FPV for whoops

The first broad exemption application for FPV should likely be for whoops, since they are the lowest-risk class of FPV flying imaginable.

The initial draft has been started!

What follows is my initial risk assessment and evaluation on which the exemption request will be based.

We would note, in the risk analysis, that:

• with very low mass, and the relatively low maximum speed, the maximum impact energy is well below that of a firmly struck cricket ball, soccer ball, frisbee or other common recreational toy, especially 1S whoops with weight below 50g. Probably need to identify that 1S are slower and less hazardous than heavier 2S. See table below. The risk of kinetic energy based injury to person or property is so low as to be irrelevant for 1S, and very small for 2S.
• with enclosed propellers, and the absence of sharp points generally, combined with the low speed and light weight, the risk of skin laceration or eye injury is extremely small, even with full speed impacts
• low mass and the very low maximum altitude restriction greatly reduces the risk to other airspace users; risk of damge from impact is far less than that of a 1kg bat or 250g bird, for instance
• maximum free-fall speed is low; risk of failure while flying over populous areas is small
• drag:thrust is relatively low, limiting range and top speed.
• The risk of error flying FPV is less than LOS due to lack of spatial cues when flying LOS with such a small drone
• by not permitting autonomous flight, flyaways are unlikely
• by having FPV specific checks and procedures, the safety of FPV greatly enhanced over not having defined procedures
• The noise of the drone is far less than of larger drones.
• The risk of fire from a tiny drone is miniscule since the impact energy is insufficient to breach the lipo and the heat to surface area ratio of these tiny lipos is very low.

Relative kinetic energy table, with typical average ball speeds, and near max speed for Whoops:

Type	Mass(g)	Velocity(kph)	KE(kg.kph^2)
Pingpong Ball	2.7	50	67
Frisbee	175	50	437.5
Cricket Ball	260	80	1,664
Soccer Ball	430	70	2,107
Whoop_Small	40	60	144
Whoop_Large	100	80	640

The application could include videos of impacts of whoops vs various objects, comparing a whoop to a cricket ball, demonstrate sufficient visibility at night, demonstrating inability to harm people or damage property.

Possible proposal:

Requested exemptions

• FPV allowed
• Spotter not required (near zero risk of injury, low probability of hitting someone)
• separation from people or property 5m for under 50g, 10m under 100g
• flying over populous areas permitted, but not roads with traffic
• flying within 1km of approach/departure of airport permitted
• may be flown at night provided that the area and the drone are illuminated well enough that the pilot's FPV view is as good as daylight, and the drone can be by other people at least as well as in daylight.

The drone itself:

• AUW < 100g
• FPV camera physcially fixed (no gimbal), must point forward, and must not point downward
• prop tips must be within ducts so they cannot cause skin laceration on impact
• autonomous flight not permitted (eg, no auto return to home, no auto manouevres)
• automatic motor disarm after loss of Rx for 1s or longer
• battery voltage and Rx signal strength indication, with visual alarm in the OSD or auditory via telemetry to the Tx

Flight procedures:

• must not cause a safety hazard
• should not be a nuisance (noise, proximity, distraction of other people)
• additional FPV specific pre-session safety checks and procedures must be followed
• must not be flown above 100 feet AGL
• must not be flown over roads with traffic
• battery status must be monitored and return leg planned appropriately
• special care when flown on windy days
• keep away from people: Under 50g, >5m away, under 100g, >10m. etc