VLOS 107.31 Personal story

[Deleted member 94307]

I think it’s good that they are vague on vlos . Don’t complain about it. If someone is flying under 400ft and goes out of vlos it’s far less dangerous than flying in the airspace of any class airport..

BUT the silly thing about any of this is that they don’t enforce and can’t really.

IF THEY LET US FLY IN PARKS (not over people) the Rangers could check in us. They have the time to do it .. maybe certain hours sunrise to 7am for instance.

 

[Deleted member 94307]

Only dangerous scenario I can think of is a helicopter rescue from traffic accident or coast guard flying low for rescue but you are supposed to stay away from emergencies and you can look up coast guard activity and MOA before flying.. even if you can see your drone those situations can be dangerous.

I admit before strobes I had flown over the bay at 40 feet out of vlos.

 

[Mavic Maveric]

Your chances of getting a VLOS waiver are very remote. We get them via the SGI process for search and rescue operations, and the waivers come with a TFR to protect air traffic. No VLOS waiver without a TFR, and they are not likely to let you have a TFR.

Yep, I've already been told. Darn. Never hurts to try. Funny thing is, I like the process as much as the outcome.
Thanks for your reply. Have a great day.
MM

 

[Mavic Maveric]

Here is what Advisory Circular AC-107-2 says
5.7.2.2 To make this communication possible, the remote PIC, person manipulating the controls, and VO must work out a method of effective communication, which does not create a distraction and allows them to understand each other. The communication method must be determined prior to operation. This effective communication requirement would permit the use of communication-assisting devices, such as a hand-held radio, to facilitate communication from a distance. AC 107-2 - Small Unmanned Aircraft Systems (sUAS) – Document Information
So...it appears that you can use radios with a VO on a Part 107 flight.

The new recreational exceptions, to be officially published in the Federal Register tomorrow, May 17, Public Inspection: Exception for Limited Recreational Operations of Unmanned Aircraft, states this:
3.The aircraft is flown within the visual line of sight of the person operating the aircraft or a visual observer co-located and in direct communication with the operator.

Wait! Really?? Holy cow!! I will delve into the this. Thank you so much!!!

 

[Mavic Maveric]

Wait! Really?? Holy cow!! I will delve into the this. Thank you so much!!!

PS: The FAA helpdesk said that I couldn't and that my VO must be next to me. Maybe he was going by older rules? Thanks again!

 

[BigAl07]

Here is what Advisory Circular AC-107-2 says
5.7.2.2 To make this communication possible, the remote PIC, person manipulating the controls, and VO must work out a method of effective communication, which does not create a distraction and allows them to understand each other. The communication method must be determined prior to operation. This effective communication requirement would permit the use of communication-assisting devices, such as a hand-held radio, to facilitate communication from a distance. AC 107-2 - Small Unmanned Aircraft Systems (sUAS) – Document Information
So...it appears that you can use radios with a VO on a Part 107 flight.

No this allows you to use Radio Comms for "additional" VO's who are not the ones standing next to the RPIC who IS able to assist with VLOS momentarirly while the RPIC looks away from the aircraft. You can utilize more than a single VO but the primary VO (the one who might assume VLOS) but be positioned next to the RPIC and not relying on "technology" for communications. Other VO's (for situational awareness etc) who are not positioned next to RPIC can utilize Radio Comms.

When we are setting up to do Night Flights at events we have used 3 & 4 different VO's to help maintain safety and situational awareness. All the remote VO's talking back to my Primary VO via handheld and my VO talking directly to me verbally.

PS: The FAA helpdesk said that I couldn't and that my VO must be next to me. Maybe he was going by older rules? Thanks again!

No he was going by BOTH rules as they have not changed. What has happened is the "Guidelines" for hobby have been codified into LAW and are now fully enforceable across the board. On the flip side for Part 107 operations you have been given "clarification" on the existing laws concerning VO operations.

You have a firm and accurate understanding of the laws for VO so don't let others steer your into doubting what you already know. The FSDO is the source for your information and everything else is just chatter. I commend you for going directly to your FSDO. That's how this works in the real world.

 

[Mavic Maveric]

Wait! Really?? Holy cow!! I will delve into the this. Thank you so much!!!

It's official. You are absolutely right! The FAA guy was wrong. I CAN use a VO at a place away from me for Part 107 operations and for recreational flying. The PIC and VO do not need to be next to each other and 2 way radios are perfectly acceptable.

Read for yourself: https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_107-2.pdf

5.7.2 VO. The use of a VO is optional. The remote PIC may choose to use a VO to supplement situational awareness and VLOS. Although the remote PIC and person manipulating the controls must maintain the capability to see the UA, using one or more VOs allows the remote PIC and person manipulating the controls to conduct other mission-critical duties (such as checking displays) while still ensuring situational awareness of the UA. The VO must be able to effectively communicate: • The small UA location, attitude, altitude, and direction of flight; • The position of other aircraft or hazards in the airspace; and • The determination that the UA does not endanger the life or property of another. 5.7.2.1 To ensure that the VO can carry out his or her duties, the remote PIC must ensure that the VO is positioned in a location where he or she is able to see the small UA sufficiently to maintain VLOS. The remote PIC can do this by specifying the location of the VO. The FAA also requires that the remote PIC and VO coordinate to 1) scan the airspace where the small UA is operating for any potential collision hazard, and 2) maintain awareness of the position of the small UA through direct visual observation. This would be accomplished by the VO maintaining visual contact with the small UA and the surrounding airspace, and then communicating to the remote PIC and person manipulating the controls the flight status of the small UA and any hazards which may enter the area of operation, so that the remote PIC or person manipulating the controls can take appropriate action. 5.7.2.2 To make this communication possible, the remote PIC, person manipulating the controls, and VO must work out a method of effective communication, which does not create a distraction and allows them to understand each other. The communication method must be determined prior to operation. This effective communication requirement would permit the use of communication-assisting devices, such as a hand-held radio, to facilitate communication from a distance.

 

[BigAl07]

^^^ SMH!

You are taking it out of context!!! You, the RPIC (or if you have someone flying for you manipulating the controls) has to be able to see the aircraft the entire flight. Adding the VO away from you does not alleviate that very first portion of the regulations:

5.7.2 VO. The use of a VO is optional. The remote PIC may choose to use a VO to supplement situational awareness and VLOS. Although the remote PIC and person manipulating the controls must maintain the capability to see the UA, using one or more VOs allows the remote PIC and person manipulating the controls to conduct other mission-critical duties (such as checking displays) while still ensuring situational awareness of the UA.

You can use a VO away from you (to enhance SituA) but only a VO stationed within talking distance can assume (temporarily) the VLOS for the RPIC.

You got the official break down yourself from the FSDO and now you're trying to back peddle and say the official ruling was wrong?? Come man you're much more intelligent than that.

 

[BigAl07]

This topic has been debated and PROVEN from the FSDO. I'm convinced that regardless of the "Official" evidence etc that member will continue to argue and try to swing the law their way.

It's been stated time and time again what the law states (in it's entirety) what is requred and allowed. I don't think anything I say is going to make a difference one way or another.

I hope you fly safe and have no incidences going forward.

Sincerely,
Allen

 

[ac0j]

It's official. You are absolutely right! The FAA guy was wrong. I CAN use a VO at a place away from me for Part 107 operations and for recreational flying. The PIC and VO do not need to be next to each other and 2 way radios are perfectly acceptable.

There is no allowance for VO in recreational use. Maybe if you you hold your mouth right, you could read that a part 107 can use a VO in lieu of keeping VLOS, but that is NOT how I read it.

 

[Mavic Maveric]

There is no allowance for VO in recreational use. Maybe if you you hold your mouth right, you could read that a part 107 can use a VO in lieu of keeping VLOS, but that is NOT how I read it.

No allowance for VO in recreational use? Read this. How can I misread that? I underlined it so that you can read it, and you DON"T need to hold your mouth just right.

Please explain to me what Co-located means to you? In direct communication can mean 2 way radios. To me this is black and white.

DEPARTMENT OF TRANSPORTATION
Federal Aviation Administration
[Docket No. FAA–2019–0364]
Exception for Limited Recreational
Operations of Unmanned Aircraft
AGENCY: Federal Aviation
Administration (FAA), Department of
Transportation (DOT).
ACTION: Notice implementing the
exception for limited recreational
operations of unmanned aircraft.
In this document, you will see Visual Observer:

Fly only for recreational purposes
• Keep your unmanned aircraft within
your visual line-of-sight or within the
visual line of sight of a visual observer
who is co-located and in direct
communication with you

 

[Keule]

what Co-located means to you? In direct communication can mean 2 way radios.

You should quote the whole paragraph:

3. The aircraft is flown within the
visual line of sight of the person operating the aircraft
or a visual observer co-located and in direct communication with the operator.
Either the person manipulating the controls of the recreational unmanned aircraft or a visual observer, who is near the operator and able to communicate verbally, must have eyes on the aircraft at all times to ensure the unmanned aircraft is not a collision hazard to other aircraft or people on the ground. Using a visual observer generally is optional, but a visual observer is required for first-person view (FPV) operations, which allow a view from an onboard camera but limit the operator’s ability to scan the surrounding airspace

That sounds as the VO has to be close range to the PIC and communicate verbally (by mouth)

 

[Mavic Maveric]

This topic has been debated and PROVEN from the FSDO. I'm convinced that regardless of the "Official" evidence etc that member will continue to argue and try to swing the law their way.

It's been stated time and time again what the law states (in it's entirety) what is requred and allowed. I don't think anything I say is going to make a difference one way or another.

I hope you fly safe and have no incidences going forward.

Sincerely,
Allen

Hey Allen,

I'm just trying to get to the bottom of the truth. I know you've gone 'round & round wiht this topic many times...sorry that it's one more time. I was completely and utterly on-board with you and the FAA guy, then I read these two documents which spells out exactly what I now believe. How would you read the information below? The one directly below was published yesterday. What does co-located mean to you? To me, it doesn't mean right next to me, it means away from me. Hand held radios? Again, not next to me.


Man, I really wish your voice, the FAA guy's voice and the two documents that I have read would all agree. I will ask my FAA contact about these documents which state otherwise. My parents always told me that I would make a good lawyer. They might have been right.

The second document dated 6/21/16. VO is positioned in a location? From a distance? Hand-held radio to facilitate communication from a distance? How did misread any of that? I would really love to know. Honestly, Allen, I'm being sincere. I'm not a smart ***, just a guy who likes truth. I would love to hear what you have to say about these document entries. I also think I'll shoot the info below to Paul (FAA) and she what he says.

Fly only for recreational purposes
• Keep your unmanned aircraft within
your visual line-of-sight or within the
visual line of sight of a visual observer
who is co-located and in direct
communication with you.

FAA Advisory Circular dated 6/21/16:

5.7.2.1 To ensure that the VO can carry out his or her duties, the remote PIC must ensure that the VO is positioned in a location where he or she is able to see the small UA sufficiently to maintain VLOS. The remote PIC can do this by specifying the location of the VO. The FAA also requires that the remote PIC and VO coordinate to 1) scan the airspace where the small UA is operating for any potential collision hazard, and 2) maintain awareness of the position of the small UA through direct visual observation. This would be accomplished by the VO maintaining visual contact with the small UA and the surrounding airspace, and then communicating to the remote PIC and person manipulating the controls the flight status of the small UA and any hazards which may enter the area of operation, so that the remote PIC or person manipulating the controls can take appropriate action.
5.7.2.2 To make this communication possible, the remote PIC, person manipulating the controls, and VO must work out a method of effective communication, which does not create a distraction and allows them to understand each other. The communication method must be determined prior to operation. This effective communication requirement would permit the use of communication-assisting devices, such as a hand-held radio, to facilitate communication from a distance.

 

[Mavic Maveric]

I think it’s good that they are vague on vlos . Don’t complain about it. If someone is flying under 400ft and goes out of vlos it’s far less dangerous than flying in the airspace of any class airport..

BUT the silly thing about any of this is that they don’t enforce and can’t really.

IF THEY LET US FLY IN PARKS (not over people) the Rangers could check in us. They have the time to do it .. maybe certain hours sunrise to 7am for instance.

You are so right. I hear one thing from an FAA guy and from people here, then read something completely to the contrary. I have printed out the documents that say I can locate my VO in a location I designate so that between the both of us my sUA will be in the VLOS at all times and that we can use 2 way radios. I will carry the documents with me for proof if ever questioned. I just wrote to my FAA contact for clarification of the documents I am reading. He (and others) say one thing but I read another. Completely confusing. LOL...geesh!

 

[ac0j]

the newest release or recreational flying rules adds more controversy. It appears a VO and using goggles is allowed now.......
I have not read too deep into it I expect it to be contradicted in the later pages of the document. So still a crapshoot

 

[sar104]

You are so right. I hear one thing from an FAA guy and from people here, then read something completely to the contrary. I have printed out the documents that say I can locate my VO in a location I designate so that between the both of us my sUA will be in the VLOS at all times and that we can use 2 way radios. I will carry the documents with me for proof if ever questioned. I just wrote to my FAA contact for clarification of the documents I am reading. He (and others) say one thing but I read another. Completely confusing. LOL...geesh!

I don't think there is any ambiguity in the written guidance, either for recreational or Part 107.

Under the new recreational rules the FAA has added the option for a co-located VO, specifically to permit FPV racing but, since it is not exclusive, any other situation. But since the VO must be co-located it doesn't buy much except allowing the pilot to use goggles.

Part 107 hasn't changed - it permits the use of a VO to maintain visual contact with the aircraft if the pilot has to look away - for example to look at the controller screen or app. However, since it also requires the pilot to be able to regain visual on the aircraft at any time when needed, that also rules out using a distant VO to permit the aircraft to be flown BVLOS.

 

[Drbobk]

Which part of “co-located” is vague? A second VO can always be located somewhere else, but the pilot can’t rely solely on that one for situational awareness.