Daylight operations waiver just shot down.


Kirk
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Is there anyone willing to share their insights on how to write a approved daylight operations request to the FAA? I wrote what I thought was an iron clad request. Not so much. You could private message me the info, hint, hint. Would very much appreciate any help.

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@Uaviator53 Thanks for the info. As I'm finding after some research this morning that I made the mistaken assumption the FAA would refer to my application and send it to me via e-mail during this process. Not as an excuse but I entered all of the data on the FAA site from my iPhone during a job and wasn't thinking. I will have to request a copy of my app as i did not save it when submitted. Not my usual record keeping but I made a mistake. Here is the FAA denial letter, that I do have.

 

FAA daylight operations denied 3-29-17.pdf

Edited by Kirk
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Yeah, funny how the waiver, when granted, requires the PIC to have a copy of the application on hand, BUT they don't give u a copy unless u ask for it. The portal has no option to save/print the application. Next update?

No biggie, you just have to respond with a whole lot of verbiage (remember it's the federal govmn't) and be very repetitive (feds don't appreciate conciseness nor brevity).addressing each performance standard (assume you are explaining each answer to a 5 year old):

Hope you don't mind my suggestions....

Performance-Based Standards 
 
1. Applicant must provide a method for the remote pilot to maintain visual line of sight during darkness.

(In precise detail) Go into your strobe lights, position of lights on aircraft, (lumens, tech data) how many, bla, blah, ground test of distance visibility, etc., etc. VO-VO-VO

2. Applicant must 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.

Your familiarization with sectional charts, local airport operations,  traffic patterns, volume of night time activity, daylight visit and mapping every obstruction, location and height on a map accessible to you and VO. I keep an external monitor on a table (HDMI feed) so not only VO but everyone around can see video/HUD display...Actually, my only night flight audience so far were cops, I asked one of them to be my VO (trained in night vision) and another to act as safety officer with authority to call an immediate safety time out (sort of an Air Boss). FAA eats this bs up.

3. Applicant must 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 (sUA).  

VOs plus explain the HUD, and your emergency plan if you lose display, i.e Ipad dies, lose video signal, remind them the controller still operates w/o HUD, and that you maintain situational awareness of you aircraft at all times, RTH, etc.

4. Applicant must assure all required persons participating in the sUA operation have knowledge to recognize and overcome visual illusions caused by darkness, and understand physiological conditions which may degrade night vision.

Train everyone on the team. I attached what I developed below

5. Applicant must provide a method to increase conspicuity of the sUA to be seen at a distance of 3 statute miles unless a system is in place that can avoid all non-participating aircraft.  
 Repeat item 1.

Give it a few days and the smart folks here will be able to offer much better advice.

PIC EXAM for sUAS Night Flying.pdf

Edited by Uaviator53
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@Uaviator53 I do appreciate all the input. You can never have to much information. I've been on a mission today. I've written a very comprehensive Wavier request. I did as you suggested and taken each of the 5 performance items and beat them to death! Lots written on night vision alone to appease the mighty FAA. Funny thing is I was a flight test tech for Mc Donnell Douglas and received an actual night vision training certification. So me trying to get this is and having trouble is kinda funny.

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