Is situational awareness mandated?

[John Locke]

After 5yrs of flying DJI, and a Part 107 cert, there seems to be some uncertainty with many pilots beliefs for rules. I'd like to review a few things and make sure all all understand the rules, including me.

1. From my experience and study, I've never seen a mandate from the FAA that situational awareness is required, only VLOS. No doubt that situational awareness by eye is better, but I'm not sure just how important that is. Whenever I see a helicopter, parasailer, or airplane, my first reaction is to descend, immediately to under 100', assuming nothing is in my way. There has never been a situation where ascending is a good evasive maneuver. Since descending is a natural evasive manuever, knowing situational awareness isn't needed for that, only FPV view to prevent hitting ground based objects.

2. From my experience and study, I've never seen a mandate from the FAA to watch the drone 100% of the time VLOS. This means the requirement is that you need the ability to see the drone at that distance. There is no requirement to my knowledge how long it takes you to located it visually. It only requires to be able to SEE the drone. Hence strobe lights help to locate faster, but still there's not requirement for locating time needed VLOS.

If I'm correct above (please correct me if I'm wrong), I don't have to watch the drone 100% after take off, and there is no requirement for how much I have to watch it, meaning situational awareness VLOS is not a requirement, albeit it would be better of course.

I personally have tested my eyesight for distance for VLOS when not taking my eyes off the drone. I can see it at 3000', and have gone to 4000' on a good day. So, because of that I know that 3000' is my limit to be able to see the drone. I realize that if I don't watch it from takeoff, that it's very hard to locate it, and it may take 5 min, which isn't good, but I know I can see it with enough time to locate.

Is this stretching the rules? Yes. But I'm not breaking them if I stay within 3000' on a clear day.

I know I'll be getting a lot of pushback on this interpretation of FAA rules, but they are the rules, as I understand them. I do value input on this to see where this goes. I try to obey these rules, but sometimes I slip up, during the adrenaline rush of the subject I'm flying. My methods to mitigate aircraft interference are to fly low, under 300'. With that I only have to worry about helicopters, which I'll hear anyway. I never fly near airports, not even small ones, so I don't have to worry much about fixed wing aircraft down at my 100 to 200' flight elevations, unless they're risking their own guidelines. There are exceptions like farm sprayers, etc.

 

[old man mavic]

so what happens during that 5 mins when you have lost sight of the drone ,this argument (sorry debate) about interpreting VLOS can, has, and will ,go on for ever and a day

 

[brett8883]

After 5yrs of flying DJI, and a Part 107 cert, there seems to be some uncertainty with many pilots beliefs for rules. I'd like to review a few things and make sure all all understand the rules, including me.

1. From my experience and study, I've never seen a mandate from the FAA that situational awareness is required, only VLOS. No doubt that situational awareness by eye is better, but I'm not sure just how important that is. Whenever I see a helicopter, parasailer, or airplane, my first reaction is to descend, immediately to under 100', assuming nothing is in my way. There has never been a situation where ascending is a good evasive maneuver. Since descending is a natural evasive manuever, knowing situational awareness isn't needed for that, only FPV view to prevent hitting ground based objects.

2. From my experience and study, I've never seen a mandate from the FAA to watch the drone 100% of the time VLOS. This means the requirement is that you need the ability to see the drone at that distance. There is no requirement to my knowledge how long it takes you to located it visually. It only requires to be able to SEE the drone. Hence strobe lights help to locate faster, but still there's not requirement for locating time needed VLOS.

If I'm correct above (please correct me if I'm wrong), I don't have to watch the drone 100% after take off, and there is no requirement for how much I have to watch it, meaning situational awareness VLOS is not a requirement, albeit it would be better of course.

I personally have tested my eyesight for distance for VLOS when not taking my eyes off the drone. I can see it at 3000', and have gone to 4000' on a good day. So, because of that I know that 3000' is my limit to be able to see the drone. I realize that if I don't watch it from takeoff, that it's very hard to locate it, and it may take 5 min, which isn't good, but I know I can see it with enough time to locate.

Is this stretching the rules? Yes. But I'm not breaking them if I stay within 3000' on a clear day.

I know I'll be getting a lot of pushback on this interpretation of FAA rules, but they are the rules, as I understand them. I do value input on this to see where this goes. I try to obey these rules, but sometimes I slip up, during the adrenaline rush of the subject I'm flying. My methods to mitigate aircraft interference are to fly low, under 300'. With that I only have to worry about helicopters, which I'll hear anyway. I never fly near airports, not even small ones, so I don't have to worry much about fixed wing aircraft down at my 100 to 200' flight elevations, unless they're risking their own guidelines. There are exceptions like farm sprayers, etc.

1. Incorrect. Very incorrect actually. Above all else you have to have situational awareness.

§ 107.31 Visual Line of Sight Aircraft Operation

• (a) With vision that is unaided by any device other than corrective lenses, the remote pilot in command, the visual observer (if one is used), and the person manipulating the flight control of the small unmanned aircraft system must be able to see the unmanned aircraft throughout the entire flight in order to:
• (1) Know the unmanned aircraft’s location;
• (2) Determine the unmanned aircraft’s attitude, altitude, and direction of flight;
• (3) Observe the airspace for other air traffic or hazards; and

• (4) Determine that the unmanned aircraft does not endanger the life or property of another.
• (b) Throughout the entire flight of the small unmanned aircraft, the ability described in subsection (a) of this section must be exercised by either:
• (1) The remote pilot in command and the person manipulating the flight controls of the small unmanned aircraft system; or
• (2) A visual observer.

2. Correct.
You are correct that there’s no requirement to literally watch the aircraft at all times and you can even purposely lose VLOS legally for brief moments while still adhering to § 107.31 but you do always have to maintain the ability to “see and avoid.”


“VLOS Aircraft Operation.

The remote PIC and person manipulating the controls must be able to see the small UA at all times during flight. Therefore, the small UA must be operated closely enough to the CS to ensure visibility requirements are met during
small UA operations. This requirement also applies to the VO, if used during the aircraft operation.
However, the person maintaining VLOS may have brief moments in which he or she is not looking directly at or cannot see the small UA, but still retains the capability to see the UA or quickly maneuver it back to VLOS. These moments can be for the safety of the operation (e.g., looking at the controller to see battery life remaining) or for operational necessity. For operational necessity, the remote PIC or person manipulating the controls may intentionally maneuver the UA so that he or she loses sight of it for brief periods of time. Should the remote PIC or person manipulating the controls lose VLOS of the small UA, he or she must regain VLOS as soon as practicable. For example, a remote PIC stationed on the ground utilizing a small UA to inspect a rooftop may lose sight of the aircraft for brief periods while inspecting the farthest point of the roof. As another example, a remote PIC conducting a search operation around a fire scene with a
small UA may briefly lose sight of the aircraft while it is temporarily behind a dense column of smoke. However, it must be emphasized that even though the remote PIC may briefly lose sight of the small UA, he or she always has the see-and-avoid responsibilities set out in part 107, §§ 107.31 and 107.37. The circumstances of what would prevent a remote PIC from fulfilling those responsibilities will vary, depending on factors such as the type of UAS, the operational environment, and distance between the remote PIC and the UA. For this reason, there is no length of time that interruption of VLOS is permissible, as it would have the effect of potentially allowing a hazardous interruption or prohibiting a reasonable one.

If VLOS cannot be regained, the remote PIC or person manipulating the controls should follow pre-determined procedures for a loss of VLOS. These procedures are determined by the capabilities of the sUAS and may include immediately landing the UA, entering hover mode, or returning to home sequence. Thus, the VLOS requirement would not prohibit actions such as scanning the airspace or briefly looking down at the small UA CS.”

https://www.faa.gov/documentlibrary/media/advisory_circular/ac_107-2.pdf

 

[Motorcycle Rider]

This poor horse has been beaten to death.

 

[old man mavic]

This poor horse has been beaten to death.

you can say that again

 

[John Locke]

• (a) With vision that is unaided by any device other than corrective lenses, the remote pilot in command, the visual observer (if one is used), and the person manipulating the flight control of the small unmanned aircraft system must be able to see the unmanned aircraft throughout the entire flight in order to:
• (1) Know the unmanned aircraft’s location;
• (2) Determine the unmanned aircraft’s attitude, altitude, and direction of flight;
• (3) Observe the airspace for other air traffic or hazards; and

I appreciate the detail above, but I still think the guidelines are being followed if I'm within 3000' of home point as mentioned.
1. I am able to see the craft (if I look long enough for it), the strobe helps for this.
2. I do know the location (radar + telemetry)
3. I do know the craft's attitude and altitude, and direction of flight (radar + telemetry)
4. I can easily observe the airspace for other traffic and hazards. I do this every flight.

Although the statement implies you have to do all this visually, we all know it can be done better with telemetry information. For instance, it's way more accurate using telemetry data than guestimating altitude visually. Most of us could not accurately "determine altitude" only by looking at the craft. The telemetry data from the craft is much more accurate and relevant IMO, which is important to stay under 400' AGL (assuming flat ground).

These.guidelines appear to be written more for fixed wing model aircraft IMO. Although more accurate data is available with DJi's telemetry system, they overlook this in their wording, not focused on the best relevant data.

@Motorcycle Rider and @old man mavic , Sorry to beat this subject to death, and thanks for the condecenting comments, but it's of interest to some folks.

 

[sar104]

I appreciate the detail above, but I still think the rules are being followed if I'm within 3000' of home point as mentioned.
1. I am able to see the craft (if I look long enough for it), the strobe helps for this.
2. I do know the location (radar + telemetry)
3. I do know the craft's attitude and altitude, and direction of flight (radar + telemetry)
4. I can easily observe the airspace for other traffic and hazards. I do this every flight.

Although the statement implies you have to do all this visually, we all know it can be done better with telemetry information. For instance, it's way more accurate using telemetry data than guestimating altitude visually. Most of us could not accurately "determine altitude" only by looking at the craft. The telemetry data from the craft is much more accurate and relevant IMO, which is important to stay under 400' AGL (assuming flat ground).

These.guidelines appear to be written more for fixed wing model aircraft IMO. Although more accurate data is available with DJi's telemetry system, they overlook this in their wording to use the best and relevant data.

@Motorcycle Rider and @ Old Man Mavic, Sorry to beat this subject to death, and thanks for the condecenting comments, but it's of interest to some folks.

Part 107 doesn't imply that it must be done visually - it categorically states it. You may feel that you can achieve equivalent safety using telemetry, but it isn't legal.

 

[brett8883]

I appreciate the detail above, but I still think the guidelines are being followed if I'm within 3000' of home point as mentioned.
1. I am able to see the craft (if I look long enough for it), the strobe helps for this.
2. I do know the location (radar + telemetry)
3. I do know the craft's attitude and altitude, and direction of flight (radar + telemetry)
4. I can easily observe the airspace for other traffic and hazards. I do this every flight.

Although the statement implies you have to do all this visually, we all know it can be done better with telemetry information. For instance, it's way more accurate using telemetry data than guestimating altitude visually. Most of us could not accurately "determine altitude" only by looking at the craft. The telemetry data from the craft is much more accurate and relevant IMO, which is important to stay under 400' AGL (assuming flat ground).

These.guidelines appear to be written more for fixed wing model aircraft IMO. Although more accurate data is available with DJi's telemetry system, they overlook this in their wording, not focused on the best relevant data.

@Motorcycle Rider and @old man mavic , Sorry to beat this subject to death, and thanks for the condecenting comments, but it's of interest to some folks.

Im no fan of the FAA so I’m not trying to defend them but time and time again they say the point of VLOS is so the operator can “see and avoid” other aircraft. They are not saying you need to determine altitude by visual reference. If you have better data use it.

“Remote pilots have effective techniques to determine altitude without mandating the installation of an altimetry system. For example, with the unmanned aircraft on the ground, a remote pilot in command may separate him or herself 400 feet from the aircraft in order to gain a visual perspective of the aircraft at that distance. Remote pilots may also use the known height above the ground of local rising terrain and/or structures as a reference. The FAA acknowledges that these methods of estimating altitude are less precise than equipment-based altitude determinations, which is one of the reasons this rule will increase the separation between manned and small unmanned aircraft by reducing the maximum altitude for small unmanned aircraft to 400 feet AGL.

Additionally, the FAA will provide, in its guidance materials, examples of equipment options that may be used by remote pilots to accurately determine the altitude of their small unmanned aircraft. One example is the installation of a calibrated altitude reporting device on the small unmanned aircraft. This device reports the small unmanned aircraft's altitude above mean sea level (MSL). By subtracting the MSL elevation of the control station from the small unmanned aircraft's reported MSL altitude, the aircraft's AGL altitude may be determined. The installation of a GPS altitude-reporting device may also provide for a requisite level of altitude control. The FAA emphasizes, however, that this equipment is simply one means of complying with the altitude restrictions in this rule.”

https://www.federalregister.gov/documents/2016/06/28/2016-15079/operation-and-certification-of-small-unmanned-aircraft-systems

By the way this document above explains in great detail all the rules and the reasons for them Also it great detail. It includes point and counter point and why they did it the way they did.

Interesting though to read their reasons why they didn’t require UAS to carry ADS-B and how the new proposed rule for remote ID is in stark contrast to the FAAs original opinion. Back in 2016 they are basically saying that there is no safety reason to require UA to transmit their location data and that the cost to do so would be an undue burden on remote pilots...

 

[John Locke]

Im no fan of the FAA so I’m not trying to defend them but time and time again they say the point of VLOS is so the operator can “see and avoid” other aircraft. They are not saying you need to determine altitude by visual reference. If you have better data use it.

Yes, that's my point. I can see my craft at 3000' range, barely. However, I know exactly where it is with GO telemetrty, and I can see and hear craft coming into my airspace. And better yet, my altitude, attitude and elevation data is way better than by eyesight at a 500' range. The Go4 app provides better data, and I use it.

My point is the visual situational awareness that many insist is needed, is WORSE data than using a combination of Go4 telemetry data and visuals for other aircraft. If the data is better than the FAA guidelines given for data collection (visual), it's prudent to use the better GO4 data. Private pilots fly by instruments all the time, because it's better data than visual. Since the data is better from GO4, it's adequate as per guidelines IMO.

However I realize there are those that always stop at every stop sign, no rolling stops, ever. Is it safer? Not really, if it's safe, no other cars or pedestrians in the area. Is it legal? No. But almost all of us do rolling stops. I know the same thing happens with DJI drones, by thousands, and there hasn't been much of a problem in 5yrs.

It's really simple to avoid other aircraft if flying at 200'. Just descend to 100' when you notice a craft come into your airspace. You can do that in about 11 seconds (if my math is right). Plus the chances of craft flying at 200' AGL is pretty low anyway (where I fly). I never fly in town. I'm really not too worried about being safe.

 

[brett8883]

Yes, that's my point. I can see my craft at 3000' range, barely. However, I know exactly where it is with GO telemetrty, and I can see and hear craft coming into my airspace. And better yet, my altitude, attitude and elevation data is way better than by eyesight at a 500' range. The Go4 app provides better data, and I use it.

My point is the visual situational awareness that many insist is needed, is WORSE data than using a combination of Go4 telemetry data and visuals for other aircraft. If the data is better than the FAA guidelines given for data collection (visual), it's prudent to use the better GO4 data. Private pilots fly by instruments all the time, because it's better data than visual. Since the data is better from GO4, it's adequate as per guidelines IMO.

However I realize there are those that always stop at every stop sign, no rolling stops, ever. Is it safer? Not really, if it's safe, no other cars or pedestrians in the area. Is it legal? No. But almost all of us do rolling stops. I know the same thing happens with DJI drones, by thousands, and there hasn't been much of a problem in 5yrs.

It's really simple to avoid other aircraft if flying at 200'. Just descend to 100' when you notice a craft come into your airspace. You can do that in about 11 seconds (if my math is right). Plus the chances of craft flying at 200' AGL is pretty low anyway (where I fly). I never fly in town. I'm really not too worried about being safe.

Well what the rules are and what the rules should be are rarely the same.

 

[TampaTC]

Talking 107 pilots, Note: not everyone fly the same aircraft, weather conditions, Land contours, air space, or vision. The FAA has to start with a general rule that blankets most pilots and conditions. They then Implement waivers for flyers to do advanced flying. Lets say you can only see your aircraft at 1000 feet. You want fly 2000 feet legally you put in for a waiver for blvs up to 2000 feet and the area you will be flying (city or town) note airspace, aircraft type, amount of time on the sticks, use of cameras, telemetry, and plans in case of an emergency. I suggest having insurance information to provide and use during blvs. I would also have a short description of why you need to fly further, tha having to move your location to a better point. (1k feet Radius equals 2k feet Diameter)
I know this works, it helps by doing this the right way to let the FAA know that safe operations are happening, and pilots are knowledgeable. Stats (Bad and Good) help build the industry, rules, and regulations.
FLY SAFE ALL, enjoy the sky..

 

[Ty Pilot]

I appreciate the detail above, but I still think the guidelines are being followed if I'm within 3000' of home point as mentioned

They're not guidelines, they're rules. And also the whole point of VLOS is that you can achieve them visually; not by starring at the telemetry on the screen. When all of these conditions are achieved - visually - you HAVE situational awareness, so therefor - yes it is mandated.

• (1) Know the unmanned aircraft’s location;
• (2) Determine the unmanned aircraft’s attitude, altitude, and direction of flight;
• (3) Observe the airspace for other air traffic or hazards; and

• (4) Determine that the unmanned aircraft does not endanger the life or property of another.
• (b) Throughout the entire flight of the small unmanned aircraft, the ability described in subsection (a) of this section must be exercised by either:
• (1) The remote pilot in command and the person manipulating the flight controls of the small unmanned aircraft system; or
• (2) A visual observer.

 

[theDRONEranger]

Yes, that's my point. I can see my craft at 3000' range, barely. However, I know exactly where it is with GO telemetrty, and I can see and hear craft coming into my airspace. And better yet, my altitude, attitude and elevation data is way better than by eyesight at a 500' range. The Go4 app provides better data, and I use it.

My point is the visual situational awareness that many insist is needed, is WORSE data than using a combination of Go4 telemetry data and visuals for other aircraft. If the data is better than the FAA guidelines given for data collection (visual), it's prudent to use the better GO4 data. Private pilots fly by instruments all the time, because it's better data than visual. Since the data is better from GO4, it's adequate as per guidelines IMO.

However I realize there are those that always stop at every stop sign, no rolling stops, ever. Is it safer? Not really, if it's safe, no other cars or pedestrians in the area. Is it legal? No. But almost all of us do rolling stops. I know the same thing happens with DJI drones, by thousands, and there hasn't been much of a problem in 5yrs.

It's really simple to avoid other aircraft if flying at 200'. Just descend to 100' when you notice a craft come into your airspace. You can do that in about 11 seconds (if my math is right). Plus the chances of craft flying at 200' AGL is pretty low anyway (where I fly). I never fly in town. I'm really not too worried about being safe.

Your very last sentence kinds scares me a bit!