My point is that at a distance where you can't see the drone and are relying on telemetry for position and travel, you can't maintain see and avoid. I have had helos fly through my airspace and not show up on screen until they were well past.
VLOS Reality Check
- Thread starter Dmcvey
- Start date
The FAA restrictions are such that they make it impossible that any significant incident can occur via a drone flight. Yet they could be significantly looser and still achieve that same goal.
The comment your responding to is saying the FAA doesn't want to worry about dealing with drones - therefor they focus on the 370 number on the non-drone side and on the drone side, they set regulations set such that they can just ignore drones exist rather than create rules with more nuance.
it may be ironic that the VLOS rules make it so that the bigger the drone, the further the VLOS
I've lost sight of both my Mini 2 and Mini 3, on cloudy days at a couple of hundred feet from home when the altitude has been 250 feet. Just glancing down at my control screen and I couldn't visually re-acquire sight of the drone.
meanwhile, I can keep sight of my Mavic 3 at least 3 to 5 times further, maybe more. It's simply the size of the drone and the color
the irony comes in that the VLOS rules are safety rules, yet in a very real way they encourage people to have bigger drones. So then, which is safer in a crash scenario: a half pound object traveling 30MPH or a 2 pound object traveling 45MPH?
or I could go crazy and have an M30 and have an 11 pound object traveling 50MPH. I'd probably double my VLOS over the Mavic 3 with that drone. I'd also have lots of time to fly because if I spent $14,000 on a drone my wife would divorce me. The Mavic 3 already tested that boundary
I've lost sight of both my Mini 2 and Mini 3, on cloudy days at a couple of hundred feet from home when the altitude has been 250 feet. Just glancing down at my control screen and I couldn't visually re-acquire sight of the drone.
meanwhile, I can keep sight of my Mavic 3 at least 3 to 5 times further, maybe more. It's simply the size of the drone and the color
the irony comes in that the VLOS rules are safety rules, yet in a very real way they encourage people to have bigger drones. So then, which is safer in a crash scenario: a half pound object traveling 30MPH or a 2 pound object traveling 45MPH?
or I could go crazy and have an M30 and have an 11 pound object traveling 50MPH. I'd probably double my VLOS over the Mavic 3 with that drone. I'd also have lots of time to fly because if I spent $14,000 on a drone my wife would divorce me. The Mavic 3 already tested that boundary
VLOS is but one part of the rules that are intended for safe UA operation. In your scenarios, you're argument suggests VLOS is a stand-alone rule and does not make things safer because it doesn't address weight. Neither does VLOS address pilot behavior, hazardous attitudes, understanding airspace, weather, airport communications, risk management, preflight procedures, record keeping, healthy diets, sleep depravation, alcohol and drug use and a whole lot more.
The primary goal of the VLOS rule is to ensure that when a UA is in the air - the PIC has complete situational awareness of the airspace around it. It (VLOS) is meant to be a means by which UAV pilots can achieve our primary goal in the air, and that is to avoid manned aviation. And in that respect - yes, bigger does allow further flight distance while still achieving the goal of VLOS.
There are many other rules that cover the dangers of a falling drone and flights over people where weight is considered. The regulations are meant to taken, and followed as a whole, we can't pick one and say "oh look - it doesn't cover that".
you're overthinking a response to my rather simplistic post
I wasn't delving into the nuances of the rules and regs. I was simply pointing at the type of rudimentary response that many might have to the VLOS rule. That being that a bigger drone is visible from further away.
Just an update.
Our BVLOS report that will be given to the FAA at the next Advance Aviation Advisory Committee (AAAC) will be edited and ready by 2/28.
Unfortunately it will be a bit longer before it can be made public. We found out today that the AAAC meeting scheduled for March will be delayed until April.
Keep track of this at the AAAC webpage: Advanced Aviation Advisory Committee | Federal Aviation Administration
We'll share what we can when we can. But the report will be made public about 5-10 days before the AAAC meeting with the E-Book for the meeting is published. Until then, we're under embargo.
I was co-chair of the eVLOS sub-committee, and we really hope the FAA takes our suggestions and runs with them.
We'll see.
Feel free to ask questions. I'll answer what I can.
Our BVLOS report that will be given to the FAA at the next Advance Aviation Advisory Committee (AAAC) will be edited and ready by 2/28.
Unfortunately it will be a bit longer before it can be made public. We found out today that the AAAC meeting scheduled for March will be delayed until April.
Keep track of this at the AAAC webpage: Advanced Aviation Advisory Committee | Federal Aviation Administration
We'll share what we can when we can. But the report will be made public about 5-10 days before the AAAC meeting with the E-Book for the meeting is published. Until then, we're under embargo.
I was co-chair of the eVLOS sub-committee, and we really hope the FAA takes our suggestions and runs with them.
We'll see.
Feel free to ask questions. I'll answer what I can.
Last edited:
Then how do you explain this?
On Oct 1, 2021, at 10:51 AM, Taylor, Alex Q (FAA) <[email protected]> wrote:
Good morning,
VLOS is defined in the reg as seeing the drone well enough to meet ALL of those criteria (LAADON) with unaided vision other than spectacles. If you don't meet all of LAADON criteria, you don't have VLOS, as far as the reg is concerned. 107.31 requires the RP to be able to have the ability to determine VLOS at all times during the flight, even if a VO is used and even if a VO is exercising the VLOS ability. As far as momentarily looking away, I suggest you read AC 107-2A, or the preamble to the final rule part 107. Both of those documents discuss "momentary" looking away as being an acceptable practice, but the documents also emphasize that the requirement for VLOS is not excused by looking away momentarily (to check telemetry, for example)
The VLOS requirement of 107.31 is required for both day and night operations, in all operating conditions. The 107.29 requirements are additional, and applicable for night. So if 107.31 applies at night, we can deduce that simply seeing an anti-collision light is not sufficient for meeting VLOS. The night visual illusions show why simply seeing the lights alone will not help determine LAADON, which is still required. It can be moving away from the pilot at a constant angle, for example, and the pilot won't know direction of flight or altitude in that example.
We know that visual acuity is much less at night, so we can also deduce from eye physiology that the distance one can determine LAADON is much less at night than it is during the day. The 3SM requirement for the anti-collision lighting is for the benefit of manned pilots to see the drone in time to maneuver away if needed, not for the drone pilot to use as the sole means of meeting VLOS at night.
I hope this helps you out.
Regards,
Alex Q. Taylor
Aviation Safety
Aviation Safety Technician
Springfield FSDO
1250 North Airport Drive, Suite 1
Springfield, IL 62707-8417
Office: (217) 744-1910
Desk: (217) 744-1913
Cell: (202) 642-5245
You're going to have to be more specific in your question. I'm not going to go through 86 previous posts to find out what I was referring to. This is an old thread.
"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 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."
FAA assertions and test data does not support the above contention
Maybe I'm being thick, but what are you asking?
I agree that VLOS is easier to maintain at night with the correct lighting, but the FAA doesn't agree. I've had this very discussion with them about the ability to use positioning lights in addition to anti-collision lighting. AC 20-30B even states the differences between anti-collision lights and positioning lights (https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_20-30B.pdf). But that's not how the FAA sees it.
If you saw the AAAC meeting last month, I gave a report to the FAA that encourages them to allow drone pilots to fly up to 3 miles from control station if you have command of the airspace. We'll see if it goes anywhere, but it was also part of the BVLOS Aviation Rulemaking Committee (ARC).
107.31 states you have to have the ability to see the drone in order to:
"(1) Know the unmanned aircraft's location;
(2) Determine the unmanned aircraft's attitude, altitude, and direction of flight;
(3) Observe the airspace for other air traffic or hazards; and
(4) Determine that the unmanned aircraft does not endanger the life or property of another."
According to the FAA, you can't maintain 2, 3, & 4 at night. I don't agree, but that's the current ruling.
Also, that FSDO is working off of old wording. RPIC are allowed to momentarily lose VLOS for looking at screens, and/or the drone flying behind a visual barrier. They can do that as long as they can maintain safety.
If we an get eVLOS (extended VLOS, the 3 mile limit) passed, this will all be moot.
NightFlightAlright
Well-Known Member
The left wing is not the only location of a red light… my 152 had a red light on the tail as well, visible all directions.
A small point and I am not arguing with you but.
I don't know about others but when a drone gets beyond 'close' I, by direct obervation of the drone alone and in relation to towards-me/aways-from-me flight only, find it difficult to tell whether or not the drone is moving vertically / horizontally.
As far as my eyes are concerned only increasing or decreasing size really tells me what it is doing.
In fact, when outbound or inbound, I often try to fly a drone so that it appears to be stationary in the sky, by combining horizontal and vertical movements.
Obiviously with knowledge of the stick inputs I have an additional sensory input but still a drone flying away from me horizontally appears to be descending and the reverse.
Additionally if the drone is fighting wind this adds another layer of possible confusion.
The same thing would, with out knowledge of the stick inputs, happen in a night time flight.
If by chance you are flying via goggles and with an observer then unless you tell the observeR what stick commands you are giving the observer may have the difficulty described above.
Might such thoughts be behind 2)? But then again they apply equally to daylight flights.
NightFlightAlright
Well-Known Member
Yes, a slow on/off not a strobe though… and the nav lights should be steady.
And due to orientation would not indicate “coming towards”… red flashing + green means flying left to right from our POV.
And the NAV lights should be steady, despite the usual misinformation on the internet.
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If anyone can see green or red seperated or even discernible in colour difference at night (or daytime) beyond normal daytime VLOS, they have super human eyesight.
They tend to just merge into one series of flashes after a certain distance.
They tend to just merge into one series of flashes after a certain distance.
NightFlightAlright
Well-Known Member
The human vision system’s color perception is at a very low resolution. Our higher resolution perception is essentially “black & white” limited to the luminance channel and disregarding hue and chroma.
Hue/chroma perception is a third to a fifth the resolution of luminance.
When you see yellow on your computer display, you are actually seeing red and green light (only) but the red and green sub pixels are so small and close together, we integrate them into a perception of yellow.
An RGB display only emits wavelengths we identify as red, green, or blue—but combinations thereof stimulate vision to give the perception of a much larger gamut of colors.
Hue/chroma perception is a third to a fifth the resolution of luminance.
When you see yellow on your computer display, you are actually seeing red and green light (only) but the red and green sub pixels are so small and close together, we integrate them into a perception of yellow.
An RGB display only emits wavelengths we identify as red, green, or blue—but combinations thereof stimulate vision to give the perception of a much larger gamut of colors.
For the record, Steve Rhodes is not and never has been an anti-drone individual. As chief pilot of the Wake Forest F&R, flying both manned and unmanned aircraft, how could he be. His objective has always been to assist Part 107 pilots understand the regs (not unsubstantiated opinions) to make sure they don't run afoul of the FAA. Just ask Mical Caterina what can go wrong:
www.dailysignal.com
Concerning use of strobes to satisfy VLOS requirements, explain the following:
On Oct 1, 2021, at 10:51 AM, Taylor, Alex Q (FAA) <[email protected]> wrote:
Good morning,
VLOS is defined in the reg as seeing the drone well enough to meet ALL of those criteria (LAADON) with unaided vision other than spectacles. If you don't meet all of LAADON criteria, you don't have VLOS, as far as the reg is concerned. 107.31 requires the RP to be able to have the ability to determine VLOS at all times during the flight, even if a VO is used and even if a VO is exercising the VLOS ability. As far as momentarily looking away, I suggest you read AC 107-2A, or the preamble to the final rule part 107. Both of those documents discuss "momentary" looking away as being an acceptable practice, but the documents also emphasize that the requirement for VLOS is not excused by looking away momentarily (to check telemetry, for example)
The VLOS requirement of 107.31 is required for both day and night operations, in all operating conditions. The 107.29 requirements are additional, and applicable for night. So if 107.31 applies at night, we can deduce that simply seeing an anti-collision light is not sufficient for meeting VLOS. The night visual illusions show why simply seeing the lights alone will not help determine LAADON, which is still required. It can be moving away from the pilot at a constant angle, for example, and the pilot won't know direction of flight or altitude in that example.
We know that visual acuity is much less at night, so we can also deduce from eye physiology that the distance one can determine LAADON is much less at night than it is during the day. The 3SM requirement for the anti-collision lighting is for the benefit of manned pilots to see the drone in time to maneuver away if needed, not for the drone pilot to use as the sole means of meeting VLOS at night.
I hope this helps you out.
Regards,
Alex Q. Taylor
Aviation Safety
Aviation Safety Technician
Springfield FSDO
1250 North Airport Drive, Suite 1
Springfield, IL 62707-8417
Office: (217) 744-1910
Desk: (217) 744-1913
Cell: (202) 642-5245
Finally, the main point of the VLOS multi-week test, voluminous data acquisition and report, that Steve published, was again to provide Part 107 pilots real world information (not conjecture, repeated false posts, etc) on what the FAA was / is requiring of 107 pilots and the inherent fallacies of 107.31 (which should be challenged) so a defensible position could be established if 107 pilots were ever ramp checked (the unannounced arrival of FAA inspectors to audit all the pilot is responsible for, grounding the aircraft, sanctioning and / or fining the pilot for found infractions). Those who have read the report and tested the observations on their own have found it to be accurate.
Minnesota Man Faces $55K in Fines After Flying Drone
According to the FAA, Mical Caterina violated five regulations, with fines of $11,000 each, for flying his drone at an event honoring Cecil the Lion.
www.dailysignal.com
Concerning use of strobes to satisfy VLOS requirements, explain the following:
On Oct 1, 2021, at 10:51 AM, Taylor, Alex Q (FAA) <[email protected]> wrote:
Good morning,
VLOS is defined in the reg as seeing the drone well enough to meet ALL of those criteria (LAADON) with unaided vision other than spectacles. If you don't meet all of LAADON criteria, you don't have VLOS, as far as the reg is concerned. 107.31 requires the RP to be able to have the ability to determine VLOS at all times during the flight, even if a VO is used and even if a VO is exercising the VLOS ability. As far as momentarily looking away, I suggest you read AC 107-2A, or the preamble to the final rule part 107. Both of those documents discuss "momentary" looking away as being an acceptable practice, but the documents also emphasize that the requirement for VLOS is not excused by looking away momentarily (to check telemetry, for example)
The VLOS requirement of 107.31 is required for both day and night operations, in all operating conditions. The 107.29 requirements are additional, and applicable for night. So if 107.31 applies at night, we can deduce that simply seeing an anti-collision light is not sufficient for meeting VLOS. The night visual illusions show why simply seeing the lights alone will not help determine LAADON, which is still required. It can be moving away from the pilot at a constant angle, for example, and the pilot won't know direction of flight or altitude in that example.
We know that visual acuity is much less at night, so we can also deduce from eye physiology that the distance one can determine LAADON is much less at night than it is during the day. The 3SM requirement for the anti-collision lighting is for the benefit of manned pilots to see the drone in time to maneuver away if needed, not for the drone pilot to use as the sole means of meeting VLOS at night.
I hope this helps you out.
Regards,
Alex Q. Taylor
Aviation Safety
Aviation Safety Technician
Springfield FSDO
1250 North Airport Drive, Suite 1
Springfield, IL 62707-8417
Office: (217) 744-1910
Desk: (217) 744-1913
Cell: (202) 642-5245
Finally, the main point of the VLOS multi-week test, voluminous data acquisition and report, that Steve published, was again to provide Part 107 pilots real world information (not conjecture, repeated false posts, etc) on what the FAA was / is requiring of 107 pilots and the inherent fallacies of 107.31 (which should be challenged) so a defensible position could be established if 107 pilots were ever ramp checked (the unannounced arrival of FAA inspectors to audit all the pilot is responsible for, grounding the aircraft, sanctioning and / or fining the pilot for found infractions). Those who have read the report and tested the observations on their own have found it to be accurate.
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