How to get a
Beyond Visual Line of Sight (BVLOS) Approval
Everything you need to know to get started
Table of Contents
- Your Drone Program: What Are You Trying to Accomplish?
- Build the Operational Key Ingredients
- What Is BVLOS?
- What is BLOS?
- What is EVLOS and TBVLOS?
- What is VLOS and LOS?
- What is the Benefit of BVLOS?
- Efficiency, improved results, safety, cost
- Benefits for Industries and Businesses
- BVLOS and Regulations: What is required for BVLOS flight?
- Regulatory Challenges
- How to Achieve a Waiver: Everything You Need to Know
- Review Specific Operations Risk Assessment (SORA)
- Create, maintain, and follow established UAS documentation
- Develop a Concept of Operations (CONOPS)
- Establish a Fleet Safety
- Select approved BVLOS aircraft
- Assess your site/location
- Address Risk/Hazard Mitigation Plan
- Prepare your C2 infrastructure
- Provide documentation of training (secure third-party verification of
- training programs)Package your submission for waiver
- Iris Automation Solution
- Iris RRC to fast-track BVLOS approval
Your Drone Program: What Are You Trying to Accomplish?
Everything starts from this question: What are you trying to accomplish with your drone program? Begin by selecting your use case. Use case is important because it determines the Return on Investment (ROI) of your program, the type of aircraft and hardware you will need to purchase, and the regulatory permissions you will need to pursue.
Understand your personal motivations and scale to the organization
Build the Operational Key Ingredients
A good BVLOS program is designed to be a highly effective and reliable operation. The recipe for success begins with these four key ingredients:
- Detect-and-Avoid (DAA): DAA refers to the capability to see, sense, or detect conflicting traffic or other hazards and take the appropriate action to ensure the safety of humans and property. Iris Automation makes this solution available to your organization with Casia Detect-and-Avoid.
- BVLOS Operational Regulatory Permissions and Certification: In order to run a commercial BVLOS program in the United States, you will need to obtain a Part 107.31 waiver (a waiver from being required to have visual line of sight to the aircraft under Part 107) or a Part 135 certification. Iris Automation can assist you with obtaining BVLOS approval through our Regulatory Resource Center
- Mission Planning: Before your drone even leaves the ground, a lot of preparation needs to be done. Carefully programming the details of your drone’s flight plan with modern tools that provide safety features like geo-fencing and low altitude authorization and notification (LAANC) is necessary for successful autonomous operations.
- Concept of Operations (CONOPS): The basic premise of a CONOPS document is to enable the executing agent to understand the purpose behind what must be done. CONOPS should relate a narrative of the process to be followed. It must also define the roles of the various stakeholders involved in the process. It should offer a clear methodology to realize the goals and objectives of the approach to software development/acquisition of core assets and systems.
What Is BVLOS?
BVLOS means Beyond Visual Line of Sight. The FAA (Federal Aviation Administration of the United State’s) regulatory framework around safe drone flight operation relies on the concept of “see-and-avoid,” which is intended to avoid the risk of a mid-air collision between aircraft.
So, what Is BVLOS?
BVLOS means “Beyond Visual Line of Sight.” Sometimes it is referred to as Beyond Line of Sight (BLOS). In literal terms, this means flying the aircraft beyond the RPIC, or Remote Pilot in Command’s direct sight of the aircraft. This is generally taken to mean having either a visual observer (VO) to maintain visual observation of the aircraft or having some kind of detect-and-avoid technology on-board to maintain the ability to avoid a mid-air collision.
The framework under which a BVLOS flight can be conducted in the United States is covered under FAA Part 107 – Small Unmanned Aircraft Rule. More specifically, a BVLOS operation may be conducted if a waiver is received from complying with Part 107.31 of this rule (Visual Line of Sight Aircraft Operation). In addition, some operators may also decide to get a waiver from Part 107.33 – Visual Observer rules.
Text of Part 107.31:
§ 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.
Text of Part 107.33:
§ 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.
What does it mean to fly BVLOS?
In the BVLOS world, you would be able to fly an unmanned aircraft without having to maintain sight of it at all times. You can achieve this by either using a visual observer, having an appropriate technology, or following certain actions or procedures that minimize the risk of a mid-air collision.
Part of this process involves getting a waiver for complying with Part 107.31. The FAA has a list of questions typically asked that help them determine if you have the right procedures, risk mitigation, and technology to help avoid mid-air collisions. These questions are broadly based on the following topics:
1. Describe how the Remote Pilot in Command (RPIC) will be able to continuously know and determine the position, altitude, attitude, and movement of their small unmanned aircraft (sUA) or drone and ensure the sUA or drone remains in the area of intended operation without exceeding the performance capabilities of the command and control link.
2. Describe how the RPIC will avoid other aircraft, flying over/into people on the ground, and ground-based structures and obstacles at all times.
3. Describe how the visual conspicuity of the sUA or drone will be increased to be seen at a distance of at least 3 statute miles (mi).
4. Describe how the RPIC is alerted of a degraded sUA or drone function.
5. What procedure will be followed to ensure the required persons participating in the operation have relevant knowledge of all aspects of operating a sUA or drone that is not in visual line of sight of the RPIC?
6. Describe how the RPIC will operate the sUA or drone within the weather requirements while en route.
7. Describe the emitters and command and control link used in the sUA or drone.
Having a Part 107.31 waiver doesn’t mean you can fly an aircraft without any form of visual observation – in fact most Part 107.31 waivers are granted with operators having visual observers (VO) maintaining sight of the aircraft. Depending on the distance flown by the aircraft in a BVLOS operation, a waiver from Part 107.33 may also be needed to account for communication latency between the VO and the RPIC (e.g. if you have the VO in a chase car following the aircraft or daisy-chaining VO’s):
“Waiver from 107.33 Visual Observer 1. Describe how you will account for the communication latency between the visual observer(s) (VO) and the Remote Pilot in Command (RPIC).”
So – in general – you can fly BVLOS if you:
1. Always know the position, altitude, attitude, and movement of your drone/sUA and ensure the sUA or drone remains in the area of intended operation without exceeding the performance capabilities of the command and control (C2) link
2. Are able to avoid other aircraft, flying over/into people on the ground, and ground-based structures and obstacles at all times
3. Your drone can be seen from at least 3 miles away
4. Can be alerted immediately if your drone is degraded or functioning incorrectly
5. All the members of your team involved in the operation have relevant knowledge of all aspects of operating a sUA or drone (and not just your RPIC and VO’s)
6. Be able to comply with weather conditions/requirements during flight (especially with fluctuating weather conditions)
7. Have a strong C2 link
8. Are able to account for any latency in communication between VO’s and the RPIC
Some of these requirements can be fulfilled with a visual observer, but most can also be fulfilled with a detect-and-avoid system (particularly around point #1, and point #8).
More broadly, using detect-and-avoid technology helps mitigate risks such as losing your C2 link for periods of flight, and for avoiding mid-air collisions with other aircraft, ground-based obstacles and such. You may also not need a VO, although most organizations applying for Part 107.31 waivers obtain Part 107.33 waivers as well.
What Is EVLOS and TBVLOS?
What Is VLOS and LOS?
To begin to understand Beyond Visual Line of Sight operations, you have to start with Visual Line of Sight Operations rules.
In manned aviation, this rule is generally fulfilled by having a pilot on-board looking out from inside the aircraft and scanning the horizon for any aircraft that may be on a collision course with their aircraft. In unmanned aviation, however, it is not possible for the pilot to “see” other aircraft heading towards their drone. This is why the current FAA rules dictate that a drone or small UAS operation is conducted “within visual line of sight.” This requirement is currently satisfied in manned-aircraft operations by a pilot on board the manned aircraft looking out from inside the aircraft to see whether other aircraft are on a collision course with the pilot’s own aircraft. However, the person controlling the small UAS cannot see other aircraft in the same manner because they are not inside the aircraft.
This is why the operator of the small UAS must always be capable of maintaining visual line of sight of the small unmanned aircraft they are piloting, unaided by any technology other than prescription glasses or contact lenses. This is called Visual Line of Sight operations (VLOS).
It is much easier to start a drone program as a visual line of sight operation, especially if you have never created a drone program before. Starting out as a VLOS program helps you build the operational culture to manage a more complex operation, including building a heritage of safe flight operations, hiring the right team of pilots and flight operators, and developing your team’s proficiency in mission planning and following the CONOPS.
What Is the Benefit of BVLOS?
The benefits could not be more clear. Having beyond visual line of sight operational capabilities truly unlocks your drone program’s potential—enabling you to integrate drone operations into every aspect of your organization without requiring a corresponding ramp-up in pilot hiring and training. It enables you to fly your drones further and longer while gathering more data per flight than ever before.
Benefits of BVLOS drone operations include:
- Enabling pilots to launch and operate drones from an incident response center without going on field
- Increasing the volume of data gathered per flight
- Use in situations dangerous to humans (fire inspection) or where it will be faster (medical equipment delivery in rural areas) than humans
- Enabling organizations to operate more flights per pilot and reducing overheads
Efficiency, improved results, safety, cost
Benefits for Industries and Businesses
BVLOS and Regulations: What is required for BVLOS flight?
How to Achieve a Waiver: Everything You Need to Know
Review Specific Operations Risk Assessment (SORA)
Create, maintain, and follow established UAS documentation
Develop a Concept of Operations (CONOPS)
Establish a Fleet Safety
Select approved BVLOS aircraft
Assess your site/location
Address Risk/Hazard Mitigation Plan
Prepare your C2 infrastructure
Provide documentation of training (secure third-party verification of
training programs)Package your submission for waiver
Iris Automation Solution
Iris RRC to fast-track BVLOS approval
How To Achieve A Waiver
The key to every successful approval is detailed documentation of flight operations
Specific Operations Risk Assessment (SORA)
Reference JARUS guidance. 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.
Flight Operations/General Operating Manual
- Flight Operations/General Operating Manual
- Standard Operating Procedures
- Emergency Management Manual
- Safety Management System & Manual
- Training Manual
- Maintenance Manual & System
Concept of operations (CONOPS)
Fleet & Safety management system
Iris Automation has a list of approved BVLOS resellers as well that integrate directly with Casia from the OEM. Try to keep in mind the Size, Weight, and Power (SWAP) of the aircraft, C2 radios, autopilot compatibility, and any standard that the aircraft may need to meet. The FAA has already initiated sUAS type certification for some platforms!
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.
These can be separated into tactical and strategic mitigations. One example, given below, highlights Casia:
- Detect and Avoid Equipment: Unlocking BVLOS capability requires you to maintain well clear and right of way per many CAA’s regulations. There are many emerging ways to address this as operations transition to removing the human visual observer. Choose the one that is most appropriate for your operation.