Sample 107.33 Visual Observer Waiver Application

By | April 5, 2021

Are you looking for a sample 107.33 waiver application so you can do operations without a visual observer?

Part 107 does not require a visual observer so this waiver is generally paired up with a 107.31 waiver.

The FAA said,

14 CFR §107.33 (visual observer) states if a visual observer is used during the aircraft operation, all of the requirements of 107.33 must be met. Because using a visual observer is not a requirement to operate a small unmanned aircraft in compliance with the standard provisions of part 107, waiver requests to 107.33 should be requested in combination with an additional regulatory section listed in 107.205. For example, the FAA has included 107.33 in issued waivers in combination with waivers to 107.31.

The FAA has spoken elsewhere:

Note: A VO may not be required for certain part 107 operations. If a VO is part of your operation, Title 14, Code of Federal Regulations (14 CFR) § 107.31 requires the VO(s) to all be able to see the small unmanned aircraft (sUA) or drone throughout the duration of the flight. You may need a waiver to certain portions of § 107.33 (specifically § 107.33(b) and § 107.33(c)(2)) if your operation requires the use of multiple VOs, not all of which will be able to maintain visual line of sight with your sUA or drone. An example of operations where this may apply is when using a daisy-chain of VOs (where VO(s) maintain direct visual contact with the sUA or drone throughout the entire flight in place of the RPIC doing so)

Questions to Answer in 107.33 Waiver Application

Even though the FAA didn’t provide a sample application, here are the questions the FAA wants you to answer that are specific to 107.33.

§ 107.33 Visual Observer
1. Describe how you will account for the communication latency between the visual observer(s) (VO) and the Remote Pilot in Command (RPIC).
a. How will the RPIC and VO(s) communicate with each other if they are not near each other?
b. If this communication method fails, how will the RPIC and VO(s) be alerted to the failure?
c. What will the RPIC and VO(s) do if a communication failure occurs?

You should also answer completely and thoroughly in your 107.33 waiver application all of the general questions the FAA has listed here.

If you want more waiver application samples, go to my Part 107 waiver examples page where I list them all.