SkarpChapter 2 of 23
Remote PIC Authority, VLOS, and Core Operating Rules
Every flight has one person who carries final regulatory accountability, even when someone else holds the controls. Scenario-driven distinctions among the remote PIC, control manipulator, and visual observer reveal how authority and responsibility actually work.
One Flight, One Final Authority
The central rule
Every Part 107 flight has one designated remote PIC. That person may fly, supervise a control manipulator, and use a visual observer, but those arrangements never shift final accountability.
Verbatim definition
"A remote pilot in command must be designated before or during the flight of the small unmanned aircraft. The remote pilot in command is directly responsible for and is the final authority as to the operation of the small unmanned aircraft system."
Controller versus authority
The person touching the controller is the control manipulator. A VO watches and communicates. Neither role automatically becomes remote PIC. Ask who can finally launch, continue, change, or stop the operation.
Exam decision rule
When a question asks who is accountable for compliance or who must terminate an unsafe operation, identify the designated remote PIC. The remote PIC can hear crew advice, but makes the final operational decision.
Who May Manipulate the Controls?
The permitted arrangement
A non-certificated person may manipulate Part 107 flight controls only under the direct supervision of a certificated remote PIC who can immediately take direct control of the small unmanned aircraft.
What direct supervision requires
The remote PIC must be able to take over immediately. Being reachable by telephone, viewing a delayed feed, or being positioned where takeover is impossible does not satisfy the rule.
Worked scenario
A certificated remote PIC stands beside an unlicensed trainee, monitors the flight, and has a linked controller for immediate takeover. The trainee may manipulate controls under that direct supervision.
Responsibility remains
Even when a trainee flies, the designated remote PIC remains directly responsible and the final authority. Direct supervision permits the arrangement; it does not delegate the remote PIC's regulatory accountability.
Visual Line of Sight: What You Must Be Able to Do
Functional, not merely visual
VLOS is not merely spotting a distant dot or checking a map. The aircraft must be visible well enough to establish location, attitude, altitude, direction, airspace hazards, and whether it endangers life or property.
Verbatim requirement: part 1
"With vision that is unaided by any device other than corrective lenses, the remote pilot in command, the visual observer (if one is used), and the person manipulating the flight control of the small unmanned aircraft system must be able to see the unmanned aircraft throughout the entire flight in order to: (1) Know the unmanned aircraft’s location; (2) Determine the unmanned aircraft’s attitude, altitude, and direction of flight;"
Verbatim requirement: part 2
"(3) Observe the airspace for other air traffic or hazards; and (4) Determine that the unmanned aircraft does not endanger the life or property of another. Throughout the entire flight of the small unmanned aircraft, the ability described in paragraph (a) of this section must be exercised by either: (1) The remote pilot in command and the person manipulating the flight controls of the small unmanned aircraft system; or (2) A visual observer."
Devices and VLOS
Corrective lenses are allowed. Binoculars, an FPV display, telemetry, and a map may aid the crew, but cannot replace the required unaided visual capability. A properly used VO may exercise that capability.
Using a Visual Observer Correctly
VO role
A visual observer assists the remote PIC and control manipulator in seeing and avoiding other air traffic or objects aloft or on the ground. A VO assists the operation; the VO is not the final authority.
Coordination before launch
Before flight, coordinate who flies, who scans, what airspace sectors each person watches, what hazards matter, and which words trigger an immediate maneuver or landing. Do not improvise essential crew roles after launch.
Communication throughout
The remote PIC must ensure effective communication among the remote PIC, control manipulator, and VO throughout the operation. The method may vary, but safety-critical calls must be prompt, intelligible, and actionable.
Practical VO call
A useful report identifies the hazard and needed action: "Helicopter west, approaching, land now." The remote PIC remains responsible for directing the response and may terminate the mission even when the planned work is unfinished.
Do Not Start, or Continue, an Unsafe Flight
Safe operating condition
Before flight, the remote PIC must ensure the small unmanned aircraft is in a condition for safe operation. Inspect the aircraft, batteries, propulsion, payload, control station, links, operating area, weather, airspace, and people.
Control links
The remote PIC must ensure all control links between the control station and aircraft work properly. An intermittent link, unreliable controller, or suspect battery is a reason to correct the problem or not operate.
Medical self-assessment
Part 107 generally does not require an FAA medical certificate. However, a person may not act as remote PIC or manipulate controls when they know or have reason to know a physical or mental condition would interfere with safe operation.
Apply the standard
Fatigue, illness, medication effects, alcohol, impaired vision, or serious distraction can be disqualifying for that flight. Do not ask only, "Can I fly?" Ask, "Could this condition interfere with safe operation?"
Right-of-Way and Real Collision Avoidance
Absolute yield duty
A Part 107 small unmanned aircraft must yield the right of way to all aircraft, airborne and on the surface. This includes manned aircraft and other unmanned aircraft, regardless of who arrived first.
What yielding means
Yielding means giving way and taking action needed to avoid a collision hazard. Descend, alter course, land, or terminate early. Never depend on a manned-aircraft pilot seeing a small drone in time.
See-and-avoid actions
Scan the airspace systematically, listen for aircraft, watch expected approach paths, and account for buildings, glare, and noise. A VO can help scan, but the remote PIC remains final authority for the avoidance response.
Exam trap
The drone does not gain right-of-way because it is established first, flying a planned route, or conducting commercial work. If awareness is inadequate or another aircraft approaches, modify or discontinue the operation.
Core Prohibitions: Recklessness, Payloads, and Team Limits
Careless or reckless operation
No person may operate a small unmanned aircraft carelessly or recklessly so as to endanger life or property. This broad rule can be violated even when a flight appears to meet specific altitude, airspace, or visibility limits.
Dropped objects
An object may not be dropped from a small unmanned aircraft in a manner that creates an undue hazard to persons or property. The key is risk: object, height, wind, landing area, and people below all matter.
Hazardous material
A Part 107 small unmanned aircraft may not carry hazardous material. A secure package, short route, or commercial reason does not by itself create permission to carry a hazardous material.
One operation at a time
A person may not act as remote PIC or visual observer for more than one small unmanned aircraft operation at the same time. Automation and proximity do not remove this simultaneous-operation restriction.
Decision Drill: Stop or Continue?
Apply the rules step by step
A licensed remote PIC, Elena, supervises an unlicensed intern who manipulates the controls beside her. A VO is positioned on a rooftop and has reliable two-way radio communication with Elena. During a facade inspection, the VO reports a helicopter approaching from the west. At nearly the same moment, Elena notices the aircraft's battery is declining faster than expected.
Choose the best sequence mentally before revealing the analysis.
- Who has final authority to decide what happens next?
- Is the intern allowed to manipulate the controls in this setup?
- Which rule requires the sUAS to give way to the helicopter?
- What is the safest operational decision?
Reveal
- Elena, the designated remote PIC, has final authority and direct responsibility.
- Yes, if Elena can immediately take direct control and is directly supervising the intern.
- Under 14 CFR 107.37, the sUAS must yield to all aircraft.
- Elena should direct immediate collision-avoidance action, normally an early descent and landing if safe. The unexpectedly declining battery adds a separate safe-operating-condition concern. Continuing the inspection to finish the job would prioritize mission completion over safety.
Notice how the facts connect: effective VO communication supplies hazard awareness, but does not transfer decision authority; direct supervision permits the intern to fly, but does not transfer responsibility; and a second developing hazard makes a conservative termination decision even stronger.
Quiz: VLOS and Crew Roles
Select the best answer
A remote PIC uses an FPV display while a certificated control manipulator stands nearby. Neither can see the aircraft without the display. A VO, however, can continuously see the aircraft with unaided vision and maintains effective radio communication with the remote PIC. Which statement is correct?
Which statement is correct?
- The operation may meet the VLOS requirement because the VO exercises the required visual capability and communicates effectively.
- The operation violates VLOS because both the remote PIC and control manipulator must personally see the aircraft at all times.
- The operation is compliant only if the FPV display has a high-definition camera.
- The operation is compliant because telemetry always substitutes for visual observation.
Show Answer
Answer: A) The operation may meet the VLOS requirement because the VO exercises the required visual capability and communicates effectively.
The VLOS rule allows the required ability to be exercised by either the remote PIC and control manipulator, or by a visual observer. FPV and telemetry do not replace VLOS, but a properly positioned VO with effective communication can fulfill the visual-observation function.
Flashcards: Fast Regulatory Recall
Flip each card
Aim to state the rule first, then give a one-sentence operational consequence.
- Who is the final authority for an sUAS operation?
- The designated remote PIC. The remote PIC is directly responsible for and is the final authority as to the operation of the small unmanned aircraft system.
- Can a non-certificated person manipulate flight controls?
- Yes, when directly supervised by a certificated remote PIC who can immediately take direct control of the small unmanned aircraft.
- What does VLOS require beyond locating the drone?
- The ability to determine attitude, altitude, and direction; observe air traffic or hazards; and determine that the aircraft does not endanger life or property.
- What is the sUAS right-of-way rule?
- The small unmanned aircraft must yield the right of way to all aircraft, airborne and on the surface.
- When may an object be dropped from an sUAS?
- Only when it is not dropped in a manner that creates an undue hazard to persons or property.
- May a remote PIC supervise two simultaneous sUAS operations?
- No. A person may not act as remote PIC or visual observer for more than one small unmanned aircraft operation at the same time.
Quiz: Final Accountability
Select the best answer
A certificated remote PIC launches Drone A for a bridge survey. While Drone A is airborne, a coworker asks the remote PIC to act as remote PIC for Drone B, which another crew is about to launch nearby. Both flights would occur at the same time. What should the remote PIC do?
What should the remote PIC do?
- Accept, if Drone B uses automated flight modes.
- Accept, if both drones remain within visual line of sight.
- Decline acting as remote PIC for Drone B while acting as remote PIC for Drone A.
- Accept, if a visual observer watches one of the drones.
Show Answer
Answer: C) Decline acting as remote PIC for Drone B while acting as remote PIC for Drone A.
Under 14 CFR 107.35, a person may not act as remote PIC or visual observer for more than one small unmanned aircraft operation at the same time. Automation, VLOS, and use of a VO do not remove that restriction.
Exam Method: Build the Answer from the Role and Hazard
Step 1: Assign the roles
Identify the designated remote PIC first. Then identify the control manipulator and any VO. Do not confuse someone holding the controller or watching the sky with the person who has final regulatory authority.
Step 2: Test the crew setup
If a non-certificated person flies, verify direct supervision and immediate takeover capability. For VLOS, determine whether the remote PIC and control manipulator exercise it, or a VO exercises it with effective communication.
Step 3: Find the hazard
Screen for unsafe aircraft condition, faulty links, impaired personnel, approaching aircraft, people or property risk, hazardous material, an undue-hazard drop, or a careless or reckless operational choice.
Step 4: Choose the safe action
The remote PIC must make the final safe decision: yield, change course, land, or discontinue. Strong exam answers protect collision avoidance and safety rather than mission completion, schedule, or client pressure.
Key Terms
- visual observer
- A person acting to assist the remote pilot in command and the person manipulating the flight controls to see and avoid other air traffic or objects aloft or on the ground.
- direct supervision
- Supervision by a certificated remote PIC who is able to immediately take direct control of the small unmanned aircraft.
- control manipulator
- The person who physically manipulates the flight controls of the small unmanned aircraft system.
- visual line of sight
- With vision that is unaided by any device other than corrective lenses, the remote pilot in command, the visual observer (if one is used), and the person manipulating the flight control of the small unmanned aircraft system must be able to see the unmanned aircraft throughout the entire flight in order to: (1) Know the unmanned aircraft’s location; (2) Determine the unmanned aircraft’s attitude, altitude, and direction of flight; (3) Observe the airspace for other air traffic or hazards; and (4) Determine that the unmanned aircraft does not endanger the life or property of another. Throughout the entire flight of the small unmanned aircraft, the ability described in paragraph (a) of this section must be exercised by either: (1) The remote pilot in command and the person manipulating the flight controls of the small unmanned aircraft system; or (2) A visual observer.
- remote pilot in command
- A remote pilot in command must be designated before or during the flight of the small unmanned aircraft. The remote pilot in command is directly responsible for and is the final authority as to the operation of the small unmanned aircraft system.
- small unmanned aircraft
- An unmanned aircraft weighing less than 55 pounds on takeoff, including everything that is on board or otherwise attached to the aircraft.