Chapter 15 Waiver for Operations over People - ParaZero

15.1 General

UAS activity over people (other than Flight Personnel) are prohibited under 14 CFR 107 unless the operator has been granted an FAA Certificate of Waiver that waives the prohibition in 14 CFR 107.39 on flights over human beings that are not directly participating in the operation of the UAS or located under a covered structure or inside a stationary vehicle that can provide reasonable protection from a falling unmanned aircraft.

The University of California was granted an Operational Waiver of 14 CFR 107.39(a) - Operation over Human Beings (Waiver Number: 107W-2019-04492). This waiver is specific for DJI Mavic 2 series UAS with the ParaZero SaveAir Mavic and ASTM Professional Kit installed. This waiver is only applicable within Class G airspace, and may only be utilized in accordance with the provisions within this manual. The following is an addendum to the previous operational instructions within this manual.

15.2 Aircraft Restrictions

  • Operations conducted under this Waiver may only occur with DJI Mavic 2 series UAS equipped with the ParaZero SafeAir parachute system and in compliance with ASTM F3322-18 Standard Specifications for sUAS parachutes.
  • The parachute must be packed or repacked by the manufacturer or a manufacturer certified repacker. If the SafeAir system has been opened or deployed, contact to receive shipping instructions for repacking.
  • Any UAS that has undergone maintenance that affects the UAS operation or flight characteristics (e.g., replacement of a flight critical component), must undergo a functional test flight prior to conducting operations under this Waiver. The functional test flight may only be conducted in accordance with requirements of part 107 (without waiver). Operations over human beings during functional test flights are prohibited;
  • Any modification to the UAS design is prohibited. Repair and replacement of damaged components is allowed, provided the replacement part is exactly the same as the original. No substitutions are allowed unless a new waiver application is submitted;

15.3 Addendum to Roles and Responsibilities

The following items are added to the respective Roles and Responsibilities.

System Designated UAS Authority

  • The Systemwide Designated UAS Authority listed on the Operational Waiver is responsible for the safe conduct of operations. Prior to conducting UAS activity that are subject of the waiver, the Systemwide Designated UAS Authority :

    • Must ensure all Direct Participants are informed of the terms and provisions of this Waiver and the strict observance of the terms and provisions herein,
    • Must ensure all Direct Participants are informed and familiar with part 107 regulations not waived, and
    • The Systemwide Designated UAS Authority must keep a record of the communications that establish compliance with the above paragraphs. This record must be presented for inspection upon request by the Administrator or an authorized representative;

  • The Systemwide Designated UAS Authority listed on this Waiver must maintain a current list of unmanned aircraft by registration number(s) and SafeAir parachute system serial number used in the UAS activity that are subject to the waiver. This list must be presented for inspection upon request by the Administrator or an authorized representative;

  • The Systemwide Designated UAS Authority listed on this Waiver must maintain a current list of remote pilots by name and remote pilot certificate number used in the UAS activity that are subject to the waiver. This list must be presented for inspection upon request by the Administrator or an authorized representative;

  • The Systemwide Designated UAS Authority must maintain the sUAS and its components in accordance with manufacturer’s instructions. The aircraft manufacturer may provide the maintenance program, or, if one is not provided, the Responsible Person must develop one prior to performing sUAS operations that are the subject of this waiver. sUAS maintenance includes scheduled and unscheduled overhaul, repair, inspection, modification, replacement, and system software upgrades of the sUAS and its components that are necessary for flight. Each sUAS operated under this Waiver must comply with all manufacturer safety bulletins. Records of this maintenance must be retained for 90 days after the expiration date of the waiver;

  • If the intended operation would be contrary to or obviate a common or special provision of this waiver, then the Systemwide Designated UAS Authority must apply for an amendment to this Waiver;

  • If a discrepancy exists between the special provisions in this Waiver and the procedures outlined in the waiver application, the provisions herein take precedence and must be followed. Otherwise, the Systemwide Designated UAS Authority must follow all procedures as described in the waiver application;

Remote Pilot in Command

  • An RPIC operating under this waiver must have at least 5 hours of flight training with the UAS
  • The RPIC must have conducted at least 3 launch and recovery operations within the last 6 months with the UAS to be considered current.
  • The RPIC must have completed a UAS Operations Over People knowledge course and must annually pass a knowledge exam with a passing score of 100\(\%\). A certificate of completion of the course and the exam with a passing score must be submitted to the Designated Local Authority and the Systemwide Designated UAS Authority, and must be available while on-site.
  • The ASTM documentation provided by ParaZero must be submitted to the Systemwide Designated UAS Authority before use.

Visual Observer

  • At least two Visual Observers are required for any operation under this waiver.
  • No one may operate as a Visual Observer unless they have read and familiarized themselves with the content of the Part 39 waiver.
  • The Visual Observer must have completed a UAS Operations Over People knowledge course and must annually pass a knowledge exam with a passing score of 100\(\%\). A certificate of completion of the course and the exam with a passing score must be submitted to the Designated Local Authority and the Systemwide Designated UAS Authority, and must be available while on-site.
  • At least one Visual Observer must maintain verbal communication with the RPIC without the need for a radio or electronic devices.
  • Auxiliary Visual Observers may utilize a radio or other devices to maintain verbal communication.
  • At least one Visual Observer must be sufficiently trained to land the unmanned aircraft in the event that the RPIC is incapacitated, and must be able to take command of the unmanned aircraft within 10 seconds.

15.4 Addendum to Flight Planning

The following provisions are required for UAS activity under the Waiver:

  • The FAA has the authority to cancel or delay any or all flight operations in order to maintain safety or to ensure compliance with the terms of this Waiver.
  • This Waiver must not be combined with any other waiver(s), authorizations(s), or exemption(s) without specific, prior authorization.
  • Operations under this Waiver are to be conducted in Class G airspace only unless specific airspace authorization or waiver is received from the FAA in accordance with § 107.41.
  • A copy of this Waiver must be available during the sUAS operations that are the subject of this Waiver.
  • Operations over all human beings (including nonparticipants) are permitted.
  • Operations may not occur over moving vehicles.
  • The sUA must be flown at a minimum at least 70 ft AGL when above nonparticipants.
  • Flight Personnel must be easily identifiable visually (e.g. apparel, safety vests).
  • The location and time of UAS activity must be selected to provide the maximum safety of people and equipment, and UAS activity must be conducted only if necessary. The decision to operate above people is not to be considered lightly and other options must be considered first.
  • If the UAS loses communications or loses its GPS signal, the UAS must return to a predetermined location within the operating area and land. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. If all standard reconnection procedures fail, the RPIC has the ability to safely terminate the flight by manually triggering the SafeAir System if the sUAS does drift towards an area that is deemed to be higher risk.

15.5 Record Keeping Requirements

Records shall be maintained for each flight conducted under the terms of this waiver, and records must be retained for a period of 90 days after the expiration date of the Waiver. The Responsible Person shall keep these records at its principal place of business or at other places approved by the Administrator, and shall make the records available for inspection by request of the Administrator. Each record should contain the following:

  • Date, Name of Operator, Responsible Person, Waiver number and Aircraft registration number

  • All operating locations, to include location city/name and latitude/longitude

  • Number of flights (per location, per aircraft)

  • Total aircraft operational hours

  • Approximate average altitude of flight

  • Equipment malfunctions. Reportable malfunctions include, but are not limited to the following:

    • On-board flight control system
    • Navigation system
    • Power plant failure in flight
    • Electrical system failure
    • Control station failure
    • Any failure or malfunction that was followed by a ground collision

  • The number and duration of lost link events per sUA per flight.

  • Number of people, if any, impacted by the sUA

  • Descriptions of any injuries that anyone suffers as a result of an impact with the sUA.

15.6 Supplementary Training Requirement

The UC has developed a supplementary training program that includes an online Operations over People knowledge course and corresponding knowledge exam. All persons involved in the flight operations must have completed this UAS Operations over People knowledge course and knowledge exam prior to any operations under the Waiver.

The knowledge course covers the following material:

  • General knowledge of Operations over People

  • Review of Part 107 requirements

    • Aeronautical Decision Making
    • Crew Resource Management

  • Equipment

    • DJI Mavic 2 series
    • ParaZero SafeAir parachute system setup
    • ParaZero ASTM compliance

  • Operation planning

    • Site Inspections

    • Site Evaluations

    • Example Scenarios

      • Closed-set filming
      • Sparse Crowds at Events

  • Emergency Management

    • Air Traffic Avoidance Procedures

    • Optical Illusions

      • Auto Kinesis
      • False Depth Perception
      • Flicker Vertigo
      • Reversible Perspective Illusion
      • Size and Distance Illusion