Lets talk about where you *CAN* fly BVLOS

[Zbip57]

I've never looked at the Canadian regs, but a quick read of what you posted suggests that your interpretation is correct - the pilot or a VO has to be watching the aircraft at all times, but the pilot doesn't even have to be able to see it as long as a VO with good communication with the pilot is performing that function.

Back to the original question of where one *can* fly BVLOS, it's still not allowed in Canada unless you have special permission under an SFOC. But it's important to understand what BVLOS actually means according to these differences in regulations.

From an FAA perspective, any time the pilot is unable to see the drone, regardless of whether he has a visual observer or not, that's BVLOS. Your regs say the pilot and observer must both be able to see the drone at all times. Even if the pilot is wearing goggles and only the observer is physically looking at the drone, the pilot must still keep it within range to be able to see it if he takes his goggles off.

The Canadian regs allow for the pilot to be unable to see the drone for whatever reason, as long as he has a visual observer in communication keeping track of the drone. This is still considered Visual Line-of-Sight in Canada, but would be deemed BVLOS by the FAA.

I think the Canadian version makes more sense and the FAA's version is overly restrictive.

It's similar to a crane operator lifting construction material from street level onto the rooftop of a tall building. If the operator can't see the load at both ends of the lift, either street level or rooftop, he relies on communication with a visual observer, either by hands signals or by radio, to direct the safe raising or lowering of the cargo load. It would be overly restrictive and make no sense if the rules required that both the operator and observer must be able to see the load at all times.

 

[sar104]

Back to the original question of where one *can* fly BVLOS, it's still not allowed in Canada unless you have special permission under an SFOC. But it's important to understand what BVLOS actually means according to these differences in regulations.

From an FAA perspective, any time the pilot is unable to see the drone, regardless of whether he has a visual observer or not, that's BVLOS. Your regs say the pilot and observer must both be able to see the drone at all times. Even if the pilot is wearing goggles and only the observer is physically looking at the drone, the pilot must still keep it within range to be able to see it if he takes his goggles off.

The Canadian regs allow for the pilot to be unable to see the drone for whatever reason, as long as he has a visual observer in communication keeping track of the drone. This is still considered Visual Line-of-Sight in Canada, but would be deemed BVLOS by the FAA.

I think the Canadian version makes more sense and the FAA's version is overly restrictive.

It's similar to a crane operator lifting construction material from street level onto the rooftop of a tall building. If the operator can't see the load at both ends of the lift, either street level or rooftop, he relies on communication with a visual observer, either by hands signals or by radio, to direct the safe raising or lowering of the cargo load. It would be overly restrictive and make no sense if the rules required that both the operator and observer must be able to see the load at all times.

For most operations the Canadian version satisfies the goal of maintaining situational awareness. The FAA regulation is more restrictive but the reasoning is that if the pilot needs to take over manual control (e.g. in ATTI mode) then that's going to be difficult working from a VO's instructions - it really requires direct observation of the aircraft.

The crane analogy doesn't really address the second situation since it is such a constrained system and there is no equivalent of a flyaway with a crane.

 

[Zbip57]

I guess it all depends on the actual situation. I sometimes prefer to fly in ATTI mode as the response is smoother as the drone doesn't brake to an abrupt halt whenever sticks are centred as happens in GPS mode. I generally prefer to fly by watching the monitor screen as it gives me a much better sense of being onboard and knowing exactly where the drone is located and where it's heading, as opposed to watching it from a distance from the ground. But if I'm going to be manoeuvring the drone in close proximity to anything, then I really do need to be able to watch it directly from nearby (especially if in ATTI mode), and I don't see how that could ever work satisfactorily when directed remotely by a visual observer.

In the event of an (uncontrollable?) flyaway, how would it make a difference either way whether the pilot can still see it or not? Except of course, if it's so far away that the pilot can no longer see it for himself, then there's an increased likelihood of loss-of-signal.

In any case, Canada's VLOS interpretation seems more relaxed than the FAA's.

Another strange difference is in the trick question, what is the maximum number of drones one visual observer is allowed to monitor? Obviously if you have ten different pilots flying ten different drones you'd need ten different visual observers, each monitoring only a single drone. However...

The FAA is very clear about that.

§ 107.35 Operation of multiple small unmanned aircraft.​

A person may not manipulate flight controls or act as a remote pilot in command or visual observer in the operation of more than one unmanned aircraft at the same time.

Strangely enough, Transport Canada allows something different.

Visual Observers​

• 901.20 (3) No visual observer shall perform visual observer duties for more than one remotely piloted aircraft at a time unless the aircraft are operated in accordance with subsection 901.40(1) or in accordance with a special flight operations certificate — RPAS issued under section 903.03.

Unless? Well, 901.40 says:

Multiple Remotely Piloted Aircraft​

• 901.40 (1) No pilot shall operate more than one remotely piloted aircraft at a time unless the remotely piloted aircraft system is designed to permit the operation of multiple aircraft from a single control station and unless the aircraft are operated in accordance with the manufacturer’s instructions.
• (2) For the purposes of subsection (1), no pilot shall operate more than five remotely piloted aircraft at a time except in accordance with a special flight operations certificate — RPAS issued under section 903.03.

In this particular case, one visual observer can monitor up to five drones at once! That's bizarre, eh?

 

[sar104]

I guess it all depends on the actual situation. I sometimes prefer to fly in ATTI mode as the response is smoother as the drone doesn't brake to an abrupt halt whenever sticks are centred as happens in GPS mode. I generally prefer to fly by watching the monitor screen as it gives me a much better sense of being onboard and knowing exactly where the drone is located and where it's heading, as opposed to watching it from a distance from the ground. But if I'm going to be manoeuvring the drone in close proximity to anything, then I really do need to be able to watch it directly from nearby (especially if in ATTI mode), and I don't see how that could ever work satisfactorily when directed remotely by a visual observer.

In the event of an (uncontrollable?) flyaway, how would it make a difference either way whether the pilot can still see it or not? Except of course, if it's so far away that the pilot can no longer see it for himself, then there's an increased likelihood of loss-of-signal.

In any case, Canada's VLOS interpretation seems more relaxed than the FAA's.

Another strange difference is in the trick question, what is the maximum number of drones one visual observer is allowed to monitor? Obviously if you have ten different pilots flying ten different drones you'd need ten different visual observers, each monitoring only a single drone. However...

The FAA is very clear about that.


Strangely enough, Transport Canada allows something different.


Unless? Well, 901.40 says:


In this particular case, one visual observer can monitor up to five drones at once! That's bizarre, eh?

I was referring to loss of positioning triggering ATTI mode as an example. Another, perhaps better, example would be loss of video feed, such as when the app crashes.

 

[Etdronehome]

Interesting discussion for me in regard to the Canadian law.

As always there is the “spirit” vs “letter” of any law. As arrests are made and argued in court “precedent” will be formed to guide what the actual judgements will be and/or how the laws will be updated.

One of the things that has puzzled me is the 250gram “micro drone” distinction.
If some kid gets clipped in the head by a Mini 2 going flat out in Sport mode is the worst case medical outcome going to be somehow different than the same kid getting bashed by a “heavier” drone.

The logic of this limit escapes me.

The VLOS and BVLOS “spirit” of the law is there to define common sense behaviour from the participants. Imho for what that’s worth.

I think there is an exponential growth in the number of people getting into the activity we enjoy so much. Lots of posts here about, just got my first drone ….
Couple that with social media posts where it’s obvious that the video subjects are having a lot of fun flying BVLOS and I think it’s reasonable to assume that innocent rookies are going to emulate it. Next someone gets injured or worse, it gets picked up in the media, government knee jerk responds and the laws get stricter and are actually enforced.

Most of that bleak future could likely be avoided if the majority follow the spirit of VLOS not look for ways to get around the letter of the law.

Rant over - my apologies.

 

[Meta4]

One of the things that has puzzled me is the 250gram “micro drone” distinction.
If some kid gets clipped in the head by a Mini 2 going flat out in Sport mode is the worst case medical outcome going to be somehow different than the same kid getting bashed by a “heavier” drone.

That would depend on many factors including the weight of the heavier drone.

The logic of this limit escapes me.

The kinetic energy of a moving object (the capacity to cause damage) is a function of the mass of the object and its velocity, thus the heavier drone could cause more damage.

How the 250g threshold was arrived at was explained in a recent thread.
Read from here to see it:

The Terminal Velocity of a Falling Mavic 2

If we are going to get that far into the details then this needs some clarification. Objects don't accelerate at 9.8 m/s² until they reach terminal velocity, and then discontinuously stop accelerating. The rate of acceleration follows from Newton's 2nd Law (F = ma), where F is the weight of the...

mavicpilots.com

 

[Etdronehome]

That would depend on many factors including the weight of the heavier drone.

The kinetic energy of a moving object (the capacity to cause damage) is a function of the mass of the object and its velocity, thus the heavier drone could cause more damage.

How the 250g threshold was arrived at was explained in a recent thread.
Read from here to see it:

The Terminal Velocity of a Falling Mavic 2

If we are going to get that far into the details then this needs some clarification. Objects don't accelerate at 9.8 m/s² until they reach terminal velocity, and then discontinuously stop accelerating. The rate of acceleration follows from Newton's 2nd Law (F = ma), where F is the weight of the...

mavicpilots.com

Not sure if you are just having a little sport but OK I’ll take another bite.

Let’s say that there are a bunch of 6 year old kids playing soccer at a local sports field. I was a soccer parent coach so what that means is a cluster of about 20 kids all around the ball surrounded by their doting extended families many of them live streaming the event on social media. One of the players is the daughter of a senior politician so a news crew is also there covering the event.

Then two people new to “droning” show up in the general area but are just marginally BVLOS of the soccer field. One has a Mini 2 the other a Mavic 3. They start flying around emulating the guys they have seen on YouTube and go into Sport mode. They spot the kids game and decide to go get a closer look and end up “accidentally” crashing into the group of kids at the top speed of the drones at exactly the same time striking two of the kids (identical twins) square in the face killing them instantly.

Does it matter that the M3 has more kinetic energy at point of impact, or will anyone in the general public care about the two pilots lawyers arguments about what constitutes legal VLOS, will the politician take advantage of the press coverage and launch a bill to ban recreational drone flying.

 

[sar104]

Not sure if you are just having a little sport but OK I’ll take another bite.

Let’s say that there are a bunch of 6 year old kids playing soccer at a local sports field. I was a soccer parent coach so what that means is a cluster of about 20 kids all around the ball surrounded by their doting extended families many of them live streaming the event on social media. One of the players is the daughter of a senior politician so a news crew is also there covering the event.

Then two people new to “droning” show up in the general area but are just marginally BVLOS of the soccer field. One has a Mini 2 the other a Mavic 3. They start flying around emulating the guys they have seen on YouTube and go into Sport mode. They spot the kids game and decide to go get a closer look and end up “accidentally” crashing into the group of kids at the top speed of the drones at exactly the same time striking two of the kids (identical twins) square in the face killing them instantly.

Does it matter that the M3 has more kinetic energy at point of impact, or will anyone in the general public care about the two pilots lawyers arguments about what constitutes legal VLOS, will the politician take advantage of the press coverage and launch a bill to ban recreational drone flying.

I'm not clear what you are trying to argue here. The point is that the aircraft with the higher kinetic energy is likely to do more damage/injury. Is that not obvious?

 

[Etdronehome]

I'm not clear what you are trying to argue here. The point is that the aircraft with the higher kinetic energy is likely to do more damage/injury. Is that not obvious?

Not really trying to “argue” anything.

My initial point about a separate grouping of drones under 250g being “safer” or “less lethal” just because they are lighter doesn’t make sense to me.

I understand about kinetic energy but in my scenario it really doesn’t matter that the M3 is a heavier faster drone than the Mini 2 as the resulting damage/injury ends with the same lethal result.

 

[Meta4]

My initial point about a separate grouping of drones under 250g being “safer” or “less lethal” just because they are lighter doesn’t make sense to me.

I understand about kinetic energy

Sounds like you don't understand kinetic energy at all.

but in my scenario it really doesn’t matter that the M3 is a heavier faster drone than the Mini 2 as the resulting damage/injury ends with the same lethal result.

Your contrived scenario is just something from your imagination.
Because you imagined the two different drones having the same (unlikely) outcome, doesn't mean that would happen in reality.

 

[sar104]

Not really trying to “argue” anything.

My initial point about a separate grouping of drones under 250g being “safer” or “less lethal” just because they are lighter doesn’t make sense to me.

I understand about kinetic energy but in my scenario it really doesn’t matter that the M3 is a heavier faster drone than the Mini 2 as the resulting damage/injury ends with the same lethal result.

That's because your scenario is cherry picked to create that result. I could contrive an equivalent scenario where one person is improbably killed by the impact of a Mavic Mini and another person is killed by a 3-ton truck. Does that make them equivalently dangerous?

 

[MS Coast]

Not really trying to “argue” anything.

My initial point about a separate grouping of drones under 250g being “safer” or “less lethal” just because they are lighter doesn’t make sense to me.

I understand about kinetic energy but in my scenario it really doesn’t matter that the M3 is a heavier faster drone than the Mini 2 as the resulting damage/injury ends with the same lethal result.

Let's get back to simple examples.

Drop a baseball on your foot. Drop a bowling ball on your foot. Which does the most damage? Why would things be different for lighter drones and heaver drones? The heavier the object, the greater the kinetic energy and the greater the potential for damage. How can that not be apparent?

 

[Etdronehome]

In my defence I don‘t believe I said that the child that was struck by the heavier drone going faster suffered less injury than the other child. My point was that both children died, only one level of dead that I’m aware of so the end result was the same from the child’s perspective.

Pretty sure the parents, bystanders and anyone else that suffered are not going to care about kinetic energy, terminal velocity of brick shaped objects, BVLOS vs VLOS regulations.

Does anyone believe that the degree of injury, the physics involved or the legal definitions are going to matter if or more likely when some ‘innocent” child gets dinged by an irresponsible drone operator and it gets wide media coverage?

Creating a sub class under 250g doesn’t make sense to me - as it just increases the complexity for no real value.

My opinion - not claiming fact or is that not allowed here?

 

[sar104]

In my defence I don‘t believe I said that the child that was struck by the heavier drone going faster suffered less injury than the other child. My point was that both children died, only one level of dead that I’m aware of so the end result was the same from the child’s perspective.

Pretty sure the parents, bystanders and anyone else that suffered are not going to care about kinetic energy, terminal velocity of brick shaped objects, BVLOS vs VLOS regulations.

Does anyone believe that the degree of injury, the physics involved or the legal definitions are going to matter if or more likely when some ‘innocent” child gets dinged by an irresponsible drone operator and it gets wide media coverage?

Creating a sub class under 250g doesn’t make sense to me - as it just increases the complexity for no real value.

My opinion - not claiming fact or is that not allowed here?

I think it's simply preferred that your opinion makes some kind of sense. Otherwise it looks like trolling.

 

[Meta4]

In my defence I don‘t believe I said that the child that was struck by the heavier drone going faster suffered less injury than the other child. My point was that both children died, only one level of dead that I’m aware of so the end result was the same from the child’s perspective.

Pretty sure the parents, bystanders and anyone else that suffered are not going to care about kinetic energy, terminal velocity of brick shaped objects, BVLOS vs VLOS regulations.

Does anyone believe that the degree of injury, the physics involved or the legal definitions are going to matter if or more likely when some ‘innocent” child gets dinged by an irresponsible drone operator and it gets wide media coverage?

Creating a sub class under 250g doesn’t make sense to me - as it just increases the complexity for no real value.

My opinion - not claiming fact or is that not allowed here?

Your contrived scenario is pointless for the issue you are attempting to discuss.
It's just something you made up.
Your opinion (paraphrased), is that conventional physics cannot be trusted.

Whether or not they used the correct weight for rulemaking, is a different thing.

 

[MS Coast]

In my defence I don‘t believe I said that the child that was struck by the heavier drone going faster suffered less injury than the other child. My point was that both children died, only one level of dead that I’m aware of so the end result was the same from the child’s perspective.

Pretty sure the parents, bystanders and anyone else that suffered are not going to care about kinetic energy, terminal velocity of brick shaped objects, BVLOS vs VLOS regulations.

Does anyone believe that the degree of injury, the physics involved or the legal definitions are going to matter if or more likely when some ‘innocent” child gets dinged by an irresponsible drone operator and it gets wide media coverage?

Creating a sub class under 250g doesn’t make sense to me - as it just increases the complexity for no real value.

My opinion - not claiming fact or is that not allowed here?

The regulations weren't created to deal with the emotions of people in the aftermath of an injury or to deal with the media reporting on an accident.

The weight-based classes are a way to define risk and mitigate risk. They allow less stringent regulation of less potentially dangerous aircraft. That's a good thing. Or would you prefer that every lightweight drone be subjected to the same regulations as the 55-pound aircraft my Part 107 rating allows me to operate?

Regarding post #52, do you maintain that there is not difference in dropping those two balls on your foot? It's not esoteric physics known and understood only by a few people in ivory towers at national research laboratories. It's just common sense. Condemn the 250-gram figure if you like. But you can't suggest that risk is not affected by mass and should be ignored.

 

[Zbip57]

If some kid gets clipped in the head by a Mini 2 going flat out in Sport mode is the worst case medical outcome going to be somehow different than the same kid getting bashed by a “heavier” drone.

Yes, with all others factors held equal (speed, shape, etc), the outcome will almost certainly be different if one object carries more mass than the other.

Nothing in life is without risk. Is a Mini 2 capable of actually killing anyone? It's not completely impossible. Some people may drop dead of a hysterical heart attack from the mere sight of a drone.

Clearly, mass alone is not enough to judge whether an object is safe to fly or not. Many other factors play a role. But it's a MUCH simpler threshold to regulate mass, than kinetic energy.

It's a similar issue with speed limits on roads. Speed alone is an overly-simplistic method for regulating vehicle safety. Obviously a heavily loaded 18-wheeler transport truck is packing hugely more kinetic energy than some little car, yet they're both allowed to travel at the same speeds on our roads. Even a bicycle presents a potentially lethal threat to pedestrians.

At some point, society (and regulators) need to draw a line at which the risk is considered acceptable or non-acceptable, even if that line is not always logical.

If there comes a point where kids are being killed left and right in playgrounds by recklessly flown Mini-2s, there may well be changes to the sub-250g regulations someday. It's not impossible, just highly unlikely.

How many people (or kids) have been killed so far worldwide by any multi-rotor recreational drone weighing between 250g-25kg? 25kg seems much more likely to cause grievous injury, and yet how many times has even that actually happened?

 

[Zbip57]

Back to BVLOS...

I was referring to loss of positioning triggering ATTI mode as an example. Another, perhaps better, example would be loss of video feed, such as when the app crashes.

I'm still trying to wrap my head around this...

A loss of GPS reception, and concurrent loss of VPS, would trigger ATTI mode. In itself, ATTI mode is not an insurmountable problem as the drone is still controllable, it merely lacks the capability to hold position when sticks are centred and it loses any auto-navigational capability. Without GPS it cannot find its way Home in RTH, nor can it report its current location back to the map displayed on the controller.

A loss of video signal, on top of that, would also prevent the pilot from seeing the way home from the drone's perspective.

Therefor, the FAA requires the pilot to "be able" to see the drone at all times, regardless of whether or not a visual observer is standing beside him, since the pilot can then always use his own visual line-of-sight to guide the drone home.

So then what's the purpose of having a visual observer?

The observer is required to provide all of the same visual line-of-sight functions whenever the pilot is "temporarily" looking away from the drone to glance down at his monitor, or even when the pilot is semi-permanently looking away while wearing goggles. Whenever the pilot is not actually looking at the drone, it is the responsibility of the visual observer to monitor the airspace and so he can tell the pilot how to avoid conflicting traffic or obstacles in the way of the drone.

If the GPS and video signals both fail simultaneously, leaving the pilot blind, why couldn't the visual observer continue to perform these exact same visual line-of-sight functions directing the pilot on how to steer the drone?

And, if it's the visual observer's responsibility to perform that function, what difference does it make if he's standing right next to the pilot, or communicating by radio?

 

[sar104]

Back to BVLOS...

I'm still trying to wrap my head around this...

A loss of GPS reception, and concurrent loss of VPS, would trigger ATTI mode. In itself, ATTI mode is not an insurmountable problem as the drone is still controllable, it merely lacks the capability to hold position when sticks are centred and it loses any auto-navigational capability. Without GPS it cannot find its way Home in RTH, nor can it report its current location back to the map displayed on the controller.

A loss of video signal, on top of that, would also prevent the pilot from seeing the way home from the drone's perspective.

Therefor, the FAA requires the pilot to "be able" to see the drone at all times, regardless of whether or not a visual observer is standing beside him, since the pilot can then always use his own visual line-of-sight to guide the drone home.

So then what's the purpose of having a visual observer?

The observer is required to provide all of the same visual line-of-sight functions whenever the pilot is "temporarily" looking away from the drone to glance down at his monitor, or even when the pilot is semi-permanently looking away while wearing goggles. Whenever the pilot is not actually looking at the drone, it is the responsibility of the visual observer to monitor the airspace and so he can tell the pilot how to avoid conflicting traffic or obstacles in the way of the drone.

If the GPS and video signals both fail simultaneously, leaving the pilot blind, why couldn't the visual observer continue to perform these exact same visual line-of-sight functions directing the pilot on how to steer the drone?

And, if it's the visual observer's responsibility to perform that function, what difference does it make if he's standing right next to the pilot, or communicating by radio?

The purpose of the VO is to allow the pilot to do other things, such as video, photography, FPV etc., under conditions where the aircraft is operating normally. The pilot is required to maintain VLOS in case of abnormal conditions requiring direct intervention by the pilot.

 

[Uncle Hoser]

Yeah, nice technology I guess, but the pizza will be really cold by the time you get it!

That's why microwave ovens were invented long before drones!