The Federal Aviation Administration has responded to Disney’s request for an exemption under Section 333, permitting the company’s use of unmanned aerial vehicles (UAVs) for theme park entertainment. After a period of time soliciting comments from the public — 12 in all, most decidedly against granting Disney the exemption — the FAA has responded, but with a series of questions seeking more clarification on Disney’s intents and implementation. The list of questions the FAA is requiring answers for before making a final determination are as follows:
- Will flight operations be conducted at night only? After twilight? Will the hours of operation coincide with the fireworks display?
- Will the payload lights (show lights) be illuminated throughout the operation? Will they flicker at intervals? Will they be cycled on then off and then back on again?
- Do the “Flixels” aircraft have navigation and/or anti-collision lighting systems? To what capabilities? How far are the lights visible? Are these separate from the payload light?
- Will the nav and anti-collision lights be illuminated throughout the entire operation?
- Would a 500’ buffer from spectators be prohibitive to Disney’s operation?
- How has Disney tested the geo-fencing capability? Is there data which can be provided to the FAA? What happens when GPS fails?
- How is altitude and speed limited in the aircraft? Are there software limits?
- Is the specific UA identified if it breaks the geo-fence or limits? How?
- How will Visual Observers (spotters) be used and how will they be positioned?
- What is the reliability of the platform’s communication links? What is the susceptibility to interference?
- What is the lost link procedure? What is the susceptibility of the communication links to interference and/or hacking?
- Is there any flight test data to validate the show area and geo-fence safety distances?
- Have test flights of the shows been conducted? How many hours or shows have been successfully completed? Are there any known accidents or incidents?
- Further explain the heartbeat/watchdog concept.
- Is there any reliability data for the flixels safety response escalation steps?
- Is there wind test data on the 48” X 48” X 48” payload configuration?
- Provide a 3 view scale drawing of each of the flixel payload configurations.
- Confirm the service ceiling for the lightest flixel payload configuration.
- Confirm the maximum number of UAS per operation is 50 aircraft, that they will all be multi-copters, and the maximum flight time will be 5 minutes.
- Send a scaled version of Figure 2 found in the non-proprietary petition document. Does Figure 1 scale apply?
- Is the hardware, battery, and/or multi-copter malfunction rate more than 10% of the fleet? If so, how is this addressed?
It appears the FAA’s strongly concerned with the safety aspects of Disney’s drone use, which was also a running theme to those vocally opposed to the exemption, particularly in the absence of licensed pilots. Question #5 is rather interesting in that Disney’s original request was to keep guests just 100 feet away from the operations, but the FAA seems to be pushing for a buffer zone five times greater.
Despite the number of technical questions, the FAA granted Disney just two weeks to satisfy the request or they ‘will close the docket without notifying [Disney] further.’ The notice was actually issued on May 10, 2016, which meant Disney had up until yesterday to respond to the request for more information. No additional information has yet been made public.