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The Importance of Maintaining VLOS

The Federal Aviation Administration requires the remote pilot in command (RPIC) to maintain direct, unaided, visual line of sight of their aircraft at all times. It is perhaps one of the least followed, least understood rules contained in Part 107. Yes, you can apply for a waiver of this rule, but let's discuss why we have this rule. Spend 15 minutes on the various Facebook UAS forums, and you'll see just how misunderstood and downright ignored this regulation is. Not long ago, I saw a post where the pilot was bragging about getting 17,000+ feet distance out of his drone. He also mentioned that he had conducted the flight in a "rural area." It appeared to me that this person genuinely did not understand what FAA P107.31 says, so I tried to educate him politely. If you have been on these forums, you could probably guess how this went. Within just a few minutes, the comments numbered in the dozens and were multiplying fast. Some reasonable folks understood what I was saying, however, and sadly, two groups of people outgunned me. The first group I call "the mis-informed." These folks just haven't read and or fully comprehended what the FAA means by

a visual line of sight (VLOS), and they aren't interested in hearing the truth. They argue that since they can "see" via their first-person view camera (FPV), they are legal and safe. They are neither legal or safe. Not even close, but more on that in a moment. The second group I call "the drone cowboys." These guys know the rules but have determined in their infinite wisdom that this regulation is flat out stupid and have willfully decided to violate it. They even post mind-numbing videos complete with telemetry showing unsafe and illegal flying seemingly free of worry about the "stupid rules."

So what did I say to this guy online boasting about flying his Mavic over three miles from home that blew up the internet? Well, since he seemed to be more uneducated than "cowboy," my comments were pretty straightforward. As I said, the original poster seemed not to understand, so I asked why he had mentioned that he conducted this flight in a "rural area." As I thought, he was under the impression that this type of location makes beyond VLOS operations ok. I explained that it does not. He also claimed that he could "see" because of the drone's camera feed, so I told him why that is also misinformation.

Let's see what the regulation actual says:

Section 107.31 says:

"(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."

Two of the most critical elements of Part 107.31 are #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.

These sections are all about preventing accidents involving manned aircraft and unmanned aircraft. The FAA has a term called "see and avoid and it is at the heart of the FAA's regulatory structure for reducing the risk of aircraft colliding in midair. For manned-aircraft operations, the pilot inside the airplane looking out the windows for conflicting aircraft satisfies this requirement. However, the RPIC of UAS cannot see other aircraft in the same manner because they do not have anything close to a comparable view. It is physically impossible to utilize "see and avoid" techniques using a single forward-looking FPV camera; therefore, they must be able to see the big picture at all times. The airspace in which we operate is three dimensional. Potential aircraft conflicts can pop-up from your left, your right, above you, below you, behind you, etc. Flying beyond VLOS presents a real danger to actual humans flying in aircraft. No matter how you try to justify it, it's wrong, and the consequences could be truly catastrophic. Putting the legality aside for a moment, ask yourself this question: Could you live with the thought of killing the crew and passengers of a medivac helicopter lifting off with a critical patient from the side of a road two or three miles beyond your line of sight? You'd have no idea they were even there until it was too late for you and them.

As a professional UAS operator, I am often frustrated with the FAA. Some of the rules and procedures are, in my opinion, are overkill, but Part 107.31 is not one of them. It is currently the only method for ensuring the safety of flight for everyone, manned and unmanned, operating in the National Airspace System. So, if you're unsure what this is all about or are a "drone cowboy," I implore you to stop and think about what you're doing. Take the time to fully understand the regulations and the possibly deadly consequences of not following them. You could prevent a tragedy.

Fly safe out there!

Todd Tucker

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