Want to fly your drone at night? Learn how you can with an FAA waiver!
Hello, everyone, welcome back to the summer webinar series presented by the Federal Aviation Administration. I'm Kevin Morris. I work in flight standards, and I'll be your host again today for part two of our double feature week on Daylight Waiver Applications for Part 107 operations. So, today we're going to talk about a few things related specifically to Daylight Waiver Applications. It's a continuation of Part 1. Part 1 was started on Tuesday, and so, this would be the Part II follow up for that. Again, just a reminder on the basics, the audio is gonna be through your computer speakers, and the sessions are being recorded, and we'll have the website at the end of this presentation to show you where you can go view previous webinars that we've done.
We do have the Q&A pod. It is now active at the bottom of your screen, and probably one of the second, or at least maybe, the second most important thing that you guys have access to today, other than the content, is you have access to FAA UAS experts, and you get that access through the Q&A pod at the bottom of your screen. So, if you do have a question related to waivers, or airspace, or anything Part 107 related, please put the question into the Q&A pod, and we will try to answer it today. If for some reason we're unable to answer it, it will be answered, and posted to our website, which is the same website where you can view the previous webinar series we've done, and again, we'll get you that address at the end of the presentation.
So today, is a continuation of the Dark Knight. This is episode 2, and what we want to do is walk you through the application process, specifically related to operating your UAS at night. So, we're talking about Daylight Waivers. We hope to clarify this process for you, and in the process of that, help you understand what the FAA expects from you. So, Part 1 of our Dark Knight covered the challenges of operating at night, and we dove a little bit into the Waiver Safety Explanation Guidelines, specifically question number one. So today, we're going to cover question numbers 2 through 5.
And this is important because these questions are some of the most often missed elements of waiver applications. Specifically, Waiver Safety Explanation Guidelines questions number two and questions number four. More on that in a little bit. So we've mentioned it again. We're mentioning it again. I should say we've mentioned it before, the Waiver Safety Explanation Guidelines – This is your starting point, and this is what we're going to be focusing on today through this webinar.
Helping you understand how these questions relate to your operation, and by helping you understand, you'll increase your chance of having a more successful waiver application. When you're filling out your waiver application, when you're looking at these questions, keep in mind what we, as the FAA, are looking for is: How are you going to ensure your operation remains safe at all times? That is a key element in starting your safety case for your operation, and then if unusual circumstances or different circumstances arise, how are you going to handle that? This information must be included in your waiver application, and again, the Waiver Safety Explanation Guidelines is a great place to start.
Now, we've said it before as well, these are not all-inclusive questions. Simply because you answer the questions that we put forth on the Waiver Safety Explanation Guidelines, doesn't mean you've hit all the marks. Each operation is unique, and because each operation is unique, you may need to supply more information to us to help with our assessment of your application. But the Waiver Safety Explanation Guidelines is a great place to start. So, as I mentioned earlier, we covered topic number one of the Waiver Safety Explanation Guidelines for Daylight Waivers, which was talking about maintaining visual line of sight.
How are you going to do that at night? So, if you want to find out the answers of those questions, please view our part one of this two part series. Today, we're going to cover the rest. So, we're gonna talk about seeing and avoiding other aircraft, knowing your telemetry data, knowing what your UAS is doing at night, ensuring that the people associated with your operation are knowledgeable on the challenges that night operations pose, and then increasing the conspicuity of your small unmanned aircraft. So, how are you going to make sure that that vehicle is visible to other aircraft and other people operating at night? So, let's get right into it! Waiver Safety Explanation Guideline question number two talks about wanting to know how you're going to, as the remote pilot-in-command, see and avoid other aircraft, and people on the ground, and ground-based structures and obstacles during darkness? That's a lot of information on the one topic. So, I've highlighted some words in bold there, on the right side of the screen, specifically and because, all of these elements need to be included when you're addressing this Waiver Safety Explanation Guideline question, and where people fall short is that they don't address all of the concerns.
So, I'm gonna walk you through a little bit of that today, and hopefully, this will help you out in your application. So, one of the first questions we want you to at least understand here is: How is the remote pilot-in-command, or if you're going to use visual observers, locate other people? How are you going to know if other people, or aircraft, or obstacles are there in the dark? Remember, the remote pilot-in-command, you need to know what you're flying over, and probably one of the easiest ways to handle that, is to survey the location during the day. Again, that is not the solution to everyone's operation, but it might help you out if you're operating in a particular area. that's unfamiliar to you, that has a lot of obstacles, to do a daylight surveillance of that.
A lot of applicants will indicate at this point to that there is adequate lighting in their operation. So, they know where the obstacles are, because adequate lighting is there to help illuminate that. The problem is the word "adequate" is a little bit subjective, and it's really operationally dependent. So, if you're going to say that there's adequate lighting, you're gonna need to help us understand: What do you mean by "adequate"? On this topic again, a lot of people put in, "I'm going to use thermal cameras, or Infrared, or some other aided vision to help me avoid obstacles during the dark." And while that's a great tool to have in your operation, in part of a great mitigation strategy, remember that, things like thermal vision and infrared are considered aided vision, and what you need to operate at night, is you need to be able to see visual line of sight. You have to see those obstacles, as a remote pilot-in-command.
Certainly, that information can help you, but it's you, as the RPIC or the remote pilot, that needs to find these obstacles. So, consider marking, in some form or fashion, the obstacle. So, if you run out and do a daylight surveillance of the area, maybe there's a way that you can mark these obstacles that are gonna be in your flight path, so you know where they are at night. So now, what do we do if other people or aircraft are located during the flight? This is a big question. This is the big question where we get a lot of the "WHAT," but not a whole lot of the "HOW." So, a lot of applicants will say: "I will avoid any aircraft, or helicopter, or person that enters my area of operation at night." Great.
How are you going to do that? How are you going to avoid them? Are you going to utilize multiple visual observers? Are you going to position those visual observers in unique spots to help you identify anybody that's coming into your operation area, or any aircraft that's coming into your operation, that you did not plan on? And then if they do spot other people or other aircraft, how are they gonna notify you as a remote pilot-in-command. Is this a two-way radio? Can they shout? I mean, can you hear that person where they're talking to you? We talked a little bit about this in part one of The Dark Knight, but what modes does your UAS have to assist you in deonflicting with other people, or deconflicting with aircraft coming into your operational area? Again, that return-to-home, that's a nice feature to have, but as we saw in the previous episode we did earlier this week, that's not always the full solution. So, you need to explain to us how you're going to deconflict with unknown persons or unknown hazards that become known to you in your operation.
What is your process for that? We also want to make sure that you have a risk mitigation strategy to avoid hitting things at night. How are you going to, as a remote pilot-in-command, ensure that you're not going to run into something or strike something during flight at night? So really, you need to ask yourself: Are you aware of where all the obstacles are? So, how are you going to know the location and orientation of your unmanned aircraft, so that it remains clear of these obstacles that you are aware of? Does your flight crew, your visual observers, do they know where all the obstacles are? How do they know? Can they communicate effectively with you? A lot of people talk about Illuminating the operational area at night. Now, that doesn't work in every case, because we all know part of the reason we fly at night, is because the unique photography or videography type information it can get us, but if you're going to illuminate your area at night: How are you going to do that? Is that flood lighting? Are you going to mount external lighting on the UAS that you can activate or deactivate to help you identify obstacles, as you move toward the mission area? If that's your plan, let us know.
Again, key thing, we can't make assumptions in this. We need you to explain to us how this stuff is going to work. So, we talked about this lighting, and how do we know that lighting is going to be sufficient or adequate, prior to the operation? This is very much dependent on where you're going to fly. So, the lighting that you put on your UAS at night, how do you know that that's gonna be sufficient before you fly? Because if you're flying in the city or in a sparsely populated area, your lighting requirements are going to change. It also depends on what you're flying over. City, park, or residential housing, or perhaps open water? Where, if you're flying over open water on a clear night, you may be getting some reflections off that water with your light.
So, as important as it is to make sure that the UAS has appropriate lighting, it's important to make sure that that lighting is adequate for the area that you intend to operate. Again, that's information that you need to help supply us, so we can do a risk assessment on your waiver application. So, the next Waiver Safety Explanation Guideline topic talks about how you, as a remote pilot, know the attitude, the orientation, the movement, which way your UAS is pointed at night. Because if it's dark, depending on the configuration of your unmanned aircraft, it may be difficult for you to obtain it, simply by looking at the vehicle. So, a key point to remember in all your night flying is: You are not exempt from, or not waived from, the requirement to maintain visual line of sight . A lot of applicants will put in, "I'm using telemetry data." That's how I know exactly which direction my UAS is pointed, or which direction it's moving, or where it is flying geographically." Again, telemetry data is a good starting point, but it's not a complete answer, because you have to maintain this visual line of sight with your aircraft.
Therefore, you have to be able to know, by simply looking at your unmanned aircraft, what it's doing visually; position, attitude, altitude, movement. So, colored lighting can help with that. Strobes can help with that. What we want to do, is make sure that, while you're operating visual line of sight, as a remote pilot-in-command, you continuously know real-time information. That is; the geographic location, your altitude above the ground, the attitude of the aircraft, which is the the deck angle or pitch or bank of the aircraft, and you also want to know what direction that aircraft is moving, and that all has to be done, primarily, visual line of sight.
Again, telemetry, you can use it as a backup, but you need to ensure that you can do this visually. So, if you're flying at night, how are you going to know the real-time geographic location? Well, there are certain things you may be able to do. You can uniquely position your visual observers to help you ensure that it never leaves a certain mission operation area, that you defined previously.
You can use geofencing capabilities in your program. So, if your software allows you to stop the vehicle, stop your aircraft moving beyond a certain point, or if you can put a Polygon. directional control in there, how do you keep that from exceeding those parameters? That might be something that's capable on your aircraft that you want to let us know about. So that, you always know the geographic location. What about altitude? How do you know the real-time altitude of the unmanned aircraft? Well, again, your telemetry data can help support your knowledge of the altitude, but can the software itself also limit how high your UAS Is going to go? Or maybe during mission, how low it's going to go? For example, if you know the treetops in your area are roughly 50 feet high, can you limit via software that you know your unmanned aircraft will be no lower than 60 feet, during your operation? That's a mitigation strategy, and through that technology, can help you maintain that safety factor with your altitude.
So, do your visual observers know how to take a look at your UAS, and see how high it is? Roughly, how high it is? Again, this information needs to be obtained visually, but certainly, you can use backup devices, like telemetry. What about the deck angle, or pitch, or the bank angle, or the orientation of the UAS at night? Without lights, this might be quite challenging. So, when we're talking about differential lighting: Are you using different colors on the front or the back of your UAS? Are you using different colors on the top or the bottom? Or does the actual configuration of your UAS, the actual aircraft itself, provide clear data. For example, a fixed-wing UAS versus a quadcopter UAS. Or maybe the fixed-wing gives you clear indication of what direction it's going, and where it's pointed. But how is that information going to be obtained by the remote pilot-in-command at night? Put that information in your waiver application.
So, differential lighting is also about direction of flight. So, do you have different lights on the front or the back? If most UAS flights tend to go straight out and straight back, depending on operational needs, if the UAS is moving slowly away from you or slowly towards you at night, can you tell the difference, simply by looking at the aircraft itself, and using the lighting configuration to help you with that? So, different colored lights on the front or the back, or the left or right, that can help you out, and again, your telemetry data can assist you with that; but you, as a remote pilot-in-command, need to pick up this information VISUALLY- The whole visual line of sight requirement.
The next topic we have, and the Waiver Safety Explanation Guidelines talks about: Knowledge. So, this is knowledge of the remote pilot-in-command. It's knowledge of maybe, the remote pilot that's flying it under the authority of the RPIC. It's knowledge of your visual observers, anybody that's part of your operation. How are you going to ensure that they understand the challenges operating at night poses? So, they'll think back to part one of our episode, we're talking about: Visual illusions, how the eye works, how the weather can change at night. Those types of things. How do you know if your flight crew understands all those risks? Obvious answer: We do training! Testing, education, continuing education. We would ask that when you put this information, you consider a few things: Who is going to maintain this information? Now, it might make most sense for your operation to have the responsible person maintain all the documentation related to your operation, underneath that Certificate of Waiver. It may not. But whatever person you choose, whoever's gonna document it, needs to be identified in your waiver application, and furthermore, How are you going to train these folks? Is it going to be an online course, that you're gonna make them take? Is it simply you lecturing them? Or are they going to attend a ground school somewhere? Is it a self-study course? Here's the book, or here's the chapter, please read this, and let me know when you're done.
If you're going to have somebody teach the class, it might be important to let us know what their qualifications are. Are they a private pilot? Are they a current private pilot? Do they teach ground schools? Are they a flight instructor? Are they somebody with their Part 107 Remote Pilot Certificate? That information we need to know, and the reason we need to know it, is because a lot of mistakes. Again. this topic we're talking about here is another highly missed opportunity during our waiver applications.
We need to know what that information is being transmitted. So, we need to know what you're talking about, and who is talking about it? So, a lot of applicants will say, "I'm going to use companyname.com." Whatever that company is, some .dom company's online training course, and then that's the end of it. The problem is, we don't know who that company is, and we don't know what the course is about.
So, if you're going to say, "I'm going to use ABC or some company.com training course for online training, provide us with what's being taught. What's the outline? What are the topics? How long is the course? Because that simple answer of, "I'm just using an online training." It doesn't work. It doesn't provide enough information. One thing I do want to mention at this point, when we're talking about online training or online courses, the FAA, the Federal Aviation Administration, does not approve, or endorse, any Part 107 training providers. So, if you're going online, don't look at somebody's website, and think they've got an FAA seal on there, and that equals an automatic endorsement from the FAA for Part 107 training, because we do not endorse, or approve, Part 107 training at this time.
But if you're going to use it in your application, be very precise on what it's going to be about. Once you've done the teaching, once you've done the training, how are you going to verify that the transfer of knowledge has taken place? Essentially, how do you make sure they understood what you're teaching them? So, are you going to use testing? There's no requirement that you use testing, but testing is probably one of the most common methods we use to verify knowledge transfer.
If you're going to test, is it going to be a written test? Is it computer-based? Is it a verbal test, where you're just sitting down and quizzing them? And then once the test is complete, what's a passing grade? How are those documents gonna be maintained? Are they gonna have to come back every year and do training with you? There's no necessarily right answer to this, because each operation is individual.
What works for you? What process are you going to use in your application? And then let us know, in as much detail as possible, when you're making your safety case. The last point we want to talk about with the Waiver Safety Explanation Guidelines is increasing the conspicuity of your unmanned aircraft at night, so that it can be seen for at least three miles. Remember, this portion of the Waiver Safety Explanation Guidelines is not so much to ensure that you, as the remote pilot-in-command, can see the lights for three miles, but that the lighting can be seen for three miles for non-participating aircraft, or non-participating persons. Because, as we've talked about before, your requirement to maintain visual line of sight, does not include simply staring at a tiny light way out from the distance, and knowing that it's attached to your unmanned aircraft. You have to see your small unmanned aircraft visually at night when you're operating. So, this portion of it here, is your chance to tell us how you're going to ensure that other aircraft operating can see your small unmanned aircraft flying, for at least three miles away via lighting.
So, lighting plays a huge role in this; the color bit, the intensity or the strobes that you're going to use. Are you gonna put lighting on top? What about on bottom? How about the strobe operation? Is that something you can activate or deactivate, depending on your mission needs? If so, we need to know about that. Some folks have used illuminating tape. Tape that is just simply blowing the dark tape. Excuse me, that may work for your operation, as well. Again, your operation is individual. So, whatever works best for you, whatever safety mitigations you're providing, please provide that to us. So, with lighting, and we mentioned this earlier, but where you're flying, plays a large role in what type of lighting you're going to need. If you're way out in the country, and it's dark, you may not need very, very bright lighting; but if you're operating in a city or urban environment, then you may need a lot of bright light, and bright lighting on your UAS, because you're competing with that background lighting.
If that's something that you can control, you can adjust the intensity on the on the aircraft's lighting, let us know, because that's an important safety feature that you're going to use. Finally, if you're going to state, or if you're going to operate in an area where, you do not need to incorporate this type of lighting that can be seen for three miles, because let's say you're operating in a temporary flight restriction area, where there's no other aircraft permitted, or you're in a restricted area where there's no other aircraft permitted, you can let us know that, but this is going to increase the risk of your operation.
Keep that in mind. And as you know, when the risk increases, because you're not going to ensure lighting visible for three miles, you're going to have to have the same type of increased mitigations to ensure that that risk is brought down to an acceptable level. So, some people say, "I'm using a powered tether system." So, the tether on my UAS is also the power cord from a UAS, and if if that were to fail, the UAS comes straight down. That might work for you. We've had some people say, "Well, I don't need to have lighting visible for three miles, because my UAS can never get away from me, because I have fishing line attached to it." That may work as well. But what type of fishing line do you have attached? Is it five pound? Ten pound test? Could it survive a rotor blade strike from your UAS and still continue to tether? That information that we're going to need.
This gets back to making sure you're providing complete, detailed information to us in your waiver application, when you're looking at these Waiver Safety Explanation Guideline questions. So it's a little bit of shorter episode today, but I want to make sure that we covered the remaining topics. And then also, our three tips here at the end. Remember, when you're applying for a Daylight Waiver, make sure you understand the increased risks present with night operations.
Understand the technical requirements Needed to mitigate those increased risks. And, at the very, very start of every waiver application, make sure you're reading through both the Waiver Application Instructions, and the Waiver Safety Explanation Guideline Questions. We do have some resources that are always available for you folks. I use the Airplane Flying Handbook to get a lot of this content here today, and that's available in our drone zone, Drone info zone downloads, on the left side of the page there. Chapter ten is night operations. The Remote Pilot Study Guide has some additional information about operating during twilight, civil twilight hours and challenges at night. Our website is our one-stop shop for everything UAS. So, if you can't find it here, during this webinar, you can go to our website, there on the screen, and it will have a lot of information for you about a variety of UAS topics. The Dronezone documents are found on their Dronezone portal. That's the same portal that you do your waiver applications through, your registrations through, but you'll find the Waiver Application Instructions and the Waiver Safety Explanation Guidelines.
All that information is there for you as well. Our summer webinar series is up online. You can see the website there, at the bottom of the screen, that's going to give you access to all the previously recorded episodes that we've done. It will give you access to supporting documents, and all the questions that you folks are putting in during the live Q&A, or during the lecture portion of the presentation, for all the episodes, are posted on there as well. And we try to get those up as quickly as possible. But all the questions that you have submitted, we consolidate to make sure that there's no duplicates, and we post them online for you to see. So, all the informations there, as well. I do want to add one more thing about our website here: It's important, certainly, if you're looking to get a Daylight Waiver, that you view today's episode part 2, and the previous episode we did, which is part 1. But also, Just as critically as important, as you watch the previous episodes of that, which talks about the Waiver Application process, how to do a risk assessment, and what facts we need in your waiver application.
Those combined with these two parts on The Dark Knight, should give you a great head start on your Daylight Waiver Application. So, thanks once again for joining me. I appreciate you taking time out of your Thursday afternoon to watch and listen. And I hope you were putting in some questions that we can get answers to you for. We're gonna take a short little break, and then we're going to go to our live Q&A portion.
I hope you stick around for that, because you can continue to put questions into the Q&A pod, during the live Q&A portion, and you can also ask questions live on the air, and we'll try to get that answered. So, thanks again, for joining. Stick around for our live Q&A, coming up shortly..