Pilot In Command 

Training Guide

Training GuideRef-12
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

 Pilot in Command

 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 Pilot In Command?

 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 is provided by existing rules and 

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

Administration 
Pilot In Command Requirements

 PIC Requirement 

 A PIC must be capable of safely flying a sUAS

 Why?

 To exercise the see-and-avoid responsibilities required by 14 C.F.R. 91.111, 91.113, and 

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

receiving assistance from the VO with navigational awareness. 
Pilot In Command Requirement

 PIC Requirement 

 PICs must; 

 Not allow the aircraft to operate beyond 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) 

 Exercise effective control of the UA 

 Complying with 14 C.F.R. 91.111, 91.113, and 91.115 

 Preventing the UA from creating a collision hazard

 Flying the UA back towards the base station before Visual Contact is Lost 
Pilot In Command Requirement

 PIC 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 a PIC’s field of view
Pilot In Command Requirement

 PIC 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 PIC provides see-and-avoid actions in situations of hazard or when 

requested to by the VO and due to this, must have immediate communication 

with the Visual Observer.

 Verbal Communication Range at all times

 Not Permitted

 Cell Phones

 Text

 Walky-talkies 
Post-PIC Training Qualifications

 UAS PIC Qualifications 

 All PICs must have an understanding of Federal Aviation Regulations (FARs) 

applicable to the airspace where the UAS will operate.

 PICs are captains of UAS crews 

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

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

Knowledge

 UAS PIC Qualifications 

 PICs must complete sufficient training to communicate with the VO 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 sUAS in the United States under the granted form 

of this Petition for Exemption will be limited to the listed aircraft within the 

exemption petition.

 Aircraft will weigh less than 55 pounds including batteries and operational & 

technical payloads

 Aircraft will not exceed 100 mph airspeed maximum
 All commercial sUAS flights will be limited to those applications proposed and 

granted within a successful Petition for Exemption.

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

otherwise advised in an FAA-Granted Certificate of Waiver or Authorization. 

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

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

(100 mph) airspeed maximum.

Section 333 Petition for Exemption Parameters
 All flights 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 

C.F.R. 61.51(b). Additionally, a record of the PIC training will be documented 

and made available upon request to 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 C.F.R. 91.119. 

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

flight. 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.

Section 333 Petition for Exemption Parameters
 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 familiar 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 sUAS 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 contained within the 

Exemption Petition and Operations Manual. 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, etc. 

 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. 

 Set Advisory and Critical Battery Warnings (Smart Batteries)

 Use a timer (Non-Smart Batteries) 

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 sUAS 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.

 Ensure an adequate home point is calculated before taking off

 Confirm the location of your fail-safe switches 

Section 333 Petition for Exemption Parameters
 The operating documents required under 14 C.F.R. 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.

 Follow the granted petition for exemption when following flight rules.

 If a discrepancy exists between the conditions laid out in the 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 

Section 333 Petition for Exemption Parameters
 Obtain written and/or oral permission from the landowners, farmers, 

property owners, or otherwise authorized agents for flights above their 

property. 

 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
 Do not conduct operations at night and always follow VLOS flight rules.

 Adhere to the operating areas laid out in your 200 Foot COA or other granted 

COAs.

 Flights should be in accordance with airspace requirements established by the 

COA, including;

 Class of Airspace

 Altitude Level, and potential;

 Transponder Requirements

Section 333 Petition for Exemption Parameters
 Do Not operate the sUAS 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. 

 Always follow VMC guidelines for VFR flights;

 Visibility equal to or in excess of 3 statute miles from the PIC

 Maintain an adequate distance of no less than 500 feet below, or less than 2,000 

feet horizontally from a cloud.

 Conduct all flights in Class G airspace nationwide or as otherwise advised in 

an ATO-issued COA. 

Section 333 Petition for Exemption Parameters
 Prior to commercial operations, ensure the radio frequency spectrum used to 

operate and control the sUAS complies with FCC rules.

 Always yield the right of way to manned aircraft.

 Commercial sUAS Operations under this Petition do not allow for operating 

sUAS from moving vehicles, such as;

 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.

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

structure by the owner/controller of these properties. 

Section 333 Petition for Exemption Parameters
 The Petitioner will log and report to the UAS Integration Office 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 was operating. 

 Report all accidents to the National Transportation Safety Board (NTSB).

Section 333 Petition for Exemption Parameters
Questions?
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