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VLOS Reality Check

Dmcvey

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Excerpt:
"What the Testing and Data Tell Us
Put your beliefs aside for a moment and just try to square the facts with reality. CFR 107.31 requires us to maintain those required observational items to be compliant with VLOS flight. COAs and even a Tactical BVLOS waiver all require VLOS by a VO if the aircraft is BVLOS for the pilot.

Night flight distances would be no higher than 40 feet or further than 65 feet from the VO, even with strobes on during flight.

During the day flight should not be more than 1,200 feet if you are using a VO that has not lost contact. If you are flying as a Part 107 pilot without a VO, you are required to maintain VLOS at all times but if you do look away, testing data showed that the safe flight distance was 400′ AGL and about 500′ from the responsible party watching the aircraft."
 
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Steve Rhodes is an anti-drone drone guy. I know that doesn't make sense, but he's a helicopter pilot by training, and feels drone operators are second class citizens. Many local drone pilots (including many First Responder drone pilots) do not like Steve at all.

He and I have had more than one conversation about this. I wouldn't take much of what is on his site as actual fact.
 
I know most of us won't admit it, and it is sort of a taboo conversation, but really, how many of us actually watch our drones directly with our eyes while flying, recording or photographing? At the risk of being arrested, I'll admit that I don't always watch it and navigate by the controller monitor. How else can you tell what you're photographing? Why else would you fly a drone with a camera? VLOS is fine for takeoff and landing. Let's get real.
 
From my experience, i think he has some valid points. I lose my M2 at about 1700 feet. I can still see the dot but if I were to close eyes and spin drone I would not be able to tell orientation by looking at the drone. Orientation is one of the 3 parts of VLOS. I see too many "range" tests and other stupid stuff on YouTube that are out of bounds for safety.

I witnessed a pilot start a mapping flight and proceeded to put the controller on hood of car and start answering emails on laptop. The drone was less than 500 feet away but he did not have VLOS.
 
I know most of us won't admit it, and it is sort of a taboo conversation, but really, how many of us actually watch our drones directly with our eyes while flying, recording or photographing? At the risk of being arrested, I'll admit that I don't always watch it and navigate by the controller monitor. How else can you tell what you're photographing? Why else would you fly a drone with a camera? VLOS is fine for takeoff and landing. Let's get real.
I was working CAT losses after Sally and Ida, on 3 occasions had helos fly through my mapping or site inspection at 200' AGL. My drone was 400' down range and i barely got it below tree level on one event. In those cases, i heard the copter before I saw it due to trees. Reaction time to avoid collision less than 6 seconds. He passed within 20' of where i had just been.

If you are 1000-2000-5000 feet out, there is no way to avoid that collision because you may not hear the approach.
 
I know most of us won't admit it, and it is sort of a taboo conversation, but really, how many of us actually watch our drones directly with our eyes while flying, recording or photographing? At the risk of being arrested, I'll admit that I don't always watch it and navigate by the controller monitor. How else can you tell what you're photographing? Why else would you fly a drone with a camera? VLOS is fine for takeoff and landing. Let's get real.
I fly BLVOS regularly. And I have no qualms about who knows it. Even the FAA folks I am good friends with know this. I fly monthly stockpile flights that are 90% BLVOS, and 100% safe.

The FAA knows this is safer that regs allow at the moment. And we are working on ways to help the FAA expedite BVLOS rule changes. Our report will be ready to present at the March AAAC committee meeting.

Kenji and I will also be releasing the application process of our BVLOS waivers next month. That should also help get more BVLOS folks in the air legally as well.
 
I know most of us won't admit it, and it is sort of a taboo conversation, but really, how many of us actually watch our drones directly with our eyes while flying, recording or photographing?
I, for one, am nearly always flying VLOS. Not being a professional photographer, I line up my shot, then quickly check the video screen, then let her rip.
 
I fly BLVOS regularly. And I have no qualms about who knows it. Even the FAA folks I am good friends with know this. I fly monthly stockpile flights that are 90% BLVOS, and 100% safe.

The FAA knows this is safer that regs allow at the moment. And we are working on ways to help the FAA expedite BVLOS rule changes. Our report will be ready to present at the March AAAC committee meeting.

Kenji and I will also be releasing the application process of our BVLOS waivers next month. That should also help get more BVLOS folks in the air legally as well.
I managed to slug my way through the entire Advisory and Rulemaking Committees UAS BVLOS ARC Final Report but haven't seen anything that follows up on what the FAA is going to do with the recommendations. Is this something that will come up in the March meetings?
 
I know most of us won't admit it, and it is sort of a taboo conversation, but really, how many of us actually watch our drones directly with our eyes while flying, recording or photographing? At the risk of being arrested, I'll admit that I don't always watch it and navigate by the controller monitor. How else can you tell what you're photographing? Why else would you fly a drone with a camera? VLOS is fine for takeoff and landing. Let's get real.
While I would agree that most don't watch their drones 100% of the time, obviously splitting visual time with the monitor screens, it would seem to me that the regulation revolves around the ABILITY to see your drone 100% of the time. It appears to me that the VLOS regulation applies to FLYING within the line of sight, not requiring eyeballs glued to the drone.

To answer your question, "why would you fly a drone with a camera?", the answer is simple: To see what you are recording.
 
While I don't know who Steve Rhodes is, there is nothing in his statement that by FAA regulation requires one to be able to see one's drone as if there were no strobes on it. And while yes, strobes are required so that other aircraft can see your drone at night, there is nothing that states that you cannot use strobes for your own ability to maintain VLOS and use your strobes to maintain distance from any other aircraft. The FACT is that at night, with strobes, it is far easier to maintain VLOS and the flight path and position of a drone for far greater distances than during daylight hours, with or without strobes.
 
I managed to slug my way through the entire Advisory and Rulemaking Committees UAS BVLOS ARC Final Report
Congratulations, you're one of about 10 people who did. I didn't even read the whole thing.
but haven't seen anything that follows up on what the FAA is going to do with the recommendations. Is this something that will come up in the March meetings?
At the October AAAC meeting, there was a Task Group formed titled, "BLVOS ARC Opportunities". We are tasked with: "AAAC to examine BVLOS ARC recommendations and identify opportunities where industry can assist and accelerate implementation of BVLOS regulatory actions."

I'm part of that Task Group. We'll have a report for the FAA at the March meeting that will suggest ways for the FAA to accelerate BLVOS. Stay tuned...

Check out the tasking in the public meeting book, on page 101 here: https://cms.faa.gov/sites/faa.gov/files/AAAC-Meeting-Public-eBook_10202022.pdf
 
While I don't know who Steve Rhodes is, there is nothing in his statement that by FAA regulation requires one to be able to see one's drone as if there were no strobes on it. And while yes, strobes are required so that other aircraft can see your drone at night, there is nothing that states that you cannot use strobes for your own ability to maintain VLOS and use your strobes to maintain distance from any other aircraft. The FACT is that at night, with strobes, it is far easier to maintain VLOS and the flight path and position of a drone for far greater distances than during daylight hours, with or without strobes.
Exactly. With the right strobe configuration, BVLOS is even better at night. Something Steve and I vehemently argued about. To the point I removed him from my emails in that FAA email chain. I was done with him.
 
Congratulations, you're one of about 10 people who did. I didn't even read the whole thing.

It is a tad long at 381 pages but there are some very interesting discussions about the commercial delivery proposals. Especially the suggestions for a Part 108 cert with a PIC running large numbers of automated BVLOS flights. Avoidance in Class G airspace wasn't really covered all that well for that application.

At the October AAAC meeting, there was a Task Group formed titled, "BLVOS ARC Opportunities". We are tasked with: "AAAC to examine BVLOS ARC recommendations and identify opportunities where industry can assist and accelerate implementation of BVLOS regulatory actions."

I'm part of that Task Group. We'll have a report for the FAA at the March meeting that will suggest ways for the FAA to accelerate BLVOS. Stay tuned...

Check out the tasking in the public meeting book, on page 101 here: https://cms.faa.gov/sites/faa.gov/files/AAAC-Meeting-Public-eBook_10202022.pdf

Thanks - I will check out that meeting report.
 
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It is a tad long at 381 pages but there are some very interesting discussions about the commercial delivery proposals. Especially the suggestions for a Part 108 cert with a PIC running large numbers of automated BVLOS flights. Avoidance in Class G airspace wasn't really covered all that well for that application.
David Carbon (VP Amazon Flight Ops) is running the Task Group. He's a great guy, but obviously wants to push the delivery side of BVLOS. We got approval just yesterday to run a sub group for EVLOS and FPV. Dave Messina (CEO of FPV Freedom Coalition) and I are co-leading that group. We have our first meeting tomorrow and we'll have our report ready for the FAA in March as well. It will be part of the TG14 report.
Thanks - I will check out that meeting report.
 
Exactly. With the right strobe configuration, BVLOS is even better at night. Something Steve and I vehemently argued about. To the point I removed him from my emails in that FAA email chain. I was done with him.
I'll give you can find it in the sky, but at 2000', in the dark, can you VISUALLY tell orientation or attitude? Where are the red and green lights that denote starboard and port?The FAA rule does not allow using the display to gain that info.
 
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I'll give you can find it in the sky, but at 2000', in the dark, can you VISUALLY tell orientation or attitude? Where are the red and green lights that denote starboard and port?The FAA rule does not allow using the display to gain that info.
They also don't forbid it. The only visual stipulation is you can't enhance "vision that is unaided by any device other than corrective lenses".

Vision is different than visibility. There are no restrictions on enhancing visibility. Position strobes (as opposed to anti-collision strobes) can enhance visibility. And there are not regulatory prohibitions against it.

The only arguable aspect of 107.31 is (a)(4). It states we must: "Determine that the unmanned aircraft does not endanger the life or property of another." For proof of that, I give you the impeccable safety record of drones in the air. Millions of flights have taken place with zero fatalities, and almost zero injuries or damage to "property of another". And even with injuries, that vast majority of the time its to the one flying the drone.

Accidents happen, but the numbers don't support it being an actual issue with the safety of UAS.

There were an average of almost 370 deaths per year from general aviation between 2016-2020. The FAA wants zero deaths from drones. We can't accept that answer. It's unfair to the industry. That's why I'm working so hard on getting the BVLOS requirements relaxed.
 
I disagree with that article's claims about distance to operate within VLOS. I also disagree with the suggestion that; when we can only see our aircraft as a dot, that we cannot tell orientation and attitude without looking at the screen. And lastly, VLOS does not require a pilot to only look at their aircraft and in fact, requires the opposite. Scanning the sky, looking at the screen for critical flight information such as battery life, framing for photo or video work, and more are part of VLOS as spelled out in AC-107-2A

I think a lot of drone pilots start out flying a drone in the most accommodating way: starring at the screen. In doing so they never gain the skill and coordination of control input matching-what they see externally, while looking at their drone in the sky. Anyone who has flown RC learned exactly the opposite.

If you train your self to be able to fly solely by looking at the aircraft at distances of 1,000', 1,500' or more; and couple that ability with the 'usual' means of drone flying, you can operate at far greater distances and still remain within VLOS.
 
I was working CAT losses after Sally and Ida, on 3 occasions had helos fly through my mapping or site inspection at 200' AGL. My drone was 400' down range and i barely got it below tree level on one event. In those cases, i heard the copter before I saw it due to trees. Reaction time to avoid collision less than 6 seconds. He passed within 20' of where i had just been.

If you are 1000-2000-5000 feet out, there is no way to avoid that collision because you may not hear the approach.
The FAA probably doesn't see it this way, but when I think about VLOS, I think there are 4 "levels" of VLOS where the risk increases as one moves from 1-4: 1) Actually being able to see the drone; 2) having an unobstructed view of where your drone is and the area around it but you can't actually see it; 3) the drone is close enough where you have situational awareness but not are not able to actually see it; and 4) not being able to see your drone or its surroundings at all.
 
..... he FAA wants zero deaths from drones. We can't accept that answer. It's unfair to the industry. ..........
With respect, are you suggesting that there is an acceptable death rate for non involved people stemming from the use of something that, for probably the vast majority of users, is an entertainment or passing phase for those users?
 
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