I have been asked to help with a local project which involved flying a drone above 300 school children who will be spelling out a word on the School field. I will be flying upwards above them to reveal the word. This is all done with the consent of the school and head teacher.
I have been trying to check what the rules are for flying above a group of 300 school children but to me it doesn’t seem clear. As far as I can tell as long as the crowd is less than 1000 and they have given permission there are no issues. I guess in this instance parental permission might be required?
I have a GVC certificate so can fly in the specific category.
My initial reaction to this is that, as the children are all aware that you will be there, and can be briefed on what you are doing, what to do if things go wrong etc, then they are no longer “uninvolved people” and so the normal separation distances do not apply.
What type of drone is it?
I don’t think there is a specific number that specifies a ‘crowd’ as its more to do with whether they can get out of the way if things go wrong.
I guess I was a little uncertain what defined a “crowd” - it seems a bit vague to be honest. I think I will speak to the school and leave the parental permission up to them and assume that if the School say it is ok then the 300 primary school kids are ‘involved’ and I can fly over them.
Obviously I will brief everyone involved on the day and beforehand carrying out a full risk assessment etc.
The drone I have is a Phantom 4 RTK - as we usually carry out environmental surveys - so it is not ideal for this task really. We are doing it has a favour and I normally carry out photogrammetry surveys in the middle of the countryside with no one around, hence the apprehension on this one.
Yes, I would be a little nervous of flying a 1.4kg drone over 300 kids, even if they are involved.
The DJI Mini series drone are ideal for these scenarios being sub 250g. Not sure if you’ve been considering buying one - it certainly is a ‘must-have’ for the drone toolkit.
you probably also need to brief them on what the planned flight is, so they can tell what it will look like when its going right and anything else maybe going wrong and they will need to move away, plus where your TOAL is and your back TOALS are should something need to be aborted
children are a difficult one under the law as to what constitutes age of responsibility … I believe 10 is the age above which children are able to take criminal responsibility for their actions (legally) … it comes from murder, a child under 10 I don’t believe can be tried for murder but one 10 or over can be as under 10 they could not understand what they are doing. you can transpose this into agreement and understanding… I’ve don’t fly a drone over a group of 300 under 10 year olds as no amount of explanation or agreement would have their understanding as to what they are agreeing to…
mental age is another one if you have people with mental impairments
no amount of parental consent will permit something to happen as really you need to make the persons involved persons
What makes an assembly is not the number of people, or whether they are 'involved, but rather whether they have the ability to escape should the UA pose a risk to them (CAP 722 2.1.5.2)
e.g. if the UA started to fall towards them, could they get out of its way in time, or would they fall over each other in a mad scramble?
Thanks for the advice @robertspark much appreciated and all makes sense. I think the age of criminal responsibility in Scotland is 12 rather than 10 (probably England & Wales I imagine) but I take your point. Sounds like it could be a fun day
On the face of it I’d have said that if you make them involved persons then the legality of the ‘over uninvolved persons’ is handled and it becomes about whether or not you think the risks can be sufficiently mitigated…
But let’s be honest, at the very least, a group of 300 kids is going to include some with a propensity to… well, to act like kids and misbehave. You’re certainly going to have to tailor your briefing for the age group and you’ll need to think carefully about any risk above and beyond those involved with a group of adults.
As @robertspark says, you’ve also got the question of whether primary-aged children can even consent to being involved persons here. If not, can their parents consent through a simple permission slip? I suspect not, in the same way that a disclaimer on the back of a ticket wouldn’t be seen as getting consent from everybody at a festival.
At the end of the day, you’re the responsible pilot. If you’re confident that you’ve mitigated the risks and everybody there is ‘involved’ (and that you can justify that confidence if something does go wrong), then fill your boots.
You could always ask the CAA directly what their stance is on briefing children for this. Worst they can say is no…
Email uavenquiries@caa.co.uk or telephone 0330 022 1908 (Monday to Friday 8:30am to 4:30pm).
Could you get the pupils to do one letter at a time? Reduce the number put at risk per time, also allows escape space to take them out of the ‘assembly’ situation. Combine with a personal briefing and an emergency practice (which they may enjoy …)
Then stitch together the letter pictures to make the word in Photoshop
I agree I am definitely over thinking it and I think your suggestion is a good one and that is what I intend to do to avoid being directly overhead. There is a Drone No Fly Zone right next to the school (in fact it overlaps with some of the school grounds) which give me less room to play with, but I am sure I will figure it out.
Discussion of “involved persons” is irrelevant. In the Open category, you cannot fly over “assemblies of people” in any subcategory. Full stop. It doesn’t matter if you brief them. See CAP1789A, Article 4(1)(c).
In the Specific Category, the GVC is of no value on its own. It is just the training evidence to acquire an Operational Authorisation from the CAA, and if you have an OA you’ll know exactly whether you can overfly a crowd: it will set out in detail what you can do, and how to do it. If you don’t have an OA, the GVC is worthless.
If you did get an OA, the default version is “UKPDRA01” (in CAP722H), which is also clear that “Flights must not be carried out within 50m horizontal separation of assemblies of people”, and also includes the 1:1 rule (i.e. it’s more onerous in many cases than what we can do in the Open category). There are some people with better OAs, but I suspect very few can fly over an assembly.
