Night Waiver Training on Visual Illusions & Physiological Conditions

If you are planning on obtaining a night waiver or going to fly under a Part 107 night waiver, you’ll need to figure out what you are going to do regarding some training. The night waivers being granted by the FAA say, “Prior to conducting operations that are the subject of this Waiver, the remote PIC and VO must be trained, as described in the Waiver application, to recognize and overcome visual illusions caused by darkness, and understand physiological conditions which may degrade night vision. This training must be documented and must be presented for inspection upon request from the Administrator or an authorized representative;”

I’ve been assisting clients with night waivers since they first started coming out in August 2016.  I noticed there was very little information on the internet regarding night training. To help assist my clients, I created a Night Operations Online Training Course located at Rupprecht Drones. Gold Seal also advertises night training. There are some others that do night training but Gold Seal seemed to have the most internet exposure.

This article is a comparison and contrast of Gold Seal’s course vs. Rupprecht Drone’s night course.

I signed up for Gold Seal’s course and here is what I found. Note that this is from January 20, 2018.

Pros of Gold Seal:

  • They are affordable at $20.
  • The class is taught by an FAA certified flight instructor. Woohoo! No posers here.
  • You have a certificate you obtain that you can print out to keep for your records so you can prove the training was accomplished in case of the FAA auditing you. This is great for operations with multiple pilots where the responsible person can outsource the training.
  • They covered aircraft lights which are critical for determining the direction of travel for aircraft.
  • The quiz requires you to obtain 100% on the test to obtain the certificate. This is perfect because the FAA wants any areas that are deficient to be corrected to 100%. I really like that they have this requirement.

Cons of Gold Seal:

  • Their training does not go in depth to explaining the potential “no man’s land” situation with 1.1’s definition of civil twilight of Part 107 where you canNOT fly under 107’s civil twilight or under the night waiver. Keep in mind that this affects only a small portion of the U.S. in the northern latitudes of the lower 48.
  • The course did NOT accurately describe night per the regulations.
  • They do not talk about all of the visual illusions. They talked about only 5 of them. The reason why all of the illusions should be taught is because people fly in different environments and with different aircraft (fixed wing and rotorcraft).
  • Of the night illusions they listed, they INCORRECTLY talked about some of them. For example, they prescribed the incorrect remedy for the visual illusion called autokinesis and they mixed up reversible perspective illusion with the relative motion illusion when discussing the visual illusions.
  • Very little was said about physiological conditions which may degrade night vision. There was a brief bit of talking about protecting your night vision and off center viewing, but nothing was said about smoking, altitude, night myopia, etc. and how those things WILL degrade your night vision.
  • Lastly, there was no night time scanning pattern taught on how to use the off-center viewing. The off-center viewing is just taught with no overall pattern which is a problem because nighttime scanning is done DIFFERENTLY than daytime scanning because of the off-center viewing.


In summary, they only covered 5 illusions and remedies (two of which they did incorrectly), there is little information on the physiological conditions which may degrade night vision, and no night time scanning techniques are taught.

I can just now hear you saying, “Hold up there Jonathan. Are you saying that Gold Seal’s course doesn’t meet the requirements that the FAA requires to fly under the night waiver? Am I going to get in trouble?” The FAA does not define what is the minimum amount of visual illusions that need to be addressed or the physiological conditions degrading night vision which need to be taught. So I don’t know the answer to that or need to answer it. Fortunately, you don’t need to answer this question also because you have an alternative.


Night Operations Online Training Course for the Night Waiver


I created a night training course covering specifically visual illusions, physical conditions which degrade night vision, and nighttime scanning techniques.  It is located at Rupprecht Drones. A student who finishes the course can print out the completion certificate which acts as the documentation of training in case of an FAA audit. Another bonus is that Rupprecht Drones has aviation insurance covering the instruction.

Physiological Conditions Which Degrade Night Vision/Night Scanning

Rupprecht Drones

Gold Seal

Rod & Cones and Off center viewing.YesYes
Vitamin DeficiencyYesNo
Carbon MonoxideYesNo
Altitude HypoxiaYesNo
2 Types of Night MyopiaYesNo
Presbyopia and CataracsYesNo
Day and Night blind spotsYesNo for day and sort of for night.
Ways to protect night visionYesNot really.


Night Illusions and Their Remedies


Rupprecht Drones

Gold Seal

AutokinesisYesYes, but didn’t cover remedy.
False Depth PerceptionYesYes
Flicker VertigoYesYes, but didn’t cover remedy.
Reversible PerspectiveYesWrong. They mixed up this illusion with the relative motion illusion.
Size & Distance IllusionYesYes
False HorizonsYesNo
Fascination (Fixation)YesNo
Confusion with Ground LightsYesNo
Relative Motion IllusionYesNo, see reversible perspective illusion note.
Structural IllusionYesNo
Altered Planes of ReferenceYesNo
Parallax Error (This is one I brought up which is really just pointing out that your judging distance totally stinks at night and especially when you are some distance from the other person).YesNo.


Night Time Scanning Techniques

Rupprecht Drones

Gold Seal

Night and Day Blind SpotsYesJust the night blind spot. The day blind spot was not talked about.
Off Center ViewingYesNo
Scanning PatternYesNo

Aircraft Lights

Position and Anti-collision lightsYesYes


CertificationsFAA Certificated Flight Instructor (CFI &CFII), Licensed Attorney, & Professor.I believe a CFI was involved. Keep in mind these guys work with highly experienced Master CFIs so some of them might have helped.

If you are interested in learning more about the Rupprecht Drone’s Night Operations Training Course, simply head on over.

For free, you can sign up and sample the first couple of videos to know what type of information you are obtaining.

Jonathan Rupprecht

Mr. Rupprecht is an aviation attorney who focuses on drones. Read more about his background as a commercial pilot, flight instructor, Embry-Riddle Aeronautical University grad, and legal author. He has had media appearances on Forbes, Newsweek, Politico, NPR, Marketwatch, The Independent, Motherboard, and other sources. Feel free to send Jonathan a message here.