Waiver Watch | Ep 21: Drone Spraying & Can it Map?
Welcome to Waiver Watch!
Here is the agenda for this episode:
Weekly totals
North Dakota Clean Sweep on 107.39 waivers
Spraying with a drone
Mavic Mini - can it map?
But first, a question…
How far is Visual Line of Sight to you?
Weekly Waiver Totals
Waivers Granted
March 26 - April 1, 2020 saw 27 waivers approved:
21 for Daylight Operations (107.29)
2 for Simultaneous Operation of Multiple Small UAS (107.35)
2 for Operations Over Human Beings (107.39(a))
Both North Dakota Public Safety Agencies!
1 for Operational Limitations: Altitude (107.51(b))
1 for BVLOS and Operations Over Human Beings
107.31, 107.33, 107.39
Slow week but some very interesting waivers approved nonetheless. We'll dig into the 107.35 waivers and the BVLOS waiver below.
Spinks Aerial Spraying Solutions - 107W-2020-01473
Hyve Remote Aerial Solutions, LLC - 107W-2020-01514
We’re covering a double-header this week as two companies received a 107.35 waiver to conduct aerial spraying with up to 2 UAS simultaneously. Ronny Spinks III of Spinks Aerial Spraying Solutions and Gildardo Bravo of Hyve Remote Aerial Solutions LLC both received a 107.35 waiver on the same day with nearly exactly the same provisions. Both operators are utilizing DJI Agras MG-1 to conduct spraying operations.
DJI Spraying Flight Path
Interesting waiver provisions.
Both waivers may be combined with Exemptions which is not something we’ve seen before! Sometimes waivers can be combined with other waivers, such as a 107.39 and a 107.29 waiver, but a waiver combined with an Exemption is unique. We’ll touch a bit more on the Exemption below.
Provision #10 indicates that both operators can fly 2 sUA simultaneously with one RPIC.
Provision #16 shows a tie to Part 137 which governs Agricultural Aircraft Operations. This provision indicates that the RPIC must pass the knowledge and skills test required by 137.19(e) and be documented in accordance with 137.71.
How about those Exemptions?
Exemptions are another mechanism the FAA uses to allow an operation that is contrary to the regulations. Part 107 Waivers and Exemptions are similar at the end of the day but Exemptions can be used more broadly across any of the federal regulations. Exemptions are published on regulations.gov and typically require a public comment period. Like waivers, they offer insight into the requests.
Both Spinks Aerial Spraying Solutions and Hyve Remote Aerial Solutions, LLC have published dockets that can be searched and again, both operator’s exemptions are similar. Each one exempts the following regulations:
107.36 - Carriage of hazardous material
137.19(c) - Pilot in command
137.19(d) - Aircraft requirements
137.19(e)(2)(ii)-(v) - Skills Test
137.31(a) & (b) - Aircraft requirements
137.33 - Carrying of certificate
137.41(c) - Pilot in command
137.42 - Fastening of safety belts and shoulder harnesses
Spraying from a manned aircraft requires compliance with Part 137 regulations and spraying from an unmanned aircraft requires compliance with a combination of Part 137 and Part 107. So both operators identified the regulations from each Part that they would need exemption from to spray from a UAS. For each regulation identified, the operators proposed how they can still operate safely.
One example is 137.42 requires the PIC of a manned aircraft to fasten his or her seatbelt. When operating unmanned aircraft, this obviously doesn’t make sense so the regulation can be exempted without impacting safety in the NAS.
It’s also worth mentioning that beyond FAA regulations, spraying from an aircraft must be compliant with Department of Agriculture and state laws. The term “economic poison” includes most materials sprayed from an aircraft and is heavily regulated. Consult with your local Department of Agriculture and FSDO representatives before spraying from a UAS.
Mavic Mini - can it map?
Have we said how much we like Mavic Mini? For $400 you get a flying high quality camera. Sure it doesn’t have the 1” sensor that the Mavic 2 Pro has but it’s also 1/6 the price! Now, the obvious thing to do with it is take some selfies and cool shots of the things around you. But.. we decided to find out if it could do more than that. Can it do photogrammetry??
The answer is yes. By manually flying a tight lawnmower pattern and capturing nadir photos, a stitched image and 3D model can be generated in programs like DroneDeploy or Pix4D. We wouldn’t recommend using the Mavic Mini for survey grade work or anything where a certain accuracy is required, but if you need a quick model or something the Mavic Mini is a great option. The Mavic Mini is also a great option from a risk standpoint. It’s low weight ensures that in the event of an incident, it’s impact will be low.
Wrap Up
Thanks for reading this week! Leave us a comment if you have any questions or would like us to write about any specific waivers next time! If you have a waiver and would like to join us on the show to talk about it and other waivers, drop us a note! Until then…
