Visual Observer 

Training Guide

Training Guide
Overview – 2 Part Guide

 Visual Observance Learning Seminar (Part 1 – 60 Minutes)

 Challenges to human visual perception 

 Limits of human visual perception 

 How outside factors impact our visual perception

 How motion, lighting changes, and changes in depth affect visual perception

 Classroom Training (Part 2 – 90 Minutes)

 Introduction to the Role

 Responsibilities Review

 Terminology

 FAA Regulation Review for Applicable Airspace

 COA Provisions Review
Part 1 – Visual Observance Seminar
Perception

 Perception 

 The ability to see, hear, or become aware of something through the senses. 

 Detection of a Sensory Stimulus 

 Typical UAS Sensory Stimuli

 Visual Stimuli

 Light Flash

 Color Change

 Sound Stimuli

 Humming

 Grinding

 Odor Stimuli

 Melting Plastic
Concepts

 Central vs. Peripheral Vision 

 Central vision is where your acuity and color vision is best

 Acuity – Sharpness in Visual Perception 

 Utilized for high resolution and focus. 

 Peripheral Vision

 Orientation

 Relative Speed/Movement 

 Motion in your surroundings 
Acuity – Visual Sharpness

 Our resolution is a function of pixels

 Important for Visual Line of Sight Rules

 UAS must be flown within UNAIDED VISUAL LINE OF SIGHT 

 Aid is permitted via contact lenses/prescription lenses but nothing else

 Visual Sharpness or Acuity is Necessary to Pick Out an aircraft over long distances

 Particularly important with UASs because of the small size of the aircraft
Contrast Issues
Depth Perception

 Depth Perception 

 Difficult beyond 20 yards 

 Limited to 200 yards 

 Points of Reference are needed 

 Visual overlay

 Haze

 Shadow
Depth Perception Continued

 Size Reference
Depth Perception Question

 How far away is this Boeing 787 Dreamliner? 

 Difficult with no reference point.
Visual Observance Challenges

 Altered appearances compared to ground operations 

 Atmospheric effects (dust and humidity) 

 Cloud Color vs. Craft Color

 Loss of Contrast

 Haze is a distant visual cue 

 Light sources from below 

 Light angles can hide shadow cues 

 Loss of Depth, Texture, and Size cues 

 Indistinct features are difficult to assess 
Example – Loss of Contrast
Relative Motion

 Relative Motion 

 Objects moving in our peripheral vision are easier to detect

 Remember Peripheral Vision is used for motion 

 Objects moving toward or away from you are difficult to perceive

 Central Vision is for sharpness and HD Vision, not motion

 https://www.youtube.com/watch?v=2vMbATfG-5I
Strategies for Better Visual Observance

 Beware of conditions that degrade image sharpness 

 Correct scanning techniques 

 Improve contrast issues 

 Aircraft color/lighting, vantage point, light conditions 

 Alter aircraft coloring if necessary

 Check backgrounds for contrast 

 Colored lenses (in some settings) 
Things to Consider

 Beware of visual obstructions 

 Color and shape similarity 

 Consider relative motion problems 

 Central vs. Peripheral Vision 
Classroom Training – UAS Flights 
Why do we need a Visual Observer?

 Why? 

 Compliance with applicable sections of Title 14 of the Code of Federal Regulations 

(14 CFR) to operate in the NAS

 Compliance with the Petition for Exemption and Granted Section 333 Exemption 

 To ensure at least an equivalent level of safety as it provided by existing rules and 

regulations for the National Airspace System as developed by the Federal Aviation 

Administration 
Observer Requirements

 Observer Requirement 

 A VO must be positioned to assist the Pilot In Command

 Why?

 To exercise the see-and-avoid responsibilities required by §§ 91.111, 91.113, and 91.115 

by scanning the area around the aircraft for potentially conflicting traffic and assisting the 

PIC with navigational awareness. 
Observer Requirement

 Observer Requirement 

 VOs must; 

 Not allow the aircraft to operate beyond the visual line-of-sight 

 Be able to see the aircraft and the surrounding airspace sufficiently at all times 

 Determining the UA’s proximity to all aviation activities and other hazards (e.g., terrain, 

weather, structures) 

 Exercising effective control of the UA 

 Complying with §§ 91.111, 91.113, and 91.115 

 Preventing the UA from creating a collision hazard

 Inform the PIC before losing sufficient visual contact with the UA 
Observer Requirement

 Observer Requirement 

 Why are visual aids not permitted to be used to keep an aircraft within “Line 

of Sight?”

 Visual Aids including;

 Telescopes

 FPV Goggles

 Binoculars

 Distort vision and alter an observer’s field of view
Observer Requirement

 Observer Requirement 

 In a UAS flight crew the PIC operates like a captain and the VO as the 

assistant, therefore the PIC will select a location from which the VO will 

perform their duties so as to afford the best available view of the entire area 

within which the operation is to be conducted.
Communications

 Communication Requirements 

 A VO provides see-and-avoid assistance to the PIC and due to this, must have 

immediate communication with the UAS pilot

 Verbal Communication Range at all times

 Not Permitted

 Cell Phones

 Text

 Walky-talkies 
Post-Observer Training Qualifications

 UAS Observer Qualifications 

 All observers must have an understanding of Federal aviation regulations 

applicable to the airspace where the UAS will operate (Class G Airspace)

 Observers are considered crewmembers 

 Observers must NOT perform crew duties for more than one UAS at a time

 Observers are not allowed to be both the VO and PIC 
Observer Qualifications – Regulatory 

Knowledge

 UAS Observer Qualifications 

 Observers must complete sufficient training to communicate to the pilot any 

information required to remain clear of conflicting traffic, terrain, and 

obstructions, maintain proper cloud clearances, and provide navigational 

awareness. 

 Overview 14 CFR: 

 § 91.111, Operating Near Other Aircraft; 

 § 91.113, Right-of-Way Rules: Except Water Operations; 

 § 91.115, Right-of-Way Rules: Water Operations; and 

 § 91.155, Basic VFR Weather Minimums; 
COA Provisions Review 

 Blanket 200 Foot COA 

 Applicable to all Section 333 Exemption Holders

 Rules

 At or below 200 feet

 Aircraft that weigh less than 55 pounds

 Operate during daytime Visual Flight Rules (VFR) conditions

 Operate within visual line of sight (VLOS) of the pilots

 5 nautical miles (NM) from an airport having an operational control tower; or

 3 NM from an airport with a published instrument flight procedure, but not an operational tower

 2 NM from an airport without a published instrument flight procedure or an operational tower

 2 NM from a heliport with a published instrument flight procedure
Terminology

 UAS Terminology 

 Return to Base 

 Land Immediately 

 Terminate Aircraft 

 Traffic/Obstacle advisory 

 Maneuver aircraft to avoid conflict 
Section 333 Petition for Exemption Parameters

 Proposed operations using SUASs in the United States under the granted form of 

this Petition for Exemption will be limited to the following aircraft, which all 

weigh less than 55 pounds including batteries and operational & technical 

payloads;

 DJI Phantom

 DJI Phantom 2

 DJI Phantom 2 Vision

 DJI Phantom 2 Vision +

 DJI Phantom 3 Advanced

 DJI Phantom 3 Professional

 DJI Inspire 1

 DJI Matrice 100
 The proposed use-cases/applications contained within this Petition for 

Exemption under Section 333 are as follows;

 Agriculture – Precision Agriculture, Animal Agriculture applications

 Land Information Services – Aerial Surveys, 3D mapping, Stitched Imagery

 Real Estate – Aerial Cinematography and marketing pieces

 Insurance – Aerial surveys of insured assets

 Aerial Cinematography – Landscape Videos

 Infrastructure Inspections – Aerial Infrastructure Assessments and Inspections

 All of these flights will take place in Class G airspace nationwide unless 

otherwise advised in an ATO-issued Certificate of Waiver or Authorization. 

Section 333 Petition for Exemption Parameters
 All flights conducted will be below 400 feet AGL (Above Ground Level)

 All flights conducted will be controlled by a trained flight crew consisting of a 

licensed (at minimum Sport Pilot’s Certificate) PIC with a Medical Certificate 

or equivalent valid U.S.A. Driver’s license and a trained Visual Observer.

 All flights conducted will include aircraft that are flying below the 87 knot 

(100 mph) airspeed maximum, highlighted by the FAA in their guidelines. 

Section 333 Petition for Exemption Parameters
 All flights conducted will be conducted within Visual Line of Sight and adhere to 

Visual Flight Rules under the Visual Meteorological Conditions associated with Class 

G airspace. 

 Link to VMCs -

https://www.faa.gov/air_traffic/nas_redesign/regional_guidance/eastern_reg/nynjphl_r

edesign/documentation/feis/appendix/media/Appendix_ANational_Airspace_System_Overview.pdf

 The Petitioner will not allow any PIC to operate a sUAS unless the PIC meets the 

qualification standards set by the Federal Aviation Administration (i.e. Minimum -

Sport Pilot’s Certificate/Medical or U.S.A. Driver’s License) and by the safety 

guidelines and operational capabilities relating to safe sUAS operations, such as;

 Evasive Maneuvers

 Emergency Actions

 Fail-Safe Knowledge

 Flight Skills

 Maintaining adequate distances from;

 People

 Property

 Structures

 Etc.

Section 333 Petition for Exemption Parameters
 PIC qualification flight hours will be logged in a manner consistent with 14 

CFR § 61.51(b). Additionally, a record of the PIC training will be documented 

and made available upon request by the Administrator. 

 Training operations will only be conducted during dedicated training sessions. 

During training, all persons not essential for flight operations will be deemed 

nonparticipants, and thus, the PIC will operate the UA with appropriate 

distance from nonparticipants in accordance with 14 CFR § 91.119. 

 As highlighted by the FAA, the Visual Observer’s duty is to visually observe the 

relevant airspace for aircraft, hazards, obstacles, structures, or the like. For 

this reason, the VO will not be allowed to operate the camera or other 

instruments. 

Section 333 Petition for Exemption Parameters
 The PIC for the duration of an unmanned flight will be named prior to the 

flight. Due to this, once the PIC is named and a flight is begun, the PIC will 

not be able to transfer his/her designation as the PIC though the duration of 

the flight. Furthermore, the PIC is the Captain of the flight crew and will 

ensure that the Visual Observer is qualified to hold the VO position for the 

duration of the flight. 

 Each commercial SUAS flight performed will be planned for ahead of the flight 

date. This will be to ensure adequate time for all participants to prepare and 

to obtain all the necessary permissions (landowners, homeowners, property 

owners, etc.) if any are needed. All flights will be preceded by a meeting at 

least one day before the flight at which all participants of the flight will be 

present. This is to ensure adequate knowledge and preparedness prior to the 

SUAS flight. 

Section 333 Petition for Exemption Parameters
 Aircraft maintenance is obviously vital for any commercial SUAS operation. It 

ensures safety and is necessary prior to each flight to maintain safe, efficient, 

and effective flight operations. Once again, the PIC, as the captain of the 

flight crew, will take a leading role in inspecting the aircraft prior to flight. 

The PIC will likely have the most experience of anyone on the flight crew and 

will be in turned with the specific maintenance needs of each specific flight 

craft. If the PIC were to find an error in the flight craft or any of the 

associated systems, including the Ground Control System for example, he/she 

would ground the flight until adequate maintenance is completed and the 

aircraft is once again safe to fly. All maintenance on flight crafts will be 

noted and logged as to ensure the safety of all aircraft and the people 

operating them. 

Section 333 Petition for Exemption Parameters
 Relating to the above Condition, anytime a flight-critical component is 

replace or anytime there is mission-critical maintenance on the craft, the PIC 

will conduct a flight test of the system before completing the intended, 

commercial mission. Once again this flight test will be logged by the PIC. 

 Routine maintenance and inspections of the SUASs will be logged by the PIC in 

accordance with the requirements and suggestions laid out by the aircraft 

manufacturer in terms of aircraft component maintenance, overhaul, 

replacement, inspection, and life limits, which are part of the supporting 

documents for each aircraft below in Exhibits 5-68. The logging of these 

maintenance/inspection checks will be included in the aircraft records and 

include the total time of service and description of work. 

Section 333 Petition for Exemption Parameters
 All SUAS flights will be conducted within Visual Line of Sight (“VLOS”) of both the 

PIC and VO at all times. Furthermore, VLOS means visual observance unaided by 

any device other than corrective lenses such as eye glasses or contacts. The use 

of telescopes, FPV systems (for purposes of VLOS flights), binoculars, and the like 

will not be permitted. Also, both the PIC and VO should be in constant, verbal 

communication range. The use of other devices to communicate out of verbal 

range are not permitted. These devices would include, cell phones, text 

messaging, walky-talkies, and the like. 

 No commercial flight missions will be executed unless it can be determined that 

the flight crew can complete their mission from take-off through landing, with a 

reserve of 20% battery life. New flight crafts have adaptive battery monitors and 

for this reason this condition will an automated process as the Petitioner can set 

the default Advisory and Critical Battery warnings to 30% and 20% respectively, 

which will warn the PIC of the depleted battery and engage him/her to fly home 

and land with 20% remaining power. For all systems without this automated 

feature, a watch will be used to monitor flight times to ensure a safe return home 

with adequate battery power. 

Section 333 Petition for Exemption Parameters
 In the case of an unexpected obstacle or in-flight issue, each sUAS operator will 

have the ability to abort a mission and take corrective actions. 

 The sUASs utilized will be programmed so that if the sUAS loses signal with the PIC 

or Ground Control Station during flight, the system will return to a 

preprogrammed GPS location located within the operating area containing the 

flight crew. Furthermore, this failsafe can also be used in controlled situations, 

meaning the failsafe will be able to be engaged should something happen on the 

ground that disallows the PIC from bringing the SUAS in a normal fashion. 

Additionally, in both situations described above, where the failsafe is either a 

controlled action from the pilot or an uncontrolled situation, like radio-link signal 

loss, the unit will not only fly back to its preprogrammed home point, it also has 

the ability to land itself. This creates safe operations of the aircraft even in bad 

situations, like signal loss, and prevents the unit from flying off uncontrollably or 

landing in an unknown location. 

Section 333 Petition for Exemption Parameters
 The operating documents required under 14 CFR §§ 91.9 and 91.203 will be maintained and 

available to the PIC at the Ground Control Station of the UA anytime the SUAS is operating. 

Furthermore, these documents will be available for review by the Administrator or other law 

enforcement officials upon request. 

 It is always important to specify precedent when determining operating practices. For this 

reason, if a discrepancy exists between the conditions laid out in this Petition for Exemption 

and the actual Granted Exemption, the conditions laid out in the finalized Granted Exemption 

will take precedent over the conditions laid out in this Petition. Furthermore, if there are no 

discrepancies between the Petition and Grant of Exemption, the Petitioner will follow the 

procedures outlined in the Operating Documentation below. Additionally, if any changes are 

made to the Operating Procedures and Documentation contained in this Petition for 

Exemption, the Petitioner will present the updated documents upon request from the 

Administrator. Also, should the Petitioner determine that an update or change to the 

procedures or documentation would affect the basis of the approved version of this Petition 

for Exemption, the Petitioner will either file for an amendment to the existing Exemption or 

create a new Petition with the revisions. 

Section 333 Petition for Exemption Parameters
 As has been noted, the Petitioner will obtain written and/or oral permission 

from the landowners, farmers, property owners, or otherwise authorized 

agents for flights above their property. 

 The Petitioner will also obtain all required permissions and permits from 

territorial, state, county or city jurisdictions, including;

 Law Enforcement

 Fire Departments

 Municipal Agencies or;

 Other Appropriate Governmental Bodies 

Section 333 Petition for Exemption Parameters
 The Petitioner will not conduct operations at night, as defined in 14 CFR § 1.1. Furthermore, 

all operations will be conducted under visual meteorological conditions (VMC).

 The Petitioner is aware of the need to obtain an Air Traffic Organization (“ATO”) issued 

Certificate of Waiver or Authorization (“COA”) prior to conducting operations under the grant 

of exemption. The Petitioner intends to fly under the Blanket COA provided by the FAA in 

March of 2015 for flights below 200 feet to all Section 333 Exemption holders or under a 

future ATO-issued COA that will be applied for by the Petitioner after receiving their Section 

333 Exemption. 

 All SUAS flights conducted by the Petitioner will be done so in accordance with airspace 

requirements established by the FAA and/or an ATO-issued COA, including;

 Class of Airspace

 Altitude Level, and potential;

 Transponder Requirements

Section 333 Petition for Exemption Parameters
 As has been stated, the SUAS will not be operated within 5 nautical miles of 

an airport reference point as noted on a current FAA-published aeronautical 

chart unless a letter of agreement with that airport’s Air Traffic Control is 

obtained, and the operation is conducted in accordance with a NOTAM as 

required by the Operator’s COA. 

 As stated previously, the Petitioner will follow VMC guidelines for VFR flights 

and as such, will fly only when there is visibility equal to or in excess of 3 

statute miles from the PIC, while maintaining an adequate distance of no less 

than 500 feet below, or less than 2,000 feet horizontally from a cloud.

 All operations by the Petitioner will be conducted in Class G airspace 

nationwide or as otherwise advised in an ATO-issued COA. 

Section 333 Petition for Exemption Parameters
 All aircraft utilized by the Petitioner operate via radio frequency, which is governed by the 

Federal Communications Commission (“FCC”). For this reason, prior to commercial 

operations under a granted Section 333 Exemption, the Petitioner will ensure the radio 

frequency spectrum used to operate and control its SUASs complies with FCC or other 

appropriate government oversight agency rules and regulations. 

 As is stated in FAA guidelines, an SUAS is required to yield the right of way to all manned 

aircraft and aviation operations at all times. This rule will be strictly followed by the 

Petitioner. 

 The concentration of a PIC is necessary for safe operations. It is for this reason that the 

Petitioner will not allow any SUAS operations while a PIC is in a moving device or vehicle. 

These vehicles would include things like;

 Cars/Trucks/SUVs

 Boats

 Tractors

 ATVs

Section 333 Petition for Exemption Parameters
 All SUAS operations by the Petitioner will be conducted at least 500 feet from all 

nonparticipating people, vessels, vehicles, and structures, unless the following 

conditions apply;

 Protective barriers are present that adequately protect nonparticipants from flying 

shrapnel or debris should there be an accident. Furthermore, should a nonparticipant 

leave this safe-zone, the PIC will end the flight. 

 The Petitioner has been granted permission to operate near a vessel, vehicle, or 

structure by the owner/controller of these properties. In addition to permission, the PIC 

will also have to perform a risk assessment of the situation and potential obstacles/flight 

hazards and determine the safety of the flight. If it is determined that the hazards 

present no risk, the PIC can start the mission. 

 Operations nearer to the PIC, VO, operator trainees or essential persons do not present 

an undue hazard to those persons per § 91.119(a).

Section 333 Petition for Exemption Parameters
 The Petitioner will log and report to the UAS Integration Office (AFS-80) 

within 24 hours of any incident, accident, or flight operation that occurred 

outside the horizontal and vertical boundaries of the operational area as 

defined by the COA under which the flight operating. Furthermore, the 

Petitioner will report accidents to the National Transportation Safety Board 

(NTSB).

Section 333 Petition for Exemption Parameters