Beyond Visual Line of Sight Rating (BVLOS)

[cgmaxed]

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.

You make a very good point. I think, maybe drone regulation isn't just about safety. There seems to be something else going on. In the days when we only had RC plane pilots, the regs were minimal. The surge in regulations seems to coincide with the release of camera equipped RC drones. The cameras allow the operator to fly anywhere they can see. And the fact that they can see, really bothers the general public and authorities. Especially authorities. They didn't like it when they saw news helicopters flying above, and they certainly don't like the idea of some Joe citizen filming them from above. You see how they treat someone filming them with a cell phone. They go absolutely insane sometimes. They might go even more insane if someone were to fly a drone in a safe place, but close enough for them to be filmed. Why?, there wouldn't be a person behind the camera they could try to intimidate or arrest by saying, "your interfering with a police investigation, you will be arrested if you do not cease and desist your filming."

 

[cgmaxed]

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.”

I was just talking about an "instruments only" class of drones that could be flown in another thread. Maybe someday, tech could help drones be aware of ALL aircraft nearby, even ones not transmitting ADS-B. Police often don't transmit ADS-B. I know this, because when flying my Air2S and a police helicopter comes zooming over my house, I get no alerts whatsoever.

 

[scro]

Interesting discussion!

I suspect that eventually there'll be a widespread accepted mechanism for routinely flying BVLOS. As @cgmaxed has said, there are many sUAS pilots flying BVLOS already (doesn't necessarily make it right or safe) and we are not seeing any alarming trend in sUAS/manned aircraft collisions. sUAS are relatively small target to hit, and generally tend to inhabit airspace that doesn't see usage by manned aircraft. I personally avoid flying my drone in airspace that I think has even a remote chance of being used by manned aircraft, mostly by maintaining a relatively low altitude (typically 20-50m). It is true that manned aircraft could legally fly in the same bit of airspace as me at the same time, and therefore increase the chance of hitting a still small target but then the pilot would be significantly increasing their chance of colliding with a whole lot of terrestrial objects too.

Just a thought about the presumably significantly higher numbers of drones compared to manned aircraft in the US. Do sUAS spend as high a percentage of time in the air as manned aircraft? I appreciate I'm probably at the lower end of the usage spectrum, but my drone has only seen 21hrs of use in the ~14000hrs I've owned it for - less than 0.2% of its time airborne. That's like a commercial airliner doing one 1.5hr flight a month. However, I'll not be the only low-usage drone owner bringing the average down.

 

[cgmaxed]

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.

Agree with all above. Especially the idea that ---BVLOS DOES NOT NECESSARILY IMPLY LOSS OF SITUATIONAL AWARENESS---. For example. let say I fly off a 10 story balcony. I have no obstructions. I can see the sky in every direction around my drones trajectory or flight path. Even though you may not be able to see it, you know where it is in general. If you see an aircraft anywhere nearby, you could easily lower your drone to tree level where you know the plane or helicopter won't fly until it's out of your airspace. Also, the FAA should really consider the drone users ability to use instruments, like the cameras, the GPS Location Map, and ADS-B. Manned aircraft can use instrument only flight, but the FAA won't even consider allowing a drone to use it's instruments at all. It's like they think all drones have no GPS map, Camera or ADS-B. We all know, that we all know exactly where our drones are even when we can't see them. And if you have a full view of the airspace around your drone, avoiding a manned aircraft is as simple as descending to the lowest altitude (beyond that of the capability of a manned aircraft) and waiting for the aircraft to pass.

 

[brett8883]

Do sUAS spend as high a percentage of time in the air as manned aircraft?

No but I imagine the fact that sUAS have short flight times is a contributing factor to the excellent sUAS safety record. Small object in the big sky for short periods=low collision risk.

 

[Malcx]

We’re talking about the United States...

OK then two from the United States.

DJI Drone Collided with US Army Black Hawk Chopper and Dented Its Rotor

On September 21st, 2017, a DJI Phantom 4 camera drone flying recreationally near Brooklyn, New York, collided with a US Army Black Hawk helicopter. The

petapixel.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

 

[Malcx]

In all of the talk about instrument flying people seem to miss a fairly fundamental point. In an aircraft, if instruments fail catastrophically a pilot still has a reasonable chance of bringing the aircraft down safely by eye alone and certainly has a good chance of avoiding other aircraft.

BVLOS, if your phone decides to restart or run out of battery or other instrument fails then you don't even know the direction your drone is facing and have, at best, to rely on RTH to bring it home. RTH doesn't currently have any avoidance of fast moving manned aircraft.

Yes technology can in time mitigate these, but that's a long way off being consumer level.

 

[Ty Pilot]

. . . . The surge in regulations seems to coincide with the release of camera equipped RC drones. The cameras allow the operator to fly anywhere they can see. And the fact that they can see, really bothers the general public and authorities.

Prior to 'drones' RC aviation was largely a self governing activity and by self governing I don't just mean we followed AMA rules. The process of learning to fly took place at very specific, and known locations and indeed VLOS was the ONLY method of operation - if you couldn't see your aircraft and it's orientation and attitude, you were a few seconds from a potential total loss. Most if not all experienced RC Pilots had losses, and through them gained knowledge and experience. RC pilots that were lax or didn't work at their skill sets would crash so much that they either quit or only flew lightweight and slow trainers - it was a self regulating process through the pilot's pockets.

As long as RC took place within the confines of a regulated AMA flying site, the FAA pretty much had no interest.

When the modern drone emerged, there were two facets that put them squarely on the radar of the FAA and general public, first; they require no experience to fly - literally anyone that could flip a switch and push a button, could get airborne and second, they can be launched from virtually anywhere and thus no longer where they confined to known and sanctioned locations.

Drones started showing up in National Parks, Sporting Events, Airports, Neighbors Backyard BBQ's, Skyscrapers and dozens more places where RC aviation almost never could be found. This is why we are where we are today.

 

[WW5RM]

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

Agreed! Everything in life is a risk! Stepping out your front door is a risk! Driving down the road is a much bigger risk! Etc.

I think the whole safety issue is blown way out of proportion and its the big A behind it! Just follow the money!

Maybe if you have liability insurance and training then let us BVLOS. Honestly what's the point of even the Mavic Mini if you have to VLOS? No need in 26dbm transmitters just to VLOS!

WW5RM

 

[brett8883]

OK then two from the United States.

DJI Drone Collided with US Army Black Hawk Chopper and Dented Its Rotor

On September 21st, 2017, a DJI Phantom 4 camera drone flying recreationally near Brooklyn, New York, collided with a US Army Black Hawk helicopter. The

petapixel.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

The California one could very well could be another. I am using the NTSB database and they are still investigating the California incident and their preliminary report doesn’t detail the incident.

We are still talking about an extremely small number of incidents and wether it’s 1 or 2 doesn’t really change the point that there are an extraordinary few number of incidents for as many drones there are in the US.

 

[maelstrom]

Bad might happen, rather than because something Bad is likely to happen.

This premise that something “could” happen being the reason to not do something seems to control a lot of things and most people.

But that's what many aviation regulations are based on - the potential for something bad to happen rather than the statistics available after it does. Would you want to be the regulator who saw the possibility of something catastrophic happening but did nothing to try to prevent it until after it did?

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

How do you know that this isn't because of the regulations? Also, look at the number of aviation incidents each year which involve bird strikes (similar size and weight to a drone) and the number of those which cause forced landings (and fatalities in rare cases).

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.”

Do you fly along constantly rotating your drone? What about the times you're taking a video or a photograph which involves maintaining a particular drone heading - how do you check the airspace around you then?

BVLOS with a drone is nothing like instrument flying! You don't need any specialised skills to fly most modern drones. When you're instrument flying you use the flight instruments to maintain the aircraft's stability and position in space (attitude, height, heading speed and direction), you don't use them to avoid other aircraft. That's what you have an air traffic service for.

 

[Drone-Retriever]

Beyond Visual Line Of Site will require that the drone is flying Autonomously with full Artificial Inteligence.
The DRONE itself will need to be certified by the manufacturer First!!!

 

[brett8883]

Also, look at the number of aviation incidents each year which involve bird strikes (similar size and weight to a drone) and the number of those which cause forced landings (and fatalities in rare cases).

Yes there are lots of bird strikes, however, there are an estimated 10-20 billion birds in the US depending on the season so the probability of hitting one is 25,000 times greater than hitting a drone assuming the drone pilot doesn’t see the aircraft coming and avoid it. Also bird strikes very rarely cause injuries much less deaths. As you said since they are similar size and weight should be further evidence that drones are safe.

 

[B52-D]

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.

Here is a FAA link for Bird Strikes.

https://www.faa.gov/airports/airport_safety/wildlife/media/Wildlife-Strike-Report-1990-2019.pdf

B52-D

 

[brett8883]

Here is a FAA link for Bird Strikes.

https://www.faa.gov/airports/airport_safety/wildlife/media/Wildlife-Strike-Report-1990-2019.pdf

B52-D

It says 41% of bird strikes happen a 0ft AGL! I realize that is very dangerous when taking off down the run way but for our comparison to drones it takes nearly half off the table lol

 

[projectarjun]

Worst comes to push, we have RTH at hand ?

 

[RoboticTundra]

Some perspective...

Someone in the U.S. is about 5x as likely to be killed by someone driving a car as someone in Europe. Someone riding a bicycle in the U.S. is about 11x as likely to be killed as someone riding a bicycle in The Netherlands, Sweden, Germany, etc. Someone walking near a road in the U.S. is about 17x as likely to be killed as someone doing the same in Europe.

Traffic engineers in Europe are, correctly, quick to point to U.S. road designs as the primary reason for this disparity but also add that driver training along with European's higher regard for laws and law enforcement play critical roles.

While clearly defined and reasonable rules and regs are critical and I do support them, the bigger risk is likely from people who are ignorant of the rules and more so those who break so many other laws (from speeding or right-on-red without stopping to pot & prostitution) that the concept of obeying a law is watered down and they wonder why then obey a toy drone law.

 

[Chaosrider]

You make a very good point. I think, maybe drone regulation isn't just about safety. There seems to be something else going on. In the days when we only had RC plane pilots, the regs were minimal. The surge in regulations seems to coincide with the release of camera equipped RC drones. The cameras allow the operator to fly anywhere they can see. And the fact that they can see, really bothers the general public and authorities. Especially authorities. They didn't like it when they saw news helicopters flying above, and they certainly don't like the idea of some Joe citizen filming them from above. You see how they treat someone filming them with a cell phone. They go absolutely insane sometimes. They might go even more insane if someone were to fly a drone in a safe place, but close enough for them to be filmed. Why?, there wouldn't be a person behind the camera they could try to intimidate or arrest by saying, "your interfering with a police investigation, you will be arrested if you do not cease and desist your filming."

I think your experience with law enforcement is very different from mine...

In my life, the cops have always been the Good Guys.

TCS

 

[Chaosrider]

But that's what many aviation regulations are based on - the potential for something bad to happen rather than the statistics available after it does. Would you want to be the regulator who saw the possibility of something catastrophic happening but did nothing to try to prevent it until after it did?


How do you know that this isn't because of the regulations? Also, look at the number of aviation incidents each year which involve bird strikes (similar size and weight to a drone) and the number of those which cause forced landings (and fatalities in rare cases).


Do you fly along constantly rotating your drone? What about the times you're taking a video or a photograph which involves maintaining a particular drone heading - how do you check the airspace around you then?

BVLOS with a drone is nothing like instrument flying! You don't need any specialised skills to fly most modern drones. When you're instrument flying you use the flight instruments to maintain the aircraft's stability and position in space (attitude, height, heading speed and direction), you don't use them to avoid other aircraft. That's what you have an air traffic service for.

Actually, when I'm going to new territory, I do a great many 360º turns, just to see what's what.

Flying a drone BVLOS is a lot like instrument flying in terms of aircraft control and navigation. In terms of collision avoidance, it isn't.

TCS

 

[Chaosrider]

Beyond Visual Line Of Site will require that the drone is flying Autonomously with full Artificial Inteligence.
The DRONE itself will need to be certified by the manufacturer First!!!

There will and should be aircraft requirements to fly BVLOS, but full autonomous AI won't and shouldn't be part of the requirement.

Perhaps an enhanced RTH function that included obstacle avoidance would be useful.

TCS