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I recently attended a football scrimmage and was concerned about the operation of a drone during the event. The flight was mostly stationary, but over the field, and often times over participants (coaches and players). My observations of the flight led to my opinion that the operator (apparently a coach) most likely did NOT have all the appropriate credentials for the operation. I did a little research on the use of drones in high school football in Texas, and then sent an email to the head coach in an attempt to educate him and his staff. I hope it works. Here is the email, which contains the results of my research on this specific use (as well as an interpretation of "commercial use"). I hope this proves helpful to others. FS ***** Dear Sir, Although I was intrigued by your staff's use of a drone during Friday's scrimmage, I would like express my concern, as I thought you might be unaware of several issues surrounding the flight operation. 1) According to the TASO (Texas Association of Sports Officials) website, the UIL Policy states: In compliance with all applicable FAA regulations (attached) and related law, subject to local discretion, drones may be used for practice purposes only. Drones shall not be used in conjunction with any scrimmage or game. 2) According to a memo generated by the Legal Services department for TASB (Texas Association of School Boards), "Under current law, school district use of drones does not fall neatly into any of the categories or exceptions (for use by public institutions). As such, there is inherently some risk involved when a drone is used for school business or activities. Unauthorized UAS flights may result in FAA enforcement actions, including steep fines." 3) Given that the pilot-in-command of the aircraft appeared to be part of coaching staff, he would be operating the aircraft as part of his professional responsibility, therefore he would be classified as a commercial pilot. Under current FAA regulations, he would need to be a licensed pilot and must also have a section 333 exemption. If he were a licensed pilot, holding the 333 exemption, then he would have been well aware of the restrictions regarding the operation of an sUAS over persons not involved in the actual operation of the flight. It is my opinion that the flight operation was unsafe, and against FAA guidelines, if not specific regulations. I hope that you will reconsider the use of your sUAS (drone) in future, similar situations. As new regulations go into effect at the end of this month, I would recommend, at a minimum, that your pilot or someone on your staff obtain a remote pilot airman certificate. This requires passing an aeronautical exam, taken at an FAA-approved testing center. A website that I have found helpful in understanding drone regulations: http://uavcoach.com/ Thank you for your time. **********
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