Part 107 Night Operations Waiver

Discussion in 'Flight Regulations' started by Freddie Murphy, Nov 16, 2016.

  1. Freddie Murphy

    Freddie Murphy New Member

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    I'm interested in applying for the Night Operations waiver, and was curious as to what everyone was using equipment wise.


    I found a really good article about the regulations of night operations here.

    Part of the process of getting the waiver is installing an anticollision light system that's viewable from 3 statute miles. Do the LEDs on the Alta count for this? I'm assuming they're not quite bright enough. Has anyone gone through the process of getting the night waiver? What are you using to satisfy the lighting requirement?
     
  2. Lane Wooder

    Lane Wooder New Member

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    I am in the application process, and have been researching as how to best satisfy that aspect of the performance standards. I have been told by multiple FAA sources to go out and test it myself. I have a place where I can pull it off, but I don't know how soon I can do it. I even contacted Freefly, who said they were not sure themselves. I have been given LED recommendations, and there are other sellers I have found who claim it satisfies FAA night operations requirements, but so far I have found only one that says it has visibility greater than 3 miles: https://www.northamericansurvivalsystems.com/DS-30-WHITE-DRONE-STROBE_p_60.html
    A company called Flytron has some neat options that serve as Nav lights. One seller claims these can be seen up to 3 miles, but I have been trying to confirm that through customer service: http://www.flytron.com/led-systems/...n-light-white.html#/output_type-with_wires5gr
    The company Freefly recommended does not have a 3 mile product, I received an email from them yesterday about it. One of Freefly's re-sellers suggested lume cube. While their lights are super bright, they are directional, so I have not contacted them yet. This is a very important issue and it would be nice if the manufacturers started offering a little guidance on compliant products.
     
  3. Freddie Murphy

    Freddie Murphy New Member

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    The first one you linked seems pretty compact and easy to mount. Thanks for the info!
     
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  4. Gary Haynes

    Gary Haynes Administrator
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    Freddie find someplace where you can have line of sight at 3 miles. Buy a couple of different types of lights. Have someone be the person turning on and off the various lights, via cell phone. Get a couple of buddies, preferably other pilot so that you have you and two witnesses. If everyone says they see the lights then write an affidavit for each individual and have them notarized. That should suffice for the requirements at the FAA when you make your application. Note the time, date, weather, GPS map locations of send and receive, light specs, brands, model numbers, etc. Be overly thorough. Most important is more than you as an observer and notarized statements. Photos/videos would also help.
     
  5. Michael McVay

    Michael McVay Active Member

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    Great idea for the paper trail Gary.
     
  6. Shaun Stanton

    Shaun Stanton Active Member

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    A friend of mine put in for one and got it. He did not specify equipment in the request other then it will be visible at 3NM. He put in other safety measures like obstacle avoidance by surveying the area before flight and using spotters if necessary.
     
  7. Freddie Murphy

    Freddie Murphy New Member

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    Good to know, Shaun. Additional safety measures laid out seem like a good step.

    Gary, great idea! The FAA seems to love logging things, so that seems like it would be a good way to satisfy the requirements. Time to order some LEDs.
     
  8. Josh Lambeth

    Josh Lambeth Well-Known Member

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    Hopefully someone can help with this. I already have an explanation but apparently they want more. What are they looking for for this?

    Applicant must provide a method by which the remote pilot will be able to continuously

    know and determine the position, altitude, attitude, and movement of their small

    unmanned aircraft (sUA).

    • Applicant must provide a method to assure all required persons participating in the sUA

    operation have knowledge to recognize and overcome visual illusions caused by darkness,

    and understand physiological conditions which may degrade night vision

    Thanks in advance!
     
  9. Shaun Stanton

    Shaun Stanton Active Member

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    For the first one I put in that the aircraft will have in addition to the 3SM anti collision lights, position lights in the which delineate the front from rear and such as green in the rear and red in the front. Each boom has a light or lights which aid in determining the aircraft's attitude. Described that by having a light on each boom arm would be visible enough to know what the attitude and direction of travel the aircraft was. I put in this information can be aided by aircraft instrumentation which can available through real time telemetry data that is either down linked to a smart device such as the GoApp for DJI equipment like the Inspire and Phantom series. Or it is interlaced to the pilots independent video system though an On Screen Display Device that shows altitude, attitude, speed direction of travel as well as proximity from the launch location. I described the DJI GoApp for all my DJI equipment. I also put in that if the aircraft is flown beyond proximity of the pilot to reasonably see objects at night such as power lines, that Visual observers will be used to aid in in verifying the altitude with the aircraft's proximity to objects. VO's will be trained to know what the aircraft looks at various altitudes and distances from objects. I described the technique of using objects in close proximity to pilot and VO as a reference of measurement for aiding in determining the altitudes and speeds. I went verbose and decribed all of these systems give altitude measurements based on data fusion from barometric sensors and GPS/GLONASS to aid in setting the altitudes above ground level. I also put in that the integrity of these systems will be determined by an initial climb to an altitude of an object that can compared to local GEO reference data using google earth and the daytime site surveys.

    Essentially I tried to describe every humanly possible way to determine this stuff.

    For your last one I went to a helicopter flying handbook and described that VO's will be taught ground school on night vision physiology and appropriate scanning techniques. I described what was in that book. Some stuff doesn't apply like the illusion of lights on sloping plane which give appearance of being in a bank, since that is describing being in a physical cockpit of an aircraft. I described things like how the human eye has blind spots which require a scanning technique like in 10 degree increments in a square pattern. Described that at night the eye relies on rods vs cones which limit the use on direct focal vision and relies more on the peripheral vision to see and detect objects especially ones in motion. I also put in the limitations of eye adaptation to night vision which require the eye to be out of direct light sources for 30 minutes to acclimate to night vision. I also put in that each VO would get practical training in an area acceptable for night RC flying.

    I found from a friend who got one that I put in more detailed information than many people do. I don't know what the FAA's deal is with these. I think they make this more of an issue out of this than necessary. IMO flying at night was easier in some respects keeping orientation than in the day time with the appropriate boom light, especially when flying the original cinestars. Essentially, I guess they want to know that you put in some forethought into it other than just plugging in a battery and letting it rip.
     
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  10. Lane Wooder

    Lane Wooder New Member

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    Everything Shaun said is spot on! Having received my waiver I can give a few more insights that may help, especially since I talked with several FAA personnel involved with UAS operations in the process of applying.

    For the first requirement, my only addition is if you are using the ALTA. The FPV video feed from the ALTA gives a great HUD that can display not only simple telemetry such as height, distance, and speed, but also aircraft attitude such as its pitch and direction of travel. As Shaun said, stress orientation lights, use of strategically placed VOs (more than one if necessary), and telemetry.

    For the second requirement, if you have a Part 61 Private Pilot's Certificate or greater you have received the proper training in night operations and are good to go as a member of the flight crew (PIC, operator, VO). If not, you need to receive instruction in the areas you listed (knowledge to recognize and overcome visual illusions caused by darkness, and understand physiological conditions which may degrade night vision). I spoke with both FAA personnel in the national office as well as my local FSDO, and they recommended anyone needing this training receive 1-2 hours of ground school from a CFI or DPE in these areas and have the instructor sign off on some form of documentation (log book, certificate, etc.). Therefore, I put in my waiver application that any member of my flight crew will have either a Private Pilot's license or greater, or have received ground school training in these areas by a CFI or DPE and have documented proof to show FAA personnel if so requested. Depending on how familiar your FSDO and the instructor you choose are familiar with Part 107 you may have to point them to the national office for clarification. My FSDO was up to speed and helped communicate with the instructor I am using to train my crew.
     
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