Operational Waiver: Night Flight Request

Reference Number: 107W-2019-06117

Approved

Attachments / Information Requests

SubjectStatusDate ReceivedResponse DueDate RepliedRespondentACTION
REPLIED
12/04/2019
01/02/2020
12/08/2019
ROBERT RAWLINGS

Select an Information Request entry to respond.

Responsible Party

ROBERT RAWLINGS
ROBERT RAWLINGS
budster10@comcast.net
2259 Highview Ln NW
E102
BREMERTON, WA
98312
United States
(360) 509-1578

Pilot

ROBERT RAWLINGS
Small UAS
2259 Highview Ln NW
E102
BREMERTON, WA
98312
United States
(360) 509-1578

Waiver Application

Daylight operation (§107.29)
My company (Kitsap Sky View,LLC) , an Aerial Videography/Photography company are called upon to use lighting at night of homes and or properties to take photos. Sometimes we are asked to take photos at night. (As per 107.200(b)) Our Safety Mitigation plan is as follows: Always using a (VO) Visual Observer . Aircraft will be using multiple strobe lights which can be seen up to 3 NM distance. We will maintain situation awareness during the daylight hours prior to any operation, giving the crew opportunity to scout the area for potential hazards. Launching will only be from a secure area, using verbal notifications for each step of the process. All participating individuals will be working in a clear and defined area. These areas will be defined with a set of orange traffic cones and if available caution tape to mark off the area of flight, to ensure no bystanders become a potential hazard. Should someone enter the area, we will immediately fly the sUAS to a safe spot and assist the person out of the controlled area, as with often times flying over streets, should the area become populated with people and or vehicles we will fly to a safe spot until such area is clear. All crew members wear a Highly visible vest, protective eye wear and brightly colored hard hat during the entire operation. The reason for this is for the safety to the crew as well as identification of the crew should there be any resident concerns. In the unlikely event of a lost connection of the sUAS; we will follow established Lost Link procedures, including verbal announcement to anyone near the area .A maximum altitude of 200 feet AGL is requested. All pre flight procedures will be conducted in a well lit area when necessary or requested. Local Law enforcement will be notified in case there any calls be concerned residents. Performance Base Standards:1:Pilot will use strobe lights to maintain visual line of site the entire operation. 2: Pilot uses a Visual Observer (VO) to avoid other aircraft, people on the ground, ground based structures and obstacles during the dark night of flying. 3: Pilot will be using telemetry information for the UAS, broadcasting on either 2.4 GHz or 5.8 GHz to the control station. In doing this the pilot is able to have continually monitoring of the sUAS to determine the position of the aircraft, altitude, and movement of the small unmanned aircraft at all times. 4:The pilot will become aware and have knowledge to recognize and overcome visual illusions caused by darkness, and understand the physiological conditions that may degrade night vision. These include auto-kinesis caused by staring at a single point of light for more than a few seconds. The light appears to move even if it isn't. This can be eliminated by focusing the eyes at varying distances and by increasing speed of visual scanning. Reversible perspective illusion. The one is less likely when the VO is on the ground to see fixed light reference, but can still occur. So we've added it to our procedures. This occurs when a aircraft may look like it is moving away from you but is actually moving towards you. To eliminate this the VO and PIC will double check with each other for any possible moving light by comparing it to the fixed light on the surface. Size/Distance Illusion. This occurs when a light is slow lying, pulsing creating a false impression of approaching or receding aircraft. To eliminate this we will also verify verbally between all parties on sight. This is especially possible when helicopter traffic is present. This is why we will have a NAV/VHF Radio on hand. Fascination: Becoming fixed on one particular subject and not paying attention to the surroundings. This is one fairly easily eliminated by continually scanning the scene. We will pay specific attention to this, because of the case at which one can focus on concentration on the UAS. We will communicate frequently this concern during the flights. Flicker Vertigo: This is a concern for us and has been a concern for our ground base station, and should it occur when a light cycle can induce nausea, vomiting dizziness, as with many of the night time illusions, this can be eliminated by continued scanning. Loss of night vision, how to fix the problem: Reduce all lighting around flight deck area and closed off take off area. We will also be aware when we move from bright to dark areas, We also won't look at the strobe lights of the UAS. Issue: Inability to focus on a subject. Solution: Understand that night vision focus works better if you don't look directly at the subject you're focusing on. Issue Dehydration causing both night vision and exhaustion . Solution, Stay hydrated. Impairing night vision. We will also be aware of current weather using the forecast and other information from NWS. Also we will consult NOTAM's or DRONETAMS in our area of operation. Crew will also be using a wind meter at all times on scene to keep track of any wind speeds and changes of direction. Crew will also have a first aid kit available. At no time will the sUAS be operated near any restricted/prohibited areas, MOAS, or military RPIC and all VO's will be using wireless headsets for communication of any aircraft sighting and identification in area of operation. If during the operation an aircraft is sighted in the area of operation the RPIC will descend the sUAS immediately to a safer altitude and land in the designated Landing Zone if necessary. The RPIC/VO's will constantly scan the sky in a box formation from right to left to see and identify any aircraft. If during the operation headset communication is lost at any time. The VO's and RPIC will use a combination of verbal and hand communications will be used to point out air traffic. VO's will have sufficient training which will include knowledge of the rules and responsibilities described in 14 CFR 91.111, Operating Near Other Aircraft: 14 CFR 91.113. Right-of-Way Rules: Except Waiver Operations: and 14 CFR 91.155, Basic VFR Weather Minimums: knowledge of air traffic and radio communications, including the use of approved ATC/Pilot phraseology; and knowledge of appropriate sections of the Aeronautical Information Manual. This training will be documented in a training folder. Areas of operation will be scouted out during daylight hours by all parties involved RPIC, VO's to identify all obstacles/structures. Additional VO's will be posted near potential obstacles/structures during any operation and will call out over the headset any issues that may arise during the operation. RPIC and VO's will be able to identify aircraft by looking at the orientation of the red/green light and also aircraft strobe light anti-collision beacon. All operation will Landing Zones will be conducted in a well lite area with non-LED, low wattage lights and to not blind any one and cause night blindness.

sUAS Details

DJIInspire 2FA3LYNC7PX
DJIMavic Pro 2FA3AL9RWL7

Operation Parameters

12/10/2019
12/31/2023
Kitsap Sky view would like to use their sUAS at night to take images of real estate for sale all over un incorporated Kitsap County. We are requesting a max altitude of 200ft AGL Our equipment consists of a quad copter carrying a camera on a gimbal that is secured to the aircraft by a secure locking connection and is also secured via additional safety wire. The gimbal/camera will not be able to dropped from the sUAs as it is secured to the drone via a secure metal connection and safety wire. We will not be operating over people. The drone weighs no more than 10 lbs. and will be equipped with strobe lights that are visible at night for 3NM or more. sUAS are powered by lithium-Ion batteries and have a maximum flight time of 25 minutes and a max speed of 35 MPH. The DJI Inspire 2 measures 2 ft rotor to rotor. We will be using DJI Geo-fencing to ensure the aircraft flies only where it is directed to. (RTH) or Return to Home switch will be used for an immediate flight termination use. The closest airport is KPWT -- Bremerton National Airport. We will operate only in Class E airspace. We will not operate within 5NM of KPWT or any of the military base in Kitsap County. Our operating location is Latitude: 47.5417 Longitude: -122.6750 The RPIC has been a 107 for over a year and has received approximately 15 hours of hands on night training in the operation of sUAS. We plan on using a minimum of 2 VO's during any operation and each VO will have completed our night practical training and testing prior to being a VO. This training and testing will be documented and kept on file.
200 ft.