Question about FAA Advisory Circular AC91-57C regarding VLOS

[brett8883]

No worries. In that respect, the rules are identical in both cases.

It is kinda interesting that the two VLOS rules as written don’t conflict with each other at all. The only differences come from what is specified in one rule but not specified in the other.

 

[NightFlightAlright]

“must coordinate to do the following:”

Means that at least one of the enumerated persons has direct visual contact, in a coordinated effort to ensure the RPIC and PMFC maintain situational awareness at all times.

The VO telling the RPIC that the drone is 10 feet above the high voltage line they are inspecting is providing the RPIC with information to maintain situational awareness, even if the RPIC does not have direct sight at that instance.

107.33 (b) clearly enumerates only the VO as having to have visual contact.
(a) and (c) provides that situational awareness shall be maintained through coordinated communication.

 

[Vic Moss]

No worries. In that respect, the rules are identical in both cases.

The rules are similar. The major difference being the use of VOs. For 44809, the VO must be "co-located". Under 107.33(a), the VO and RPIC "must maintain effective communication with each other at all times."

So they can actually communicate via radio if warranted. They do both have to maintain the ability for VLOS though.

 

[swadrvr]

That's a good comparison. When driving a car I don't take my eyes of the road for more than a second or two. What do you think a good rule of thumb would be for a drone, in terms of how long you could safely look away?

The rule is written exactly this way (for once on rare occasion by the Feds) to use common sense. They understand a drone pilot needs to look at their RC AND want you to keep your drone within sight as you look back up. There is no “time period”. The meat and potatoes of the rule is actually quit clear, keep your drone within visual sight while in flight, unless your 107 AND have applied for and received an exemption (waiver) for a specific flight, in writing by the Feds to deviate from the rule.

 

[Vic Moss]

The meat and potatoes of the rule is actually quit clear, keep your drone within visual sight while in flight, unless your 107 AND have applied for and received an exemption (waiver) for a specific flight, in writing by the Feds to deviate from the rule.

Waivers aren't really for specific flights any more. Some are, but most are 3 year waivers for most airspace.

For instance I'm allowed to use mine in any airspace "not closer than 5 NM from an airport during the operation". And it's good until 12/31/26.

 

[MA2 317]

I posted this in 2018 on the Spark Pilots Forum...

An excerpt from the document...5.7, The paragraph before 5.7.1

"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."

I got it from the FAA which now has a dead link to this document.


Is this wording still valid?

.

 

[dart106]

Question: The wording says you must "be able to see the UA" and it doesn't say you must continuously see the UA. Is this ambiguous? Being "able to see" means you could look away for periods of time, such as looking at your RC, so long as you could look up and see the UA if you wanted to. Am I understanding this correctly? Or must you continuously have eyes directly on the drone without looking away, in which case, how could you ever look at your RC?

If you can look away, is there guidance on for how long you can look away? For how much of your flight could you be looking at your RC and not the drone, so long as you are still "able to see" the drone if you wanted to? Could you fly the whole flight looking at your RC, so long as you are "able to see" the drone if you want to?

It appears you’re over thinking it. The obvious word would be “continuous”. Since that is missing in the wording, “be able to see….” logically suggests a glance back and forth is acceptable. The feds make wording hard enough to understand as it is. Overthinking it will only make one’s head hurt.

 

[PepperBird]

Question: The wording says you must "be able to see the UA" and it doesn't say you must continuously see the UA. Is this ambiguous? Being "able to see" means you could look away for periods of time, such as looking at your RC, so long as you could look up and see the UA if you wanted to. Am I understanding this correctly? Or must you continuously have eyes directly on the drone without looking away, in which case, how could you ever look at your RC?

If you can look away, is there guidance on for how long you can look away? For how much of your flight could you be looking at your RC and not the drone, so long as you are still "able to see" the drone if you wanted to? Could you fly the whole flight looking at your RC, so long as you are "able to see" the drone if you want to?

You missed this part "throughout the entire flight"

 

[Dangerly]

You missed this part "throughout the entire flight"

I got that part. I was asking about whether "being able to see" means you have the ability to see, or that you must continuously see. After reading other replies I now believe it means you must continuously see, with reasonable short breaks for operational safety.

 

[Dmcvey]

My experience is trying to acquire the aircraft after looking down briefly. It may only be 500 feet away, hovering over a roof against a gray sky. Visually trying get my eyes to focus and acquire the target takes a bit. Push that out to 1500-2000 feet and it becomes difficult to reacquire.

 

[brett8883]

I posted this in 2018 on the Spark Pilots Forum...

An excerpt from the document...5.7, The paragraph before 5.7.1

"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."

I got it from the FAA which now has a dead link to this document.


Is this wording still valid?

.

They cut out the part that explicitly allows you to intentionally lose VLOS for operational necessity. Everything else is the same.

https://www.faa.gov/documentLibrary/media/Advisory_Circular/Editorial_Update_AC_107-2A.pdf

 

[KJC Imaging]

Question: The wording says you must "be able to see the UA" and it doesn't say you must continuously see the UA. Is this ambiguous? Being "able to see" means you could look away for periods of time, such as looking at your RC, so long as you could look up and see the UA if you wanted to. Am I understanding this correctly? Or must you continuously have eyes directly on the drone without looking away, in which case, how could you ever look at your RC?

If you can look away, is there guidance on for how long you can look away? For how much of your flight could you be looking at your RC and not the drone, so long as you are still "able to see" the drone if you wanted to? Could you fly the whole flight looking at your RC, so long as you are "able to see" the drone if you want to?

I like the way the FAA frames its rules, because they understand that they can’t and shouldn’t prescribe narrow or over-specific limitations which could never account for all situations. Instead they decide their goals and compose regulations to facilitate those goals. Consider the intent of the rules. There are two primary risks the FAA want to mitigate, namely, collision with another aircraft or object, and injury to people. Maintaining VLOS is primarily about avoiding mid air collision, but it is also applicable to avoiding hitting things and people on the ground, depending on the circumstances at the time.

So to your question. Let’s say you want to positioned your sUAS. Whilst moving to that position, how can you maximize your SA? Would it be entirely from looking directly at the drone, entirely from looking at the video feed, or some combination? Typically I expect you’d get most SA from looking at the drone, scanning around it and listening for aircraft, with quick glances at the controller to monitor range, altitude and battery.

Now once you are positioned where you want to be, you will probably want to be looking more at your controller to get the information you want (photos, video, etc). But what happens to your SA during this heads down time? It drops off. That’s why you want a VO with their eyes in the drone, scanning around for other aircraft, people on the ground under the drone, or whatever risk factors are in play.

The pilot at the controls should be able to look up and see the drone immediately at any point. He should have a plan for what ti do if suddenly a low flying helicopter or something approaches.

The rules don’t specify too much, and that is how they delegate responsibility for safe flight to pilots. The thought of not being able to see your drone and the airspace around it should be very uncomfortable for a pilot of a sUAS. If it isn’t an uncomfortable thought then the pilot most likely doesn’t understand their responsibilities.

I don’t watch my drone continuously, but I hope I have very good SA on other aircraft and people below the drone. I can see it if I look up. I have FlightRadar24 filtering ADSB from aircraft below 1000’ within 3 miles. I am listening to ATC on an airband receiver if there’s one nearby that can add to my SA.

 

[New England Droning]

If that were true, it would be impossible to fly FPV drones legally.

that is not true, it just means we can't fly it more than 500-1,000 ft away. If you realize that you can't see it then you should come back till you have VLOS again and then you can go out till you lose it and then you come back again... All these people with distance tests are just violating the rules. I bend them in this area and if I lose it I come back... eventually. Be responsible and it will be legal.