One of the Section of article HR 302 is Operation of numerous small unmanned aircraft. My Commentary on Section HR 302 Operation of multiple small unmanned aircraft. This is typically referred to as a swarm type of surgery. You merely need to get a waiver. Also, take note that ITAR/EAR regulations may apply to this particular flight.
FAA’s Discussion on Section 107.35 Operation of numerous small unmanned aircraft in the Last Small Unmanned Aircraft Rule The NPRM proposed that an operator or visual viewer would be restricted to working no more than one little UAS at precisely the identical time. The NPRM explained that performing the duties required of a crewmember in real time is a concentration-intensive task and therefore, it’s necessary to put a limitation on the amount of UAS that someone can operate simultaneously. This prohibition will be waivable if someone establishes that their simultaneous operation of more than one small unmanned aircraft can safely be run under the conditions of a certificate of waiver.
The International Brotherhood of Teamsters urged the FAA to keep all operational limits and protects presented in the NPRM, including the limitation of one UAS per operator, until there’s technological certainty that no employees, or the general public, are at risk from automated package delivery.
Other commenters disagreed with the proposed limit on the amount of small UAS that someone can operate simultaneously. Several commenters claimed that technology now exists to allow for the secure operation of multiple modest UAS by one operator. AirShip Technologies said that it now incorporates technology which will enable clusters of UAS with similar assignments to be pre-programmed and controlled by a single operator. Boeing and Aviation Management likewise said that current technology permits a group or swarm of numerous vehicles to function safely and efficiently in highly automated modes.
The commenters also claimed that new operator consoles had been proven to be able to control multiple smallish UAS systems securely. Vision Services Group said various smallish UAS operations should be allowed if both the operator and visual viewer have a License to Operate and a legitimate Third Class Medical Certificate.
As mentioned in the visual-line-of-sight part of the preamble, the remote pilot in control, the individual manipulating the flight controls of the tiny UAS, and the visual observer (if one is used) are expected to maintain visual consciousness of the small unmanned aircraft and the surrounding airspace to be able to minimize the danger of a mid-air collision with a manned aircraft. This action requires active attention and operating over one unmanned aircraft in precisely the same time would divide the concentration of the tiny UAS crewmembers. By lowering the amount of attention that the remote pilot in command, individual manipulating the flight controls, and a visual viewer can devote to every tiny unmanned aircraft, the performance of numerous small unmanned aircraft at precisely the same time may introduce additional risk into the NAS. This risk will likewise be compounded if more significant numbers of aircraft are operated at the same time because each plane could get an even smaller portion of every individual’s attention.
The FAA recognizes that technologies may enable a remote pilot in command to run several small unmanned aircraft as a single system. While such a system might, in certain conditions, help address the split-attention issue discussed previously, it might introduce considerably more risk into the operation due to the remote pilot’s potentially reduced ability to solve multiple aircraft or system failures into a safe outcome. By way of instance, if one little-unmanned aircraft at a multi-aircraft system loses its connection to the control channel, it might cause the entire system to break down, leading to loss of favorable control of multiple small unmanned aircraft and significantly raising the threat to the NAS. The FAA notes that, right now, none of the technology cited by the commenters has established an essential degree of reliability through a nationally recognized formal testing procedure like through ASTM International, SAE International, or civil aviation airworthiness certification. Accordingly, this rule will prohibit someone from manipulating the flight controls of over one unmanned aircraft or acting as a remote pilot in command or visual observer from the functioning of more than one unmanned aircraft in precisely the same time.
Commenters such as Aviation Management, Boeing, the Little UAV Coalition, and AIA reported that the FAA should revise the rule to create the frame for the agency to administratively approve multi-UAS operations. Several of these commenters, in addition to Google, Amazon, and AUVSI, amongst others, supported allowing the performance of numerous modest UAS per operator in certain instances using a risk-based strategy. Amazon, for example, stated the proposed provision should be revised to explicitly permit the performance of numerous modest UAS by one operator” when shown that this could be done safely.” The Little UAV Coalition said approval for the production of multiple modest UAS by one operator could be based on a demonstration of operator talent and technical capacities of the UAS.
DJI said it might be possible for an operator to run more than one little UAS at one time if there are adequate visual observers or detect-and-avoid technology. An individual stated the rule should allow for using multiple modest UAS by one operator if all the UAS are inside the visible line of sight of either the operator or visual viewer or if there’s another means of compliance for see-and-avoid for all tiny UAS involved in the operation.
Other commenters said the last rule should have the flexibility to adopt emerging technologies in this region. The Utah Governor’s Office of Economic Development said that”[t]here has to be a roadmap, and provisions for, multiple UAS per operator to allow this technology to be tested and finally implemented.” The University of Illinois in Urbana-Champaign said there must be an exception to the proposed limitation for research to developing technology to permit some drones to navigate together successfully. MPAA claimed that”as management systems improve it can become possible to run more than one system at a time.” MPAA urged the FAA to supply a mechanism in the rules to permit additional flexibility for filming in controlled environments as such technology improvements. The National Association of Broadcasters, National Cable & Telecommunications Association, and Radio Television Digital News Association stated that given the pace at which technology is developing, the FAA should be amenable to thinking about automated systems that consider one person controlling multiple smallish UAS that demonstrate an equivalent level of security to the demands of the last rule.
The FAA acknowledges the points raised by the commenters that the dangers discussed above may, at some stage in the future, be mitigated via technology. But as of this writing, the FAA doesn’t have information on which to base security finding the available technology for multiple simultaneous small unmanned aircraft operations by a single individual has developed to the extent required to allow these kinds of surgeries in a rule of general applicability. The FAA also acknowledges the benefits of research and development related to the simultaneous operation of multiple unmanned aircraft and considers that additional flexibility is called for in this rule so the bureau can administratively allow these kinds of activities based on operation-specific mitigations. To obtain a waiver, someone will need to demonstrate that his or her simultaneous operation of more than one small unmanned aircraft can safely be run under the conditions of a certificate of waiver. The FAA recognizes the possibility of a single person having the ability to operate multiple small unmanned aircraft and will evaluate operations performed under FAA-issued waivers to help inform future agency activities to allow the simultaneous operation of numerous modest UAS. Amazon claimed that the proposed limitation is based on the faulty premises that little UAS has to be operated under continuous manual control and that FAA-recognized mitigation measures like flight termination systems aren’t already available today. Aerial Services and MAPPS said that the FAA should enable the functioning of swarms of UAS if the flight management system is capable of supporting it and every aircraft has stiff automated procedures in the event of loss of signal.
As mentioned previously, swarms of numerous small unmanned aircraft which are linked up to one system pose additional risk into the NAS as one unmanned aircraft losing its connection to the management system may destabilize the system and result in a reduction of favorable control of multiple aircraft. Additionally, the FAA doesn’t currently have information on which to base a finding that the appropriate technology has grown to the extent necessary to enable the safe operation of numerous small unmanned aircraft in a rule of general applicability. Therefore, the FAA will consider using the technology on a case-by-case basis through the waiver procedure.
AirShip Technologies and the NJIT Working Group cited army and non-military uses for clusters, swarms, and numerous UAS. These include battle, first responder assignments, mapping, and search and rescue operations.
The FAA agrees with the commenters that the performance of numerous unmanned aircraft may offer a valuable and broad spectrum of solutions. However, the technology needed to mitigate risk associated with this kind of surgery is still in its infancy and hasn’t yet been shown to meet a degree of reliability sufficient to allow that technology to be relied on for hazard mitigation in a rule of general applicability. As mentioned previously, the waiver process will continue to be accessible for smaller UAS operations that fall outside the operational parameters of part 107.
The commenters further stated that the FAA has a constitutional responsibility to explore the adequacy of simultaneous performance technology. Otherwise, the commenters continued, the principle will significantly increase the expense of working UAS, thus limiting their accessibility for both consumer and commercial applications that are protected by the First Amendment.
Depending on the number and higher quality of the comments submitted, the FAA believes that this lack of information wasn’t an oversight but, rather, evidence of the fact that present data concerning this technology is quite limited at the moment. The FAA will keep on exploring the feasibility of the technology in future agency activities which are going to be informed, in part, by little UAS operations which will happen below a part 107 waiver permitting the operation of numerous small unmanned aircraft in exactly the exact same time.