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How to Allow UAS to Operate BVLOS

Silas is an aviation safety inspector who obtained his Master of Science in Aeronautics and Safety.

The Best Route to Enable Beyond Visual Line of Sight (BVLOS) Operations

The Federal Aviation Administration (FAA) needs to develop a baseline to certify equipment used to enable Beyond Visual Line of Sight (BVLOS) operations.



How to Allow UAS to Operate BVLOS

Over a million operators have registered their unmanned aircraft systems (UAS). This number increases as the market expands. The unmanned aircraft (UA) weighs less than 55 pounds present challenges for others to see and avoid them with the human eye. See and avoid has been the pilot’s responsibility for decades, as mentioned by the Federal Aviation Administration (FAA). Under the 107 law, it allows a remote pilot to operate the UA within the visual line of sight. The pilot can see the UA with the human eye to detect hazards such as other planes flying in the airspace. However, complexity increases when UAS pilots prefer to operate beyond visual line of sight (BVLOS). Increases risk and require a strategy to enable the unmanned aircraft to operate beyond the pilot’s visual line of sight.

This article presents a solution for beyond visual line of sight (BVLOS) operations through technology certification. Producing certification standards will enable UAS to integrate into the airspace faster than what has happened over the past decade.

BVLOS presents a problem while the pilot cannot maintain visual contact with the aircraft. So, waivers granted allow the pilot to operate BVLOS through an electronic means of compliance. Waivers create more problems as the technology remains uncertified and has not gone through the FAA certification procedure, such as a Cessna or Boeing aircraft. Not having certified technology to detect and avoid other aircraft presents an added risk to the airspace. Therefore, developing an aviation safety plan is essential to focus on establishing safety priorities for UAS expansion. The priorities need regulation changes and aircraft certification to allow BVLOS operations.

Visual Line of Sight (VLOS)

Visual Line of Sight (VLOS)

Visual Line of Sight

There is an extensive amount of risk associated with not having a pilot onboard the unmanned aircraft. Without the pilot onboard, see and avoid presents one of the missing elements to protect the airspace from escalating the potential for a midair. Next, depending on the UA weight predicates which rule to follow. Aircraft weighing less than 55 pounds must operate under part 107, and those that weigh more than 55 pounds follow part 91.

Parts 91 and 107 require the pilot to see and avoid other aircraft and maintain separation from other aircraft. Part 91.113 mentions that the pilot must maintain vigilance to see and avoid other aircraft. Part 107.31 states the person manipulating the flight control of the small unmanned aircraft system must be able to see the unmanned aircraft throughout the entire flight 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

(4) Determine that the UA does not endanger the life or property of another

In 2016, the Federal Aviation Administration (FAA) promulgated the 107 regulation to allow UAS operations for aircraft weighing less than 55 pounds (2016). The law requires the pilot to keep visual contact with the unmanned aircraft (UA) and identify other aircraft in the area. The FAA considers a visual line-of-sight operation low risk. Risk is low considering the FAA allows a human on the ground to search for airborne hazards that may present themselves. For example, a manned aircraft enters the area of operation will require the remote UAS pilot to give way to the other aircraft. A choice to mitigate the airborne hazard involves landing the UAS to prevent the potential of a midair collision.

Beyond Visual Line of Sight

Beyond Visual Line of Sight

Beyond Visual Line of Sight (BVLOS)

The risk elevates as UAS operations expand into Beyond Visual Line of Sight (BVLOS). This method requires the pilot on the ground to use his eyes to keep visual separation from the other aircraft. Instead, BVLOS allows a UA to operate without the pilot's ability to see the aircraft with the human eye. However, the FAA allows a visual observer to maintain visual contact with the aircraft and scan the sky for other aircraft hazards. This choice provides a method to prevent a mid-air collision while the visual observer communicates information to the pilot. The visual observer extends the pilot's eyes while they operate BVLOS. However, the industry has requested BVLOS operations with the use of technology instead of visual observers. The term detect and avoid denominates the electronic means to see and avoid.

Using the detect and avoid method through electronic means increases the risk level from low to medium or high risk depending on the airspace congestion. Allowing UAS to run Beyond Visual Line of Sight (BVLOS) is one of the most significant challenges the FAA and industry seek to solve. The FAA allows UAS operations under BVLOS conditions to use technology. The technology sends out electronic signals to detect other aircraft that may present themselves as a threat. Without certificated equipment, the potential for failure exists, and the operator must reduce the risk.

Without an airworthiness certificate, the technology probability of failure is unknown. The pilot cannot see and avoid hazards once the electronic device fails. Since the 107 regulation release, many pilots ask for a 107.31 waiver to operate beyond the visual line of sight without a visual observer. Challenges exist as a result of the level of risk associated with the non-certified equipment.

Aerial Shot

Aerial Shot

Final Note

Both see and avoid and detect and avoid are necessary for BVLOS operations. One without the other places users of the airspace at risk and increases the mid-air collision chance. Political pressure from the White House has pushed the FAA into a frenzy to enable UAS operations. Integration into the NAS and BVLOS operations without equipage certification or develop standards for detection and avoidance creates the potential for a disastrous outcome. The FAA is in the crawl phase while analyzing each BVLOS operation and determining the best mitigation strategy to use for these types of flights. Without standards and equipment certification, political pressure pushes the FAA into approving UAS operations that are increasing the airspace risk to other users.

This content is accurate and true to the best of the author’s knowledge and is not meant to substitute for formal and individualized advice from a qualified professional.


Silas Still (author) from Baltimore, MD on February 07, 2021:

DW, thanks for the comment, and you are correct about regulatory challenges. The challenge of operating unmanned aircraft involves understanding the regulatory requirements. Part 91, 101, and 107 lists different paths for hobby and commercial operations. Within each part include several options to operate. For example, the five-mile notification requirement for recreation flights does not exist under part 107, commercial operation. A test of knowledge exists to remain within the appropriate authorization without mixing requirements from other regulations.


DW Davis from Eastern NC on February 07, 2021:

An excellent Hub with lots of great information.

The advent of the UAV has presented a lot of regulatory challenges. I imagine most hobby users are not aware of many of the rules they are supposed to follow when operating their vehicles.


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