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USA Part 107 Night Waiver Question

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I hope this is in the right spot, apologies if not.

I feel like in my waiver request I was pretty clear on the performance based standards regarding this but the FAA has requested more information pertaining to 107.29 The following is cut and pasted from the email I received:

"For a waiver from section 107.29 - Daylight Operations:
• Applicant must provide a method for the remote pilot to maintain visual line of sight during darkness."

It's the only portion of the waiver they've requested more info on. They didn't quote anything I'd written previously, so I'm formulating a new response for that section and any help I could get drafting the language would greatly appreciated.
 
I hope this is in the right spot, apologies if not.

I feel like in my waiver request I was pretty clear on the performance based standards regarding this but the FAA has requested more information pertaining to 107.29 The following is cut and pasted from the email I received:

"For a waiver from section 107.29 - Daylight Operations:
• Applicant must provide a method for the remote pilot to maintain visual line of sight during darkness."

It's the only portion of the waiver they've requested more info on. They didn't quote anything I'd written previously, so I'm formulating a new response for that section and any help I could get drafting the language would greatly appreciated.

"Method for the Remote Pilot to Maintain Visual Line of Sight During Darkness.

We will be using an anti-collision light that is visible for 3 statute miles or more. The remote PIC may reduce the intensity of the anti-collision lighting if he or she determines that, because of operating conditions, it would be in the interest of safety to do so."
 
I think there looking for a bit more than "...using an anti-collision light".

Maintaining VLOS is obtained (3) ways:
1) through the use of a anti-collision light... add details
2) the use of a visual over sever...
3) reduce the fly off distance and altitude to enable VLOS, aircraft orientation and positive aircraft control...
(Define limit) 200' lateral & 100' AGL

In addition:
1) The takeoff and landing area will be:
a) illuminated and free & clear of a obstruction for a 25' radius.
b) identified with flags, markers, or safety cones to prevent NPPP from entering the TO/LDG Zone

2) the planned area of operation, flight paths, RTH paths, will be either:
1) illuminated...
2) evaluated for hazards and a minimum safe altitude will be used
a) A RTH altitude will programmed to
ensure safe clearance above
obstacles and hazards should a
Loss-of-link occur

You can add lots of little statements to ensure safety, but so far it seems that they're looking for series of actions to define your methods in a simple but thorough statement to sound like you know what you're doing without going too deep. Striking a balance seems subjective depending on who's review your requests.
 
My night waiver was successful. Here's the advise I gave other successful applicants: Write the justification and conditions like you are explaining it to a 5 year old. When you think it has been simplified enough, simplify it some more. We are writing for a bunch of contractors, some of which may be retired FAA old dogs (with lots of horse sense), others may be young kids out of college with **** retentive personalities. Caveat emptor.
 
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