Night Operators

[jwaitkus]

Good point. I didn't think of the GPS. Any pictures of your setup?

 

[We Fly Florida]

I'll grab a couple pictures next time I send it up at night.

 

[jwaitkus]

That would be great. Did you have any pics of the drone itself and how you placed the lights?

 

[Tim Jones]

I plan to put my lights on top of a canopy and direct up and out
camera is slung low underneath
as extra caution I will be adding an on off switch if needed

 

[AVBud]

I just wanted to share my problems in attaining a night waiver. We hired a consultant who boasted they were the leader in the industry and had the fast track on getting waivers. Nearly a year later we were on our the third request from the FAA for additional information. I inquired to the consultant about the operations manual submitted on our behalf only to be informed they were now closed and unable to pay for outstanding legal bills. They blamed it on the FAA taking the position that a "consultant" was not necessary to receive a waiver of any type and that the FAA Waiver Team wanted to see the application for waiver come directly from the applicant so they can be sure they are knowledgeable and aware of the regulations and procedures etc. This same "consultant" had made the same boast of being the leader in Sec. 333 Exemptions. Bottom line we are out a couple thousand dollars and lost a year in the process of getting nightime waiver that we need for Thermal Infra-red scanning. \Currently I am in the process of putting the application together for submittal. Frankly I took the lazy way out and should have done it myself to begin with.

 

[Russ Still]

Hi, AVBud. You can do it yourself if you rigidly stick to the Performance Based Standards. It sounds like your consultant didn't really know what he was doing (other than fleecing his customers).

 

[RNCotton]

I've been trying to get a daylight waiver since June 2017. The first one, I admittedly half-assed it because other pilots were telling me, "Oh yeah, just fill out the online form. FAA is giving out night waivers to anyone." When it came back denied, I sat down and wrote out specific policy and procedures, documented everything, and sent it all back in. Denied again.

Third time a charm, right? I dotted every i, crossed every t, and got back a request for more information. The FAA started playing "What If" scenarios with me. "What if this happens, how will you mitigate the situation?" I would write policy to cover that scenario, send it in, and get back another request for more info about how the failsafe RTH feature would avoid flying over people since I did not have direct control of the aircraft. Or a half dozen other "what if" scenarios. Finally, first week in December they denied it completely and told me to start over.

I haven't touched it since. I've been too frustrated to think about it again. So ... I'd love to be able to bounce my stuff off someone who has already gotten an approval, and see if we can collectively get my stuff in order.

COA will handle it for my day job with the City. But for my personal photography business, I need my own waiver. Who's up for helping me out?

 

[Russ Still]

Ok, RN, I'll try to point you in the right direction. First off - are you familiar with the Performance Based Standards and did you follow them exactly, one at a time, in your application?

 

[RNCotton]

Performance Based Standards and did you follow them exactly, one at a time, in your application?

I did. And when the FAA kept asking for more details about everything, it turned into a mess.

I've got it on my to-do list for January to go through and re-write the whole thing. I'd like to run it by another set of eyes before I send it to the FAA to figure out what I'm missing. Obviously I'm not seeing something they are wanting.

 

[Russ Still]

Did they indicate which of the 5 areas in the PBS that you were lacking in?

 

[RNCotton]

Did they indicate which of the 5 areas in the PBS that you were lacking in?

They probably did in a back door kind of way. They just kept giving me what-if scenarios and asking me to provide more information about things that, in my opinion, didn't matter because they were the same for daylight operations as they would be for night operations.

It didn't help that I was so frustrated because (a) the FAA doesn't make anything clear, and (b) nobody will help you. That's why I just shelved it for a while. So pissed off that I didn't even want to bother thinking about it over the holidays. It's a new year, so I'll get back on it.

 

[Russ Still]

Ok, well if you have questions about something specific, sing out.

 

[Dronescape Imagery]

I would be interested in knowing what kind of anti-collision lighting people are using for nighttime ops.

I developed a system for the 3DR Solo which meets FAA requirements, and would like to adapt it for use on the Phantom series.

Brite Lite anti-collision lighting

I don't have access to a Phantom or any information on how power can be obtained for external devices. If any Phantom owners would like to help, please PM me so we don't clog up the thread. Thanks!

Hey Tim, I bought this product about 3 weeks ago and I can't say enough about how well these operate and they are fully 107.29 compliant. They have 4 Cree LEDs and are extremely bright. This particular model is the newest version and it has 3 modes of flashing. (Strobe, Flash, and Constant). I attach securely with industrial strength, low profile velcro to my drone and with them being so light, they will not separate from the drone in flight. I love this product, no wires and about 4 to 6 hours run-time before needing next charge. I hope this helps.

Drone UAS UAV Quadcopter LED Strobe Light

 

[We Fly Florida]

The Arc is the best one to get! ^

I highly recommend 3 of those!

 

[Dave Pitman]

Did they indicate which of the 5 areas in the PBS that you were lacking in?

They probably did in a back door kind of way. They just kept giving me what-if scenarios and asking me to provide more information about things that, in my opinion, didn't matter because they were the same for daylight operations as they would be for night operations.

Hi Russ.

I have had 2 rejections so far and my third is in the queue. I have spoken with others that have received the waiver in the past and compared applications. (I did not copy anyone for any of mine so far.) The information they submitted was no more inclusive than what was in mine. Their approvals were from early 2017 and before. It appears that the FAA contractors are not at all on the same page or someone told them to get more restrictive, I don't know.

RN Cotton is correct though. In my second application, they came back with the what-if questions that were in my opinion simplistic and there was no way to cover every scenario that they wanted to explore. The answer in "real aviation terms" to some of the questions was simply "see and avoid" and "take evasive maneuvers as each situation warranted". They were not accepting answers like that. If they asked "what would you do if someone entered the operational area after you were in the air" and the answer was "exit the area in the safest direction to avoid the person until the area is clear," apparently, that is an insufficient answer. There were several questions like that in my request for more info in which I bit my tongue and wrote an answer. But I did reply that there was no way to write down every possible scenario that may be a problem and what exactly you will do to compensate.

I think the underlying problem is

A. The FAA needs to write up regs that must be followed to be in compliance and not expect each applicant to write their own regulation that sounds sufficient to the contractor.

B. In general, treat 107 certificate holders the same as 61 certificate holders. If the current training and requirements are not sufficient for the FAA to have confidence in doing that, then they need to address that and change the requirements so that they can have confidence.

We'll see how #3 turns out but I'm not holding my breath.

 

[Russ Still]

One of the tricks is to get an email address for someone and pin them down on what the complaint is. I agree 100% that if they don't give you specific objections there's no reasonable way for you to provide the documentation they want.

One of the more common complaints I've seen is the part about education (and documentation) for the Remote Pilot as well as the VOs. More and more, simply saying that you'll read such-and-such chapter in the PHAK isn't cutting it with them. Second thing is providing acceptable wording for night ops training of the RPIC, but then leaving out the same training for VOs.

 

[Dave Pitman]

One of the more common complaints I've seen is the part about education (and documentation) for the Remote Pilot as well as the VOs. More and more, simply saying that you'll read such-and-such chapter in the PHAK isn't cutting it with them. Second thing is providing acceptable wording for night ops training of the RPIC, but then leaving out the same training for VOs.

Yes, I agree with this. In my latest app, I have basically included all of the Vision in Flight section with specification on how study and knowledge would be demonstrated with paperwork. My prior apps had reference to various elements of the section with responsibilities and so forth but something wasn't enough.

As with many things gov't, common sense is the last thing they worry about. One of the "what if" questions I had was what specifically would you do if you saw a manned aircraft that would be a safety factor in the operation". Note that my app had addressed this already in general but apparently not well enough.

I (again) bit my tongue, and wrote a thoughtful reply. At the end of it I added that from the perspective of a Part 61 pilot, I could assure them that if there was a manned aircraft at less than 500' agl, at night, in a non-airport environment, I would know that the aircraft was most likely experiencing an emergency and that would also be taken into account with my maneuvering.

...Denied.

 

[Russ Still]

Another one to include in your sales pitch: A crew member will monitor the CTAF or Tower frequency for any airport within 10 miles.Overkill on the 10 mile thing, but better than saying 5 miles and getting rejected for it.

 

[Mike Overstreet]

I am building out a high powered LED lighting set up, And eventually want to use it for light painting video and photos.
That means submitting for night operations.
If you have successfully applied for one, could you share your opinion on why it was successful
if you have applied and it failed what was the reason

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I own a video production company, do news work, and need to add night flight to my bag of tricks. I'm also a part 61 aircraft pilot which includes night flight. I too would be VERY interested in seeing a successful FAA application for night flight that might give some general guidance on getting such a waiver to operate legally. I'm tired of drone owners who just DO IT and hobbyists who have virtually no restrictions but there doesn't even seem to be any specific guidance from the FAA as to what they want in this regard.

 

[Russ Still]

Hi, Mike. You probably are already aware, but the first step in applying for a daylight waiver is to download the FAA's Performance Based Standards. Used that to model your application.