Business Risk Management and VLOS Distances

[aerialnorthwest]

Happy Mother's Day! How far away can we really safely see our drone in flight? Considering the airframes of DJI's Mavic 3 or Air2S, I feel like 800 feet (245 meters) is about the safe visual max - with or without VOs. I wonder if regulators may wind up imposing distance limits based on the size of the UAV airframe. What say you?

One of the most blurred rules in drone operations is the legal requisite to operate an unmanned aircraft (‘UA’) while maintaining constant visual line of sight (‘VLOS’) of the aircraft while in flight. Whether or not the FAA went about creating a confusing drone mandate is perhaps an argument for another day.

For now, we set our sights upon a most troublesome common sense UAS safety concern by taking an in-focused look at how an unmanned aircraft pilot goes about determining their maximum visual line of sight distance for a given in-flight aerial drone mission and some of the factors that affect a UA pilot’s ability to maintain constant visual observation during in-flight operations.

I hope this brief drone business risk mitigation synopsis is useful for you and the continued growth and health of your drone service business endeavor!

The Paper + Infographic: VLOS: How Drone Pilots Determine Maximum Flight Distances

Make it great Mother's Day weekend!

Fly cognitively! T

 

[WanderLost]

Well in Britain for example, there is a VLOS limit of 500 meters. Irrespective of the size of the drone. That may be where many other countries are headed in order to eliminate the "confusion".
"The CAA will normally accept that the VLOS requirement is met when the UA is flown out to a distance of 500 metres horizontally from the remote pilot, but only if the aircraft can still be seen at this distance."

I wonder if the use of strobes which can be seen from much further would make any difference for the FAA's or Transport Canada's interpretation of VLOS.

 

[aerialnorthwest]

Well in Britain for example, there is a VLOS limit of 500 meters. Irrespective of the size of the drone. That may be where many other countries are headed in order to eliminate the "confusion".
"The CAA will normally accept that the VLOS requirement is met when the UA is flown out to a distance of 500 metres horizontally from the remote pilot, but only if the aircraft can still be seen at this distance."

I wonder if the use of strobes which can be seen from much further would make any difference for the FAA's or Transport Canada's interpretation of VLOS.

We adamantly believe that the further distance one flies, the greater the risk. Our flight objective is to continuously mitigate risk. It's better for business and better for our industry at large to ensure we as pilots have full control of our mission from lift-off to landing! Just because there are limitations imposed by law, doesn't mean we should always fly to the edge of the boundary line! Just because a pilot might see a "tiny drone dot" far off in the distance does not mean they have complete control of the aircraft, particularly when we factor in wind condition variables, flying wildlife, connectivity malfunctions, or other large, small, or tiny aircraft. ;-) T

 

[Ty Pilot]

@aerialnorthwest thank you for writing these papers, I find them very informational and well written. I have just been to your sight and read you latest paper about VLOS, and have a few things that I think are important to add here.

First, in the section titled: The Dilemma of the Visual Line of Sight Rule you pose the following question:

What’s a sUAS pilot to do about this somewhat confusing dilemma? If the pilot holds true to such requisite while in flight, how would the pilot look away from the aircraft to look down to view and interpret the remote monitor without losing visual line of sight?

What you wrote is how many interpret the regulation for VLOS, but it is only when one reads the accompanying FAA AC-107A, which further defines the rule; does one get the full meaning. Below is from that document:

5.9 VLOS Aircraft Operation. The remote PIC and person manipulating the controls must be able to see the small unmanned aircraft at all times during flight (§ 107.31). The small unmanned aircraft must be operated closely enough to ensure visibility requirements are met during small UAS operations. This requirement also applies to the VO, if used, during the aircraft operation. The person maintaining VLOS may have brief moments in which he or she is not looking directly at or cannot see the small unmanned aircraft, but still retains the capability to see the small unmanned aircraft or quickly maneuver it back to VLOS. These moments may be necessary for the remote PIC to look at the controller to determine remaining battery life or for operational awareness.
Should the remote PIC or person manipulating the controls lose VLOS of the small unmanned aircraft, he or she must regain VLOS as soon as practicable. Even though the remote PIC may briefly lose sight of the small unmanned aircraft, the remote PIC always has the see-and-avoid responsibilities set out in §§ 107.31 and 107.37. The circumstances that may prevent a remote PIC from fulfilling those responsibilities will vary, depending on factors such as the type of small UAS, the operational environment, and distance between the remote PIC and the small unmanned aircraft. For this reason, no specific time interval exists in which interruption of VLOS is permissible, as it would have the effect of potentially allowing a hazardous interruption of the operation. If the remote PIC cannot regain VLOS, the remote PIC or person manipulating the controls should follow pre-determined procedures for the loss of VLOS. The capabilities of the small UAS will govern the remote PIC’s determination as to the appropriate course of action. For example, the remote PIC may need to land the small unmanned aircraft immediately, enter hover mode, or employ a return-to-home sequence. The VLOS requirement does not prohibit actions such as scanning the airspace or briefly looking down at the small unmanned aircraft CS.

 

[Ty Pilot]

Also, in regards to VLOS, that rule was brought over to the 'drone' world, borrowed from the methods in place to fly RC fixed and rotational winged aircraft. It was evident that to remotely pilot those types of aircraft, VLOS was not just required, it was mandatory, as there were no self-righting or safety features built in. Positive control required an RC pilot to see all of the elements that are now required by current VLOS: attitude, altitude, and direction of flight.

 

[WanderLost]

We adamantly believe that the further distance one flies, the greater the risk. Our flight objective is to continuously mitigate risk. It's better for business and better for our industry at large to ensure we as pilots have full control of our mission from lift-off to landing! Just because there are limitations imposed by law, doesn't mean we should always fly to the edge of the boundary line! Just because a pilot might see a "tiny drone dot" far off in the distance does not mean they have complete control of the aircraft, particularly when we factor in wind condition variables, flying wildlife, connectivity malfunctions, or other large, small, or tiny aircraft. ;-) T

Totally agree! Although I thought I was just answering your question, "I wonder if regulators may wind up imposing distance limits based on the size of the UAV airframe. What say you?"
And I responded with what I have read about a country actually mentioning a VLOS horizontal limit. Something I haven't seen before. This is not my personal opinion or my endorsement - just an observation in relation to your question.

 

[aerialnorthwest]

@aerialnorthwest thank you for writing these papers, I find them very informational and well written. I have just been to your sight and read you latest paper about VLOS, and have a few things that I think are important to add here.

First, in the section titled: The Dilemma of the Visual Line of Sight Rule you pose the following question:

What’s a sUAS pilot to do about this somewhat confusing dilemma? If the pilot holds true to such requisite while in flight, how would the pilot look away from the aircraft to look down to view and interpret the remote monitor without losing visual line of sight?

What you wrote is how many interpret the regulation for VLOS, but it is only when one reads the accompanying FAA AC-107A, which further defines the rule; does one get the full meaning. Below is from that document:

5.9 VLOS Aircraft Operation. The remote PIC and person manipulating the controls must be able to see the small unmanned aircraft at all times during flight (§ 107.31). The small unmanned aircraft must be operated closely enough to ensure visibility requirements are met during small UAS operations. This requirement also applies to the VO, if used, during the aircraft operation. The person maintaining VLOS may have brief moments in which he or she is not looking directly at or cannot see the small unmanned aircraft, but still retains the capability to see the small unmanned aircraft or quickly maneuver it back to VLOS. These moments may be necessary for the remote PIC to look at the controller to determine remaining battery life or for operational awareness.
Should the remote PIC or person manipulating the controls lose VLOS of the small unmanned aircraft, he or she must regain VLOS as soon as practicable. Even though the remote PIC may briefly lose sight of the small unmanned aircraft, the remote PIC always has the see-and-avoid responsibilities set out in §§ 107.31 and 107.37. The circumstances that may prevent a remote PIC from fulfilling those responsibilities will vary, depending on factors such as the type of small UAS, the operational environment, and distance between the remote PIC and the small unmanned aircraft. For this reason, no specific time interval exists in which interruption of VLOS is permissible, as it would have the effect of potentially allowing a hazardous interruption of the operation. If the remote PIC cannot regain VLOS, the remote PIC or person manipulating the controls should follow pre-determined procedures for the loss of VLOS. The capabilities of the small UAS will govern the remote PIC’s determination as to the appropriate course of action. For example, the remote PIC may need to land the small unmanned aircraft immediately, enter hover mode, or employ a return-to-home sequence. The VLOS requirement does not prohibit actions such as scanning the airspace or briefly looking down at the small unmanned aircraft CS.

Thank you Ty! ;-) All about actionable risk management to ensure the greatest flight and public safety attainable. T

PS. Either we can police ourselves or the police will have to police us. (No need to get them involved. Those in BLUE already have their hands full with the ever-evolving myriad of "all about me" egotists, the "run of the mill" bloviators, and your "garden variety" of self-serving know-it-alls strewn all across our public landscape!)