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FAA Daylight Operation Waiver Approval

I have applied for FAA 107.29 Daylight operation waiver and have had 4 failed attempts. The feedback from the last failed attempt is listed below. Does anybody have any ideas on how I can resolve these last remaining issues?

For a waiver from section 107.29—Daylight operation:

Describe how the RPIC will see other aircraft, or see and avoid people on the ground during darkness.
a. How will the RPIC and/or VO locate other persons or aircraft in the dark?
b. What will they do if other persons are located during flight?

What procedures will be followed to ensure all the required persons participating in the operation have knowledge to recognize and overcome visual illusions caused by darkness and understand physiological conditions which may degrade night vision?
a. How will the RPIC and any other participants in the operation demonstrate knowledge about night operation risks, such as overcoming night visual illusions, limitations to night vision, and conditions that can affect night vision?
b. How will the Responsible Person verify the knowledge has been obtained and documented?

It would help if you would post what your response to those issues were, then we could suggest what you are missing.

Thanks for taking the time!! One thing to note is I did say that only 1 person would be involved in the operation.
Here is what I put down about night operations:

Familiarity with Hazards of Night Operation:

Operational procedures will require that prior to conducting night operations the RPIC and VO(s) will be trained to recognize and overcome visual illusions caused by darkness and understand the physiological conditions which may degrade night vision.

Training materials will come from a variety of FAA-disseminated sources. Primarily, training will be adapted from Chapter 10 of the Airplane Flying Handbook and Chapter 13 of the Helicopter Flying Handbook, both titled "Night Operations”. Specific topics of focus will include (at a minimum) the following:

  • • Autokinesis: Fixation on a stationary object may cause incorrect perception of motion.
  • • Fixation / Fascination: Pilots may tend to fixate on a single point, making them less aware of other traffic. Scanning and off-center viewing techniques will be discussed.
  • • Reversible Perspective Illusion: Difficulty determining if an object is moving towards you or away from you
  • • Size-distance illusion: Objects may incorrectly seem closer when brightly lit, and further away when dimly lit.
  • • Flicker vertigo: Viewing a flickering light can be distracting, annoying, and disorienting

As stated above, training materials and records of training compliance will be documented by the RPIC. In order to act as an RPIC or VO, at a minimum, participants in the operation must read the above chapters (in addition to any other provided materials). The RPIC will keep a written record of when the documents were last read by the participants. The participants will be required to re-read the referenced material at least once every 12 months. Additionally, a log will be maintained documenting night operational experience.

Here is a copy of the daylight waiver accepted by FAA:
Daylight operation (§107.29)
Purpose
The purpose of night flight is to capture infrared images of roofs and building walls to assist in performing energy audits if the involved facilities. Equipment employed is expected to include the following sUAS and potentially others as added to inventory. No items will be allowed to drop from sUAS. All craft will be set to automatically RTH on loss of signal at a saafe altitude.

  1. DJI Matrice 100: A quad rotor with 25.6” diagonal size between motors (add 14 inches for propeller rotor size), with 9.37 lbs. max loading with a 27g payload of a DJI ZenmuseXTR 336 IR camera with integrated gimbal. RTH
  2. DJI Phantom 4 Pro with integrated gimbal and camera. Max flight speed 45 mph, GPS/GLONASS control, RTH, 13.8’ diagonal size plus 10 ’ propellor. Max takeoff weight 3.06 lbs.

How the RPIC will be able to continuously know and determine the position, altitude, attitude, and movement of the sUAS.

UAS will be equipped with strobing Strobon white anticollision light (mounted on top) and navigation lights: red (mounted on left), green (mounted on right side). Lights will be self-verified to provide visibility for clearance from aircraft at three miles and visibility and orientation for the RPIC and VO.
Observing the relationship between the anticollision and navigation lights the RPIC and VO shall be able to determine the position as well as relative motion and direction of the sUAS.
Telemetry display will be positioned near the sight picture of the sUAS position allowing near-instant feedback of the geographic position, altitude above ground and deck angle of the craft.

Proceduresto be followed to ensure all the required persons participating in the operation have knowledge to recognize and overcome visual illusions caused by darkness and understand physiological conditions which may degrade night vision.

• RPIC will have taken specific training on Night Operations from a reputable training source (Rupprecht Drones).
• RPIC will brief VO on the following visual night illusions
a. Autokinesis: Phantom motion; protracted staring may cause it to appear that an object is moving contrary to reality.
b. Fascination (Fixation): Pilots/Observers ignore orientation cues and fix their attention on a goal or an object.
c. Reversible perspective illusion: Inability to determine if an object is moving towards you or away from you.
d. Size-distance illusion: Dimly lit objects appear to be further away and brightly lit objects appear closer.
e. Flicker Vertigo: Flashing lights may cause nausea or disorientation.
Landing zone will be carefully selected and marked to exclude non-participants in the event of a loss of signal RTH.

Increasing the visual conspicuity of the sUAS to be seen at a distance of at least 3 statute miles (mi).
UAS will be equipped with strobing Strobon white anticollision light (mounted on top) and navigation lights: red (mounted on left), green (mounted on right side). Lights will be self-verified to provide visibility for clearance from aircraft at three miles and visibility and orientation for the RPIC and VO.

Maintaining Line of Sight
• All operations will be performed in visual line of sight (VLOS) only.
• All operations will be performed with a minimum crew of remote pilot in command (RPIC) and a properly briefed visual observer (VO).
• UAS will be equipped with strobing Strobon white anticollision light (mounted on top) and navigation lights: red (mounted on left), green (mounted on right side). Lights will be self-verified to provide visibility for clearance from aircraft at three miles and visibility and orientation for the RPIC and VO.
• In the event visual sight of the UAS is lost the following procedure shall be performed:
a. Stabilize the craft. If GPS lock is indicated do not move the craft.
b. Make a brief attempt at reacquiring visual sight using accepted scan techniques without fixating in visual scanning.
c. Use cues from video data link to identify nearby landmarks. Rotating craft in place may help identify landmark items without increasing collision risks.
d. If visual sight has not been reacquired following these efforts, raise the craft vertically to safe maximum altitude. Increasing altitude may help separate craft from ground clutter.
e. If craft has not yet been identified, perform return-to-home (RTH) function ensuring that pre-established landing area is clear of persons, vehicles, or obstructions.

At least one VO will be required at all flights. If an airport is within 5 miles the VO will monitor (monitor only no transmission) the appropriate CTAF frequency. VO will be instructed to verbally and physically (shoulder tap) the RPIC whenever aircraft are observes
RPIC will brief VO on the following visual night illusions
a. Autokinesis: Phantom motion; protracted staring may cause it to appear that an object is moving contrary to reality.
b. Fascination (Fixation): Pilots/Observers ignore orientation cues and fix their attention on a goal or an object.
c. Reversible perspective illusion: Inability to determine if an object is moving towards you or away from you.
d. Size-distance illusion: Dimly lit objects appear to be further away and brightly lit objects appear closer.
e. Flicker Vertigo: Flashing lights may cause nausea or disorientation.
Landing zone will be carefully selected and marked to exclude non-participants in the event of a loss of signal RTH.

Aircraft/building/personnel avoidance–see and avoid
• UAS will be equipped with Strobon white anticollision light (mounted on top) and navigation lights: red (mounted on left), green (mounted on right side). Lights will be self-verified to provide visibility for clearance from aircraft at three miles and visibility and orientation for the RPIC and VO.
Perform preflight site inspection and briefing of all participants including VO. This shall include daylight scouting of the flight area for obstacles, with special attention paid to area immediately around launch area. RPIC and VO will conduct area scout, and mark up maps for the entire flight crew if necessary. VOs will also be instructed to maintain vigilance while scouting skies and ground during mission for non-participatory aircraft (manned or unmanned), people, or vehicles. Primary VO will also use an air band radio to monitor local traffic frequencies.

What will they do if other persons/aircraft are located during flight?
a. If any member of the flight crew sees an approaching aircraft, RPIC will be immediately notified both verbally and physically (motion or touch) if necessary, and RPIC will then verbally confirm notification. RPIC will immediately put the UAS into a stationary hover until aircraft direction and altitude can be determined. Wingtip and tail mounted navigation lights on the manned aircraft will be used to determine direction of travel. If it is determined to not be a threat, mission will continue with special attention given to that aircraft until well away from flight area. If aircraft altitude and direction cannot be determined in a safe amount of time, RPIC will lower aircraft as quickly and safely as possible. If necessary, and time permits,RPIC will return UAS to launch area. As a last resort, PIC will institute an emergency flight termination procedure over a predetermined safe area that has been marked on the map. This will only be used as an emergency last resort due to the RPIC losing all control of the UAS at that point. If a non-participatory person or vehicle gets close to, or enters into the flight area, the same VO/RPIC notification and confirmation procedure will be performed as above. Same hover and return procedures will be performed, with the added safety precaution of keeping the UAS from flying over, or too close to, non-participatory people or vehicles.
b. How will they avoid hitting obstacles/structures during flight?
The daylight scouting session and preflight meeting will be sufficient to keep sUAS away from obstacles and structures. If necessary, a nonprimary VO will use a flashlight to illuminate any possible obstacles when sUAS reaches a predetermined distance from them. VO will monitor sUAS and obstacle map to ensure safety. Flightcrew will always err on the side of being overly cautious when it comes to obstacle avoidance. Launching and landing zone will be sufficiently lit to maintain a safe area for operations.
c. If flight operations occur in an area with lighting sufficient for the RPIC and VO to see their aircraft, and other obstacles, persons, and aircraft, how will they determine the lighting is sufficient prior to flight?
By using visual cues such as color and distance confirmations between flight crewmembers. If there is any doubt by any flight crewmember as to how sufficient illumination is for safety, additional lighting will be used as described above.

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