Beyond Visual Line of Sight Rating (BVLOS)

[Chaosrider2]

I've been talking about this in other places, but it really belongs here in the "Rules and Regs" section.

The idea is to develop a distinct, non-waiver-based rating that would allow properly trained and rated pilots to fly properly equipped aircraft BVLOS, in appropriate locations.

This should be available to anyone, but be much easier to get for Part 61 instrument rated pilots.

It should be limited to uncontrolled airspace, at least during a trial period.

The pilot, aircraft and location reuirements should be based on quantitative estimates of major damage. The fact that some Bad Thing COULD happen is not by itself sufficient to prohibit it. The appropriate question is...what are the odds?

If the odds of something Really Bad happening for some given combination of pilot, aircraft, and location, are of the same order as things that we routinely acccept every day, like getting into a car accident, then that BVLOS operation should be permitted.

Comments, thoughts, and suggestions greatly appreciated!



Thx,

TCS

 

[Ty Pilot]

You should present your 'idea' to the FAA and see if they 'give it a go' then get back to us.

In all seriousness, the path to get the waver is in place and while it may change slightly as tech develops in the future - it is based on solid, well understood data and fundamentals. After all, the FAA has been in the air safety business for a while now.

Personally I 'm okay with the fact that not everybody can just say - 'I got this' - and be allowed to throw caution to the wind in such operations.

If one looks into what it takes to get a BVLOS waiver you'll quickly see that it is not simply about the pilot, so regardless of what experience we may have in General or UAV aviation, it will not have little bearing on obtaining such a waiver. In a nutshell; it is a lot more about the tech you intend to use for those operations and proving you can do so safely.

As of this time last year there was a grand total of fifty-six (56) BVLOS waivers issued by the FAA, and to get some idea as to how rare that is, prior to the new rules on Commercial Night Operations, obtaining a 107.29 (night) waiver was the most issued of all for UA's and there was 4,357 of those as of this time last year. In fact 99% of all applications for BVLOS have been rejected by the FAA.

 

[Rich QR]

In the other thread, I brought up that a BVLOS pilot has no way to see and avoid traffic that's coming from a direction outside the camera's field of view. IFR flying takes care of this by having ATC provide traffic separation. You'd have to have some way to mitigate this risk. I can imagine a few possibilities:

• Fly BVLOS only in controlled airspace, limited to blocks of space that ATC is aware of (assigned via LAANC or something similar), and let ATC take the responsibility of keeping human-carrying aircraft away from the drones.
• Fly BVLOS only where human-carrying airplanes can't reasonably fly. Below tree canopy, below rooflines of nearby buildings, below fencelines, etc. Details to be worked out.
• Restrict BVLOS flying to drones that are so small and lightweight they'll do less damage in a collision than a sparrow (maybe a crow, maybe a duck, depending on what level of risk is judged acceptable).
• Require all human carrying aircraft (and parachutes, etc.) to transmit ADS-B, and require all drones to monitor it. Or come up with an ADS-B alternative with enough bandwidth so that all drones could transmit their location in a way that airplanes could be alerted. I'm aware that this is a technical bag of worms that isn't likely to be solved any time soon.

Whatever is done, I don't think it's okay to accept the (admittedly small) risk that a medevac or police helicopter crashes into a drone, and the drone pilot just says, "Well, that's a shame! I was flying BVLOS, following the rules exactly as they were written, and so I had no way of avoiding the collision".

 

[Chaosrider2]

You should present your 'idea' to the FAA and see if they 'give it a go' then get back to us.

In all seriousness, the path to get the waver is in place and while it may change slightly as tech develops in the future - it is based on solid, well understood data and fundamentals. After all, the FAA has been in the air safety business for a while now.

Personally I 'm okay with the fact that not everybody can just say - 'I got this' - and be allowed to throw caution to the wind in such operations.

If one looks into what it takes to get a BVLOS waiver you'll quickly see that it is not simply about the pilot, so regardless of what experience we may have in General or UAV aviation, it will not have little bearing on obtaining such a waiver. In a nutshell; it is a lot more about the tech you intend to use for those operations and proving you can do so safely.

As of this time last year there was a grand total of fifty-six (56) BVLOS waivers issued by the FAA, and to get some idea as to how rare that is, prior to the new rules on Commercial Night Operations, obtaining a 107.29 (night) waiver was the most issued of all for UA's and there was 4,357 of those as of this time last year. In fact 99% of all applications for BVLOS have been rejected by the FAA.

I'm OK with not letting just anyone do it too!

I suspect that the FAA is excessively denying the waiver requests, because they want to spin this up slowly. Not an unreasonable position --as a starting point. Alternatively, perhaps all of the waiver requests really have been unworthy, but that strikes me as unlikely.

I strongly suspect that waivers are being denied because something Bad might happen, rather than because something Bad is likely to happen. We need to evolve away from that, and pay more attention to quantitative risk analysis.

Maybe when I get this proposal fleshed out a bit more, I will formally suggest it to the FAA. But I'm not quite there yet.

Thx!

TCS

 

[Chaosrider2]

In the other thread, I brought up that a BVLOS pilot has no way to see and avoid traffic that's coming from a direction outside the camera's field of view. IFR flying takes care of this by having ATC provide traffic separation. You'd have to have some way to mitigate this risk. I can imagine a few possibilities:

• Fly BVLOS only in controlled airspace, limited to blocks of space that ATC is aware of (assigned via LAANC or something similar), and let ATC take the responsibility of keeping human-carrying aircraft away from the drones.
• Fly BVLOS only where human-carrying airplanes can't reasonably fly. Below tree canopy, below rooflines of nearby buildings, below fencelines, etc. Details to be worked out.
• Restrict BVLOS flying to drones that are so small and lightweight they'll do less damage in a collision than a sparrow (maybe a crow, maybe a duck, depending on what level of risk is judged acceptable).
• Require all human carrying aircraft (and parachutes, etc.) to transmit ADS-B, and require all drones to monitor it. Or come up with an ADS-B alternative with enough bandwidth so that all drones could transmit their location in a way that airplanes could be alerted. I'm aware that this is a technical bag of worms that isn't likely to be solved any time soon.

Whatever is done, I don't think it's okay to accept the (admittedly small) risk that a medevac or police helicopter crashes into a drone, and the drone pilot just says, "Well, that's a shame! I was flying BVLOS, following the rules exactly as they were written, and so I had no way of avoiding the collision".

Thanks for the re-post here!

The key underlying principle of VFR flight is:

Big sky, small airplane.

As just a crude example, imagine a 500 cubic mile volume of airspace. If you have 2 C-172s in that airspace, the probability of collision is X. If you have one C-172 and one DJI Mini-2 in that same airspace, the probability of collision is likely around 0.001 X.

You DON'T have to worry about afirmative collision avoidance measures if the odds of a collision are vanishingly small.

Certainty is not an option. When it comes to evaluting and mitigating risks, an essential principle is:

Probabilites RULE, and possibilities DROOL.

What are the odds? Possibility alone doesn't matter.

1) IMNSHO, restricting BLVOS to contolled airspace is exactly backwards. Our fundamental disagreement, I suspect, is that outside of busy areas I think the risk of a drone colliding with a manned aircraft is so trivial that it can almost be ignored, and you don't. I also strongly suspect that neither of us have solid data to support our positions!

;-)

There's also an underlying philosophical question. In my view, restrictions on personal freedom require proof of a high probability of harm. Certainty is not possible, and its pursuit is generally a fool's errand.

2) One should be required to quantitatively demonstrate a high probability of harm before being allowed to impose such a restriction.

3) BVLOS authorization should indeed be aircraft type dependent, among other things. Restricting BVLOS to bug-sized drones is at least a bad idea, and perhaps exactly backwards.

4) I think this level of affirmative control is completely unjustified based on the actual statistical risk involved.

I suspect this post will not be the end of this thread!




TCS

 

[Rich QR]

I strongly suspect that waivers are being denied because something Bad might happen, rather than because something Bad is likely to happen. We need to evolve away from that, and pay more attention to quantitative risk analysis.

Who are you to judge what level of risk is acceptable for the pilots and passengers of other aircraft?

The BVLOS pilot gets all the benefit of this proposed rule change, and has nothing at risk except a drone costing around a thousand dollars, more or less. And for the benefit of not having to stay within sight, you think a BVLOS pilot should be able to risk a multi-million dollar aircraft with multiple human lives on board? You'd better have something more convincing than, "Sure, problems might happen, but I don't think they're very likely to happen".

I'm all for allowing individuals the freedom to judge what level of personal risk they'll accept in exchange for a personal benefit. But I'd be much more wary about allowing an individual to decide to put others at risk while he stays safely on the ground, getting all the benefits. It's true that as long as we allow airplanes to overfly houses, we do allow aviators to put the public at some risk. But as long as the pilot is on board, he is very motivated to avoid crashing into those houses (or those other planes). When the pilot's on the ground, he may make decisions that the people in the air would disagree with. If the decision turns out to have negative consequenes, the person who decided to take the risk isn't the one who pays the price.

 

[brett8883]

Who are you to judge what level of risk is acceptable for the pilots and passengers of other aircraft?

The BVLOS pilot gets all the benefit of this proposed rule change, and has nothing at risk except a drone costing around a thousand dollars, more or less. And for the benefit of not having to stay within sight, you think a BVLOS pilot should be able to risk a multi-million dollar aircraft with multiple human lives on board? You'd better have something more convincing than, "Sure, problems might happen, but I don't think they're very likely to happen".

I'm all for allowing individuals the freedom to judge what level of personal risk they'll accept in exchange for a personal benefit. But I'd be much more wary about allowing an individual to decide to put others at risk while he stays safely on the ground, getting all the benefits. It's true that as long as we allow airplanes to overfly houses, we do allow aviators to put the public at some risk. But as long as the pilot is on board, he is very motivated to avoid crashing into those houses (or those other planes). When the pilot's on the ground, he may make decisions that the people in the air would disagree with. If the decision turns out to have negative consequenes, the person who decided to take the risk isn't the one who pays the price.

I think this is overblown and not based on fact. For all the pandemonium about drones there’s only been 1 reported case of a drone actually colliding with a powered manned aircraft ever (there was another with a hot air balloon but no damage) and there was only minor damage to that manner aircraft despite there being over 800,000 registered sUAS in the US compared to about 217,000 registered manned aircraft (includes anything that carries a person in the air)

There are hundreds of manned aviation deaths and thousands of serious injuries per year despite being greatly outnumbered by drones. The statistics and facts just don’t back up what you are saying. There’s absolutely no data to suggest sUAS pilots value lives less than manned aircraft pilots. That’s completely made up.

 

[Rich QR]

There’s absolutely no data to suggest sUAS pilots value lives less than manned aircraft pilots. That’s completely made up.

I never said that, and I apologize if I gave the impression that that's what I meant. I know that virtually all sUAS pilots treasure human life greatly, because virtually all human beings treasure human life greatly.

But I do know that different people have different tolerances for risk. Last night, I saw two drivers pursuing each other, weaving in and out on a crowded freeway at around a hundred MPH, where other traffic was flowing around 70-75 (speed limit was 65). I believe every driver, including the two fast ones, treasured human life tremendously. But those two had a different calculation about the acceptable level of risk vs reward. People are funny that way, especially when the likelyhood of loss is small. And since those two didn't make the news, I believe they made it home safely, and they probably feel vindicated that their calculation of risk was justified.

I have no problem with them putting themselves at risk, but I don't believe they had the moral right to put the other traffic at risk, even though the likelyhood of danger was small and everyone went home safe.

Likewise, I don't believe a sUAS pilot has the moral right to fly in uncontrolled airspace under VFR, where they are expected and legally obligated to "see and avoid", unless they acually take reasonable measures to see and avoid. Furthermore, I don't believe the law should be changed to relieve sUAS pilots of the "see and avoid" obligation that every other participant in the NAS has when flying under VFR. At least not without some restrictions that provide reasonable mitigation of the collision risk.

 

[Drone752H]

I've been talking about this in other places, but it really belongs here in the "Rules and Regs" section.

The idea is to develop a distinct, non-waiver-based rating that would allow properly trained and rated pilots to fly properly equipped aircraft BVLOS, in appropriate locations.

This should be available to anyone, but be much easier to get for Part 61 instrument rated pilots.

It should be limited to uncontrolled airspace, at least during a trial period.

The pilot, aircraft and location reuirements should be based on quantitative estimates of major damage. The fact that some Bad Thing COULD happen is not by itself sufficient to prohibit it. The appropriate question is...what are the odds?

If the odds of something Really Bad happening for some given combination of pilot, aircraft, and location, are of the same order as things that we routinely acccept every day, like getting into a car accident, then that BVLOS operation should be permitted.

Comments, thoughts, and suggestions greatly appreciated!



Thx,

TCS

I've been talking about this in other places, but it really belongs here in the "Rules and Regs" section.

The idea is to develop a distinct, non-waiver-based rating that would allow properly trained and rated pilots to fly properly equipped aircraft BVLOS, in appropriate locations.

This should be available to anyone, but be much easier to get for Part 61 instrument rated pilots.

It should be limited to uncontrolled airspace, at least during a trial period.

The pilot, aircraft and location reuirements should be based on quantitative estimates of major damage. The fact that some Bad Thing COULD happen is not by itself sufficient to prohibit it. The appropriate question is...what are the odds?

If the odds of something Really Bad happening for some given combination of pilot, aircraft, and location, are of the same order as things that we routinely acccept every day, like getting into a car accident, then that BVLOS operation should be permitted.

Comments, thoughts, and suggestions greatly appreciated!



Thx,

TCS

I could really go for something on the order of “below 300’ AGL, and maybe 1000 yards for Commercial Pilots and above in uncontrolled airspace (Class G)”. There’s an awful lot that would need to be hashed out but the restriction of VLOS is so arbitrarily restrictive. I want to take pictures of my house, all sides and the roof. Requiring me to clamber over and around fences, trees, shrubbery, vehicles and such is a little unrealistic. Just my thoughts.

If you’re a certificated commercial pilot you have a lot to lose if found guilty of an FAR violation. A $5,000 fine isn’t really a big deal but loss of license is major when that’s your livelihood.

 

[sar104]

In the other thread, I brought up that a BVLOS pilot has no way to see and avoid traffic that's coming from a direction outside the camera's field of view. IFR flying takes care of this by having ATC provide traffic separation. You'd have to have some way to mitigate this risk. I can imagine a few possibilities:

• Fly BVLOS only in controlled airspace, limited to blocks of space that ATC is aware of (assigned via LAANC or something similar), and let ATC take the responsibility of keeping human-carrying aircraft away from the drones.
• Fly BVLOS only where human-carrying airplanes can't reasonably fly. Below tree canopy, below rooflines of nearby buildings, below fencelines, etc. Details to be worked out.
• Restrict BVLOS flying to drones that are so small and lightweight they'll do less damage in a collision than a sparrow (maybe a crow, maybe a duck, depending on what level of risk is judged acceptable).
• Require all human carrying aircraft (and parachutes, etc.) to transmit ADS-B, and require all drones to monitor it. Or come up with an ADS-B alternative with enough bandwidth so that all drones could transmit their location in a way that airplanes could be alerted. I'm aware that this is a technical bag of worms that isn't likely to be solved any time soon.

Whatever is done, I don't think it's okay to accept the (admittedly small) risk that a medevac or police helicopter crashes into a drone, and the drone pilot just says, "Well, that's a shame! I was flying BVLOS, following the rules exactly as they were written, and so I had no way of avoiding the collision".

We regularly fly BVLOS, and the method used to provide separation is a TFR that keeps all other traffic out of the airspace, which seems like a fairly robust process. However, that is not going to be available to most pilots.

The most obvious alternatives are to use the planned remote ID system or to wait for all manned aircraft to use ADS-B. The latter is not going to happen any time very soon, and so this will likely depend on how well remote ID works.

 

[brett8883]

I never said that, and I apologize if I gave the impression that that's what I meant. I know that virtually all sUAS pilots treasure human life greatly, because virtually all human beings treasure human life greatly.

But I do know that different people have different tolerances for risk. Last night, I saw two drivers pursuing each other, weaving in and out on a crowded freeway at around a hundred MPH, where other traffic was flowing around 70-75 (speed limit was 65). I believe every driver, including the two fast ones, treasured human life tremendously. But those two had a different calculation about the acceptable level of risk vs reward. People are funny that way, especially when the likelyhood of loss is small. And since those two didn't make the news, I believe they made it home safely, and they probably feel vindicated that their calculation of risk was justified.

I have no problem with them putting themselves at risk, but I don't believe they had the moral right to put the other traffic at risk, even though the likelyhood of danger was small and everyone went home safe.

I would say the likelihood of danger in that situation was very high. People die all the time in car crashes where everyone was following the law and driving cautiously. There’s ample evidence showing how speeding increases the risk of an accident. BTW I couldn’t have made up a better story to show the fallacy that someone being physically in the vehicle means they are less likely to do risky things.

Likewise, I don't believe a sUAS pilot has the moral right to fly in uncontrolled airspace under VFR, where they are expected and legally obligated to "see and avoid", unless they acually take reasonable measures to see and avoid. Furthermore, I don't believe the law should be changed to relieve sUAS pilots of the "see and avoid" obligation that every other participant in the NAS has when flying under VFR.

There are on average 1.5 mid air collisions between between manned aircraft per year almost all are fatal. This is again despite vastly fewer manned aircraft than drones. Would you say that flying a manned aircraft is also morally wrong as well? Statistically it’s far more hazardous to others to fly a manned aircraft than a drone.

I don’t think anyone is saying we shouldn’t take reasonable measures and I don’t think anyone is saying there shouldn’t be a see and avoid obligation but the live feed from the camera should be included as an acceptable means of compliance with that rule. I think a drone has as much or more ability to view the surrounding airspace as the pilot of a fixed wing aircraft. There are limitations to that of course, judging distance is one, but with technology like remote ID and ADS-B in should mitigate this to a point that the probability of a collision is so low that there’s no justifiable reason to prohibit regular BVLOS operations with qualifying sUAS.

 

[Rich QR]

l don’t think anyone is saying there shouldn’t be a see and avoid obligation but the live feed from the camera should be included as an acceptable means of compliance with that rule. I think a drone has as much or more ability to view the surrounding airspace as the pilot of a fixed wing aircraft.

If you're not worried about resolution issues, drones can see to the front and below pretty well, but most don't see behind, above, or side-to-side nearly so well. If they're filming, many pilots may be reluctant to break up a shot to periodically spin the camera around and check for traffic.

Many GA aircraft don't see behind so well, either. But most have very good ability to see side-to-side with a quick turn of the head, and even the high-wing planes I used to fly have better ability to see above than a typical drone.

But there's another issue: collision problems for a GA aircraft mostly come from in front, where the pilot's windshield is pointed. If one plane is approaching another from the rear, then at least the rearward plane has an opportunity to see and avoid the plane in front. On the other hand, drones usually go slower than other air traffic. A drone is too small for most fixed-wing pilots to be able to see and avoid, so they can't rely on the other aircraft to do collision avoidance. That means the drone has to avoid traffic coming from all 360 degrees around. That's an easy task to do if a remote pilot is watching the drone and the airspace around it, but I don't know how you do it when BVLOS.

 

[Malcx]

For all the pandemonium about drones there’s only been 1 reported case of a drone actually colliding with a powered manned aircraft ever

2 seconds of google:

INCIDENT: Drone – Helicopter Collision, Occupant Injury - Mentour Pilot

A helicopter of the Chilean Navy had a collision with a drone, which broke through the windscreen and injured the on-board mechanic.

mentourpilot.com

Feds charge Hollywood man after drone collides with LAPD helicopter

A Hollywood man is arrested by the FBI after a drone crashed into a LAPD helicopter earlier this year, forcing its pilot to make an emergency landing.

www.latimes.com

I'd bet I could find more.

 

[Vic Moss]

I've been talking about this in other places, but it really belongs here in the "Rules and Regs" section.

The idea is to develop a distinct, non-waiver-based rating that would allow properly trained and rated pilots to fly properly equipped aircraft BVLOS, in appropriate locations.

The FAA is on this. And luckily one of our owners at DSPA (Kenji Sugaha) is on the ARC for this. Their first meeting was yesterday, and the next one is scheduled for all day today.

Advisory and Rulemaking Committees – UAS BVLOS ARC Charter

www.faa.gov

 

[brett8883]

2 seconds of google:

INCIDENT: Drone – Helicopter Collision, Occupant Injury - Mentour Pilot

A helicopter of the Chilean Navy had a collision with a drone, which broke through the windscreen and injured the on-board mechanic.

mentourpilot.com

Feds charge Hollywood man after drone collides with LAPD helicopter

A Hollywood man is arrested by the FBI after a drone crashed into a LAPD helicopter earlier this year, forcing its pilot to make an emergency landing.

www.latimes.com

I'd bet I could find more.

We’re talking about the United States...

 

[cgmaxed]

Who are you to judge what level of risk is acceptable for the pilots and passengers of other aircraft?

The BVLOS pilot gets all the benefit of this proposed rule change, and has nothing at risk except a drone costing around a thousand dollars, more or less. And for the benefit of not having to stay within sight, you think a BVLOS pilot should be able to risk a multi-million dollar aircraft with multiple human lives on board? You'd better have something more convincing than, "Sure, problems might happen, but I don't think they're very likely to happen".

I'm all for allowing individuals the freedom to judge what level of personal risk they'll accept in exchange for a personal benefit. But I'd be much more wary about allowing an individual to decide to put others at risk while he stays safely on the ground, getting all the benefits. It's true that as long as we allow airplanes to overfly houses, we do allow aviators to put the public at some risk. But as long as the pilot is on board, he is very motivated to avoid crashing into those houses (or those other planes). When the pilot's on the ground, he may make decisions that the people in the air would disagree with. If the decision turns out to have negative consequenes, the person who decided to take the risk isn't the one who pays the price.

Feel free to criticize this post, but be mature about it. The reality is, hobbyists ARE flying BVLOS more often than you may think. I suggest more than 50 % of all hobbyists fly BVLOS daily. It simply can't be regulated. Also, the height restriction of 400ft is probably violated frequently. The higher the drone is the less visible it becomes to anyone on the ground, and thus can't be reported by anyone or seen by police on the ground. Combining the two, flying at over 500 ft and BVLOS, nobody will know that you're doing it, except yourself. Until the Drone ID systems come rolling out, it's a free for all. There may have been only about 50 BVLOS waivers given in a year, but 10s of thousands of BVLOS flights are made every day in the united states. Not one accident specific to BVLOS flight has occurred, at least to my knowledge. The reason? It's the odds. Birds, which number in the billions, rarely crash into planes. The FAA acts like crashes between a drone and manned aircraft will be more common than bird collisions. Or, they think, if there was a collision, it would cause enough damage to crash a manned aircraft. It's not just about a crash, it's about how much damage to a manned aircraft will occur. The odds of bringing down a plane or heli with a drone is almost impossible. Except for the fact they do have to make emergency landings following a collision, which is a very expensive procedure and their flight plan or emergency mission gets interrupted. If it were so simple to crash manned aircraft with drones, terrorists would be using drones to crash them all the time, to cause mass killings. Fly a drone and crash it into an airplane taking off from an airport, that simple? No. The plane would probably just tear the drone to shreds and keep going as if nothing happened. But, may also have to turn around for an emergency landing to get the damage assessed. This costs a lot of money. The fact is, even purposely doing it, won't bring a manned aircraft crashing down. Yes there should be restrictions regarding BVLOS, but as they are, I think they are probably over cautious. I understand, that for the drone pilot, the risk is only a couple grand US dollars and possibly prison if the drone actually caused a crash or emergency landing. A manned aircraft, just being hit, will cost 10-100 thousand dollars in repairs or inspection and or lost revenue. The loss of life is almost impossible unless it's one of those super heavy monster drones. I think the rules are in place more for financial reasons. I suggest the fears of lossed revenue is what drives the BVLOS restriction. Maybe, also the fact that emergency response flights are easily disrupted just by the presence of a nearby drone. Billions of birds vs millions of drones? Even though billions of birds are in the air at any one time they rarely affect air traffic and most are flying above 500ft. Maybe, there only only a 1-3 hundred thousand drones up at any one time. Most are flying under 400 ft. Where can I find a list of reported bird with aircraft collisions and the resultant damage that occured? Anyone know? If anything it's the bigger drones we need to worry about. TAKE NO OFFENSE to my thoughts. They are just thoughts. Feel free to criticize my post. But please be mature about it.

 

[brett8883]

If you're not worried about resolution issues, drones can see to the front and below pretty well, but most don't see behind, above, or side-to-side nearly so well. If they're filming, many pilots may be reluctant to break up a shot to periodically spin the camera around and check for traffic.

Many GA aircraft don't see behind so well, either. But most have very good ability to see side-to-side with a quick turn of the head, and even the high-wing planes I used to fly have better ability to see above than a typical drone.

But there's another issue: collision problems for a GA aircraft mostly come from in front, where the pilot's windshield is pointed. If one plane is approaching another from the rear, then at least the rearward plane has an opportunity to see and avoid the plane in front. On the other hand, drones usually go slower than other air traffic. A drone is too small for most fixed-wing pilots to be able to see and avoid, so they can't rely on the other aircraft to do collision avoidance. That means the drone has to avoid traffic coming from all 360 degrees around. That's an easy task to do if a remote pilot is watching the drone and the airspace around it, but I don't know how you do it when BVLOS.

The drone can turn to look in other directions just as easily as a pilot can turn his head. In that way the drone can look in any direction. As I said it’s not perfect but the drone is so small the likelihood of a collision is that much smaller and the outcome of a collision has far less potential to be catastrophic.

As I mentioned collisions with other manned aircraft already pose a far greater risk to manned aviation. It’s not perfect and nothing will ever be perfect but other technology will be used to mitigate the risk such as remote ID and ADS-B out for manned aircraft.

The risk of any activity will never be zero. In 2019 (most recent year with statistics) 49 Americans died from boating collisions with other vessels. 90 Americans die every year mowing their lawns.

 

[cgmaxed]

We’re talking about the United States...

The author of the article states, "Such incidents happen with worrying regularity." When he could only cite 4 incidents total over the past few years. "Increasing regularity", my a**. By the way an ENGINE COWLING is the outer shell of an engine, basically used for airdynamics and gives some protection to the internal parts of an engine. It's not a mechanical part of the engine.

 

[Ripdog]

I've been talking about this in other places, but it really belongs here in the "Rules and Regs" section.

The idea is to develop a distinct, non-waiver-based rating that would allow properly trained and rated pilots to fly properly equipped aircraft BVLOS, in appropriate locations.

This should be available to anyone, but be much easier to get for Part 61 instrument rated pilots.

It should be limited to uncontrolled airspace, at least during a trial period.

The pilot, aircraft and location reuirements should be based on quantitative estimates of major damage. The fact that some Bad Thing COULD happen is not by itself sufficient to prohibit it. The appropriate question is...what are the odds?

If the odds of something Really Bad happening for some given combination of pilot, aircraft, and location, are of the same order as things that we routinely acccept every day, like getting into a car accident, then that BVLOS operation should be permitted.

Comments, thoughts, and suggestions greatly appreciated!



Thx,

TCS

I agree. Especially with sensors on your aircraft that alert you to other aircraft in the vicinity. This premise that something “could” happen being the reason to not do something seems to control a lot of things and most people. Besides you have a camera and if paying attention you should be able to survey the ground covered as well as your surroundings. I like it. I do see it as “instruments only.”

 

[Vic Moss]

Who are you to judge what level of risk is acceptable for the pilots and passengers of other aircraft?

The BVLOS pilot gets all the benefit of this proposed rule change, and has nothing at risk except a drone costing around a thousand dollars, more or less. And for the benefit of not having to stay within sight, you think a BVLOS pilot should be able to risk a multi-million dollar aircraft with multiple human lives on board? You'd better have something more convincing than, "Sure, problems might happen, but I don't think they're very likely to happen".

I'm all for allowing individuals the freedom to judge what level of personal risk they'll accept in exchange for a personal benefit. But I'd be much more wary about allowing an individual to decide to put others at risk while he stays safely on the ground, getting all the benefits. It's true that as long as we allow airplanes to overfly houses, we do allow aviators to put the public at some risk. But as long as the pilot is on board, he is very motivated to avoid crashing into those houses (or those other planes). When the pilot's on the ground, he may make decisions that the people in the air would disagree with. If the decision turns out to have negative consequenes, the person who decided to take the risk isn't the one who pays the price.

Aviation is based 100% on risk mitigation. There is no such thing as a 100% risk free flight.

BVLOS is one of those areas where the perception of risk is greatly overreaching in the propagation of regulation. Both 44809 and 107 require the operator to maintain the ability to see the aircraft at all time. It's a regulation that is overly biased towards safety.

My example: I routinely fly my Mavics beyond my ability to see them. And it's 100% safe. No question, or I wouldn't do it. And I do that in both controlled and uncontrolled airspace. However, in each and every instance, I have full command of the visibility of the airspace. I can see where my drone is (even if I can't see the drone), and maintain full situational awareness at all time.

BVLOS flights within reason can be 100% safe, even if they violate the letter of both 107 and/or 44809 regulations.

The issue is that some, either willingly or ignorantly, fly way beyond their ability to maintain situational awareness. That's where the issues come into play.

And you ask who are we to decide the risk? We're aviators. We use the same logic and risk mitigation process that manned aviators do. While the sheer number of risky unmanned flights severely outweigh the number of risky manned flights, the likely bad outcome is virtually nil. Numbers don't lie. And the vast majority of us (107 Pilots and 44809 flyers) have a full awareness of what the consequences of a mistake would be. Especially if that mistake involved manned aviation. To paint all 107/44809 folks by the actions of a few ignorant drone owners weakens your argument. Reason and facts are what make a viable discussion, not blanket statements.

Midair collisions between manned aviation aircraft are much more prevalent than midair collisions between manned and unmanned. It doesn't justify many reckless UAS operations (& operators), but it doesn't need to be overblown by the industry or the FAA either.

The FAA even knows that the BVLOS risk assessment in regulations needs to be taken into account for future BVLOS rules. That is why they created the BVLOS ARC this month. And I'm quite pleased that we (Drone Service Providers Alliance) are part of that rulemaking committee. Not only is our CEO on that ARC, but two of our board members are. Small scale UAS Pilots will now finally a very large say-so about changing the current overly restrictive VLOS rules. As it should have been all along. We will even be having a membership call for feedback from our members on the BVLOS white paper given to us at Wednesday's DAC meeting.

I look forward to our ability to have more open sky to legally (& safely) use.