FAA Webinar: How to Legally Fly Beyond Line of Sight

Overview
The Operation of Beyond Visual Line of Sight (BVLOS) is one of a family of waivers available under Part 107. As discussed in other waiver webinars, the FAA expects the language for the BVLOS to written in a certain format. In this webinar series, Kevin Morris provides tips and resources on how to increase your likelihood of obtaining a BVLOS waiver. As always, the video to this webinar can be accessed below and you can see my annotations of the video the further down you scroll.

Starting with 107.31, the remote pilot in command must maintain visual line of sight with the sUA at all times. This also applies to the control operator and the visual observers. The FAA expects that the mentioned crew can be able to determine the following items while maintaining visual line of sight.

• Aircraft Location
• Attitude, altitude, and direction of flight
• Note any other traffic in airspace
• Ensure the sUA does not endanger anybody or their property

Risks to Operating BVLOS
Perhaps the biggest concern to the FAA is making sure a waiver applicant will be able to demonstrate how they are going to use the see and avoid technique despite being beyond line of sight. Other topics of concern include but are not limited to:

• GPS signal
• Equipment reliability
• Proving that the operator knows that they will not be flying over people or vehicles
• Frequency interference
• Transmission range
• Is everything FCC approved?
• Cloud Clearance Requirements

Equipment Reliability
As mentioned in other waiver application videos, the FAA wants to know if there are life limited parts, a maintenance program to address the life limited parts, and a description of the components that make up the sUA. Furthermore this can include items such as:

• Software
• Command and control links
• Maximum distance sUA can fly without loosing signal
• Failure rate of systems

Waiver Safety Explanation Guidelines
This topic is a recurring theme in every waiver related FAA webinar that I have seen. Therefore referencing the waiver safety explanation guidelines is something that I think every applicant must do in order to have a chance at getting FAA approval. Because the FAA is highly concerned with the safe operation of a sUAS, applicants need to have detailed risk mitigation and must address circumstances that can occur in the event of an emergency. Taken directly from the video, there are 7 key items of concern which are listed below:

• Continuously knowing the position, altitude, attitude and movement of the aircraft
• Avoiding other aircraft/flying over people
• Ensuring the sUA will be seen ad a distance of at least 3 statute miles
• How will the RPIC be alerted if there is a malfunction
• Does the operating crew knows the capabilities/limitations/process of sUA?
• Weather/Cloud Coverage
• Description of Transmitters/Control Links

Important Considerations
An understanding of the latency rate and how it can affect the operations of the sUA can greatly improve your chances of obtaining an FAA approved waiver. In addition, the FAA wants to know your thought process pertaining to how you will address a lost connection and how the sUA crew will know where the sUA is.As mentioned in the video, the FAA is interested in knowing what the crew will do when the mission does not go as planned because in theory, an applicant has a reputation in completing successful missions. Nevertheless, this assumption is checked by the FAA to ensure that they can trust the applicant’s ability to safely operate a waived mission.

Transmissions and Receivers
Aside from proving to the FAA that the crew will know that the sUA will correctly navigate through it’s intended area of operation, the FAA also wants details on the ranges of the transmitters and receivers. Shown in Figure 1 is a diagram taken from Researchgate.

Figure 1: Retrieved from Researchgate

Other Applicable Rules
To emphasize that although you are applying for BVLOS this does not mean that your exempt from other Part 107 operations. In fact it would be wise to address the operations listed below:

• 107.19-RPIC responsibilities
• 107.23-Hazardous operation
• 107.37-Right-of-way
• 107.39- Operations Over People

If trying to address 107.39, the FAA wants to know what program are you using to get flight traffic data on and how close to rel time is it. In addition, the FAA wants to know about what you used to determine who you are flying over (which relates to 107.39). Since the FAA likely doesn't live in your operating area, they need to know details about the population. Furthermore, you need to ensure that the sUAS can be seen from other people from a minimum of 3 statute miles as mentioned in other FAA webinars.

Questions to Ask the Crew

• Do they understand what your doing?
• Do they understand the limitations?
• Do they know GPS liability in respect to tall structures?
• What happens when GPS goes out?
• How do you accomplish a safe let down of the sUAS if GPS is lost?
• How do you ensure clouds are consistent with the duration of UAS flight?
• Is there an FCC Grant or licence?
• Does the system operate with an acceptable bit error rate?

Conclusion
Although BVLOS is a very complex, high risk UAS operation that requires significant research, mission planning and checks and balances, it is not an impossible waiver to get. Three tips taken directly from the FAA video include knowing the airspace, having a process on how you will remain in compliance with other parts of 107, and ensuring that the RPIC will have control of the sUA at all times. In recent news, Uber Eats has been testing sUAS and has delivered food BVLOS and is rummored to be in the final stages of becoming an air carrier. Althought this will be under part 135 rules, Uber has a system that meets the FAA's BVLOS expectations. To learn more about that click the video below.