Need Night Waiver Follow Up Question Help

[dolez]

I recently applied for a night waiver and got the following follow up question:


Describe how the RPIC will see and avoid other aircraft, people on the ground, and ground-based structures and obstacles during darkness.

Your application covered some of this guideline, but appeared to omit the need to see and avoid unmanned aircraft, as well as manned. Please readdress the following elements of this guideline and include "unmanned" aircraft as you describe in detail, "how" and "what" you will be doing to see and avoid other aircraft, people on the ground, and ground-based structures and obstacles during darkness.



My waiver included the following,


How will the PIC and/or VO locate other persons, aircraft, obstacles, and structures in the dark?

When possible, missions will include a daylight scouting of the operational flight area for obstacles as well as a launch and recovery area. All VOs will be advised to be vigilant while scouting the skies and ground during mission for manned aircraft, people, structures and vehicles.

What will they do if other persons/aircraft are located during flight?

If manned aircraft approaches, PIC will immediately be informed. PIC will verbally confirm notification. PIC will put the sUAS into a stationary hover and if possible, Navigation lights on the aircraft will be used to determine direction of travel. If no threat is determined, operation will continue with special attention given to the spotted aircraft.If aircraft altitude and direction cannot be determined in a safe amount of time, PIC will lower aircraft as quickly and safely as possible. If needed, PIC will return sUAS to launch area. As a last resort, PIC will institute an emergency flight termination procedure over a predetermined safe area. This will only be used as an emergency last resort due to the PIC losing all control of the sUAS at that point. In the event a non-participatory person or vehicle gets close to, or enters into the flight area, the same VO/PIC notification and confirmation procedure will be performed as above. The PIC will hover the sUAS. The sUAS will be directed to land if any safety situation exists and return procedures will be performed, with the added safety precaution of keeping the sUAS from flying over, or too close to, other people or vehicles.

How will they avoid hitting obstacles/structures during flight?
Daylight scouting and knowledge of the area will be the primary method to avoid hazards. If necessary, PIC or VO will use flashlights, or any other means, to illuminate any obstacles when the sUAS reaches a predetermined distance from said object. All launching and landing zones will be sufficiently lit to maintain a safe area for operations.

If flight operations occur in an area with lighting sufficient for the PIC and VO to see the sUAS and other obstacles, persons, and aircraft, how will they determine the lighting is sufficient before flight?

PIC and VO will use identifiers such as color and distance between members to verify sufficient lighting. If safety is as concern of any crew member on sufficient lighting, additional lighting will be used as described above.


My question is the this, the simpleton in me says to changed manned to "manned or unmanned" and resubmit. However, I feel like they are looking for more than that. Any thoughts on how I can improve the above before submission??

Any help is apprecaited!

 

[smaliden2]

I WILL START BY SAYING DO NOT COPY AND PASTE! MAKE IT YOUR OWN DEPENDING ON YOUR EQUIPMENT.

I was sent almost the exact same letter when I applied for my night waiver. The following is a COPY of what I sent back to the FAA and the next morning my waiver was approved!

1. Description: The proposed operation would be for night photography and after gaining a large amount of night experience would eventually like to move into SAR Operations. This waiver would allow me and at least 1 visual observer to fly at night for the purpose of night photography.
2. Safety: In Classed Airspace I would attempt to ensure the local tower is aware. I would provide my location and approximate distance from the Airport center and in which direction I am from center. In the event of a flyaway, I will have communications established with the VO via cell phone or walkie talkie and would immediately dispatch the VO and other assistants if available to keep eyes on the SUAS and if possible to follow on foot or in a vehicle. If in classed airspace I would notify the airport control tower of the flyaway and if necessary the local authorities. I will fly a preplanned path via GPS waypoints. Prior to the night flight, this preplanned path will be flown in the daytime to check for obstructions or hazards that we may not be able to see at night. I will not fly over people in the open and through the daytime flight I will establish a safe altitude to fly that will allow safe clearances from any and all obstacles along the path. To ensure VLOS can be maintained, I have my SUAS outfitted with 4 "ARC" Cree Professional Series Strobe lights. It features 4 Cree lights in one unit with 3 lighting modes, Strobe, Flash, and a fixed (solid) mode. I have 4 of these lights installed on the SUAS 2 White, 1 Red, and 1 Green. Green (fixed) on the right leg, red (fixed) on the left leg, and 2 white (strobe), 1 on each back leg for 360° visibility. This should be more than adequate to satisfy FAA 107.29 compliant lights for night flights. The CREE bulbs give it clear visibility well in excess of the FAA 107 requirement for night flights (3+ SM Miles) and greatly helps in maintaining VLOS while in flight for the RPIC or a nearby manned aircraft pilot. There will be no close calls as I will yield and if necessary land in a predetermined area to avoid any and all manned aircraft. It features a 250 mhr battery rechargeable battery which provides approx 6 hours of run time in strobe mode and at least 4 hours in fixed mode.
3. Visual illusions: I am an active private pilot and have studied how to recognize and overcome visual illusions caused by darkness and understand physiological conditions which may degrade night vision. Although I have studied this previously, I have signed up for an online course on this topic and have passed the course with 100% score just to be on the side of safety. I am working on creating a 20 question test from the Pilots Handbook Of Aeronautical knowledge (FAA-H-8083-25B) similar to the online test I took. I will give this test to the VO as well as discuss and deficiencies once the test is completed. I will administer, grade, and retain a copy of the test for the duration of the operation / night waiver.

 

[dolez]

I got approved! Here was my follow up for their question for anyone who needs assistance in the future!


How will the PIC and/or VO locate other persons, aircraft, obstacles, and structures in the dark?

Locating other persons, aircraft, obstacles and structures will use a combination of procedures to fly safely. When possible, missions will include a daylight scouting of the operational flight area no more than 48 hours prior to mission launch. The area will be scouted for obstacles, a primary safe launch and recovery area, an alternate launch/recovery area as well as an emergency landing area, all of which will be documented. If the mission does not afford the ability for a daylight scout, aeronautical charts, online mapping systems such as Google maps, as well as any other means will be used to scout the area and locate potential obstacles prior to flight.
Prior to the start of the mission, VOs and PIC will allow their eyes to adjust to the darkness. This includes reducing the brightness of any screens and reducing or removing any other bright lights where possible. The landing area will also be marked with low intensity lights prior to flight. VOs, if not with the PIC, will maintain contact throughout the flight either by VHF radio or cell phone communication.
Using the techniques taught during training, VOs will scan the skies for navigational lighting, (red/left wing, green/right wing, white/rear of aircraft) , anti collision strobe (flashing white) as well as the addition of people and unknown vehicles into the flight area. VOs will maintain a safe landing zone at all times for the mission by keeping other people and vehicles at a safe distance. If during the operation, the sUAS will need to come close to a structure or object, an additional VO may be used to provide the PIC additional perspective.
All VOs will be advised to be vigilant while scouting the skies and ground during the mission for manned and unmanned aircraft, people, structures and vehicles. A sUAS equipped with forward looking infrared (FLIR) will also be utilized when possible to increase safety of the operation with the ability to see obstacles in darkness.


What will they do if other persons/aircraft are located during flight?

If any manned or unmanned aircraft approaches, PIC will immediately be informed by VOs. PIC will verbally confirm notification. PIC will immediately put the sUAS into a stationary hover and using the navigation lights of the unknown aircraft, the aircraft will be watched to determine direction of travel. If no threat is determined, operation will continue with special attention given to the spotted aircraft. If aircraft altitude and direction cannot be determined in a safe amount of time, PIC will move and lower the sUAS as quickly and safely as possible away from the unknown aircraft. If needed, PIC will safely return sUAS to launch area. As a last resort, PIC will institute an emergency flight termination procedure over a predetermined safe area. This will only be used as an emergency last resort due to the PIC losing all control of the sUAS at that point. In the event a non-participatory person or vehicle gets close to, or enters into the flight area, the same VO/PIC notification and confirmation procedure will be performed as above. The PIC will first place the sUAS into a hover. The sUAS will be directed to land if any safety situation exists and return procedures will be performed, with the added safety precaution of keeping the sUAS from flying over, or too close to, other people or vehicles.

 

[smaliden2]

Awesome im glad you got it done!!!