VLOS and Visual Observers Under Part 107

Visual line of sight is one of those Part 107 concepts everyone thinks they understand until a scenario question gets specific about what tool the pilot used to see the aircraft, or what a visual observer is actually allowed to do with that information.

What does visual line of sight mean under Part 107?

14 CFR §107.31 requires the remote pilot in command, the person manipulating the controls, and any visual observer to be able to see the unmanned aircraft throughout the entire flight with vision unaided by any device other than corrective lenses. Binoculars, a first-person-view headset, or a camera feed don't satisfy the requirement, no matter how good the picture is. The rule is about the human eye maintaining a direct line of sight, not about the pilot having situational awareness through some other means. Flying with a Remote ID broadcast module adds a separate sight requirement in Part 89, which the Remote ID broadcast post explains.

What does a visual observer change?

Adding a visual observer under 14 CFR §107.33 doesn't extend how far or how the pilot can fly; it adds a second set of eyes. The observer has to be able to see the aircraft with the same unaided-vision standard the pilot is held to, and has to be able to communicate with the pilot or the person manipulating the controls immediately enough to relay traffic, airspace, or hazard information in time for it to matter. A visual observer standing too far away to see the aircraft clearly, or with no working way to communicate in real time, isn't providing the function the rule requires just by being present on site.

Who has to keep the aircraft in sight?

§107.31 has two parts. Paragraph (a) says what unaided sight has to make possible: knowing the aircraft's location, determining its attitude, altitude and direction of flight, observing the airspace for other traffic or hazards, and determining that it does not endanger the life or property of another. Paragraph (b) then says that ability must be exercised throughout the flight by either the remote pilot in command and the person manipulating the controls, or a visual observer. When the person on the controls is not certificated, the direct supervision rule decides whether they may fly at all.

That either-or explains two things. A pilot can watch a monitor while an observer keeps the aircraft in sight, and a flight where nobody has the aircraft in sight is not compliant, however good the camera feed is.

What do the pilot and the observer have to do together?

§107.33 sets three requirements whenever an observer is used. The remote pilot in command, the person manipulating the controls and the observer must stay in effective communication at all times. The remote pilot in command must make sure the observer can see the aircraft the way §107.31 describes. And all of them coordinate to scan the airspace for collision hazards and keep track of the aircraft's position by direct visual observation.

Four statements sound right and are wrong:

• "The remote pilot must always personally keep the aircraft in sight." Not when an observer exercises the ability under §107.31(b)(2).
• "The observer can make flight decisions." The remote pilot in command stays directly responsible and is the final authority under §107.19.
• "An observer must hold a certificate." Part 107 sets no certificate requirement for observers.
• "Binoculars are fine for the observer." The unaided-vision standard in §107.31(a) covers the observer too.

The scenario the exam likes to build

A common trap: a pilot loses direct sight of the aircraft behind a building or tree line for a few seconds, but a visual observer positioned elsewhere maintains sight the whole time. Whether that's compliant depends on whether the pilot, the observer, and the person manipulating the controls (if different from the pilot) collectively maintain the VLOS and communication requirements as designed, not on any one person having eyes on the aircraft at every instant. The regulation is written around the roles working together, and exam scenarios are built to test whether you're tracking all three roles or just assuming the pilot alone has to see everything.

What still applies regardless

Neither VLOS nor a visual observer changes anything about airspace authorization, registration, or the operating limitations already in place. They answer one specific question, can the aircraft be adequately seen, not whether the flight is otherwise authorized to happen.

Visual line of sight interacts with night operations, with right-of-way, and with the proposed BVLOS framework in Part 108 vs Part 107.

Full task breakdown and drills for this topic are in the handbook.

What to do when the link or line of sight is lost is covered in the drone emergencies post.

Keeping line of sight from a car or boat is its own challenge; the moving vehicle post covers the rule.