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Visual Observers question part 107

KR1

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Jan 12, 2018
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I am planning on taking my test for Drone pilot pretty soon. One thing that I haven't been able to answer is this. If I have several VO's that can monitor the path of the drone but it travels in some areas that I cannot see. If the VO's are in radio communications with me. Am I compliant with Part 107 as far as keeping the drone under observation?
 
You are not in compliance if you or the visual observers lose sight of the UAV at any time.

If you or one of your observers can see the UAV at all times, then you are in compliance.

You and/or your visual observers MUST maintain sight of the UAV at ALL times. Otherwise, you cannot take the flight without an approved waiver from the FAA.
 
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§107.31 Visual line of sight aircraft operation.
(a) With vision that is unaided by any device other than corrective lenses, the remote pilot in command, the visual observer (if one is used), and the person manipulating the flight control of the small unmanned aircraft system must be able to see the unmanned aircraft throughout the entire flight 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.

(b) Throughout the entire flight of the small unmanned aircraft, the ability described in paragraph (a) of this section must be exercised by either:

(1) The remote pilot in command and the person manipulating the flight controls of the small unmanned aircraft system; or

(2) A visual observer.


§107.33 Visual observer.
If a visual observer is used during the aircraft operation, all of the following requirements must be met:

(a) The remote pilot in command, the person manipulating the flight controls of the small unmanned aircraft system, and the visual observer must maintain effective communication with each other at all times.

(b) The remote pilot in command must ensure that the visual observer is able to see the unmanned aircraft in the manner specified in §107.31.

(c) The remote pilot in command, the person manipulating the flight controls of the small unmanned aircraft system, and the visual observer must coordinate to do the following:

(1) Scan the airspace where the small unmanned aircraft is operating for any potential collision hazard; and

(2) Maintain awareness of the position of the small unmanned aircraft through direct visual observation.
 
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§107.31 Visual line of sight aircraft operation.
(a) With vision that is unaided by any device other than corrective lenses, the remote pilot in command, the visual observer (if one is used), and the person manipulating the flight control of the small unmanned aircraft system must be able to see the unmanned aircraft throughout the entire flight 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.​

(b) Throughout the entire flight of the small unmanned aircraft, the ability described in paragraph (a) of this section must be exercised by either:

(1) The remote pilot in command and the person manipulating the flight controls of the small unmanned aircraft system; or

(2) A visual observer.​


§107.33 Visual observer.
If a visual observer is used during the aircraft operation, all of the following requirements must be met:

(a) The remote pilot in command, the person manipulating the flight controls of the small unmanned aircraft system, and the visual observer must maintain effective communication with each other at all times.

(b) The remote pilot in command must ensure that the visual observer is able to see the unmanned aircraft in the manner specified in §107.31.

(c) The remote pilot in command, the person manipulating the flight controls of the small unmanned aircraft system, and the visual observer must coordinate to do the following:

(1) Scan the airspace where the small unmanned aircraft is operating for any potential collision hazard; and

(2) Maintain awareness of the position of the small unmanned aircraft through direct visual observation.​
Seems pretty poorly written. Interesting jumble of "and", "or", "either". Clearly I'm missing something.

A visual observer is optional, but if one is used then all flight crew (lol) must maintain direct visual observation. So at the point where the observer loses sight, as long as the pilot and the one in control can conform to 107.31 (a) 1, 2, 3, and 4 then the visual observer can be declared optional by the remote pilot in command and 107.33 does not apply, only 107.31 (b). ?

Maybe I need to see the requirements and responsibilities for the remote pilot in command. Probably not authorized to change the flight crew while airborne. Gotta love the Washington, D.C. vernacular and authoring style.

But it reads to me like 107.31 (b) is saying the remote pilot in command simply needs to ensure that either the visual observer maintains sight (and the other reqmts. of 107.31 (a)) or he and the one in control both can, or optionally all crew.
 
Seems pretty poorly written. Interesting jumble of "and", "or", "either". Clearly I'm missing something.

A visual observer is optional, but if one is used then all flight crew (lol) must maintain direct visual observation. So at the point where the observer loses sight, as long as the pilot and the one in control can conform to 107.31 (a) 1, 2, 3, and 4 then the visual observer can be declared optional by the remote pilot in command and 107.33 does not apply, only 107.31 (b). ?
That's not what is says.

It says IF an VO is used, then the Remote PIC and the person manipulating the controls (could be the same person) and the VO, must "maintain effective communication with each other at all times".

AND those three persons must coordinate to "scan the airspace ...." and "maintain AWARENESS of the position of the....aircraft through direct visual observation".

Which means that someone on the crew must have direct visual observation at all times.

The Remote PIC is responsible for ALL crew members and is responsible to ensure that all crew members are doing their jobs per the specifications.
 
That's not what is says.

It says IF an VO is used, then the Remote PIC and the person manipulating the controls (could be the same person) and the VO, must "maintain effective communication with each other at all times".

AND those three persons must coordinate to "scan the airspace ...." and "maintain AWARENESS of the position of the....aircraft through direct visual observation".
Right. That's what I said. Plus 107.33 (b) stipulates direct visual for the VO.

107.31 covers the PIC and the person controlling (both must conform), plus 107.33 covers the VO if one is used.

Which means that someone on the crew must have direct visual observation at all times.

The Remote PIC is responsible for ALL crew members and is responsible to ensure that all crew members are doing their jobs per the specifications.

Right again. The original question was must the VO (in this case multiple) always maintain direct visual. So as I read it, yes if one is used.

However since use of a VO is not required, at any point where the VO should lose direct visual the PIC can declare the VO not part of the crew, and as long as at that time the PIC and the person in control have direct visual then the flight is in compliance, yes?

So the practical answer is no, as long as the PIC and person in control have visual instead.

The only thing I see odd about this is that when the VO is used, the PIC must only ensure the VO has visual and not themself, provided there is effective communication to do so. But when a VO isn't used both the PIC as well as the person in command must each have direct visual. However, on reflection I suppose it makes sense for cases where the PIC is not in actual control of the craft since the PIC is responsible for the flight.

I see that your original reply to the question led me astray a bit in the 1st sentence, but that your 2nd and 3rd sentences seem to agree with the way I read it?
You are not in compliance if you or the visual observers lose sight of the UAV at any time.
Should it maybe have read "You are not in compliance if you and the visual observers both lose sight of the UAV at any time."? And then gone on to say ..
If you or one of your observers can see the UAV at all times, then you are in compliance.

You and/or your visual observers MUST maintain sight of the UAV at ALL times. Otherwise, you cannot take the flight without an approved waiver from the FAA.
?
 
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btw .. I'm thinking of going for the cert myself and want to make sure I understand it, which is the reason I brought it up again.
 
The wording is "a visual observer" and "if one is used".

As I read it, it means one VO. Not multiple VO's.

So I don't think you can have a VO every 1/8 th mile along it's course and have a relay of information and be in radio contact as this is not an effective way of communication should one if the radios fail along the chain.

I'm probably not correct in this but it does seem like a trick qustioin the FAA may ask.
 
The wording is "a visual observer" and "if one is used".

As I read it, it means one VO. Not multiple VO's.

So I don't think you can have a VO every 1/8 th mile along it's course and have a relay of information and be in radio contact as this is not an effective way of communication should one if the radios fail along the chain.

I'm probably not correct in this but it does seem like a trick qustioin the FAA may ask.
You absolutely can have a VO every 1/8th mile along the course and have everyone be in communication with each other by radio (everyone at all times must be able to communicate) and be in compliance. Someone who is part of the crew and property trained as a VO must have the UAV in visual sight at all times.
 
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Thanks for the info, I wasn’t sure if multiple observers were allowed. This is very new to me
 

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