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whoop_exemption.txt
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Draft application for CASR exemptions for Whoops.
Introduction
This application is for an exemption to certain Civil Aviation Safety Regulations when
operations are performed with a specific type of model aircraft, referred to herein as a
"Whoop"", being an ultra-light, enclosed propeller, non-autonomous, fixed camera FPV
drone.
These drones have an extremely low risk profile, mostly because of their very low mass,
relatively low speed and limited range. Our risk analysis indicates that they represent a
hazard to other airspace users, persons or property not meaningfully greater than that of
a frisbee, and less that that of a soccer or cricket ball.
Due to their small physical size, accurate and safe flight path control and collision
avoidance control is best provided by FPV control. We therefore seek an exemption from
the requirement that they only be flown only by direct line of sight visual control.
Because of their exceptionally low risks associated with collisions, limited speed and
range, and lack of unintended autonomous flyaway capability, we are also applying to
permit flight over populous areas, closer to other persons, closer to aerodromes, and at
night and in poor visibility (subject to conditions).
We provide a detailed risk analysis and links to videos demonstrating their extremely low
capability for damage or injury.
1. Duration
Three years
2. The model aircraft type for which the exemption is requested
The exemptions requested shall apply to all drones with the following characteristics:
(a) All up weight, including battery, is less than 100g (to limit impact damage to other
airspace users, or property, or injury to people).
(b) Equipped with an FPV camera and video transmitter.
(c) Where the angle between the camera and the frame is fixed, and the camera points
forward and not downward (so that the pilot always sees ahead).
(d) Propeller tips are enclosed within circumferential ducts (to minimise the risk of
skin lacerations on impact).
(e) Incapable of autonomous flight, e.g. unable to perform automatic return to home or
other automated or autonomous manoeuvres (to reduce the risk of flyaways).
(f) The motors automatically power down if radio control reception is lost continuously
for more than one second (to minimise injury or fire from crashing with active
propellers).
(g) Provides a visual display, in the FPV video stream, of battery voltage and radio
control signal strength, updated at least every second, and an alarm either visually
on-screen or audibly via telemetry to the radio transmitter when either value is low.
(h) provides means for the pilot to immediately disarm the flight controller and stop
the motors, at any time.
3 Exemptions
(a) 101.073 Subregulation (1) shall not apply (the drone may be operated FPV, and need
not be operated within the visual line of sight of the pilot)
(b) 101.238(d)(3) shall not apply (the drone may be operated over a populous area)
(c) The distance specified in 101.238(d)(v) of the standard RPA operating conditions
(minimum distance of RPA from the movement area of a controlled aerodrome) shall be 1000
metres.
(d) 101.385 Shall not apply (the visibility of the model aircraft must be good enough for
the pilot to be able to see it continuously), but only if:
- the visibility in the pilot's FPV display is sufficient to meet the safety requirements
that would apply if the visibility was good, and
- while in flight, the drone is visible at a distance of 20m from the drone
(e) 101.390 Shall not apply (the drone may be operated at night), but only if:
- the visibility in the pilot's FPV display is sufficient to meet all the safety
requirements that would otherwise apply in daytime, and
- while in flight, the drone is illuminated and visible at a distance of 20m from the
drone
(f) The distance specified in 101.395(2) and 101.238(c) (to keep 30m away from anyone not
directly associated with the operation of the model aircraft) shall be:
- 5 metres for a Whoop under 50g, or
- 10 metres for a Whoop under 100g
4 Conditions
The pilot shall not operate the Whoop, in controlled airspace, above 100 ft AGL.
The pilot shall not fly beyond the range where degradation of the video signal may affect
safe operation of the drone.
The pilot shall confirm the normal operation of the drone, the radio control radio link,
and the FPCV system before commencing the FPV operation.
If the FPV video image starts to degrade, the pilot shall take appropriate measures to
restore a normal video image, i.e.,turn around, increase altitude, or return to a previous
area where the signal was strong.
The pilot shall immediately disarm the drone if the video feed degrades such an extent
that safe operation of the drone is no longer possible.
The pilot shall not power up the drone's video transmitter without first confirming that
no other airspace user is currently using the intended video channel.
The pilot shall monitor the battery voltage during the flight, and ensure there is enough
residual capacity to fly to a safe landing place.
The operation of the drone should not cause unreasonable annoyance to people not
associated with the operation of the drone, e.g. as a result of noise or visual
distraction.