Power Plants, Elec Sub-Stations & sUAV Flights

[dougcjohn]

I have a construction site survey in a downtown city block that fronts up to the river on East side. The next block North... is a small electrical sub-station that sits on the Northern 1/2 of the physical block... with the remaining segment being a small City Park. The Park is between the construction block and the sub-station.

The DJI app shows an area for sub-station without any warnings, KittyHawk app doesn't even show the sub-station, the AirMap App shows it as a small zoned circle but when using LAANC to register a construction survey, it lists the sub-station in the same manor as multiple Medical Heli Pads, Local Jail, Federal Site and Airports in that it's not indicating a NFZ, TFR, or restricted section... just under the Notices it lists it as: "Electrical Power Station".
The City\Fed Jail, interestingly presents a Popup Acknowledgement Pre-Flight Notice that must be acknowledged to take-off... indicating that PIC is aware of being within a zone for a Jail, Not allowed to fly over Jail and PIC is acknowledging will not fly over the Jail.

My flight path for the construction survey does not go over the Sub-Station, but it does enter the zoned circle of the sub-station. Per my understanding, if flying over a Power Station it's not prohibited as a NFZ, but you're suppose notify and obtain permission from the Power Company.

My question, if it's a sub-station, not a power plant... and if it's restricted, shouldn't the AirMap app (or other Apps) show it's restricted, not provide PIC authorization for flight as not allowed? Does one need to obtain permission to fly in same block as the circle zone of Electrical Station if not going over the sub-station?

I've been flying the construction site for 3 months on a weekly schedule (weekend) with no issues. Police have been working the construction site driveway for dirt trucks, and Sub-Station crews have been present every weekend. This weekend, 2 Gents came over and said I wasn't allowed to fly over the sub-station and needed to cease. I mentioned I wasn't over the sub-station, offer to show my flight path and indicated I had received FAA flight approval for the flight. They did mention in the conversation, that their Boss said the area had a "NFZ" circle around it, I showed them multiple maps that indicated different. They were "Sent" over by their Boss so they didn't really care... we all chatted for a bit and they returned to work with a satisfied opinion I wasn't a concern.

I'm not wanting to be outside legal standing, but I don't want to encourage a possible refusal and then have the construction survey limited.

Am I in the wrong?

 

[R.Perry]

From what you are saying, you are legal as long as you don't fly over the jail. The power plant has no legal right to restrict you for overflying their plant, only the FAA has that authority, if there is no TFR or NFZ then you are good to go.

 

[dougcjohn]

From what you are saying, you are legal as long as you don't fly over the jail. The power plant has no legal right to restrict you for overflying their plant, only the FAA has that authority, if there is no TFR or NFZ then you are good to go.

Thanks for the reply... that was the assumption I was under, but the situation introduced question. Wasn’t there a restriction issued... Or some issuance that stated power stations were restricted due security & infrastrctures... Maybe it was discussed and never evolved by Congress... as a form of regulation. It might be something currently considered... can’t recall where I’ve read it.

 

[PatR]

Nuclear power plants are restricted. Unless DHS, the utility, and the FAA have worked out a special site restriction, as employed with many dams, standard sub stations are not restricted. You will need to communicate with site management to determine if a special restriction is in place.

 

[dougcjohn]

Nuclear power plants are restricted. Unless DHS, the utility, and the FAA have worked out a special site restriction, as employed with many dams, standard sub stations are not restricted. You will need to communicate with site management to determine if a special restriction is in place.

Thanks Pat, I'd agree and was aware of Nuclear as sited on FAA. Just thought I read somewhere standard power stations received similar restriction with allowance provided with permission. I'm probably confusing a proposal via some office, read several and may be blending with current regulations.

Communicating with power station, my concern there is accuracy. The mgmt level obtained may not know or understand, and if they're negative on drones... I question accuracy.

I thought I'd call my local tower, the ATC that works there is the one whom set the LAANC altitudes for the City. He originally had several sections (area of construction & sub-station) as Zero and required verbal communication to approve due to 3 medical heli pads, he wanted agreement that you'd call the Heli stations to communicate flight info directly. Those sections where later moved to 400 when FAA Administration indicated he couldn't require additional authorization beyound LAANC.

He may be aware of any special restrictions permitted. Although, I'm still confused as to why those wouldn't show up on various apps and sectional if it's ongoing.

 

[BigAl07]

Contact your FSDO and find out from them what restrictions are in place for that exact location. If it's deemed "Sensitive Infrastructure" then you'll need to get authorization from the Agency Having Jurisdiction over the facility.

Odds are if you ask the facility first they are going to tell you right off the bat (and possibly incorrectly) they do NOT approve your flight. You'll need to get it from your FSDO if that area is indeed "Sensitive Infrastructure" or not.

 

[PatR]

Probably the most critical thing in that flight will be making sure a drone does not experience an issue and fall into the sub station. You can’t go after it and it could bugger everything. Aerial Alchemy performs a lot of sub station work and establishes protocols with the utility to deal with the possibility.

I agree with Big Al on the permission thing. Calling corporate could end up a long process with lots of call transfers before getting an answer, with that answer dependent on the attitude for the moment of the person you talked to. If that person really didn’t know they will always take the safe path and day no.

 

[dougcjohn]

Probably the most critical thing in that flight will be making sure a drone does not experience an issue and fall into the sub station. You can’t go after it and it could bugger everything. Aerial Alchemy performs a lot of sub station work and establishes protocols with the utility to deal with the possibility.

I agree with Big Al on the permission thing. Calling corporate could end up a long process with lots of call transfers before getting an answer, with that answer dependent on the attitude for the moment of the person you talked to. If that person really didn’t know they will always take the safe path and day no.

Yep, I'd agree. The Power company Mgmt probably would be presented as a negative; I previously indicated that I was a little hesitant to contact them until getting additional information... My mid-west area particularly isn't a receptive audience for sUAV... it's a little behind the technology curve and TV media instils a lot assumed opinions.

Looking at my telemetry flight paths for video loop or pattern grid survey... neither flight broach the actual sub-station walls. I am certainly within their circle zone on Airmap's Map; but my physical path is above the park, possibly over their parking lot for the sub-station... but not transversing over their walls containing the sub-station. I'd estimate 25-80 meters south of their structural walls (walls curve).

This sub-station is an old structure, it's been on this site for over 20 years. It's not a newly introduced structure.

To make it politically challenging, the construction is Federal and was a 2-3 yr controversy and postponements. The City was against losing a full city block along the developing river... major lost revenue in Taxes. So the site is already in a contentious state with City politics. Not that it dictates the FAA regulations, but it does effect the Power Company being workable and agreeable.

 

[PatR]

Ya gotta figure that DJI flight restricts everything and unlocks nothing until we prove beyond a shadow of doubt it should not be restricted. Even then they might hang a temporary unlock on it.

A story; After DJI secretly up loaded their initial GEO system I started checking restricted areas around where I lived and operated. I noticed a local lumber mill was listed as a “power plant” with restricted airspace. That lumber mill was located adjacent to one of the U.S. largest drone manufactures, where drones of many brands and types were commonly flown. That particular area is also part of a multi (city, county, state, federal) government recreational area. DJI also listed an area fire house as restricted because of helicopter activity. The fire house did and does not have a helicopter or landing pad.

In closing, I would not ever view DJI’s restricted zones with any level of accuracy or as having justification.

 

[dougcjohn]

Ya gotta figure that DJI flight restricts everything and unlocks nothing until we prove beyond a shadow of doubt it should not be restricted. Even then they might hang a temporary unlock on it.

A story; After DJI secretly up loaded their initial GEO system I started checking restricted areas around where I lived and operated. I noticed a local lumber mill was listed as a “power plant” with restricted airspace. That lumber mill was located adjacent to one of the U.S. largest drone manufactures, where drones of many brands and types were commonly flown. That particular area is also part of a multi (city, county, state, federal) government recreational area. DJI also listed an area fire house as restricted because of helicopter activity. The fire house did and does not have a helicopter or landing pad.

In closing, I would not ever view DJI’s restricted zones with any level of accuracy or as having justification.

Copy that... now how about Airmap?
It showed the area but came back with authorization to fly the section outlined.

I did put a call, lengthy VM to local FAA; normally takes a day or two to get a callback. Not sure he's a local FSDO... I asked him that too. We had some good conversations in past, he appears to manage the LAANC for a wide area and he felt it was lacking to be useful & safe.

Don't mean to beat a dead horse... but wasn't the rational behind the LAANC system to verify the requested zone/section as permittable, notify appropriate channels of scheduled sUAV flight, communicate additional NOTAMS, TFR or special considerations? I did see that work a month or so back when President flew in for an event scheduled for evening or next day. I attempted a 9am flight and it came back denied due to TRF and sited the TFR. That was 6-8 hrs minimal before the scheduled arrival.

My opinion, may be wrong... if the LAANC comes back authorized for the defined area, then nothing in that zone is prohibited, other wise it should present a denial and provide a contact to request special permission.

Granted I should be checking Sectional, NOTAMS, TFR, new NFZ etc... isn't that the justified reason of introducing the LAANC system?

 

[PatR]

The LAANC system, in conjunction with the other federal sources of aeronautical information you mentioned, pretty much cover the officially recognized data sources.

You called it a dead horse, which it is at minimum, but DJI really needs to get out of the pseudo airspace/aircraft ownership and control business. Determining where it’s safe and appropriate to fly is the pilot’s job. The maps fall under several government (ours, not theirs) agencies.

 

[mdurbanek]

The LAANC system, in conjunction with the other federal sources of aeronautical information you mentioned, pretty much cover the officially recognized data sources.

You called it a dead horse, which it is at minimum, but DJI really needs to get out of the pseudo airspace/aircraft ownership and control business. Determining where it’s safe and appropriate to fly is the pilot’s job. The maps fall under several government (ours, not theirs) agencies.

Amen. DJI has cost me on three separate occasions, once in Class G and two instances where I obtained LAANC approval. DJI’s self unlock showed no restrictions the day before each flight. And no TFRs.

Their support staff has eventually been able to get me flying in a few days, with no admission of incompetence. And don’t even get me started on the language problem.

Agreed - they should get the heck out of the NFZ business.

 

[dougcjohn]

Amen. DJI has cost me on three separate occasions, once in Class G and two instances where I obtained LAANC approval. DJI’s self unlock showed no restrictions the day before each flight. And no TFRs.

Their support staff has eventually been able to get me flying in a few days, with no admission of incompetence. And don’t even get me started on the language problem.

Agreed - they should get the heck out of the NFZ business.

Agree on the unnecessary DJI NFZ behavior, although I'm curious what issues you & others encountered with DJI access control? I've heard other's site similar but most related to not having the acct & CC setup and tried using the phone method. Is your situation different, if so, I'd enjoy knowing for experience.

To my nativity, this is only a problem when running the DJI native Go/Pilot/GSP app or 3rd party that ties to the DJI app. When dumping the DJI app from memory and using several 3rd party apps, if wanting the DJI NFZ, there is normally a setup option to use or not use DJI NFZ notifications.

When I've encountered a DJI restricted access (native app), there are 3 levels of DJI restrictions and the first 2 are quickly accessed with acknowledgement, the 3rd takes a bit more. All operate with a DJI Acct pre-setup that includes a credit card. The acct is a "given" since it requires an acct setup for everything DJI. The credit card is optional, but with the CC protections, notifications of non-card use & location, it's not a concern to me... easy to monitor; with access of CC number isn't a concern with all the various sites already holding it's not hard to obtain.

There are alternate methods to gain access, as some resist the CC on file... although I've found that gets right past their restriction gate without headaches.

That's been my experience, is your experience beyound that burden? Again, more curious for experience... I'm not defending or onboard with DJI's NFZ behavior but I'll adapt to get the end result desired.

Going back to the initial post... DJI didn't present a block or NFZ, AirMap showed the section of concern around the Sub-Station but didn't block, KittyHawk showed no concern, FAA Sectional, NFZ, TFR... all zip. Without repeating the mission, I'm not certain which app(s) presented the Jail Notice & Acknowledgement... I beleive DJI and Litchi. I don't use any of the DJI apps for any missions... load it for FW checks, updates and get a base count on satellites and battery FW & status... then dump the DJI app out of memory and run Litchi for videos and Map apps for various image collections.

The only App or Site that agreed with the Power Company's Crew statement in identifying a zone around the Sub-Station was AirMap but didn't restrict and proceeded to submit & authorize the LAANC flights. All other tools showed absolutely zero for the sub-station... and this sub-station is greater than 15-20 yrs established. That's what initiated the question to the Wise & Experience on Forum. I didn't want to abuse a restriction if accurate. The conclusion I've gathered is "there is no concern and I can fly my construction site".

Great conversation from all, much appreciated!

 

[BryanD]

Contact your FSDO and find out from them what restrictions are in place for that exact location. If it's deemed "Sensitive Infrastructure" then you'll need to get authorization from the Agency Having Jurisdiction over the facility.

Odds are if you ask the facility first they are going to tell you right off the bat (and possibly incorrectly) they do NOT approve your flight. You'll need to get it from your FSDO if that area is indeed "Sensitive Infrastructure" or not.

I agree with BigAl. From a Power Company perspective there is a lot of critical infrastructure (substations) out there in addition to generating stations that they would not like you flying over. But truth be known the Power Companies (in regards to substations) may not have much of a leg to stand on from an FAA perspective. So yes, if you call the power company and ask for permission to fly over one of their substations they are probably going to tell you NO. Are they legally allowed to do that? Probably not. But at the same time, I would suggest not dropping your drone into one of their substations and cause an outage. Bottom line is do your homework, work within your legal and safety limits and mitigate risks. Although if you don't work for a Power Utility like myself you may not be aware where substations are let alone whether they are deemed as critical infrastructure. That is a whole other can of worms we could open that someone will eventually need to address. ;-)

 

[dougcjohn]

I agree with BigAl. From a Power Company perspective there is a lot of critical infrastructure (substations) out there in addition to generating stations that they would not like you flying over. But truth be known the Power Companies (in regards to substations) may not have much of a leg to stand on from an FAA perspective. So yes, if you call the power company and ask for permission to fly over one of their substations they are probably going to tell you NO. Are they legally allowed to do that? Probably not. But at the same time, I would suggest not dropping your drone into one of their substations and cause an outage. Bottom line is do your homework, work within your legal and safety limits and mitigate risks. Although if you don't work for a Power Utility like myself you may not be aware where substations are let alone whether they are deemed as critical infrastructure. That is a whole other can of worms we could open that someone will eventually need to address. ;-)

Appreciate the info & insight... from all, good to hear on a matter that isn’t technically, or more pointly, isn’t legally required to oblige.

I’d also agree, flying within a sub-stations walls wouldn’t be a preferred objective... for multiple reasons, some outside even the scope of this discusion.

To clarify, as described, I didn‘t fly my craft over the sub-station. I flew over the park / decorative green space on the same elongated block between my construction site and the sub-station. Although their circle “zone” that was displayed in AirMap & no other resource encompassed the majority of the block & street section within the circle. That’s where I questioned at first due to lack of agreeable resources.

Via everyone’s comments, it sounds like the consensus is their isn’t any legal FAA barrier (barring state / city), Energy Co most likely won’t give permission, and best not to play in their playground, be cooperative and just fly the construction site.

I did fly a survey grid & video loop today, no visitors so I’m assuming my last candid conversation left them with no major concerns from me.

Appreciate all the great input from all.