What is Beyond Visual Line of Sight (BVLOS)?
Beyond Visual Line of Sight operations represent one of the most significant frontiers in commercial drone technology. While current Part 107 regulations require pilots to maintain visual contact with their aircraft, the potential applications that BVLOS would enable—long-distance infrastructure inspection, automated delivery, large-scale agricultural monitoring, and emergency response over wide areas—have driven intense interest from industry and regulators alike.
BVLOS means operating a drone beyond the distance at which the remote pilot can see the aircraft with unaided vision (corrective lenses like glasses are allowed, but binoculars, telescopes, or similar devices are not). This isn’t about flying a specific distance like “beyond 500 feet” or “more than a mile”—it’s about losing the ability to see and track the aircraft visually regardless of distance.
Understanding BVLOS regulations, waiver processes, and technical requirements is essential for operators looking to expand capabilities beyond traditional line-of-sight operations.
Current Part 107 Visual Line of Sight Requirements
The baseline rule is found in 14 CFR 107.31: the remote pilot in command and any person manipulating the controls must be able to see the aircraft with vision unaided by any device other than corrective lenses.
What VLOS Requires
Under standard Part 107 rules, you must maintain visual line of sight sufficient to:
- Know the aircraft’s location – Where it is in three-dimensional space
- Determine the aircraft’s attitude and altitude – Its orientation and height above ground
- Observe the surrounding airspace – See other aircraft and potential hazards
- See and avoid obstacles and other aircraft – Maintain separation and safety
This requirement exists because visual observation is currently the primary method for:
- Collision avoidance with manned aircraft
- Obstacle detection and avoidance
- Emergency response if systems fail
- Compliance verification for airspace and operational limits
What Counts as “Visual Line of Sight”
VLOS is highly dependent on environmental conditions:
- Distance – Typically 1/2 mile to 1 mile for most consumer drones in good conditions, but could be much less
- Weather – Fog, haze, rain, or low clouds dramatically reduce VLOS range
- Aircraft size and color – Larger drones with high-contrast colors remain visible longer
- Background – Aircraft against clear sky are easier to see than against cluttered terrain
- Lighting – Sun angle, time of day, and anti-collision lighting affect visibility
- Pilot vision – Individual eyesight capabilities vary
You don’t lose VLOS just because the drone is far away—you lose VLOS when you can no longer see it clearly enough to maintain situational awareness and safety. This could happen at 200 feet in fog or 2,000 feet in perfect conditions.
Visual Observer Option
Part 107 allows the use of visual observers (VOs) to help maintain VLOS, but this doesn’t enable true BVLOS:
- VOs can extend your effective range by positioning themselves strategically
- VOs must maintain unaided visual contact with the aircraft
- VOs must have direct communication with the remote pilot
- The remote pilot OR a VO must maintain VLOS at all times
Using multiple VOs in relay formation can extend operational range, but eventually you reach practical limits and still haven’t achieved true BVLOS where no one has visual contact.
BVLOS Waiver Application Process
To legally conduct BVLOS operations, you must obtain a waiver from the FAA under 14 CFR 107.31. This is one of the more complex waiver types and requires substantial documentation.
Who Qualifies for BVLOS Waivers
The FAA evaluates BVLOS waiver applications based on:
- Demonstrated need – Clear operational requirement that can’t be met with VLOS
- Safety case – Evidence that the operation can be conducted at an equivalent level of safety
- Technical capability – Systems and procedures that compensate for lack of visual observation
- Operational history – Prior experience conducting complex UAS operations
- Risk mitigation – Comprehensive plans addressing all identified hazards
Required Elements of BVLOS Waiver Application
A complete BVLOS waiver application typically includes:
- Operational Description
- Specific area of operations (geographic coordinates)
- Maximum altitude and lateral dimensions
- Aircraft specifications and capabilities
- Mission profile and procedures
- Duration of operations requested
- Safety Case
- Hazard identification and risk assessment
- Equivalent level of safety analysis
- Accident scenario analysis
- Population density and overflight considerations
- Manned aircraft traffic analysis for the area
- Detect and Avoid (DAA) System Description
- Technical specifications of DAA equipment
- Performance data and testing results
- Integration with aircraft systems
- Alerts and notifications protocols
- Command and Control (C2) Link
- Redundancy and reliability measures
- Lost link procedures
- Failsafe behaviors
- Communication backup systems
- Crew Qualifications
- Remote pilot experience and training
- Aircraft-specific training documentation
- Emergency procedures proficiency
- Crew resource management for multi-person operations
- Operational Procedures
- Preflight planning and checks
- Normal operation checklists
- Emergency procedures
- Coordination with ATC (if applicable)
- NOTAM and TFR monitoring
- Maintenance and Inspection
- Aircraft maintenance schedules
- System testing requirements
- Record keeping procedures
Application Submission Process
BVLOS waivers are submitted through the FAA DroneZone portal:
- Log in to faadronezone.faa.gov
- Navigate to “Part 107 Authorizations and Waivers”
- Select “Apply for a Part 107 Waiver”
- Choose section 107.31 (Visual Line of Sight)
- Complete all required fields in the online application
- Upload supporting documentation (safety case, procedures, diagrams, etc.)
- Submit and receive confirmation number
Processing Times and Expectations
BVLOS waivers are among the most complex and time-consuming:
- Typical processing time: 120-180 days (often longer for complex operations)
- FAA may request additional information – Respond promptly to avoid delays
- Iterative review process – Be prepared for multiple rounds of clarification
- Conditional approvals – Initial waivers often have significant restrictions
- Phased expansion – Demonstrate safety in limited operations before expanding scope
First-time BVLOS applicants should expect the process to take 6-12 months from initial submission to approval.
Technology Requirements for BVLOS Operations
The cornerstone of safe BVLOS operations is technology that compensates for the lack of visual observation. The FAA focuses heavily on detect and avoid (DAA) systems.
Detect and Avoid (DAA) Systems
DAA systems serve as the technological replacement for the pilot’s eyes. Acceptable systems vary but generally include:
Sensor-Based Detection
- ADS-B receivers – Detect aircraft broadcasting ADS-B Out signals (required on most manned aircraft)
- Radar systems – Active detection of aircraft regardless of ADS-B equipage
- Electro-optical/infrared cameras – Visual detection systems with automated processing
- Acoustic sensors – Detection based on aircraft engine/propeller sounds
Ground-Based Observers
- Remote visual observers – Strategically positioned observers with communication to the remote pilot
- Radar surveillance – Ground-based radar monitoring the operation area
- Air traffic control coordination – Integration with ATC separation services
Operational Mitigations
- Low-population areas – Operations over sparsely populated terrain reduce risk
- Altitude separation – Operating well below typical manned aircraft altitudes (below 200 feet AGL)
- Temporal separation – Coordinating operations when manned aircraft are unlikely
- Geographic isolation – Locations far from airports and typical flight paths
Most successful BVLOS waivers use a combination of these approaches rather than relying on a single technology.
Command and Control (C2) Link Requirements
BVLOS operations demand robust communication between the remote pilot and the aircraft:
- Redundant communication paths – Primary and backup links using different technologies
- Link quality monitoring – Real-time assessment of signal strength and latency
- Lost link protocols – Automatic behaviors if communication is lost (RTH, loiter, land)
- Range verification – Testing to confirm adequate coverage throughout the operation area
- Interference resistance – Systems robust against RF interference
Navigation and Positioning
BVLOS aircraft must have highly reliable navigation:
- Multi-constellation GNSS – GPS, GLONASS, Galileo for position redundancy
- Inertial navigation backup – Continue operation through temporary GPS loss
- Barometric and radar altimeters – Precise altitude awareness
- Geofencing – Automated enforcement of operational boundaries
Common BVLOS Use Cases
Understanding approved use cases helps inform effective waiver applications:
Infrastructure Inspection
Typical operations: Railroad tracks, pipelines, power lines, communication towers
Why BVLOS is necessary: Linear infrastructure extends for miles; VLOS would require constant repositioning
Safety approach: Low altitude operations over rural areas with minimal manned aircraft traffic, ADS-B receivers, geographic isolation
Package Delivery
Typical operations: Medical supplies, commercial packages, emergency equipment
Why BVLOS is necessary: Delivery routes between facilities exceed VLOS range
Safety approach: Established flight corridors, ATC coordination, advanced DAA systems, redundant C2 links
Agricultural Operations
Typical operations: Crop monitoring, precision agriculture, livestock management
Why BVLOS is necessary: Large agricultural properties exceed VLOS range
Safety approach: Operations over private property, low altitude, rural locations, limited manned traffic
Search and Rescue
Typical operations: Missing person searches, disaster response, maritime rescue
Why BVLOS is necessary: Search areas too large for VLOS coverage
Safety approach: Coordination with incident command, TFR establishment, ground-based observers, emergency priority
Environmental Monitoring
Typical operations: Wildlife surveys, coastal erosion monitoring, forest health assessment
Why BVLOS is necessary: Survey areas exceed VLOS range, wildlife disturbance minimization
Safety approach: Remote locations, low population density, altitude restrictions
Practical Considerations for Pursuing BVLOS
Before investing in BVLOS waiver applications, operators should consider:
Cost-Benefit Analysis
- Waiver application costs – Professional safety case development, legal review, testing documentation
- Technology investment – DAA systems, enhanced C2 links, redundant navigation
- Operational overhead – Maintenance, record keeping, compliance monitoring
- Time investment – 6-12 months or more from application to approval
- Revenue potential – Does the business opportunity justify the investment?
Alternative Approaches
Sometimes VLOS operations with creative planning can achieve similar results:
- Visual observer relay – Strategic VO positioning extends effective range
- Multiple shorter flights – Repositioning the remote pilot along the route
- Higher altitude VLOS – Operating at maximum legal altitude extends visual range
- Partnering with waivered operators – Contracting with companies that already hold BVLOS authority
Building Toward BVLOS
For operators seriously pursuing BVLOS capabilities:
- Develop extensive VLOS operational history – Demonstrate safety and professionalism
- Invest in advanced aircraft systems – Build comfort with redundant systems and automation
- Document procedures and safety culture – Create the foundation for waiver applications
- Start with limited-scope applications – Request narrow operational parameters initially
- Plan for incremental expansion – Use successful limited operations to justify broader authority
- Engage with the FAA early – Consider pre-application meetings to discuss your concept
The Future of BVLOS Regulations
The regulatory landscape for BVLOS is evolving:
- Type certification pathways – Aircraft with certified DAA systems may receive broader authority
- Performance-based regulations – Moving from prescriptive rules to performance standards
- UTM integration – UAS Traffic Management systems enabling routine BVLOS in controlled airspace
- Risk-based approach – Different requirements based on operation type and location
- International harmonization – Aligning US regulations with international standards
While BVLOS remains challenging to achieve under current regulations, it represents the future of commercial drone operations. Operators who understand the requirements, invest in appropriate technology, and develop rigorous safety programs position themselves at the forefront of this emerging capability. The waiver process is demanding, but for operations that truly require BVLOS capability, the potential return on investment can be substantial.
