Drone Flight Permissions

This article discusses the laws and regulations of flying small drones for the MRSD project. It details the process to fully certify your drone and obtaining flight permissions from the Federal Aviation Administration (FAA) and Carnegie Mellon University (CMU). Furthermore, the article disucsses the rules for two registration categories. For most projects, students should consider the Recreational Fliers ruleset that does not require pilot licensure. Projects that need special flight permissions, or are pursuing further funding, should consider the Part 107 ruleset.

Background

The FAA regulates the operation of all drones due to the recent surge in Unmanned Aircraft Systems (UAS). Due to the rapidly evolving environment around drone use, this entry is only guaranteed to be accurate as of April 6, 2020. Any reader passed this date should use this entry only as a guide and reference before confirming current regulations. CMU maintains a drone information page which should be referenced for a summary of up-to-date information: https://www.cmu.edu/ogc/Guidance/drones.

There are two major categories under which students should consider when flying during the MRSD project. The first is flying under the FAA’s Small UAS Rule (Part 107). This flight category allows the most freedom in flying, but also requires more thorough registration and licensing. The second is flying as a Recreational Fliers or as part of a Modeler Community-Based Organization. This categorization offers few flight permissions but is easily obtainable and suitable for many MRSD applications. A summary from the FAA rules applicable to education users can be found here: https://www.faa.gov/uas/educational_users

Fly as a Recreational Fliers or as part of a Modeler Community-Based Organization

Flying as a recreation flier is the rule set that most MRSD students should consider for the project. Under this ruleset, students can fly drones under the guidance of Carnegie Mellon University without obtaining any sort of pilot’s license. The key caveat is students can only fly under this categorization if they “fly only for recreational purposes.” The MRSD project can satisfy this requirement because it is not directly related to a professor’s sponsored research, and all funding relating to the project is not for financial gain. As such, the project can largely be described as recreational. Students looking to commercialize their MRSD project, or wanting to otherwise fly outside of these rules, should consider flying under Part 107.

When flying under this category, abide by the following rules:

Fly only for recreational purposes
Fly at or below an altitude of 400 feet.
Fly only over CMU property, or property that you own.**
Maintain a direct line-of-sight with the drone, or within line-of-sight of a visual observer, who can see the drone.
Fly only during the day, or at twilight if installed lights on the drone clearly distinguish its pose.
Never fly over any person or vehicle.
Give right of way to all manned aircraft.
Do not interfere with emergency response activities.
Never fly under the influence of drugs or alcohol.
Do not operate the drone in a careless or reckless manner.

** If you want to fly over any other land, including parks, contact the property owner and discuss flight operations before use.

These rules are all subject to change and should be reviewed at the beginning of every Fall semester. A major change likely coming in the near future will include an online test to certify all operators. Additional rules are included in the Part 107 categorization and likely also apply to recreational fliers despite not being explicitly stated.

Fly Under Part 107

Part 107 is the main law for all small drone operations. It allows operators to fly anywhere allowable by local laws. Part 107 flying MRSD students should also consider this option if they’re planning on commercializing their project.

In addition to the recreational fliers rules, Part 107 includes several other rules that most likely apply, but are not explicitly stated under the “Recreational Fliers” page.

Operate only a single aircraft at a time.
Do not fly under a covered structure, or inside of a covered stationary vehicle.
Maintain an airspeed below 100 mph.
You can only carry an external load if it does not adversely affect the flight characteristics or controllability of the aircraft. Only transport property for compensation within state boundaries, and ensure the entire weight of the aircraft and payload is below 55 pounds.

Any teams needing to fly outside of these rules should consider applying for a Part 107 waiver from the FAA. In order to receive permission, operators must demonstrate they can safely deviate from the operational parameters and maintain flight safety using alternative methods. Waiver options include the following:

Fly over a person or people.
Fly from a moving aircraft or vehicle in populated areas.
Fly at night.
Fly beyond visual line of sight.
Fly without a visual observer.
Fly multiple drones simultaneously.
Fly in controlled airspace.

Procedures

Fly as a Recreational Fliers or as part of a Modeler Community-Based Organization

a. Select: “I Fly Under the Exception for Recreational Fliers”

b. The registration fee is $5, and you will need the drone’s serial number

c. Mark the drone with the registration number

Request permission from CMU’s legal department

a. Email drones@andrew.cmu.edu and fill out the form they send you.

- Emphasize the project only receives funding to provide materials.
- Be specific with the use case and flight parameters. Areas students typically want to fly include the athletic fields, the Cut, and the Mall.

Discuss/Meet with the departments that control the space where you want to fly.

Our team decided to fly over the football and/or soccer fields because they are open spaces. As such, we were directed to meet with the Associate Director of Athletics (Sara Gauntner). During our meeting, she recommended flying in the mornings or on weekends to avoid high pedestrian traffic. She asked us to check 25-Live to ensure the fields are not scheduled during our testing time and email her to reserve the fields. If any pedestrian does not respect our testing space, we can contact Sara, who will remove them from the field.

Fly Under Part 107

In addition to the Recreational Fliers registrations, Part 107 operators must become an FAA-Certified Drone Pilot. This process should take place before registering the drone because your pilot number is required for Part 107 drone registration.

Pilot Certification Process:

Obtain an FAA Tracking Number (FTN) by creating an Integrated Airman Certification and Rating Application (IACRA) profile prior to registering for a knowledge test.
Schedule an appointment with a Knowledge Testing Center which administers initial and recurrent FAA knowledge exams. Be sure to bring a government-issued photo ID to your test.
Pass the initial aeronautical knowledge test. Knowledge test topic areas include:

Applicable regulations relating to small unmanned aircraft system rating privileges, limitations, and flight operation
Airspace classification and operating requirements, and flight restrictions affecting small unmanned aircraft operation
Aviation weather sources and effects of weather on small unmanned aircraft performance
Small unmanned aircraft loading and performance
Emergency procedures
Crew resource management
Radio communication procedures
Determining the performance of small unmanned aircraft
Physiological effects of drugs and alcohol
Aeronautical decision-making and judgment
Airport operations
Maintenance and preflight inspection procedures

For test preparation materials, see the Further Readings

Complete FAA Form 8710-13 for a remote pilot certificate (FAA Airman Certificate and/or Rating Application) using the electronic FAA Integrated Airman Certificate and/or Rating Application system (IACRA)*
Register using the FAA IACRA system
Login with username and password
Click on “Start New Application” and
Application Type “Pilot”
Certifications “Remote Pilot”
Other Path Information
Start Application
Follow application prompts
When prompted, enter the 17-digit Knowledge Test Exam ID (NOTE: it may take up to 48 hours from the test date for the knowledge test to appear in IACRA)
Sign the application electronically and submit for processing.
A confirmation email will be sent when an applicant has completed the TSA security background check. This email will provide instructions for printing a copy of the temporary remote pilot certificate from IACRA.
A permanent remote pilot certificate will be sent via mail once all other FAA-internal processing is complete.
Have your Remote Pilot Certificate available whenever you fly your UAS

Summary

Obtaining all flight permissions and registrations under the Recreational Fliers ruleset is a straightforward procedure sufficient for most MRSD projects. If you have any questions about which ruleset you should follow, contact drones@andrew.cmu.edu for guidance. For up to date information, check the CMU drone’s page at https://www.cmu.edu/ogc/Guidance/drones and review the FAA Information under Further Reading.

Background

Fly as a Recreational Fliers or as part of a Modeler Community-Based Organization

Fly Under Part 107

Procedures

Fly as a Recreational Fliers or as part of a Modeler Community-Based Organization

Fly Under Part 107

Pilot Certification Process:

Summary

Further Reading

Part 107 Exam Material

FAA Information