Q&A: BVLOS Operation in the United States Posted on July 30, 2020 For this week’s blog article, we sat down with Niall McCallum – Flight Operations – to discuss how SkyX is working toward Beyond Visual Line of Sight (BVLOS) operations in the United States. To start, tell us a bit about what you do at SkyX. Within flight operations, my job is to ensure that SkyX has robust systems in place, so that we can deploy our aerial monitoring solution with absolute confidence. Wherever SkyX is called, I navigate the logistics, regulations and overall government-compliance process to enable standards-based BVLOS operations for each of our clients. In the past year, I’ve been digging deep into Federal Aviation Administration (FAA) regulations to understand how we can better facilitate BVLOS projects in the United States. Before we dig into those FAA regulations, why should our asset operator customers care about BVLOS flight? At its core, BVLOS enables us to bring high-resolution aerial data into the long-range space. Alongside this data, BVLOS operations deliver economic, operational, and safety benefits that far exceed the capabilities of traditional inspection methods. Manned aircraft have been the go-to for their long-range flight capabilities but deliver inconsistent and mediocre imagery. For this reason, many operators are intrigued by the incredible quality of aerial imagery a UAV or RPAS can provide. But the limitations of Visual Line of Sight (VLOS) operations make them unsuitable for monitoring thousands of miles of assets. BVLOS lets you enjoy the best of both worlds. Now, when you merge automation with BVLOS capability, the value of the system skyrockets. At SkyX, we’ve put together a highly-autonomous workflow that combines xStations, autonomous sUAS systems, and even the AI algorithms we use in the analysis process. Consequently, a fully-autonomous BVLOS system can significantly reduce the cost of inspections. Take a look at the vendor landscape for aerial inspection services today, and you’ll find Visual Line of Sight (VLOS) sUAS inspections are more expensive than manned aircraft services in dollars-per-mile. But with BVLOS capability, sUAS inspections cost nearly 40% less than manned aircraft services. You can drive costs even further down with a solution that leverages autonomy to reduce demand for on-site resources and personnel to almost nil. The cost savings realized through autonomous BVLOS operations are a major driving force for organizations to make the switch to RPAS. What is the regulatory status of BVLOS flight in the United States? Currently, most sUAS operations in the United States are governed by the FAA’s Part 107 regulations, which permits flights within Visual Line of Sight and creates a regulatory sandbox for drone operators to play in. Under Part 107, operations may not occur: Beyond visual line-of-sight Over persons At night Above an altitude of 400 feet With a UAS weight of 55 lbs. or more To perform an operation outside of Part 107’s limitations, you need a Part 107 Waiver from the FAA. Depending on the type and scope of the proposed operation, these waivers are determined based on the reliability of an operator’s remote piloting systems, command and control link, Detect-and-Avoid (DAA) capability, vehicle safety features, and failsafe measures. Keep in mind, these waivers are given on a case-by-case basis. They do not provide blanket BVLOS approval to an operator. What that means for SkyX in obtaining BVLOS approval is: we’re required to complete site-specific operational risk assessments and develop mitigation strategies for each potential client. What is SkyX’s experience with BVLOS operations? Well, we’ve built BVLOS-capable systems that operate near-autonomously under the supervision of a remote pilot, and we’ve deployed them in real-world BVLOS operations! In North America, our most significant BVLOS project was a remote medical supply delivery trial with Transport Canada. During this trial, we proved that our sUAS can safely fly BVLOS in Canadian airspace – utilizing a remote pilot that was 3,300km away from the site. In the United States, our operations team has a roster of highly-skilled sUAS pilots with the ability to fly a variety of vehicles, including fixed-wing, multirotor, and helicopter. All of these pilots are certified and we are implementing internal training standards to ensure that our Remote Pilots can safely operate in a more complex BVLOS environment. Additionally, SkyX has been doing a lot of work in Canada that carries over across the border in proving our airworthiness to the FAA: Flights Over People: As part of our ROW monitoring operations for TC Energy – one of North America’s leading energy infrastructure companies – SkyX has successfully performed multiple complex VLOS flights over people in controlled airspace. Detect-And-Avoid Innovation: SkyX was selected to participate in a trail of airborne DAA systems, which are essential to safe and reliable long-range BVLOS operations. Regulatory Partnership: SkyX works closely with Transport Canada authorities and action teams, to stay at the forefront of Unmanned Traffic Management (UTM), Special Flight Operations Certificates (SFOCs), and BLVOS flight applications. Successful BVLOS operations in Canada are compelling testimony for FAA authorities. There seems to be a bit of buzz around type certificates, can you elaborate on that? This question comes up a lot, especially considering that there is so much activity around drone delivery, which by definition, needs a type-certified aircraft. There are multiple regulatory pathways to BVLOS flight – and the best route depends on what you’re trying to do as a company. At SkyX, we’re not focused on drone delivery or urban air mobility (carrying people or property for compensation or hire), and the Part 107 framework generally gives us the flexibility to obtain waivers on a case-by-case basis to operate our sUAS for infrastructure monitoring. However, as sUAS operations become more widespread, a patchwork system of waivers just won’t cut it anymore. As the industry shifts to adopt new systems for remote ID, reliable DAA methods, and more sophisticated UTM systems – we’ll see a transition away from Part 107 in favor of Type Certificates. These certificates will become the de facto means of doing large-scale BVLOS operations. In a big way, we’ll see a return to the concepts of airworthiness certification, which is the standard for conducting flights in manned aviation. Where things get muddy, is that there aren’t any Standard Type Certificates for drones. For example, the kind you see for manned fixed-wing aircraft. Instead, manufacturers have to apply for a “special class” of type certification, which is cobbled together from existing airworthiness standards. Overall, it’s a very drawn out back and forth process with the FAA. Is there value in type certificates for commercial operations? For SkyX, it’s beneficial but not necessary. While Part 107 waivers are site-specific, requiring us to apply on a per-project basis – this is actually a more practical BVLOS-certification process for the type of remote, pre-defined asset inspections that we’re doing. If we feel the systems and processes are in place to support the operations, we’ll certainly take a look at applying for a Special Type Certificate with the FAA. Until then, we’re closely watching the FAA’s Advisory Circular that’s setting forth clearly defined airworthiness standards in the future. What is SkyX’s roadmap to BVLOS operations in the United States? First and foremost, is continuing with our standards-first approach to innovation. Standards are the universal language of aviation safety and certification, a means to demonstrate that a complex system can operate safely in National Airspace. That means continued participation in industry groups and regulatory bodies to help define these standards, while also bringing the knowledge and direction to influence the technology roadmap. On the technology side, we’re developing relationships with key academic institutions and technology providers to continually improve our systems and prove airworthiness. These collaborative opportunities allow us to test and integrate technologies that address regulatory concerns – such as DAA systems and reliable communication in remote areas. Once these technologies are integrating and functioning reliably, our strategy includes regular demonstrations at FAA test-ranges to build the regulator’s confidence in SkyX systems and operational competency. At the end of the day, it takes time, but far from being a regulatory hurdle, aviation and airworthiness standards represent the maturation of the sUAS industry to operate within the traditional model for the aviation industry. The journey will be well-worth it in the end. Have questions about how high-quality aerial data can elevate your organization? Contact our team to discuss your unique challenges and data requirements.