Unregulated VLOS

[Crouching Leopard]

As old man mavic said, it's an age old subject.

From a practical standpoint I don't know how anyone can maintain a visual on their drone 100% of the time even if it is technically within the LINE of sight. What does that mean anyway. I can fly out 10,000 feet within the LINE of sight and still not be able to see my drone until it's within 600 feet of me (1600' with strobes). If we're not in an open area, it doesn't take long for you drone to be eclipsed by trees or a building where it would have to be 400' up to see it at all. Trying to stay 100% within the intent of the rule can be quite difficult. If anyone here NEVER flies beyond where you can see it 100% of the time, I don't know who they are.

I can tell you this- IMO (at least for me) the hardest thing to do is fly IFR from your monitor. This is confirmed by the number of crashes into obstacles that I've seen on tape that might have been avoided if seeing the drone directly. I may be extra challenged in using the monitor for space considerations. I marvel at guys that can fly through car windows or train trestle beams or under bridges that only leave 8' of clearance over water and to it all flying IFR. I'd like to be better at that, for sure, but guess I'm too nervous to take chances, even when a disaster only jeopardizes the drone.

 

[Chaosrider]

@Chaosrider ,this subject has been flogged to death on this forum ,and all it will do is inflame some members ,give pleasure to others ,and have no benefit to anyone
if the day ever comes where the VLOS rules are rescinded for everyone, then repost your poll,
and see what answers you get, the rule as it stands is not about restricting peoples ability to fly their drones at distance ,it is purely there from a safety standpoint ,and its up to the individual PIC ,to choose whether or not they follow it to the best of their ability,or disregard it ,and accept the outcome if something goes wrong ,and they end up facing the consequences of their actions

disclaimer
this post is my personal views on the subject of VLOS ,and not intended to offend the OP

I must respectfully disagree.

The issue has certainly been discussed a lot, even in the relatively short time that I've been her. But a lot of the discussion has been unfocussed, and issue that are very different, get conflated.

A lot of people will follow rules just because they are rules, and this is a respectable and long standing philosophy. But it's not the only rational philosophy. I wanted to find out how much of the objection to BVLOS...on this forum, today...is based on beliefs in the importance of following rules, vs how many people think it's actually a good rule.

So far, less than 20% of the people who have voted on this list, today, would fanatically follow VLOS if it wasn't a rule. A relatively small minority. That distribution of opinion isn't always reflected in or discussions on the issue.

I don't expect BVLOS to become available to everyone. I do think it will become available to J Random Citizens, non-commercially, with an appropriate level of training and experience, and an appropriately equipped aircraft. Just like the instrument rating is today. And that's a good thing.

Statistically, in the vast majority of low population, low traffic density areas, the VLOS requirement adds virtually nothing to safety, in large part because outside of truly trivial distances, the "added situational awareness" that it "provides", is largely an illusion. The fact that it *might* make a difference is irrelevant for risk mitigation. The right question is, what are the odds that it will make a significant difference? And the answer is, imperceptibly small.

Respectfully, I don't think these aspects of the topic have been "flogged to death" at all. Quite the contrary.

Thx,

TCS

 

[old man mavic]

@Chaosrider ,with respect ,what difference will anyone's,opinion on VLOS make
the rule is there ,and as i said before ,whether you choose to follow it or not ,is up to the individual pilot
we can debate about the subject till the cows come home ,but nothing will be achieved from it
it is a very emotive subject that as i have already stated has been around for ages

 

[Chaosrider]

Trying to stay 100% within the intent of the rule can be quite difficult.

As is frequently the case with new laws/regs, the intent of the rule is frequently not the same as the text of the rule. The text is available immediately upon passage. The intent is generally revealed through a combination of enforcement, and case law. In some very broad sense, the intent of the VLOS rule is safety. But the (evolving) understanding of the intent is mostly revealed by the failure of the FAA to enforce VLOS, except in cases of egregious violations. A sensible risk mitigation strategy on their part: only pay attention to the cases that might really matter from a safety standpoint. And most don't.

I can tell you this- IMO (at least for me) the hardest thing to do is fly IFR from your monitor. This is confirmed by the number of crashes into obstacles that I've seen on tape

I agree. Flying IFR on your monitor is harder, and requires more attention, and more skill. Just like the instrument rating for fixed wing pilots. However, in my (infamous?) tree crash video, I was flying hard VLOS the entire time. There was no way I would have tried to do that BVLOS with my current aircraft (Mini-2), and my current experience level. As it was, I pushed a little too far, but that was a known risk for which I was prepared and insured.

I marvel at guys that can fly through car windows or train trestle beams or under bridges that only leave 8' of clearance over water and to it all flying IFR.

Me too. I'm nowhere near good enough to do that yet. But I will be!



Thx,

TCS

 

[Chaosrider]

@Chaosrider, I get the impression that the thinking behind many your threads is that you think that rules designed to protect others or that are an attempt to ensure their safety, infringe your personal freedoms.

Am I wrong?

Of course they do. And some restrictions on personal freedom are required to make society function. For example, driving a car while intoxicated is illegal. That's a rule that I agree with and follow.

The real question is, what restrictions on personal freedom are reasonable?

There's an arcane concept in economics called externalities. An externality, broadly speaking, is an impact of something you do, that impacts someone other than you. Externalities can be positive or negative. Restrictions on personal freedom to prevent/mitigate negative externalities imposed on others...non-trivial externalities... are the only justified government restrictions, IMNSHO.

Returning to the driving a car example, banning driving while intoxicated is a reasonable restriction on personal freedom, because it reduces the imposition of a negative externality...increased risk...on others. There's a weak statistical argument to be made that smoking cigarettes while driving also imposes risk on others, but the increased risk is so trivial that banning smoking while driving would *NOT* be reasonable, and it isn't banned for exactly that reason.

You've triggered me to think of an additional requirement that should be imposed for flying BVLOS...liability insurance. All states require it for driving a car, and I have insurance for my drone flying, as I'm sure many on this forum do. Legally, drone liability insurance is optional. It should be required to fly BVLOS legally.

Thx!!



TCS

 

[vindibona1]

The reason for rules and laws is, for the most part, because common sense isn't so common. Unfortunately when government steps in they don't have the ability to identify the different needs of different areas. They often unnecessarily approach issues with a chain saw rather than a scalpel "for the children" (hope y'all get the sarcasm). Aviation is a unique situation because it knows no boundaries and is a three dimensional situation where most other activities are more or less two-dimensional. For the most part the FAA rules do what they are intended to do, but could use some common sense tweaking.

Not to get too far afield, but I think we as citizens need to, to the best of our ability, try to make sure that governmental rules and regulations are common sense, but more importantly DO WHAT THEY ARE INTENDED TO DO, while maximizing personal freedom- a concept that seems to have gotten lost as if we can reduce risk to zero which we often foolishly attempt to do, introducing other unwanted consequences. JMO

 

[Chaosrider]

My point is, beyond the point of the value of personal freedom, is that the OP is from a place where he is only minutes from the middle of nowhere. Perhaps his intent is to examine how strict one must follow the rule of VLOS in the middle of nowhere? I don't know. But I think I made my point.

You made your point indeed sir, and made it well!

My main point isn't so much whether the VLOS rule should be followed. If you agree with a rule (like I do with drunk driving rules), then you just follow the rule because you think it's a good idea. Some people believe that rules should be followed just because they are rules. In this context, you might consider a rule, to be an order...

But if you don't think a rule is a good idea, and you don't believe in following all rules (orders) just because they are rules, then the most sensible way to decide which rules to follow is with the expected net value of a violation. If you're going to violate a rule, you do it to get something you want. What are the odds that you'll get caught, and if you are caught, how severe is the likely punishment?

If the value that you expect to get from the violation of a rule is greater than the expected cost of violating the rule, then you should violate the rule. This doesn't apply to people who believe that rules should be followed just because they are rules.

My larger interest is to see if we can come to some kind of identifiable consensus (not unanimous agreement) about what a reasonable BVLOS rule should look like. Based on the poll results so far we mostly (80+%) agree that strict 100% VLOS compliance is not a reasonable expectation for the right answer.

The harder and more important question is, what is a reasonable expectation, as defined by a non-unanimous consensus which I hope we can form?

I think I accidentally took an extra "longwindedness" pill this morning...

;-)

TCS

 

[Deleted member 103366]

Whereas, from the same data, I would conclude that 62.3% try to fly within VLOS but are not too worried about minor BVLOS incidents and thereby 62.3% think that VLOS is sensible.

 

[vindibona1]

But if you don't think a rule is a good idea, and you don't believe in following all rules (orders) just because they are rules, then the most sensible way to decide which rules to follow is with the expected net value of a violation. If you're going to violate a rule, you do it to get something you want. What are the odds that you'll get caught, and if you are caught, how severe is the likely punishment?

I think I accidentally took an extra "longwindedness" pill this morning...

I too plead mea culpa on verbosity (is that a word?).

We have devolved into a society where today laws don't even matter if you get caught, but if there are consequences. Examples are on display at every level of society. Plenty of chaos to ride these days. We need to clean up our act and I call on our leaders to truly lead if we are to have faith in the law.

 

[Chaosrider]

Believe it or not (I don't believe it), more than a few people here claim they never speed or, if they do it accidentally, they immediately slow down.

Ah, but suppose some people actually do never speed, or instantly slow down. That's not a bad thing. It would just suggest a different mindset than you and I have, a different view of what's important in the world.

Yes?

Thx,

TCS

 

[vindibona1]

Whereas, from the same data, I would conclude that 62.3% try to fly within VLOS but are not too worried about minor BVLOS incidents and thereby 62.3% think that VLOS is sensible.

I don't think that is necessarily an accurate conclusion. What that data does say is that 62.3% try to observe the law, not necessarily that the law is sensible. What I mean by that is that there are frequently instances when, from a safety standpoint, or any other standpoint for that matter (except altitude for obvious reasons) the regulation of VLOS does not merit strict obedience.

 

[Deleted member 103366]

not necessarily that the law is sensible

Fair enough but the same argument apples to "Based on the poll results so far we mostly (80+%) agree that strict 100% VLOS compliance is not a reasonable expectation for the right answer."
I.e. conclusion as to whether OR NOT people think VLOS is a reasonable constraint can not be drawn from the results of the poll.

Do you agree?

 

[vindibona1]

Fair enough but the same argument apples to "Based on the poll results so far we mostly (80+%) agree that strict 100% VLOS compliance is not a reasonable expectation for the right answer."
I.e. conclusion as to whether OR NOT people think VLOS is a reasonable constraint can not be drawn from the results of the poll.

Do you agree?

I’m not sure I fully understand the question, but I would say 100% compliance 100% of the time is an unreasonable expectation.

 

[Chaosrider]

There are way too many laws in general in many developed countries

Here here!

Certainly true in the US.

At least we allow a fair amount of state variation, but there are way, way too many laws at the federal level. Like a factor of 10 too many.

Thx,

TCS

 

[Deleted member 103366]

I’m not sure I fully understand the question,

My conclusion was that the majority of the poll's voters think that VLOS was sensible.
As you pointed out that may be flawed.
However my understanding of the sentence I quoted is that Chaosrider is suggesting that 80+% of the poll's voters think that VLOS is not a sensible constraint.
If it is incorrect for me to conclude that the majority of the voters think VLOS is sensible, then it is equally incorrect fo Chaosrider to conclude that 80+% of the voters think VLOS is not a sensible constraint.
I was asking if you would agree with the latter.
.

 

[eEridani]

VLOS is a sensible rule.

It doesn't make sense to fly your drone around when and where you can't see what it might hit.

Anyone who disagrees with this basic premise is being reckless; and saying a 100 degree camera view port is acceptable for safety doubles down on the recklessness aspect.

Sure, flying BVLOS and not having an accident happens, but it is 100% luck that something doesn't rise up to ruin the day. For example, driving fast: there are no good statistics for accidents caused by reckless drivers: the folks that are passed who are startled and panic and careen into the car beside them after the speedster went by, or who were run off the road when the guy passed on the shoulder. So this "I didn't hit no one!" excuse isn't valid. Reckless is reckless.

 

[DoomMeister]

How do these drone deliveries work as I know that is all beyond VLOS.

Drone delivery is under CFR 14 Part 135 and not under Part 107 although a waiver is needed to bypass 107.31.

https://www.faa.gov/uas/advanced_operations/package_delivery_drone/

 

[BigAl07]

Drone delivery is under CFR 14 Part 135 and not under Part 107 although a waiver is needed to bypass 107.31.

https://www.faa.gov/uas/advanced_operations/package_delivery_drone/

If they are flying under Part 135 they won't need a waiver under Part 107. I don't think they can combine those at any time. It's one way or the other unless I totally missed that in the interpretation.

 

[DoomMeister]

If they are flying under Part 135 they won't need a waiver under Part 107. I don't think they can combine those at any time. It's one way or the other unless I totally missed that in the interpretation.

I haven’t done a full read of Part 135 so is BVLOS covered, thus negating need of the waiver?

 

[BigAl07]

I haven’t done a full read of Part 135 so is BVLOS covered, thus negating need of the waiver?

It's currently being "Tweaked" for full UAS operations and I've not had a deep dive into it yet. I'd imagine it will have to have a BVLOS component for it to even be viable going forward.