Expert Insights with Drone Diva Desi

Hi, I’m Desiree Ekstein, aka. Drone Diva Desi.   I am a certified remote pilot.   I also have a night endorsement and a daylight waiver.   When I took on the task of preparing for the waiver, I wasn’t sure what information  the  FAA was looking for.   This will help you to prepare some of the information.   Each situation is different so you will need to answer the questions according to your abilities and needs.   I suggest you write your request in a word document first and then copy past to the appropriate parts.   This is not “how to fill in the information”,  this will help you to understand what information is needed.

First, daylight waiver? … why do I need it?   As a commercial remote pilot if you want to fly at night you will need it.  The 107.29 rule restricts you from flying at night as a commercial remote pilot.   You are asking the FAA to waive the daylight operations rule, and allow you to fly your UAS at night.  It is called a daylight waiver… not a night waiver.   All the waivers can be found on the FAA Website.

When filling out the applications there is a section for “Waiver safety explanation”.  This seems to be the section that causes the most confusion.   There are 5 Performance Based standards  that need to be addressed.   Think about each one and how you will handle them and mitigate risk.  Guidelines for the Applicant  (on the FAA website)

5 Performance Based Standards

  1. Provide a method for the remote pilot to maintain visual line of sight during darkness
    How are going to maintain visual line of site?   What are you going to do different knowing  it is more difficult at night?  Are you going to use additional observers? Brighter lights? Or will you always be in a well lit area?  What fits your criteria?
  2. Provide a method for the remote pilot to see and avoid other aircraft, people on the ground, and ground-based structures and obstacles during darkness.
    Explain what you will do in these situations.   Do you plan to have a visual observer?  Will you maneuver out of the way?  Think safety,  communicate, mark your area?  How will you be able to safely identify your flying area?  Is it well lit or will you need to check it out in advance?  List your emergency procedures should something happen.  Also, let me remind you, unless you have a waiver 107.39 you cannot fly directly over people. 
  3. 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.
    Telemetry is obviously very sophisticated in some of the UAS, but what will you do if you lose connection?   Hover, and wait until it reconnects or land immediately?  Maybe you will always have at least one and possibly more visual observers.   How will you communicate with your observers?   Do you have a system for communication or radios? 
  4. Provide a method to increase conspicuity of the small unmanned aircraft to be seen at a distance of at least 3 statute miles unless a system is in place that can avoid all non-participating aircraft.
    Your aircraft must be equipped with anti-collision lights.  State what you have for your aircraft to be seen for 3 statute miles, and how they can be seen from multiple directions. Stock UAS lighting is generally not bright enough or sufficient to be seen by oncoming air traffic.    The additional lights can be turned off if needed while taking a photograph or video. I do not endorse any specific lights but there are several to choose from that seem to meet the FAA approval.  Feel free to contact me if you have questions.

  5. Provide a method to assure all required persons participating in the small unmanned aircraft operation have knowledge to recognize and overcome visual illusions caused by darkness, and understand physiological conditions which may degrade night vision.
    This is extremely important because your eyes will play tricks on you.   Night illusions can cause confusion and distractions during night flight.   There are several visual illusions to be aware of.   They are found in the Pilot Hand Book (PHAK) Chapter 17 (starting at page 19).   Also, night flight and night illusions are found in the Code of Federal Regulations chapter 10 Airplane Flying Handbook, Regulations and Policies.

    • Autokinesis: Phantom motion; protracted staring may cause it to appear that an object is moving contrary to reality.
    • Fascination (Fixation): Pilots ignore orientation cues and fix their attention on a goal or an object.
    • Reversible perspective illusion: Inability to determine if an object is moving towards you or away from you.
    • Size-distance illusion: Dimly lit objects appear to be further away and brightly lit objects appear closer.
    • Flicker Vertigo:  Flashing lights may cause nausea or disorientation.

Identify the illusions and how you plan to deal with them.   Do you plan to have shorter flying times? How do you plan to allow your eyes to adjust to the darkness.   What other methods will you use to help your subject to be seen?  By looking off to the side of the subject,  or by not focusing directly on it

The main focus is the 5 Performance Based Standards and they each need to be addressed.  Explain why daylight flight is not sufficient and your operation needs to be done at night.  Remember to use proper and complete sentences and don’t be informal or use slang.   Give details of your plan for loss of sight.   Establish emergency procedures.   What will you do in these scenarios?  Land, hover or communicate.  If so, how will you communicate?  Increase your standards for night flight because of the additional risks involved.   Don’t limit yourself, but write them according to your needs.Please feel free to contact me if you have any questions regarding the process.

Desiree Ekstein – Drone Diva Desi
Desi’s fleet of drones:  DJI Mavic Pro, Phantom 4 and Phantom 3 Pro

“Expert Insight” is the independent views and opinions of the submitting named author of this article.

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