Commercial drone pilots, please give me your thoughts on my project.

[racin06]

I posted a question in another thread relating to our site; however, things have now changed. My company is an environmental consulting firm. We have recently rolled out drone services. We have a project site in a small town which entails an industrial facility with a subsurface chlorinated solvent-contaminated groundwater plume. There are residential properties adjacent to and extending three blocks away from the industrial facility that may be impacted by this plume (potential vapor intrusion). We would like to fly our drone autonomously over the industrial facility and residential properties to generate a topographic map and a 3D surface model of the area. During the flight, the drone will also fly over streets in this area. This area encompasses approximately 144 acres. The estimated drone flight altitude will be 250 ft. AGL. The estimated in-air drone flight time is 40 min. My cautious and conservative nature says that we should submit for a 107.39 waiver. Why? Because there is always a chance of the drone flying "directly overhead" a human being. For example, someone could be standing in their front yard when the drone passes overhead or the drone could pass over a moving vehicle on the street. Of course, the probability of my firm securing a 107.39 waiver from the FAA is remote given recent history. I would like to hear some thoughts from you commercial drone pilots. What would you do? Apply for the 107.39 waiver? Maybe I have too much of a strict interpretation of 107.39. Any other solutions? Thanks much.

 

[sar104]

I would argue that 107.39 is primarily about flying over crowds, or at least sufficient numbers of people in an area such that the probability of hitting someone in an uncontrolled descent is significant. Assuming that you are using VOs to maintain line of sight and can provide some form of notification to residents I think it is reasonable to proceed without a waiver. But perhaps you should run that past your local FSDO first.

 

[MapMaker53]

Personally, I wouldn't be concerned about crossing over an occasional person on the street or vehicle. The odds of you being spot-on directly over a person as you fly is probably minuscule and I don't think reflects the intent of 107.39. If you want to be extra cautious, you might look into installing an autonomous MARS parachute system on your drone.

 

[N017RW]

IIRC 107.39 grants are rare. Last I looked there were 2???
There’s a great deal of document ‘load’ too.

 

[BigAl07]

Unfortunately unless you have the best writers, the best attorneys, the right aircraft and a lot of luck I don't see a 107.39 happening.

 

[MapMaker53]

Probably the only hope (slim one at that) of getting 107.39 waiver is to state the drone will be equipped with a parachute system that automatically deploys when a flight failure is detected.

 

[doktorinjh]

This area encompasses approximately 144 acres.

Out of the total 144 acres, how many are residential?

I agree with the rest that your chances of getting a 107.39 waiver are on the low side of impossible, but I also think that it's over-conservative to begin with. Without knowing what the area looks like, I would attempt to create a flight plan that minimizes flying over sidewalks and streets and by being diligent about pausing the mission if anyone enters the area below the moving drone (not easy, I know). For example, a mission planned like this would reduce the chances of being over anyone and is likely the safest way to get the data:

 

[ed in manila]

What is your end result that you are trying to achieve? Maybe there is enough data out there to allow you to get the result you need using a GIS with publicly available data? Choice of the right basemap may give you enough detail, then combined with other vector data on your measurements would allow you to create some impactful maps...

 

[ed in manila]

Again, I don't get this. If the objective is to develop a topo map at 250ft which can then be later used to integrate into a further analysis of pollution impact... Well I have an opinion that will be very unpopular here.
The United States already has a huge amount of digitized topo maps with availability of digital elevation models (DEMs) that can be already combined as a start. Satellite imagery already exists wit good resolution for the purposes of analysis. See for example:

This image was taken at about 250ft agl using Google Earth. It's copyright is 2018, so must be 2 months old or less. This image would be similar / same to that available as a base map to a GIS like ArcGIS or Qgis . Then, combined with the pollution measurements combined in a GIS you have the analysis you need.

I am sure my post isn't going to be popular because I'm essentially arguing that in many cases drone photography may not be needed depending on the desired end result of the analysis.

All of these comments depend on
A) the importance of the visual images of the ground, and
B) the latency of the imagery from the satellites.

My work in remote regions of the philiPhilip may have old satellite imagery from early 2017 or even 2016 - in which case what you propose is sensible.

 

[BigAl07]

@ed in manila your link is broken my friend.

 

[doktorinjh]

a topo map at 250ft

At 250', you're going to have resolutions and GSDs less than 1" (~2cm), which is far better than a 10m DEM that is publicly available from the USGS, etc. When you're looking at environmental flood modeling, etc., having a detailed digital elevation maps to see small drainages and ditches can be critical. A lot of the DEMs are also +-2' contours, which might also be too crude for what the original poster was after.

Basically, with a few flights, you can have timely data at a better quality and resolution than anything available from a satellite. You'll be able to create a digital surface that captures nuances in the topography that can't be acquired through anything except for airborne LiDAR, and even then I doubt you'd get the same quality.