Hello again, welcome back to our summer webinar series on operational waivers This is going to be about “Beyond Visual Line of Sight” it’s our next installment in our summer webinar series. I hope you tune in and watch the previous webinars because they’ve had valuable information that will lead us up through the remaining three, which today is “Beyond Visual Line of Site” followed by “Operational Altitude Waivers” and then “Operations Over People”. So today we are going to talk about “Operations Beyond Visual Line of Sight” Just a couple of basics again on the Adobe Connect platform that we’re attending the webinar through here today. The audio is going to be through computer speakers so make sure you have that dialed up to the appropriate volume. At the bottom of the screen you’re going to notice that question and answer pod, the Q&A pod That will remain active throughout the content presentation here today, also through the live Q&A and we’ll leave it active for a few minutes after the end of the webinar so you can finish typing your questions. That pod at the bottom of your screen gives you direct access to a production crew full of specialists from our legal department, our air traffic control department, our operational waiver team, as well as communications and many other specialists from flight standards that are here specifically to answer your questions on operational waivers. So be sure to use that resource throughout the presentation here today All questions will be posted on our website after our presentation wraps up When we get done with the content portion we will have our live Q&A as usual and that’s the time when you can ask me directly over the air any question you might have more operational waivers or really anything drone related that you’d like to try to get an answer to I’d like to point out that the session is being recorded, we do post all of our recordings online to our YouTube channel, we’ll have more information on that later on through our webinar here today So what are we trying to do today? Today we want to talk about “Operations Beyond Visual Line of Sight” under Part 107. In order to do that we have to cover some of the challenges that are directly related to operating beyond visual line of sight and help you understand what we expect to receive in your waiver application. Through that process we’re going to go through the Waiver Safety Explanation Guidelines because that is the key component to get you started on any operational waiver application that you submit but certainly for our Beyond Visual Line of Sight. So let’s start with the rule itself: 107.31 requires visual line of sight at all times. If we state that the remote pilot in command or the visual observer and the person manipulating the flight controls must be able to see the unmanned aircraft throughout the entire flight; and that vision you being able to see your unmanned aircraft must be unaided by anything other than corrective lenses This vision that you have of the UAS required by rule helps you to know the aircraft location, the attitude, altitude, determine direction of flight, observe the airspace around your UAS for other traffic and also to ensure that your unmanned aircraft doesn’t endanger anybody or anybody’s property. That’s a critical key component of the rule itself. Throughout the entire flight those things that I just mentioned have to be seen by the remote pilot-in-command or the visual observer that’s the rule that’s what we’re all operating under But today, we’re talking about the waiver to that rule and 107.200 does allow us to wave 107.13 meaning you can operate beyond visual line of sight with an approved waiver. A reminder that when you’re submitting any waiver to the FAA you must submit that application: including a complete description of your proposed operation and justification to us that your operation can be safely conducted. That’s right in the rule itself and it bears repeating. So let’s talk a little bit directly about the risks of operating beyond visual line of sight. There are many as you probably know but I want to focus on three key elements that are really the main cornerstones so to speak of this waiver application. The first one is that operating beyond visual line of sight does not remove the responsibility for the remote pilot in command to “See and Avoid” other aircraft. There’s also issues related to the command-and-control link frequency spectrum. So there’s a lot of frequency and technology concerns with operating beyond visual line of sight Also the reliability of your equipment is important; we’re talking about failure rates, latency rates, notification process and procedures that you have as a remote pilot-in-command that you will need because you can’t see your unmanned aircraft when you’re beyond visual line of sight. In a lot of ways BV loss (Beyond Visual Line of Site) is a technology waver. When we look back at the waiver we reviewed before which was a daylight waiver for operating at night; sure that incorporated some technology. We had to have lighting equipment on the UAV, we had to have certain software that you were going to use to mitigate certain risk,

but most of it was a procedural based application: What are you going to do? and how are you going to do it? Beyond visual line of site takes that same type of procedure the what and the how and adds in a lot of technological requirements So let’s kind of go through some of this here. The big component the big concern we have with operating beyond vision line of sight is “See and Avoid”. As I just mentioned that still is the remote pilot in commands responsibility. Now obviously when you’re flying beyond visual line of sight you can’t see the aircraft itself, so how are you going to maintain that “See and Avoid” responsibility? A lot of people will put in “I’ll use ADS-B”. ADS-B is how I’m going to detect or how I’m gonna see and avoid. That’s not a magic cure because a lot of aircraft do not have ADS-B installed nor are they required to have ADS-B installed; depending on where they operate. Another factor in terms of installing an ADS-B type transmitter or receiver on your unmanned aircraft is that it needs to be TSO certified: TSO compliant. That’s a technical standard order. So that’s just some things we’re seeing in the applications that people are putting in there thinking that they’ve solved all the problems when really it’s not exactly the end-all solution to this “See and Avoid” responsibility. Another component of that is what are you flying over? Now if you’re operating within visual line of sight you should know exactly what you’re flying over because you can see your unmanned aircraft but when we go beyond that how do you know you’re not flying over a lot of people? How do you know people or cars or other vehicles aren’t underneath your UAS? That’s going to be a responsibility you have as an applicant to let us know how are you going to avoid flying over people on the ground because just like operating with the “See and Avoid” and giving “right-of-way”, operating beyond visual on a site doesn’t negate the rule that you’re not allowed to fly over human beings. Another concern that people have when beyond visual line of sight is frequencies; the frequency spectrum This is where we get involved with the FCC as well. Many frequencies that you’re “I bought it from the store open up the box and I’m flying my drone” operate on our shared: they’re shared by Wi-Fi routers, they’re shared by garage door openers, etc. It’s a real concern to us and the safety of the National Airspace System that when you’re flying somebody opening their garage door doesn’t cancel your command-and-control link or cause your UAS to take a different path and you originally intended. In talking in terms of transmission; the range obviously is another key component. How far can your UAS go and still transmit a signal back? and How far can your UAS go where you can still receive that signal? Obviously that’s critical it gets back to that command-and-control link So anything that transmits a signal in the U.S. has to carry an FCC license. In fact if you probably look on your UAS you’ve got an FCC logo somewhere on there being that the frequency has been licensed. You need to make sure that whatever frequency are using to command-and-control your UAF beyond visual line of sight is FCC approved is FCC licensed Another component you’re going to have to deal with any time you fly visual line of sight or beyond is weather, right? So just because you’re operating beyond visual line of sight does not mean you do not have to comply with the weather requirements. So one of the big questions is when you’re flying far one, two, three, four or five, ten miles away maybe from your control station is; how do you know what the weather is? how are you gonna do your pre-flight weather briefing?A lot of people have indicated that they’re gonna use radar to help with the cloud clearance requirements. The problem with that is radar doesn’t show clouds radar shows precipitation. So radar does not answer the cloud clearance requirements that you are going to run into when operating beyond visual line of sight You as a remote pilot must maintain flight visibility and cloud clearance requirements as per the rule. Finally let’s talk a little bit about equipment reliability before we get into the waiver safety explanation guidelines. There is a concern when operating beyond visual line of sight that you’re not going to have direct control within visual line of sight of a UAS and have an equipment problem. So we need to know what type of assurance is that you’re providing us for your equipment reliability. What are the failure rates of the components; the bearings, the propellers, the batteries, the software you’re using to control it? Do you have life limited parts; replace bearings after every 100 hours of operation or after every 50 hours of operation? If so does that require you to have a maintenance program? Are you going to establish a program to ensure continual maintenance of your aircraft that you intend to fly beyond visual line of sight. What about the system architecture itself; the software, the hardware, the command-and-control link All that blends into your system architecture. What is the failure rate of that system? What operating system are

you using? That’s the information that you as the applicant will need to provide to us here. So where do we start this process now that we understand some of the risks but not all? Start with the Waiver Safety Explanation Guidelines You’ve seen me say this in every single episode and I’ll continue say it again If you start with the Waiver Safety Explanation Guidelines you are on the right path to working towards a successful waiver application approval Now, when you’re addressing the Waiver Safety Explanation Guidelines remember our primary concerns here at the FAA are do you providing us an assurance that you’re going to operate safely at all times and that if circumstances arise in your operation you have a process or procedure to address those circumstances Those are the information, those are the concerns that we need to get from you addressed in your waiver application and it’s important to remember; even though you’re following the Waiver Safety Explanation Guidelines and you’re addressing all the key components particularly for operating beyond visual line of sight you’re probably going to have to go into more depth more detail on your risk management and your mitigation strategies for operating in that type of environment. So the list of questions in the Waiver Safety Explanation Guidelines are a start to your waiver application. They’re to get you there on the right foot they’re not going to be all-inclusive and you’re most likely going to need to provide additional information in that application to us. Now, the Waiver Safety Explanation Guidelines for “Beyond Visual Line of Site” has seven key areas that it addresses with different sub parts and we’re going to go through each one of those key areas to try to help you understand what they mean, what we’re kind of looking for, and what people put in there necessarily that works and kind of doesn’t work. So the first is remote pilot-in-command basic responsibility. You’re flying an aircraft you need to know what that aircraft doing at all times throughout the entire flight envelope. The “See and Avoid” concept is in there. How are you going to detect other aircraft? How are you going to avoid other aircraft? What about people on the ground? What about ground-based structures or obstacles? How about ensuring that your unmanned aircraft can be seen for a distance of at least three miles? or How are you going to be alerted if your UAS is failing in some capacity? Whether that’s a bearing that’s coming down, or a battery that’s failing faster than you intended, or there’s a link issue how are you going to know that as a remote pilot-in-command? And the last three are making sure that people who are in your program who are operating with you to do this beyond visual line of sight understand the risk; importantly with GPS. A lot of people will put in GPS technology as their navigation source and a lot of the risk mitigation involves GPS too. How are you going to make sure that everybody understands the capabilities and limitations and process for a GPS failure in that event? We talked a little bit about weather, we’re going to talk about it some more because there are some specific concerns we have with weather and determining weather conditions when you’re flying. And finally we’ll wrap up with the talk of the description of transmitters, control links, receivers, emitters, and those types of things. So let’s get into the Waiver Waiver Safety Explanation Guidelines here The first one talks about the basic airmanship stuff. Knowing what your aircraft is doing at all time. So even though your a remote pilot-in-command your aircraft is flying beyond visual line of site you need to know this information in real time. You have to know it at all times. So telemetry is good but some questions about telemetry that you probably want to think about in your application: What is that telemetry data providing you? What type of information are you getting from that telemetry? What’s the failure rate of that software? How do you know that the software is accurate? or is there a latency in the reporting? Are you getting information back in real time? or Is there a five, four, six, eight second delay and then information coming back to at your telemetry station? So how fast are you getting that information is critical and knowing what your aircrafts doing at all times? So if the primary information fails. Let’s say your telemetry data goes down. How are you gonna know that? or If the latency rate increases? So, let’s say you’ve got milliseconds of a latency rate (which is great) how are you going to know, how is the system going to tell you that that latency rate is increasing? (Which could cause problems). Because if we go from milliseconds (almost instantaneous) to a five-second delay that could be a large problem. What are you gonna do with the lost link? That’s huge with the operating beyond visual line of sight. If you can’t control the aircraft what happens next So what are you going to do when this stuff doesn’t work is as important as how are you going to use this stuff when it is working. The second part of that Waiver Safety Explanation Guidelines talks about the performance and capabilities of your transmissions and receivers. Essentially what we want to know is… if you’ve determined that your transmission and receiver, your

operational area so to speak, can be a certain radius or distance. How are you as a remote pilot and command going to ensure that your aircraft stays within that area? How will you know if you’re getting close to exceeding the limit of your command-and-control frequency? So we need details on transmitters and receiver ranges. How are you going to know this stuff is working prior to flight? So again as a remote pilot-in-command all this information has to be determined prior to flying because you have the responsibility to know what that aircraft is doing Then next Waiver Safety Explanation Guideline talks about avoiding “See and Avoid” other aircraft, “See and Avoid” obstacles, structures and things like that. Well, if you’re not directly looking at the UAS if we’re going beyond visual and a sight how are you gonna do that as a remote pilot-in-command? So clear detailed information needs to be provided. So I put it out here because I mentioned it before but when you operate beyond visual on his sight you are still required to follow the remote pilot-in-command responsibilities identified in 107.19 or ensuring that you’re not conducting a hazardous operation, that you’re giving right away, that you’re not operating over people. These are all rules that you’re still going to be in compliance with when you’re flying beyond visual and a sight. So how you do that is very important and you need to share clear detailed information how are you going to comply with those rules. How about other aircraft? How do you know where other aircrafts are? You can’t see your aircraft so how do you know what other aircraft are flying around? So, if you’re going to detail a system for identifying other aircraft and on how you’re going to find out where they are or what direction they’re moving, what altitude they’re moving. Where does that information come from? Is the information gonna be in real time? You know some people say “oh, I’m going to use third-party software I can find online, anybody can go to it and it shows me all the other airplanes in my area”. Well a couple things: is it real time or is there a delay on that information? And is it really showing you all aircraft or is it just showing you aircraft to have a discrete transponder code? That information is critical because not all aircraft are required to operate on a discreet transponder code; which is sending a signal to a radar station. So how are you gonna comply with this “See and Avoid”? How reliable is the information you’re getting from your data source? All very critical operating beyond visual line of sight When you do detect another aircraft, airborne vehicle, launch or re-entry vehicle; if you happen to be near one of the coasts and they’re doing spacecraft launches. How are you going to avoid that? What what equipment onboard your system, your UA or your transmitters, that’s going to talk to you that’s going to allow that craft to avoid the other aircraft operating in the area. You still have that responsibility, you need to provide us with that information. So you can see as we go through some of these Waiver Safety Explanation Guidelines, operating beyond visual line of sight is very detailed It’s not impossible; but it’s certainly a complex waiver request. So how are you going to avoid flying over people on the ground? How do you know if there’s people underneath your UA if you’re flying beyond visual line of sight? Well you could look at how populated is the route you intend to fly: Are you flying over a city? Are you flying in a sparsely populated area? Are flying over a desert? All these things play into the probability of you operating directly over somebody. So what mitigation strategies based on your operational environment like: What airspace are you flying in can you incorporate to reduce the risk? Can you modify your route? Can you change to the operative or sparsely populated areas only? That’s really up to you as the operator to provide that information to us because you know your mission best. So, if you’re going to alleviate this risk of flying over people by doing something, explain that to us. Don’t make an assumption that we know exactly if you give us a latitude longitude from point A to point B that we know the area You have to provide that information you have to maybe scout the area look at the people, look at the congestion and make your mitigations based on actual data coming back. So if you’re going to use technology to mitigate this risk of avoiding other aircraft or people or structures and things like that, tell us about it What type of equipment are you using how does it work? Again I’ve said this before in other presentations the “what you’re doing” or “what you’re using” is just as important as the “how are you going to use it” or “how does it work”. That’s very very key in your waiver application Furthermore is it tested to determine reliability? So what’s the failure rate of that equipment? What’s the failure rate of that technology you’re using to see and avoid other aircraft? We talked about this a little bit earlier and this also is in our daylight waiver application Waiver Safety Explanation Guideline. How are you going to increase the conspicuity

of your UA to be seen for at least three miles? Now remember we’re going beyond visual line of site. This isn’t a requirement so that you can see your unmanned aircraft at three miles or more, it’s a requirement so that other aircraft, people can see your UAS at that distance If you don’t need to increase the conspicuity of your UA because you’re operating in a TFR or there’s some sort of restricted airspace where you’re going to be the only one out there; let us know that let us know what that process procedure airspace requirement let us know how all that is set up. Otherwise we’re gonna ask that you show us how you’re going to increase your visibility of your unmanned aircraft for at least three miles. The Waiver Saftey Explanation Guidelines then going to talking about how you’re going to be alerted of a degraded UAS function. When we’re flying in visual line of sight we can see this. We can see that the UA itself we know if that’s doing something that we don’t want it to do; you can almost hear it in a lot of ways; if you’re starting to lose power, or a propeller blade is going, or rotor blade is going you can hear that audibly and you can make your determination that hey I’m starting to have a system failure of some kind. When we go beyond visual line of sight we don’t have those luxuries. So how are those equipment failures going to be reported to you as a remote pilot-in-command? Are they going to be reported to you as the system degrades? or is it going to wait for a system failure and then report it to you? And once it’s reported to you what do you do now? So there could be a lot of ways that your UAS flight beyond visual line of site can go badly. We need to know how you’re going to address that How are you going to be notified? What process you’re gonna follow it to address those types of issues of equipment failure? So if you have a UAS and it’s got a determined level of reliability please provide that information to us. We’ve talked a lot about equipment and reliability in this presentation. But some of the things that we’re curious about if you’re saying my UAS has a determined reliability of one failure with every 7000 hours or something like that we need to get that information. So what’s the mean time between failure testing with the results? Or what’s the reliability? Or what maintenance program are you following? Are their life limits on the equipment that you using? Not only the UAS itself, but the command and control software or capability control station you have. What is it doing? How is its failure rates compared to the other aircraft? So that’s the system architecture, the hardware, the reliability. You can see what we’re going with this, we want to know how reliable your equipment is and how that reliability was determined. So now we’re talking about the people you’re flying with when we get to this Waiver Safety Explanation Guideline question. The people that are on your crew, the people that are helping you out. Do they understand what you’re doing? Do they understand the limitations? Do they understand the procedures for your operation to follow if things don’t go the way you intend? So how are you going to determine things like GPS reliability? Are you going to have help with that? GPS reliability may involve more than simply checking a NOTAM to make sure that a GPS satellite is up, because flying around buildings, depending on its structure and depending where the satellites are that can affect your GPS reliability. So that’s something you need to consider before you go flying. If your UAS relies on a GPS not only for flying from point A to point B or point A to point B point C and back What happens if GPS goes out? What happens if a satellite goes down during mid-flight? What happens if your equipment on board your small unmanned aircraft no longer receives the GPS signal? We’ve had a lot of applicants say “if that happens I’m going to hover in place” The problem with that is most hover in place functionalities of UAS require GPS So if the GPS is down hover in place doesn’t necessarily work. So how are you going to accomplish a safe letdown of your UAS if GPS signal is lost? That’s something you have to consider in your application. We talked about this earlier is one of the key components or one of the considerations you have with operating beyond visual line of sight: weather. How are you as a remote pilot-in-command going to ensure that the weather you’re operating in and the cloud clearances that you’re maintaining for your aircraft are consistent throughout the entire flight when you cannot see your UAS. So I mentioned before radar doesn’t really radar will not show clouds so radar’s not a great tool to use for for cloud avoidance as required by 107.51 A lot of people say “oh I’ll pull weather from airports and reporting stations around”. That might work depending on your route of flight. But if you’re 10, 15, 20 miles away from that airport can you be sure that they whether you’re encountering is the same weather that they are encountering at the field. That’s something you have to consider Where is that weather source

reporting from? So there’s pre-flight requirements for weather as well. That’s something that you’re really going to need to research as a remote pilot-in-command operating beyond visual line of sight How are you going to tackle that that? That weather issue? Finally we wrap up here when we talk about transmitters or emitters and command and control links and things like that Do you have an FCC grant for the frequency spectrum that you’re going to use to operate your UAS. If you do include that in your application. Include the frequency license used by the unmanned aircraft or at the pilot station. If you don’t have a dedicated frequency (so you’re not sharing with everyone else) there is possibly a potential of you leasing a frequency from a license holder. That’s something that you can look into as well. If you’re going to do that and you’re going to lease a frequency to operate your UAS on make sure you include that lease agreement in your waiver application So remember the FCC requires that anything that transmits a signal has to be licensed and viewed by them and reviewed by them I should say before it’s allowed to operate. So it’s an FAA concern and it’s certainly an FCC concern when we’re talking about transmission. When you’re going to use emitters or transmitters make sure that you include in your application the frequency or frequencies that you plan to use to transmit on The type of antenna, the gain, the pattern or the maximum range, the transmission power, in watts and in decibel milliwatts that’s information that’s critical to your command-and-control link, the range of the UAS as well as FCC licensing. So make sure that when you’re applying for you Beyond Visual Line of Sight Waiver you get really into the detail on your transmitters because command-and-control is absolutely just as critical as “See and Avoid”. With your emitters whether they’re using a modulation or they’re the receiver sensitivity, system losses Do you have acceptable bit error rates? Again these are just some ideas that we want you to consider in your application This is all part of our Waiver Safety Explanation Guidelines. So you all have access to these types of questions that I’m posing here today because they’re all part of that document so please review that document thoroughly. So three takeaways from this and I’m going to put one up here that’s not necessarily listed: Beyond Visual Line of Sight is not impossible to get, but it is a very complex high-risk UAS operation which will require a very thorough detailed risk mitigation strategy and risk analysis program that you have in your application. It’s not as simple it’s not as simple as answering yes/no on these Waiver Safety Explanation Guidelines questions you really have to get into the nitty-gritty details when you’re talking about operating BV loss. So top three tips: know the airspace you intend to operate in, incorporate process to ensure that your remaining compliance with the other parts of the rule (things like not operating over people and whether requirements), also ensure that the remote pilot-in-command will have control of the unmanned aircraft at all times If GPS goes down if your command-and-control link goes down those types of things need to be addressed in your application. So where do you go for information? The usual suspects here: our FAA UAS website is a great one-stop shop for all your UAS needs, the DroneZone documents when you go to our DroneZone portal (you see the website on the screen there) that’s where you’re gonna have the Waiver Safety Explanation Guidelines that I’ve just reviewed with you all as well as application instructions our, webinar series viewed in its entirety is a great resource for you before you start your waiver application process. If you view this series you’re off to a tremendous start with your waiver application versus just trying it shooting in the dark and hoping you get a “yes” All of these videos are previously that will be recorded are put online. All the question and answers that you guys have been submitting and that we’ve been addressing will be put online and the website for that is on your screen there at www.FAA.gov/go/waiver. So that wraps up our short presentation here on Beyond Visual Line of Sight, as usual we’re going to take just a short break before we get into our live question and answer session. So I appreciate you tuning in please stick around because the Q&A pod will stay active throughout this time. You can still type in your questions to our experts who will try to get to them as quickly as possible and then the bottom another minute or so here you’re going to ask your question live on the air with me. So thanks again for joining us please stay tuned we’re just going to take a short break

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