by Trever Linn
Flying Beyond Visual Line of Sight (BVLOS) requires special regulatory permissions by Civil Aviation Authorities (CAA) around the world, such as the Part 107 waivers issued under the Federal Aviation Administration (FAA), or Special Flight Operations Certificates (SFOC) from Transport Canada. These permissions are considered and issued on a case by case basis. Meeting the regulatory requirements to achieve these permissions is possible, but CAA’s require drone operators to show how necessary mitigations address the operational risk.
Risk can be bucketed into two main items: Air Risk & Ground Risk
The key to a successful BVLOS waiver approval is risk mitigation data and detailed documentation of flight operations. For further information, refer to our detailed, step by step instructions here.
Let’s discuss a few of the key components involved in a successful BVLOS waiver application.
Risk Mitigation Methodology
Before you start writing your Concept of Operations, you need to decide on your risk methodology. Your CAA may have adopted and published an acceptable risk methodology such as the 8040.6 methodology used to assess UAS risk in the United States, or the RPAS ORA in Canada. Iris Automation recommends utilizing the Joint Authorities Rulemaking on Unmanned Systems (JARUS) guidance as a reference, the process is one of many available risk assessment methodologies that can be used to assess the safety of a UAS operation.
Keep in mind—this process might not be accepted by your CAA and you might need to “translate” it to your CAA’s safety risk management process. Always include your own CAA’s sanctioned risk methodology in your safety case!
Create, maintain, and follow established UAS documentation:
Unmanned flights take place within the National Airspace System! Requesting complex waivers and flights typically come with increased risk, and therefore a more robust approach to managing that risk must be developed. The best way to do this is to develop and adopt Part 135-like documentation that details your organization, how you intend to fly, train, and maintain your aircraft as well as your operators. There is no standard set of UAS documentation required under a waiver, but typically BVLOS waiver provisions require some combination of the following:
- Flight Operations/General Operating Manual
- Standard Operating Procedures
- Emergency Management Manual
- Safety Management System & Manual
- Training Manual
- Maintenance Manual & System
Develop a Concept of Operations (CONOPS)
This document should follow a standardized format such as the one provided by JARUS. It forms the foundation of your operations, detailing exactly how you intend to operate under the requested regulatory authority in conjunction with your organizational procedures.
Fleet and Safety Management System
A system should be put in place to manage hazards, risk, and track aircraft/pilot issues. This system can be fully automated or tracked within a spreadsheet but is necessary to ensure system reliability data can be provided to your CAA, as well as form a foundational pillar for identifying hazards and provisional requirements once operating.
Selecting an aircraft is a critical process to flying BVLOS and may determine whether the waiver is approved, or denied. Not every aircraft is meant, nor intended to operate BVLOS. Your CAA may or may not provide a list of approved aircraft for various operations (such as over people) but there is no CAA approved BVLOS aircraft.
Your aircraft selection determines the ground risk of your operation. If operations over people are to be conducted, there are certain tactical mitigation requirements that may be met a variety of ways such as introducing an ASTM certified parachute, providing frangibility data, or complying with a type certification process.
Before you select an OEM, make sure you assess and consider the following:
- Documentation of aircraft limitations, performance, and production
- Kinetic energy of the aircraft relative to the operational area
- Size, Weight, and Power (SWAP) of the aircraft to ensure tactical mitigation and payload capabilities
- Maintenance procedures and failure data
- Command and Control data
Unfortunately, due to lack of standards many OEM’s have not focused on approaching unmanned aircraft production to a manned aviation standard. The FAA has already initiated sUAS type certification for some platforms and other CAA’s have established scenarios with aircraft limitations embedded.
Unfortunately, technology and regulations are still in development and unlocking the National Airspace System entirely is still not possible.
BVLOS flights in urban and complex airspace are still in testing through various federal and industry partnerships. Keep the state of the industry in mind when identifying a use case and assessing your site:
- Identify and classify your Air Risk, and your Ground Risk
- Address manned aircraft encounter mitigation, as well as mitigations to fly over people
- Develop a visual representation of the area, your mitigation, and show all relevant operation information
- Assess and document hazards associated with the operating area such as high traffic roads, housing developments, or gatherings of people
Even with perfect documentation, your operation still must address ways you plan to avoid hazards, maintain compliance with unwaived regulations, and generally operate safely.
These can be separated into tactical and strategic mitigations. Tactical mitigation is typically a technology that enables the operator to address risk, while strategic mitigation is an operational implemented procedure (such as training). There are many emerging ways to address this as operations transition to removing the human visual observer, but you must show that you are reducing the overall risk within the air and on the ground. CAA’s may not accept all mitigation applied to lower intrinsic risk, so you must support your claims with data and relevant information. Choose the one that is most appropriate for your operation.
Command and Control (C2) Assessment
Ensure compliance with FCC (or applicable agency) regulations and current CAA guidance. Be prepared to address your C2 infrastructure limitations, performance, and overall implementation for the operation. Typically waivers will get denied simply because there are no validation flights showing C2 performance across the operational area requested. Show and explain how you maintain C2 link with the aircraft along your proposed route.
Hint: A C2 analysis under VLOS or VO rules is highly recommended to provide the CAA proof of C2 reliability along the entire route.
The operators will need to prove to the CAA that the processes and procedures built are abided by, even after documentation has been submitted. The level of training required may vary (there are currently no standards) but programs specific to BVLOS, UAS SMS, and more do exist that provide third party verification. It is vital that the applicant have an established training program that can be provided to the CAA with proof of training.
Package Your Submission
Package your submission to the CAA in the most efficient way possible: label and include all attachments, reference specific sections, annexes, and documents, and walk the reviewer through the safety case. Remember that the CAA may be reviewing hundreds of applications!
Hint: Your application may be limited to a set number of documents or attachments, a waiver can be denied on the basis of “missing information” so be sure to combine manuals or documents as necessary to ensure the reviewer as all necessary information.
Click here for more in depth information, including how Iris Automation’s proprietary DAA system, Casia, and Waver Resource Center can accelerate your path to flying BVLOS missions.