Narrative:

After carefully planning a photo flight over and near a smaller housing development area which I am familiar with. I piloted an small aircraft to the location for photographs. I chose first to orbit the outer edges of the development over uncongested, sparsely populated land at 500' AGL to obtain clear, clean pictures as legally close to the objects as possible. I also flew the aircraft at 1000' AGL over the more populated areas, at all times trying to maintain legal safe minimum altitudes as prescribed in far's part 91. At many times during my flight all controls were released so that I could use the camera equipment on board to take clear, precise pictures. I have flown this and many aircraft hundreds of hours with hands off controls activity doing aerial survey and writing and compiling information while flying. I found 2 items of my flight relating to performed safety problems. Piloting an aircraft while spending a lot of time and attention to photography can be a very difficult task while trying to maintain directional control of an aircraft at various phases of flight. Determining whether an area is congested or sparsely populated by far regulations vs personal opinion is not possible. The terms are not defined but very important and should be easily identified. On my particular flight there were numerous occasions of altitude and direction control deviation. I found that piloting an aircraft while doing photography at the same time can be an unsafe task, depending on many circumstances, situations, and site location. As a corrective action proposal: a more accurate definition should be defined as to which areas are congested, sparsely populated as to the FAA and pilots using the rules and terms. I feel that many people would vary on this topic and idea. This would greatly reduce the risk of flying too low and breaking minimum safe altitude rules as per far part 91. A write up should be disclosed evaluating and explaining a study as to which and what activities are unsafe for 1, 2-M crews, etc. More knowledge and advice in these areas would be very helpful. I found this flight to be difficult in preflight planning as to the legal minimum safe altitudes and also during the flight phase trying to maintain and track a particular route and altitude while concentrating on other activities as photography. Callback conversation with reporter revealed the following: in circling the area reporter was photographing, small aircraft flew near 1 or 2 isolated very high priced estates and apparently one of the elite did not want aircraft in area and reported him. FAA inspector who had the incident could not come up with definition of what constitutes congested area and has closed the case west/O any action. Reporter counseled since area is grey area to play it conservative and he said in future he would stay at least 1000' AGL if any doubt.

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Original NASA ASRS Text

Title: GA SMA REPORTED AS FLYING BELOW MINIMUM SAFE ALT OVER CONGESTED AREA.

Narrative: AFTER CAREFULLY PLANNING A PHOTO FLT OVER AND NEAR A SMALLER HOUSING DEVELOPMENT AREA WHICH I AM FAMILIAR WITH. I PILOTED AN SMA TO THE LOCATION FOR PHOTOGRAPHS. I CHOSE FIRST TO ORBIT THE OUTER EDGES OF THE DEVELOPMENT OVER UNCONGESTED, SPARSELY POPULATED LAND AT 500' AGL TO OBTAIN CLEAR, CLEAN PICTURES AS LEGALLY CLOSE TO THE OBJECTS AS POSSIBLE. I ALSO FLEW THE ACFT AT 1000' AGL OVER THE MORE POPULATED AREAS, AT ALL TIMES TRYING TO MAINTAIN LEGAL SAFE MINIMUM ALTS AS PRESCRIBED IN FAR'S PART 91. AT MANY TIMES DURING MY FLT ALL CTLS WERE RELEASED SO THAT I COULD USE THE CAMERA EQUIP ON BOARD TO TAKE CLEAR, PRECISE PICTURES. I HAVE FLOWN THIS AND MANY ACFT HUNDREDS OF HRS WITH HANDS OFF CTLS ACTIVITY DOING AERIAL SURVEY AND WRITING AND COMPILING INFO WHILE FLYING. I FOUND 2 ITEMS OF MY FLT RELATING TO PERFORMED SAFETY PROBS. PILOTING AN ACFT WHILE SPENDING A LOT OF TIME AND ATTN TO PHOTOGRAPHY CAN BE A VERY DIFFICULT TASK WHILE TRYING TO MAINTAIN DIRECTIONAL CTL OF AN ACFT AT VARIOUS PHASES OF FLT. DETERMINING WHETHER AN AREA IS CONGESTED OR SPARSELY POPULATED BY FAR REGS VS PERSONAL OPINION IS NOT POSSIBLE. THE TERMS ARE NOT DEFINED BUT VERY IMPORTANT AND SHOULD BE EASILY IDENTIFIED. ON MY PARTICULAR FLT THERE WERE NUMEROUS OCCASIONS OF ALT AND DIRECTION CTL DEVIATION. I FOUND THAT PILOTING AN ACFT WHILE DOING PHOTOGRAPHY AT THE SAME TIME CAN BE AN UNSAFE TASK, DEPENDING ON MANY CIRCUMSTANCES, SITUATIONS, AND SITE LOCATION. AS A CORRECTIVE ACTION PROPOSAL: A MORE ACCURATE DEFINITION SHOULD BE DEFINED AS TO WHICH AREAS ARE CONGESTED, SPARSELY POPULATED AS TO THE FAA AND PLTS USING THE RULES AND TERMS. I FEEL THAT MANY PEOPLE WOULD VARY ON THIS TOPIC AND IDEA. THIS WOULD GREATLY REDUCE THE RISK OF FLYING TOO LOW AND BREAKING MINIMUM SAFE ALT RULES AS PER FAR PART 91. A WRITE UP SHOULD BE DISCLOSED EVALUATING AND EXPLAINING A STUDY AS TO WHICH AND WHAT ACTIVITIES ARE UNSAFE FOR 1, 2-M CREWS, ETC. MORE KNOWLEDGE AND ADVICE IN THESE AREAS WOULD BE VERY HELPFUL. I FOUND THIS FLT TO BE DIFFICULT IN PREFLT PLANNING AS TO THE LEGAL MINIMUM SAFE ALTS AND ALSO DURING THE FLT PHASE TRYING TO MAINTAIN AND TRACK A PARTICULAR ROUTE AND ALT WHILE CONCENTRATING ON OTHER ACTIVITIES AS PHOTOGRAPHY. CALLBACK CONVERSATION WITH RPTR REVEALED THE FOLLOWING: IN CIRCLING THE AREA RPTR WAS PHOTOGRAPHING, SMA FLEW NEAR 1 OR 2 ISOLATED VERY HIGH PRICED ESTATES AND APPARENTLY ONE OF THE ELITE DID NOT WANT ACFT IN AREA AND RPTED HIM. FAA INSPECTOR WHO HAD THE INCIDENT COULD NOT COME UP WITH DEFINITION OF WHAT CONSTITUTES CONGESTED AREA AND HAS CLOSED THE CASE W/O ANY ACTION. RPTR COUNSELED SINCE AREA IS GREY AREA TO PLAY IT CONSERVATIVE AND HE SAID IN FUTURE HE WOULD STAY AT LEAST 1000' AGL IF ANY DOUBT.

Data retrieved from NASA's ASRS site as of August 2007 and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.