Research using IRIS..not allowed!?

Hi there,

I have been doing some IRIS+ based measurements of atmospheric temperature profiles and

submitted a research proposal to the National Forest Service to fly above a site on NFS land.

Here is the response:

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Unless you're able to point us toward FAA regs that indicate your proposed use would fall into the model aircraft (hobby/recreation) category, or produce a FAA certificate for Civil UAS use we won't be able to move forward with this aspect of your request.

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I pointed out that this is not a commercial enterprise, we are not charging or making money, off of this and it is done during daylight,line of sight, and below 400" AGL

Anyone here that can help me ?

Thanks for reading this

Dan

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Replies

    • Tom,

      I must make a request to do my flight because I will publish the data.

      My project is location specific and the Institute directive clearly requires research to comply to a high standard.

      I just can't fake it.

      Dan

    • Understood. It sounds like you must absolutely, positively adhere to all relevant regulations.

      But then the answer to your original question is that you can't legally fly your Iris for the research project you described without obtaining a COA from the FAA or waiting the probably  two years until the new proposed rules are adopted and become official. If you are going to go by the book, it simply can't be in the national airspace, whether launched from public or private land. Sorry you can't exploit any loopholes.

    • I understand that I can fly on the property we manage that is closer to the site of interest

      So that is what I will do I think I can get within 200 feet in altitude an so I will measure from 200 feet below to 200 feet above from Observatory land with a safety buffer incase I have a runaway.

      And for the moment, start learning the finer arts of dealing with USFS and FAA

      Thanks to every one who has contributed, I have a better understanding of these rules.

      Dan

    • Dan, the way the law stands as of today, is that you can't fly into federal airspace for non-hobbyist or recreational purposes without a COA from the FAA. Doesn't matter if it's from your property or the USFS's property. The only difference is that if you do it from your property you need no permission from the USFS. But you would still violate the (stupid) FAA regs. I am only stressing this because I got the sense from you that you have to really go by the book, and that's what the book says. An will continue to say that for perhaps two years.

      And as I said, were it me and my research project I'd do the flights FROM my property, take the samples in whatever airspace I felt was needed for the study, publish it clearly with the sample locations and let it go at that.

      I am aware of published journal articles involving the use of drones for mapping and thermal imaging of archaeological sites in the US and am quite certain the researchers never got FAA authorization for their flights. They just did it.

      A thought....if the number of sampling missions isn't too onerous, you could contact a "hobbyist" who might enjoy making such fights for "fun", and just include your sampling equipment on the hobbyist's airframe. Hell, it's sciencey and I'm sure there are "hobbyists" who would love flying around your dome with permission!  I loves me a good loophole.....

    • Tom,

      Thank you for your thoughts.

      Dan

    • Looks like a SteadiDrone X would come in handy, with 60+ minute flight times, 28" props, 8kg+ payloads, and 10S power. Haha! http://www.steadidrone.com/drones/steadidrone-x

      Google Earth shows a distance of approx 4.5 or 3.5 miles to the ridge of Palomar Mountain from either S6 or 79 respectively (not sure of your research area). Elevation gain of 3500-3800', so you'd need a good ground station route or excellent FPV range, while traveling LoS and within 400' AGL.

      One can dream.

    • Now thats what I am talking about!

      I am about a mile from the  site and I could get all the package I need with style with that one

      and not need to 4 wheel drive early in the morning to the ridge.

      If I did it from my home site I may not be awake when I take off and driving to the site is

      a sort of filter.

      Still, unless I get permission.........I walk not fly.

      Thank you for your comments

      Dan

    • Moderator

      "It's easier to ask forgiveness than it is to get permission" 

      from "The Wit and Wisdom of Grace Hopper" by Philip Schieber in OCLC Newsletter, No. 167 (March/April 1987)

    • So the questions are,

      Is the IRIS a model aircraft?

      Can a Model Aircraft be used for research?

      In regards to......

      Overview of Small UAS Notice of Proposed Rulemaking

      Summary of Major Provisions of Proposed Part 107

      The following provisions are being proposed in the FAA’s Small UAS NPRM.

      Operational Limitations

      •   Unmanned aircraft must weigh less than 55 lbs. (25 kg).

      •   Visual line-of-sight (VLOS) only; the unmanned aircraft must remain

        within VLOS of the operator or visual observer.

      •   At all times the small unmanned aircraft must remain close enough to

        the operator for the operator to be capable of seeing the aircraft with

        vision unaided by any device other than corrective lenses.

      •   Small unmanned aircraft may not operate over any persons not directly

        involved in the operation.

      •   Daylight-only operations (official sunrise to official sunset, local time).

      •   Must yield right-of-way to other aircraft, manned or unmanned.

      •   May use visual observer (VO) but not required.

      •   First-person view camera cannot satisfy “see-and-avoid” requirement

        but can be used as long as requirement is satisfied in other ways.

      •   Maximum airspeed of 100 mph (87 knots).

      •   Maximum altitude of 500 feet above ground level.

      •   Minimum weather visibility of 3 miles from control station.

      •   No operations are allowed in Class A (18,000 feet & above) airspace.

      •   Operations in Class B, C, D and E airspace are allowed with the

        required ATC permission.

      •   Operations in Class G airspace are allowed without ATC permission

      •   No person may act as an operator or VO for more than one unmanned

        aircraft operation at one time.

      •   No careless or reckless operations.

      •   Requires preflight inspection by the operator.

      •   A person may not operate a small unmanned aircraft if he or she knows

        or has reason to know of any physical or mental condition that would

        interfere with the safe operation of a small UAS.

      •   Proposes a microUAS option that would allow operations in Class G

        airspace, over people not involved in the operation, provided the operator certifies he or she has the requisite aeronautical knowledge to perform the operation.

      Operator Certification and Responsibilities

      •   Pilots of a small UAS would be considered “operators”.

      •   Operators would be required to:

        o Pass an initial aeronautical knowledge test at an FAA-approved knowledge testing center.

        o Be vetted by the Transportation Security Administration.

      o Obtain an unmanned aircraft operator certificate with a small UAS rating (like existing pilot airman certificates, never expires).

      o Pass a recurrent aeronautical knowledge test every 24 months. o Be at least 17 years old.
      o Make available to the FAA, upon request, the small UAS for

      inspection or testing, and any associated documents/records

      required to be kept under the proposed rule.
      o Report an accident to the FAA within 10 days of any operation

      that results in injury or property damage.
      o Conduct a preflight inspection, to include specific aircraft and

      control station systems checks, to ensure the small UAS is safe for operation.

      Aircraft Requirements

      •   FAA airworthiness certification not required. However, operator must maintain a small UAS in condition for safe operation and prior to flight must inspect the UAS to ensure that it is in a condition for safe operation. Aircraft Registration required (same requirements that apply to all other aircraft).

      •   Aircraft markings required (same requirements that apply to all other aircraft). If aircraft is too small to display markings in standard size, then the aircraft simply needs to display markings in the largest practicable manner.

      Model Aircraft

      •   Proposed rule would not apply to model aircraft that satisfy all of the criteria specified in Section 336 of Public Law 112-95.

      •   The proposed rule would codify the FAA’s enforcement authority in part 101 by prohibiting model aircraft operators from endangering the safety of the NAS.

    • Indeed it is, and that is one chance.

      I need more than one.

      our research requires updating interested parties frequently and 

      I don't want to walk away saying ..oops, my bad

      Thanks for the thought

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