Lets talk about where you *CAN* fly BVLOS

[MAvic_South_Oz]

A little different in design there, no lightweight box dangling below in the open air.
Larger means ability to contain goods, keep medicines cool, food hot.
There are many designs for drones delivering medicines etc around the World, the most efficient are certainly not drones as we know them to look at.

 

[Zbip57]

Getting back to the original question of where you *can* fly BVLOS... I'm curious to hear what other Canadians have to say about our own Cdn regulations in this respect.

It's been hammered home multiple times on this forum that the FAA does NOT allow BVLOS (without special permissions), and that if you fly FPV while wearing goggles you definitely need a visual observer, and that observer always needs to be "co-located" with the pilot, i.e. standing right beside you. That means, for instance, the observer cannot be stationed a mile away and communicating with the pilot by radio, correct? I haven't actually read all of the FAA's regulations, but that's my understanding from what people have posted in these forums.

Such a strict interpretation has never made any sense to me. Sure, if you want to fly around a tree, the drone briefly passes out of direct line of sight of the pilot, goggles or not. Either way, that's BVLOS according to the FAA.

So if you do need a visual observer to ensure there are no dangers hidden behind that tree out of view of the pilot, wouldn't it make sense to position the visual observer so the observer has a clear view of what's behind the tree? But he's supposed to stay "co-located" with the pilot. So the visual observer is no better able to see what might be hidden behind that tree. Ergo, you can never fly around a tree or any other obstruction that blocks your view.

Our Canadian regulations are nowhere near that strict.

Section 900.01 specifies these definitions:

"visual line-of-sight or VLOS means unaided visual contact at all times with a remotely piloted aircraft that is sufficient to be able to maintain control of the aircraft, know its location, and be able to scan the airspace in which it is operating in order to perform the detect and avoid functions in respect of other aircraft or objects."

Note that it does not require the pilot to be in visual contact, just someone has to be able to see the aircraft with their own eyes without the aid of a telescope or binoculars etc. That someone is the "visual observer" defined as:

"visual observer means a trained crew member who assists the pilot in ensuring the safe conduct of a flight under visual line-of-sight."

So far, so good. Then section 901.11 says:

"901.11 (1) Subject to subsection (2), no pilot shall operate a remotely piloted aircraft system unless the pilot or a visual observer has the aircraft in visual line-of-sight at all times during flight."

Still good. One or the other, either the pilot or the observer, somebody has to keep the aircraft in sight. Subsection (2) provides you'll need a Special Flight Operations Certificate (SFOC) to operate BVLOS without a visual observer, which is what the drone delivery companies must operate under.

Then 901.20 explains the duties of a visual observer like this:

"901.20 (1) No pilot shall operate a remotely piloted aircraft system if visual observers are used to assist the pilot in the provision of detect and avoid functions unless reliable and timely communication is maintained between the pilot and each visual observer during the operation."

"(2) A visual observer shall communicate information to the pilot in a timely manner, during the operation, whenever the visual observer detects conflicting air traffic, hazards to aviation safety or hazards to persons on the surface."

"(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."

"(4) No visual observer shall perform visual observer duties while operating a moving vehicle, vessel or aircraft."

Note that the Canadian regs do not say the observer must be co-located with the pilot, but they must be able to maintain reliable and timely communication to ensure safe operation of the aircraft. This does not prohibit radio communication, as long as it's reliable.

Since it is prohibited to discuss any of the exam questions, let me just say hypothetically, IF an actual exam question were to ask about potential sources of radio interference between a pilot and visual observer, wouldn't that indicate that such radio communication is not prohibited as long as it's reliable?

Anyway, it seems to me, in Canada you *can* fly beyond the visual line of sight of the pilot, as long as you have a visual observer who does have unaided line-of-sight and is in reliable and timely communication with the pilot.

Doesn't that make more sense than the FAA's overly strict requirement for co-location with no radios allowed?

 

[Defens]

Why is that. What would be different then a pizza delivery guy dropping it off at your door?

Kind of joking. Any airborne pizza delivery would need to include an insulated (probably heated) enclosure for the food and likely sufficient battery power for the heater. Without that, you'll get cold pizza and a flock of crows following the drone, looking for a free meal!

 

[MAvic_South_Oz]

you'll get cold pizza and a flock of crows following the drone, looking for a free meal!

Wait until they try fish & chips delivery and the problems with seagulls !

 

[Clintoops]

Unplanned for events like this will always make it hard to operate in this space

Package jacking attempted.
Ravens love to steal food

 

[Jagerbomb52]

All funny comments but I suspect they would do their research before going live. Which is what the Iceland pizza delivery has done.

 

[AnzacJack]

I’m sure these guys did their research. Didn’t stop this incident that could have gone south very quickly

 

[KrowNB]

<Snip> Our Canadian regulations are nowhere near that strict.<Snip>
So far, so good. Then section 901.11 says:
<Snip>

《《Here you specify Canadian requirements for flying a SRPAS beyond VLOS with an observer》》

The provisions of Canadian Aviation Regulation (CAR) Reg 900 applies to all drones, no matter the size.
"900.06 No person shall operate a remotely piloted aircraft system in such a reckless or negligent manner as to endanger or be likely to endanger aviation safety or the safety of any person."

However Reg 901 under Subpart 1 of Division II applies only to Small Remotely Piloted Aircraft Systems (SRPAS), drones weighing from 250 G to 25 Kg.

Sub-250 G microdrones don't fall within the definition of SRPAS therefore aren't regulated by Subpart 1 (Reg 901).

Transport Canada says microdrones "Should" be flown within VLOS but there is no regulation in Canada prohibiting it, it's a strong recommendation only. As long as the microdrone is flown safely and is not a hazard to aircraft, people, or property or in a prohibited area it can legally be flown beyond VLOS. Look at the "Musts" and "Shoulds" under the Microdrone category here: Find your category of drone operation

This is perfectly reasonable considering the small size of a sub-250 G drone. Flown as per Reg 900.6 (above) out over the water or over forests behind your house, for example, the only reasonable foreseeable danger would be to the few ounces of plastic that is the microdrone itself.

 

[Zbip57]

Thanks for the reply. I was beginning to wonder if anyone had even read my post.

You are correct that for sub-250, in Canada, it's not explicitly forbidden to fly BVLOS. You just need to be very careful with the broad coverage of 900.06 "reckless or negligent", as that can be interpreted to mean quite a lot of different things depending on the situation.

《《Here you specify Canadian requirements for flying a SRPAS beyond VLOS with an observer》》

That's the bit that I was more curious about, how it affects 250g-25kg "small" RPAS. Exactly what is meant by "beyond VLOS with an observer".

If I'm reading the regs correctly, it's not actually considered to be "beyond VLOS" if you have an observer. The drone can be flown beyond VLOS of the pilot, as long as the observer can see the drone and is in reliable and timely communication with the pilot. It's only BVLOS if neither can see it.

It's not just when flying while wearing goggles, with a visual observer sitting beside you. That one's obvious.

But it seems that you are allowed to fly your drone out of sight of the pilot, whenever you have an observer stationed where the observer can keep the drone in sight. And the observer and pilot can be in radio communication with each other.

Our Cdn regs permit radio communication and do not require the pilot and observer to be co-located, again keeping in mind the cardinal rule of 900.06. Furthermore, there nothing in our regs to say that you can't have more than one observer.

I don't want to provoke another thread about Ken Heron and Billy, as they obviously had no observers maintaining visual line-of-sight, and it was done in such a public and risky location, etc. But just taking that video as an example, if they had stationed a daisy chain of radio-equipped visual observers spread out along the boardwalk, to ensure there would always be at least one observer keeping the drone in constant sight with reliable and timely communication back to the goggle-wearing pilot, such a long distance flight would appear to meet the conditions for visual line-of-sight under our Cdn regs, correct?

Do the FAA regs actually say an observer must be co-located with the pilot, and that radio communication is prohibited?

Why can't we have consistent world-wide regulations that make sense to everyone?

 

[sar104]

Do the FAA regs actually say an observer must be co-located with the pilot, and that radio communication is prohibited?

Under Part 107 co-location is not required, but at all times the pilot and observer must be able to see the aircraft, so that doesn't buy you BVLOS flights, it just allows the pilot to focus on other things, at least temporarily.

Under the recreational exemption, co-location is explicitly required.

 

[NorthEastJohn]

But are there any actual non-trial drone deliveries happening anywhere?

Yes, I believe Flytrex - Drone Delivery offers food delivery service. Very interesting delivery/detach method. I was always wondering how they would find a safe method for drop and go

 

[MS Coast]

Yes, I believe Flytrex - Drone Delivery offers food delivery service. Very interesting delivery/detach method. I was always wondering how they would find a safe method for drop and go

Rainy day musings. Can't fly.

The delivery/detach method seems problematic to me, given that you're interacting with untrained and unreliable people on the ground who may have bad intentions.

Yes, customers have to register with the service and can be held accountable for damaging the drone. But, I'll bet there will be some who ignore that, grab the drop line, and try to yank the drone out of the air or simply tie it to the railing on the deck and watch while the battery runs down.

The service is apparently in used in several locations. Does anyone know how they're dealing with such concerns?

 

[Mazdaman323lx]

But are there any actual non-trial drone deliveries happening anywhere?

Manna Drone Delivery

Drone delivery made simple

www.manna.aero

Theyre testing in Ireland

 

[Zbip57]

Under Part 107 co-location is not required, but at all times the pilot and observer must be able to see the aircraft, so that doesn't buy you BVLOS flights, it just allows the pilot to focus on other things, at least temporarily.

You can't put "at all times" into the same sentence as "temporarily".

So both the pilot and the observer must "be able" to see the aircraft? In Canada our regs appear to imply that either the pilot or the observer need to be able to see it. "Both" is certainly more restrictive than "either".

And that can still mean different things. I might be looking at my monitor, but I'm still "able" to see my aircraft. As long as it's kept within an unobstructed range where I'm "able" to see it whenever I look up, that doesn't mean I need to actually be looking at it "at all times". But if neither the pilot nor observer can see it, that is obviously beyond VLOS.


Oh man, I looked up the actual wording of Part §107.31, and now I'm even more confused than ever.

§107.31 (a) states that the pilot, observer, and whoever is manipulating the controls, [all three?] must "be able" to see the drone throughout the entire flight.

That seems explicit enough. If any one of those guys at any time is unable to see the drone, then it's no longer VLOS.

§ 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.

That's pretty clear. It says "and". Pilot, observer, and controller must all be able to see the drone.

However, the very next clause then says something entirely different.

(b) Throughout the entire flight of the small unmanned aircraft, the ability described in paragraph (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.

Clause (b) then seems to say the same as our Canadian regulation. One or the other, (pilot or observer), must be able to maintain line-of-sight at any particular moment. It's not required that both always need to see the drone at the same time.

So which is it, (a) or (b)? And why don't (a) and (b) say the same thing?

[...] at all times the pilot and observer must be able to see the aircraft, so that doesn't buy you BVLOS flights,

It is still considered VLOS if at all time either the pilot or observer is able to see the aircraft. It's only BVLOS if both lose sight of the drone, no?

 

[sar104]

You can't put "at all times" into the same sentence as "temporarily".

Yes you can, because they refer to different things. Both the pilot and the VO must be able to see the aircraft at all times. But only one of them must be looking at it at all times, which is what permits the pilot to look away temporarily.

So both the pilot and the observer must "be able" to see the aircraft? In Canada our regs appear to imply that either the pilot or the observer need to be able to see it. "Both" is certainly more restrictive than "either".

Correct. This is basic knowledge under Part 107.

And that can still mean different things. I might be looking at my monitor, but I'm still "able" to see my aircraft. As long as it's kept within an unobstructed range where I'm "able" to see it whenever I look up, that doesn't mean I need to actually be looking at it "at all times". But if neither the pilot nor observer can see it, that is obviously beyond VLOS.

No - it means exactly what it says - they both must be able to see it if they look at it.

Oh man, I looked up the actual wording of Part §107.31, and now I'm even more confused than ever.

§107.31 (a) states that the pilot, observer, and whoever is manipulating the controls, [all three?] must "be able" to see the drone throughout the entire flight.

That seems explicit enough. If any one of those guys at any time is unable to see the drone, then it's no longer VLOS.

No. 107.31 has been debated and explained over and over again. 107.31 (a) says that they must both be able to see it at all times, while 107.31 (b) says that at least one of them must be exercising that ability at all times, i.e. actually watching it. There is no ambiguity here.

That's pretty clear. It says "and". Pilot, observer, and controller must all be able to see the drone.

However, the very next clause then says something entirely different.

Clause (b) then seems to say the same as our Canadian regulation. One or the other, (pilot or observer), must be able to maintain line-of-sight at any particular moment. It's not required that both always need to see the drone at the same time.

So which is it, (a) or (b)? And why don't (a) and (b) say the same thing?

It is still considered VLOS if at all time either the pilot or observer is able to see the aircraft. It's only BVLOS if both lose sight of the drone, no?

The two clauses are completely consistent. And it is BVLOS if either clause is not met - in other words if the pilot cannot see the drone if he looks for it, or if neither the pilot nor the VO are actually looking at it.

 

[Zbip57]

Oh! I see it now. Thanks for clarifying that for me.

"Must be able" is as I understood it. Even though the pilot is temporarily not looking directly at the drone, he still must "be able" to see it whenever he looks up.

So clause (a) means all of them must "be able" to see the drone at all times, even if any one person is temporarily looking away.

Clause (b) then requires that actual visual line-of-sight "must be exercised" by at least one or the other, pilot or observer, at all times.

Okay, that makes more sense now. Phew.

But it remains that our Canadian regulations don't say that. We only insist on the clause (b) portion. Our regulations don't appear to require both to be able to see it at all times. In our case, the drone can be out of visual line-of-sight of the pilot, as long as a visual observer keeps it within sight and can communicate with the pilot.

Or am I reading those wrong as well? Links to the relevant portions of the Cdn regs are in post #22 above.

 

[sar104]

Oh! I see it now. Thanks for clarifying that for me.

"Must be able" is as I understood it. Even though the pilot is temporarily not looking directly at the drone, he still must "be able" to see it whenever he looks up.

So clause (a) means all of them must "be able" to see the drone at all times, even if any one person is temporarily looking away.

Clause (b) then requires that actual visual line-of-sight "must be exercised" by at least one or the other, pilot or observer, at all times.

Okay, that makes more sense now. Phew.

But it remains that our Canadian regulations don't say that. We only insist on the clause (b) portion. Our regulations don't appear to require both to be able to see it at all times. In our case, the drone can be out of visual line-of-sight of the pilot, as long as a visual observer keeps it within sight and can communicate with the pilot.

Or am I reading those wrong as well? Links to the relevant portions of the Cdn regs are in post #22 above.

Yep - you got it.

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.

 

[Meta4]

Yes, I believe Flytrex - Drone Delivery offers food delivery service.

But do they?
Their website suggests checking their ever expanding locations, but doesn't show any.
And you cannot log into their app to see what's there.
Is this just another startup promising more than they can deliver?

 

[Meta4]

Manna Drone Delivery

Drone delivery made simple

www.manna.aero

Theyre testing in Ireland

Testing
There are several of these very limited testing projects, but are there any that have gone beyond that?

 

[KrowNB]

<Snip>

That's the bit that I was more curious about, how it affects 250g-25kg "small" RPAS. Exactly what is meant by "beyond VLOS with an observer".
<Snip>
...if they had stationed a daisy chain of radio-equipped visual observers spread out along the boardwalk, to ensure there would always be at least one observer keeping the drone in constant sight with reliable and timely communication back to the goggle-wearing pilot, such a long distance flight would appear to meet the conditions for visual line-of-sight under our Cdn regs, correct?

Do the FAA regs actually say an observer must be co-located with the pilot, and that radio communication is prohibited?

Why can't we have consistent world-wide regulations that make sense to everyone?

It would seem your "daisy chaining" example may be legal in Canada (I'm not a lawyer), depending upon how a court (if charged) would interpret "reliable and timely communication", ie is radio communication alone, without visual confirmation, reliable. Maybe yes, maybe no. I guess it would depend upon the exact circumstances and how a judge would view it. But there is nothing in our regulations that specifically state that the pilot him/herself have to have constant visual on the aircraft if there is a trained "crew member" that does and is communicating with them. If it doesn't say so then you can't assume it does.

As for consistent world-wide regulations.... I'm glad we're not in Japan where the weight of microdrones has to be below something like 240 G (too lazy to look it up), or in India where maximum flying height is 15 metres (??). I'm also glad we here in Canada are not under FAA rules and regulations as they are much more stringent than ours, especially in regards to sub-250 G drones. Our regs make much more sense, in my opinion. But even then, CAR prohibits an Air 2 or Mavic 3 from flying over treetops of uninhabited forests or to fly over water BVLOS well away from anything that could be harmed. To me (a nobody in the great scheme of things), that just not reasonable. Reg 900 suffices.