GOING BEYOND

VISUAL LINE OF SIGHT

(BVLOS)
INTRODUCTION
“Beyond visual line of sight” (BVLOS) is the most talked about concept in
the commercial drone world today, and for good reason. Many of the most
lucrative opportunities for introducing drones into real-world commercial
use are based upon inspecting and gathering data over large swaths of land
like railroads, utility lines, and farms - that require autonomy.

There are two key factors that make BVLOS flight a tipping point for
commercial drone industry expansion. The first is enabling service
providers to conduct complex drone operations such as long-line
transmission inspection without having to have the drone in sight. This
makes these tools much more viable to replace helicopters or other
methods of current inspection, and opens up serious opportunities for
introducing safer inspection operations into the world.

The second is enabling drones to be able to conduct truly unmanned flight

with no pilot needed for takeoff or landing. This has happened already
in Europe, with power company Enel using the drone-in-a-box system
Percepto for power plant inspection related to operations, maintenance,
and protection. Cutting the human out of the loop allows for additional use
cases, and drives the cost of data acquisition way down, making use cases
in low-margin industries much more likely.

Right now in the US, companies are operating under waivers for
BVLOS, and there are several initiatives looking at the safe autonomous
applications of commercial drones and operation with ground support from
longer distances that line of sight. The investor interest in this space, and
the corporate eyes in energy, agriculture, banking, and more keeping watch
around regulatory timing, is at a peak.

We’ve produced this ebook to walk through barriers to manufacturing

adoption from a regulatory standpoint, to showcase companies we believe
have opportunity in the fixed-wing VTOL space, and to shed some light on
key concepts we think everyone should know.

We’ve paired this written analysis with a series of Guinn Partner analysis
videos you can find linked at the end of this document.
BEYOND
VISUAL
LINE OF
SIGHT
BVLOS is the next step in the future of drone operations and
autonomy, but drones have to become “airworthy” to get there.
In this report, we break down the technical and regulatory
requirements that must be addressed and to summarize what is
known and what is still unclear.

In order to make a drone ready for BVLOS (beyond visual line of

sight) operation, several technical and legal requirements have
to be addressed. The primary concern for manufacturers and
pilots of BVLOS systems will be meeting the dynamic regulatory
requirements for “airworthiness” put forth by the FAA. Related to
this FAA compliance, BVLOS-ready systems require robust “detect-
and-avoid technology” for safety as well as long range reliable and
redundant communications technology. We review all three of these
major requirements for implementing BVLOS systems below.
AIRWORTHINESS

The FAA’s charter is to regulate civil aviation and generally

promote safety. Its certifications extend to both manned and
unmanned aircraft. “Airworthiness” is the FAA’s designation
for individual aircraft that it deems safe to fly. In 14 CFR 3.5,
FAA spells this out as: “the aircraft conforms to its type
design and is in a condition for safe operation”. In other
words, the FAA aims to recognize different types of aviation
technologies and implement detailed regulatory requirements
that show individual craft match the “type designs” it has
already certified. A Boeing 747, for example, has to meet
different requirements than a DJI Mavic, but both need to
demonstrate precise and consistent implementation of their
respective design plans with the exception that the Mavic does
not have a “type design” at this time.
FAA ENFORCEMENT

As defined in 14 CFR 91.203 and 14 CFR 91.7, airworthiness

refers to both the official certification given to an aircraft and the
aircraft condition which has to be maintained for safe flight. The
Airworthiness Certificate gives authorization to fly an aircraft.
However, paper certification alone is not enough, and broken
aircraft are obviously not cleared to fly by the FAA.

There are exceptions to these certificates. Through Part 107, the

FAA has waived the need of Airworthiness Certificates for low-risk
category aircraft. This has allowed commercial drones to enter
the National Airspace (NAS) without needing to pass rigorous
airworthiness criteria. However, these low-risk aircraft are limited
to low-altitude, short-distance flights in less populated areas and
cannot be flown over people or properties without consent. They
also require a human observer within line of sight at all times
while airborne. While there are waivers for Part 107 to perform
slightly higher-risk operations, BVLOS flight will almost always
require FAA certification, unless you are flying in testing facilities
or remote locations like the desert.
TYPE CERTIFICATES
& PRODUCTION CERTIFICATES

Beyond the Airworthiness Certificate, the FAA

provides two other certifications which are important
to manufacturers of UAVs. The Type Certificate
certifies that the design of the aircraft is up to par
with safety standards and provides specific technical
and design requirements about the class of aircraft.
The Airworthiness Certificate by contrast shows that
the individual aircraft fit this approved type design.

Manufacturers will also want a Production

Certificate. Given that the manufacturer already
holds a Type Certificate, the Production Certificate
certifies that the manufacturer can consistently
produce airworthy aircraft and authorizes the
production of the aircraft at scale. The Production
Certificate allows manufacturers to automatically
receive Airworthiness Certificates for every individual
aircraft (of the certified type) that they manufacture.
NEW REGULATIONS
& CURRENT CHALLENGES

These standards for airworthiness have been based in the last century
of manned aviation. Balloons, single engine planes, rotorcraft, jets,
and helicopters have all passed through these regulations as types.
However, type standards for unmanned civilian aircraft do not yet
exist and do not fit into other type standards for these other aerial
technologies. The FAA is now faced with a difficult problem of creating
a new regulatory framework for assessing UAV airworthiness as its
own type. Though many in both industry and government are eager
for new regulations to be passed and to be rid of complex exemption
processes, these new frameworks require years of flight data and
industry-regulator partnerships in order to develop standards for safe
flight and type classification.

Meanwhile, manufacturers are able to get by with manned aircraft

certification standards. 14 CFR 21.17(b) provides the interim solution:
the FAA (and especially the Los Angeles Aircraft Certification Office)
picks and chooses requirements which, though intended for manned
aircraft, are “found by the FAA to be appropriate for the aircraft
and applicable to a specific type design, or such airworthiness
criteria as the FAA may find provide an equivalent level of safety”.
For manufacturers, this process entails reviewing many (on the
scale of thousands) requirements intended for manned aircraft and
demonstrating that the UAV either satisfies the requirement or is
categorically exempt from the requirement because of its type design.
In the simplest case, a manufacturer might file an exemption that they
do not need to include a flight manual on the UAV. However, it is not
always this easy to dissect the regulations and determine whether or
not they apply in the absence of an on-board pilot.
The Path Forward for
BVLOS
Both the FAA and NASA have
made recent efforts to push the
current framework of airworthiness
forward. The FAA’s Unmanned
Aerial System Integration Pilot
(UAS IPP), for example, has created
opportunities for state and local
governments to partner with pilots
and manufacturers in order to help
bridge the gap between regulatory
standards and industry needs.
NASA’s Systems Integration and
Operationalization demonstration
has been another leading effort
toward UAS airworthiness
certifications. The “Pathfinder”
program is the cutting-edge of
development, where regulators
partner directly with technology
companies to explore the concepts
that wish to refine for developing
future regulatory standards. These
industry-regulator partnerships are
at the forefront of making BVLOS
airworthiness certifications a reality.
DETECT & AVOID
As all manned aircraft pilots know, successful flight depends on
“see and avoid”. The world outside the cockpit window receives
just as much attention from the pilot as the complex instruments
at the dashboard. Indeed, the FAA codifies this “see and avoid”
rule in their right-of-way rules for the NAS (14 CFR 91.113).
Though many of these regulations for air traffic are common
sense, the language of “seeing” has presented some difficulties
for UAVs. So far, UAV manufacturers have met these regulatory
requirements by limiting drone operational capabilities, but other
notions of “sensing” and “detection” have been gaining traction in
the regulatory space.

GOING DEEPER: ”Visual Line of Sight” for UAVs

In 2016, the FAA updated their “see and avoid” right-of-way rules
to include UAVs in 14 CFR 107.31 Visual line of sight aircraft
operation. Section 107.31 requires that the remote pilot or visual
observer knows the location, attitude, altitude and direction
of the UAV and is able to observe the airspace for hazards and
determine that the UAV does not endanger life or property. By
avoiding any explicit lateral boundary, these rules give a way for
remote pilots to “see and avoid” specific to aircraft in question,
but do not provide any direction for fully-autonomous flights.
The boundaries of VLOS, however, are not always clear, as
demonstrated by the Precision Hawk Extended Visual Line of
Sight (EVLOS) Pathfinder program. This program successfully
applied for a waiver to section 107.31 and extend their lateral
boundary to 2.5 NM. The FAA determined in this case that, even
though the unmanned aircraft itself could not be seen at 2.5 NM,
other manned aircraft could be observed at this distance. This
is a tangible step toward flights outside of human vision. Going
further, NASA has suggested that instead of “see and avoid”,
UAVs should be held to a standard of “detect and avoid” where
the UAS is able to use computers and sensors to detect nearby
air traffic and safely navigate accordingly.
IMPLEMENTING
DETECT & AVOID
Detect-and-avoid systems can take a variety of different
forms. The sensors might be on the aircraft itself
(typically radar) or might take advantage of networks
of ground-based sensors (radar coverage). Traffic
management platforms can also manage UAVs so that
they maintain distance from each other. A number of
companies and technology solutions are emerging in this
dynamic space. Still, there is some ambiguity in the FAA
regulations about staying “well clear” of other aircraft.
Though these regulations have not taken a finalized and
polished form, it is clear that unmanned aircraft will
forfeit right of way to manned systems and so detection
and avoidance will be crucial systems for any UAV.
COMMUNICATION
SYSTEMS
While being able to detect other
aircraft outside the pilot’s line of
sight is essential to drone safety,
it is not the only issue raised by
BVLOS. Extended-distance drone
operations also communicate
command and control information
and other data back to the people
who need it without link loss so
reliability and redundancy are
both essential. Several different
types of communications systems
can be used to communicate with
BVLOS drones, and we break
down the popular choices below.
These systems vary in four main
ways: data costs, hardware
costs, coverage and data
speed, and caps.
SATELLITE
Satellite communications (SatCom) are used
but the US Military for drone operations.
These systems are the most expensive, but
can be used at the largest scale. SatCom is
both reliable and can send large amounts of
data. With SatCom, you can select a network,
a modem, and a service provider based
on estimated data usage and the type of
connection needed for the operation. Service
providers like Iridium and Inmarsat offer
global coverage, low-bandwidth machine-to-
machine (M2M) services and high-bandwidth
services (for a much greater cost available in
2018). M2M systems are the most economical
choice for SatCom, if it is possible to optimize
the C2 link for minimal data transmission.
CELLULAR
Drones can also transmit data like smartphones do via cellular
networks (CellCom). These systems haven’t been used for
drones for as long as SatCom has, but they are gaining in
popularity for commercial UAVs. CellCom performs well
for multi-rotor drones in low-altitude settings as well as for
BVLOS. CellCom can be better for real-time streaming than
SatCom as 4G or even 3G networks are capable of much higher
data rates than satellites.
The pros and cons of cellular networks both lie in the fact that
they are an already-existing infrastructure. Because of this
they are not optimized for the ways drones use data. Drones
using CellCom technology will be uploading large quantities of
data using a system that is primarily designed for downloading
media. Additionally, many of the places in which drones can
be flown also won’t be high-volume cell service areas. Though
CellCom for UAVs uses the same service providers that cell
phone users do, UAV operators in remote areas can also
take advantage of “dual-radio” modems which will increase
coverage by spanning service areas of multiple providers.
RADIO
UAVs can also transmit data using point-to-
point radio links. Radio communications avoid
service fees that come with other communications
technologies, but upgrading to new hardware can
be significantly more expensive. Radios will work
independent of weather or network coverage, and
the equipment for operation is portable. Depending
on the needs of the operation, radio antennas
might fit in a suitcase or might have to be carried
in the bed of a truck.
Depending on the particular use of the drone,
available radio frequencies can include the
Industrial, Scientific and Medical FCC bands
(900Mhz, 2.4 Ghz, 5.8Ghz), or the licensed
S- and L-Bands. Though communication security
is a concern with any technology or protocol, it
is a more specific concern with using drones on
unlicensed frequencies. In addition to the risk
of a malicious agent hacking a drone-control
radio signal, even a local radio signal operating
in a nearby frequency could cause interference
problems with drones. The Radio Technical
Commission for Aeronautics (RCTA) has proposed
dedicated waveforms and frequencies to solve
some of these security issues, but they are still in
the process of being designed and implemented.
Meanwhile, unlicensed bands with upgraded
radios can still deliver strong results with
relatively minimal risks, and changing your radio
communicating frequency later will not cost you.
FIXED WING VTOL

The Best Solution

for Long-Range
BVLOS Flight
Common questions we receive at Guinn
Partners include: What is VTOL? What
does the acronym mean? What type of
aircraft are they? Why haven’t we seen
more of this type of craft in the last few
years? Why is everyone so excited about
them, and how do they work?
VTOL stands for Vertical Take Off
and Landing. By definition really any
quadcopter or “drone” by DJI or similar
to date is technically a VTOL drone
because they vertically take off and
vertically land, meaning they don’t need a
runway. So the concept by definition isn’t
particularly special, but what is special
is for a fixed-wing aircraft that can also
vertically take-off and land, sometimes
referred to as a “hybrid” from the first
use of the technology - takes off like a
helicopter and flies like a plane. When
you hear the term VTOL referred to in
the modern commercial drone industry,
it’s safe to assume the speaker means
a fixed-wing VTOL because they are
shortening that term.
WHY WOULD SOMEONE WANT
TO DESIGN AND/OR USE A FIXED-WING VTOL

Helicopters and multirotors are actually not very efficient at

flying, because they are using a significant amount of thrust to
hover. This is why a multi-rotor has less battery life if it’s just
hovering still versus flying forward at high speed. But even
when a multirotor is flying forward at a consistent speed, it is
still mainly relying on downward thrust to keep itself in the air
which is incredibly inefficient. There is a small amount of wing
effect from the rotor disc flying through the air, which is why
multi-rotors get a little bit more flight time when they’re in
motion as opposed to hovering.
Most VTOLs (as the industry uses the term) are fixed wing
aircraft that use a multi-rotor style propeller setup to be able
to take off vertically and then transition into forward flight.
What you’ll generally see is 4-6 rotors that lift the drone up
into the air, with one pusher prop in the back so as it starts
to transition into forward flight the wings can start giving the
aircraft lift. The lift from the wings means the drone needs less
and less downward thrust from the rotors that lifted it off the
ground. Then the pusher prop comes on and the drone will turn
off the lifting props, and now with the single pusher prop the
drone can fly as a very efficient airplane with the aerodynamics
of an airplane wing. These aerodynamics means it can get
significantly faster flight speed and much longer range as a
fixed wing than it can as a multi-rotor.
HOW DID THESE SYSTEMS COME ABOUT?

For years there has always been a conundrum in drone

development where an engineering team will say “Well,
if you need really long flight time and long endurance
we need a fixed wing craft”, and the results are all these
drone systems over the years that would be launched
with a catapult system, rubber bands, or hand thrown.
These systems were a big hassle to launch, and even
more of a hassle to land, because you would need a long
runway, which isn’t practical. There are very few places
that actually have a nice long runway for an autopilot on
a fixed wing drone to come down from the air and land
itself. This logistical challenge led to massive net systems
and wild apparatus to try and catch these sometimes
hundreds of thousands of dollar drones out of the air.
Fixed wing drones were never particularly practical.
HOW DID THESE SYSTEMS COME ABOUT? Continued

Drone developers eventually wanted to combine the benefits

of vertical takeoff and landing that you find in multi-rotors and
helicopters with the longer flight time and endurance of fixed
wing unmanned aerial vehicles. Now we have fixed-wing VTOL
where these two things are built together. One thing Chris
Anderson from 3DR has said many times is that these drones
were kind of like a spork for a really long time, where you get
a not-very-good spoon and a not-very-good fork. The reason
this was so hard was because the flight code had to be very high
quality, and the speed controllers and the motors had to be very
accurate. Why? Imagine first taking off with just a multi-rotor
drone with no wings, and it’s taking off in 15 mph winds and it
may be getting blown around but it’s able to stabilize itself fairly
well in wind. Now add to that multirotor some big planks for
wings. Now as you take off you have 15 mph winds hitting these
big wings, then the multi-rotor with its propellers will have a
really hard time stabilizing those wings in the wind. This is a big
development and technology component challenge.
Then the next difficult parts, especially from a flight code
perspective, is trying to transition into forward flight.
Transitioning from an autopilot flight code stabilizing a fixed-
wing into an autopilot that’s flying a multi-rotor and vice versa
involves two totally different types of flight code. Making that
transition in real time without letting the aircraft flip over, lose
control, or crash was a very difficult thing to figure out. There
are whole teams of open source and corporate engineers working
on this code, and lots of interesting designs created to try and
circumvent many of the challenges of transition.
THE PRACTICAL IMPACT

Now for the first time we’re starting to see, affordable, reliable
solutions of various types in this space that are able to make
this work. This opens up a lot of operational possibility for
commercial drones. Today, if you want to use drones for
inspecting a large mine or a long transmission line or railroad
using multi-rotors they mainly just hover very inefficiently even
when they are flying forward and are thus not able to cover that
much ground with one flight. With a fixed wing VTOL, you can
cover a lot of railroad or capture a much larger mine or farm
and have the added benefit of being able to take off and land in a
small defined area like a multi-rotor, which gives users the best
of both worlds. As people are trying to cover larger areas with
mapping missions and as companies are preparing for logistics,
delivery, longer range operations, surveillance operations up
and down borders, and really the majority of beyond visual line
of sight operations, it often makes sense to be using a fixed wing
aircraft because you get 4-5 times the flight time of a multi-rotor.
FIXED WING VTOL COMPANIES TO WATCH

AEROVEL
United States

LEARN MORE

ALTI
South Africa

LEARN MORE

ATMOS UAV
Netherlands

LEARN MORE

BIRDSEYE VIEW AEROBOTICS

United States

LEARN MORE

CARBONIX
Australia

LEARN MORE

COLUGO SYSTEMS
Israel

LEARN MORE

DRONETECH UAV
United States

LEARN MORE

ELROY AIR
United States

LEARN MORE
FIXED WING VTOL COMPANIES TO WATCH

HEUROBOTICS
United States

LEARN MORE

QUANTUM SYSTEMS
Germany

LEARN MORE

SKYX
Canada

LEARN MORE

VERTICAL TECHNOLOGIES
Netherlands

LEARN MORE

WINGCOPTER
Germany

LEARN MORE

WINGTRA
Switzerland

LEARN MORE

GERMANDRONES
Germany

LEARN MORE

RAPTOR UAS
UK

LEARN MORE
DRONE-IN-A-BOX
COMPANIES TO WATCH

AIROBOTICS
Focus: Inspection,
Asset Management, Security

LEARN MORE

AMERICAN ROBOTICS
Focus: Agriculture

LEARN MORE

PERCEPTO
Focus: Security,
Safety & Inspection

LEARN MORE
CONCEPTS
& PROGRAMS
TO KNOW
WAIVER: XCEL

So far, of the more than a thousand submitted

waivers to the FAA for BVLOS, 99% have
been denied. Many who have been accepted
reference visual observers.
Xcel Energy was granted permission from
the FAA in early 2018 to conduct regular
drone operations beyond visual line of sight
in Denver. Xcel Energy is Colorado’s largest
utility company, and their drone operations
conduct routine inspections of electronic
transmission lines.
An important note to their waiver is the
mention of “semi-autonomous” equipment
and not having a reliance on a visual observer.
PATHFINDER
INITIATIVE
The FAA’s Pathfinder Initiative was implemented to give
companies in industry the ability to test and develop
best practices around BVLOS drone operations while
researching the safety implications of flying a drone
outside of a pilot’s direct vision. BNSF Railways, CNN,
and PrecisionHawk were the three companies selected to
participate in the Pathfinder program.

LOCALIZED
BVOLS
Localized BVLOS is an operation in which the drone
operates outside the visual line of sight limit defined
in Part 107, but still within a defined local area. The
definition of “local” is not necessarily given by a strict
distance limit, and thus the term “localized BVLOS” can
describes many common commercial drone operations
that are being considered for BVLOS, such as agricultural
farm plots, mines, construction sites, swaths of rail etc.
RISK
ASSESSMENTS
One of the recommendations presented out of the
Pathfinder Initiative was that all BVLOS flights should
involve a thorough risk assessment. This assessment is
not an established regulation, but should be considered
as a likely requirement and a necessary best practice. A
comprehensive assessment should speak to the following
points:

1. What functionality must the assistive technology

be capable of to enable safe BVLOS operations in
the National Airspace System?

2. How do we expect operators to engage with the

assistive technology?

3. In what ways can this human-machine system fail?

4. How do we mitigate the risk of failure?

GUINN PARTNERS
VIDEO ANALYSIS
ANALYSIS
BVLOS - Why Is It Important?

ANALYSIS
PrecisionHawk & BVLOS

ANALYSIS
BVLOS - Key Enabling Technologies
THE AUTHORS

COLIN GUINN
Colin Guinn is a product development expert and
serial entrepreneur. He most recently founded Austin
startup Hangar, after serving as Chief Revenue Officer
at 3D Robotics and co-founding and serving as CEO of
DJI North America. He is one of the most interviewed
experts on robotics technology in the world, and has
been featured at premier industry conferences and
in countless top-rated publications and newscasts,
including 60 Minutes, Techcrunch, and Fast Company.
Colin’s uniqueness to the business world is that he
understands the technology in two dialects: the granular
argot necessary to communicate with an engineer, and
the simple, digestible language that’s interesting to the
average consumer.

OREN SCHAUBLE
Oren Schauble is an experienced sales and marketing
executive specializing in high-tech and disruptive
products. He served as the VP of Sales and Marketing
at Hangar Technology, after serving as Vice President
of Marketing at 3D Robotics and Director of Marketing
at TrackingPoint. Before this he worked agency-side as
a creative director for lifestyle brands. Oren’s specialty
is in building comprehensive sales and marketing
programs, managing complex social media content
programs, and establishing systems for companies
undergoing rapid expansion.

DIVE IN DEEPER WITH GUINN PARTNERS

Explore our website to learn more about how we bring products to market, our specific services in the
drone market segment, and our new GP Strategic information product.
 Thanks for reading,

and we hope we’ve

provided some insight

worth considering

and integrating into

your business plans

for this year.