas to ensure no pedestrian and hiker overflight.

    Let's further say that in order to do this, I decide to use TWO Inspires, and hire a SECOND Part 107 certified remote pilot. My flight line we'll call Unit A, and I would be responsible for all safety of the flight line for Unit A. The 2nd remote pilot, his/her operations we'll call Unit B -- they would be responsible for all safety for Unit B,and the decision whether to use one or more VO's would be theirs, of course. The situation might come to pass that we're both flying contemporaneously.

    Is there a minimum stand-off distance (and altitude, let's say this is in rugged terrain) between flight line Unit A and Unit B?

    Is it enough that the two remote PICs have an agreed upon mutual flight plan and are in two way radio comms?

    I really can't get any direct answers from the regs here, but my reading is that both PIC's are responsible for the safety of their own flight line and if both collectively judge that the flight plan can be conducted safely, and within VLOS and with proper see-and-avoid procedures, this could be conducted without a waiver.

    I'm curious what the other folks on here think.
     
  2. DesertWindAero

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    I didn't see anything in the regs about dual operations, standoff distances, etc.

    I think as long as both pilots take "reasonable" safety precautions, you should be ok.

    I would also write a flight operations plan, signed by both pilots, explaining the extra precautions you have taken to account for personal safety, protection of the environment, protection of wildlife, and protection of property.

    DD
     
  3. William Gaddy

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    Yes, I can imagine if for no other reason than CYA and good communication between the two remote PIC's (not to mention insurance coverage) that would be a minimum. I guess what I'm noodling is that is if there's anything at the Federal (FAA) level that I've missed that would require a waiver in that circumstance. My reading on this agrees with your take on it -- but I'm waiting for someone to try and tell us we're wrong.

    -WG
     
  4. SanCap

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    I see no regulatory issues, only common sense issues. Have a predrawn line that neither will cross, assign a 50 foot altitude difference between both copters. Where are you flying? It sounds like a fun project. I think it is still possible to draw a circle (as a reference) on your iPad screen in the go app to keep you out of range of the other copter.
     
  5. William Gaddy

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    Hi SanCap. That's what I figured. This is drawn as a hypothetical (for now), but I could see this happening with two of my Inspires for a project I'm contemplating. Mostly I was curious if anyone could point to a specific exemption or authorization issue, but since each PIC is their own responsible party, it would seem all the usual Part 107 rules would apply.
     
  6. Dave Armbrust

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    William, you seem to still be looking for permission in the regulations. It does not exist. As long as it is not prohibited you are allowed to do it.

    Another similar topic else where is how close can you fly to a non-participant moving vehicle or person. There is not a limit in the regs. 107.39 just prohibit flight over a human being. It is left to the operator/PIC to determine what over means. Does this mean I can fly a foot away from a non-participant as long as you are not over the non-participant? Yes, you can, just not very smart.

    Back to your issue. The only restriction regarding multiple UAS is 107.35 "A person may not operate or act as a remote pilot in command or visual observer in the operation of more than one unmanned aircraft at the same time." While it may seem like a good idea to use a common radio frequency for all pilots and observers the regulations state an observer is prohibited from being an visual observer for more than one unmanned aircraft. That is without a waiver.

    Of course the regulations allow visual observers so that you can fly BLOS. If both pilots remain within line of sight, then no visual observers are needed. In this case the observers can become "spotters" which are not defined in the regulations. This would allow them to aid in the operation of more than one unmanned aircraft at the same time.

    As you can see, something simple can become complex. Just be careful as to what role non-pilots take.

    The bigger issue in these cases is liability. Just because it is legal does not remove the liability issue.
     
  7. Joet

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    I concur; the PIC's responsibility is to ensure that any any stage of flight, catastrophic failure will not impact a non-participant. A flight path that provides a wide berth helps to mitigate the impact of a failure that results in the aircraft deviating from the intended path.