Do you need V/O with you on all commercial flights?

[BigAl07]

And there in lies the rub.The first sentence says "MUST ... AT ALL TIMES" and the next one says "WHEN THE RPIC MAY ... LOOK DOWN". So now we have an inconsistency even there.

Please ask your FAA sUAS Liaison why 107.31(b) has the word "EITHER" in the sentence that specifies who may fulfill ALL of the VLOS requirements in 107.31(a)(1-4).

If it's miss-worded then reword it or publish a clarification in the Federal Register.

It's not mis-worded in the least. You're missing the point. It allows for the RPIC to take his/her eyes off the bird for "brief" periods of time to share the workload. Keep in mind it's the responsibility of the RPIC to also scan the area for potential traffic and other issues so it would be impossible to never (and it's also a bad idea to focus on one single object long term or you can get fixated or other visual impairments) take your eyes off the aircraft and fulfill See & Avoid.

At no point can the RPIC handoff VLOS burden to another person except brief instances. That's totally different than positioning a VO at the far limits of the RPIC's vision and handing off the responsiblity to the VO completely. While this isn't "allowed" today under Part 107 it is something that can be waivered or supposedly can be waivered in the future.

As I said if you doubt this call your FSDO and get clarification for yourself. My interpretation came directly from the FAA which is awesome that we have that luxury now. Just a little over a year ago we did NOT have such an option.

 

[joet]

If that's what they were going for, then they wrote 107.31(b) and 107.33 very badly. They both seem to indicate pretty clearly that VLOS can be passed entirely to the VO as long as the VO is in communication with the RPIC.

 

[kennedye]

In my operations, I've found birds to be the most pervasive problem - especially with the Mavic. They seem to treat it as a potentially interloping bird and tend to come check it out, The Phantom, I guess, is loud enough and weird looking enough to avoid all but confrontations involving a nest in most cases.

Oh that's easy, just rig it up thusly: