UA.I.B.K11: Requirements when a visual observer is used.

ACS Area I — Regulations Task B: Operating Rules References: 14 CFRCode of Federal RegulationsCloseThe federal rulebook where Part 107, Part 89, Part 48, and other aviation rules live. parts 47, 48, 89, and 107, subpart B; ACAdvisory CircularCloseFAA guidance that explains acceptable ways to comply with rules or understand FAA procedures. 107-2; FAAFederal Aviation AdministrationCloseThe U.S. aviation regulator responsible for Part 107 rules, airspace, and pilot certification processes.-H-8083-25; FAAFederal Aviation AdministrationCloseThe U.S. aviation regulator responsible for Part 107 rules, airspace, and pilot certification processes.-G-8082-22

Key Concepts

Crew Status and Site Control When Using a Visual Observer

A visual observer (VOVisual ObserverCloseA person who helps the remote PIC see and avoid hazards during a drone operation.) is part of the directly participating small UASSmall Unmanned Aircraft SystemCloseA small drone plus the control and communication links used to operate it. crew. For operations over people within a closed- or restricted-access site, directly participating personnel are permitted across all operational categories in Part 107. Nonparticipants at such a site must be “on notice” under Category 3, and Categories 1 and 2 carry additional limitations for open-air assemblies as described below. Category 4 eligibility depends on the FAAFederal Aviation AdministrationCloseThe U.S. aviation regulator responsible for Part 107 rules, airspace, and pilot certification processes.‑approved Flight Manual or Administrator direction for any operating limitations that may restrict flight over people. Practically, when employing a VOVisual ObserverCloseA person who helps the remote PIC see and avoid hazards during a drone operation. at a controlled (closed/restricted) site, ensure access control and notification protocols are in place so that any nonparticipants present are properly “on notice,” and confirm that your aircraft’s category and any Category 4 operating limitations support the planned operation over people at that site^[4].

When operating where public access is not controlled, adding a VOVisual ObserverCloseA person who helps the remote PIC see and avoid hazards during a drone operation. does not relax the category-based constraints around people or vehicles. The crew—VOVisual ObserverCloseA person who helps the remote PIC see and avoid hazards during a drone operation. included—must plan the mission within those limits and anticipate how the VOVisual ObserverCloseA person who helps the remote PIC see and avoid hazards during a drone operation.’s observations will be used to maneuver and, if needed, promptly terminate or adjust the flight path to remain compliant^[2][4].

Operations Over People: Category Triggers That Still Apply With a VO

• Category 1 aircraft (weighing 0.55 pounds (250 grams) or less on takeoff and throughout the operation) may operate over people, but sustained flight over open-air assemblies is prohibited unless Remote IDRemote IdentificationCloseRemote ID broadcast requirements for most drones operating in U.S. airspace. requirements of § 89.110 or § 89.115(a) are met, or the prohibition is waived. This allowance applies whether or not a VOVisual ObserverCloseA person who helps the remote PIC see and avoid hazards during a drone operation. is used; the VOVisual ObserverCloseA person who helps the remote PIC see and avoid hazards during a drone operation.’s presence does not change the Category 1 limits^[2][4].
• Category 2 has a similar open‑air assembly restriction—no sustained flight over open-air assemblies unless § 89.110 or § 89.115(a) is met or waived. Directly participating personnel are allowed both within closed/restricted sites and in areas open to the public, subject to those assembly limits^[4].
• Category 3 operations must not operate over open‑air assemblies of human beings per § 107.125(b). Within a closed/restricted site, nonparticipants “must be on notice.” Outside a closed site, Category 3 only permits transit over people who are not directly participating (no sustained flight). Using a VOVisual ObserverCloseA person who helps the remote PIC see and avoid hazards during a drone operation. does not alter the prohibition on assemblies or the transit‑only rule^[4].
• Category 4 operations over people may be eligible if not prohibited by the operating limitations in the FAAFederal Aviation AdministrationCloseThe U.S. aviation regulator responsible for Part 107 rules, airspace, and pilot certification processes.‑approved Flight Manual or as otherwise specified by the Administrator. Even with a VOVisual ObserverCloseA person who helps the remote PIC see and avoid hazards during a drone operation., you must honor those operating limitations and the separate restriction on sustained flight over open-air assemblies unless § 89.110 or § 89.115(a) is met, or waived^[4].

Exam tip: Expect questions that test whether the presence of directly participating personnel (e.g., a VOVisual ObserverCloseA person who helps the remote PIC see and avoid hazards during a drone operation.) permits sustained overflight versus “transit only.” The answer hinges on the aircraft’s category, site control (closed vs. open), and the open‑air assembly rules—not on whether a VOVisual ObserverCloseA person who helps the remote PIC see and avoid hazards during a drone operation. is used^[4].

Moving Vehicles: Closed Sites vs. Public Areas

• At closed- or restricted-access sites, operations over moving vehicles are allowed for directly participating personnel across Categories 1–3. For nonparticipants within the site, those individuals “must be on notice.” Category 4 aircraft may be eligible to operate over moving vehicles if the FAAFederal Aviation AdministrationCloseThe U.S. aviation regulator responsible for Part 107 rules, airspace, and pilot certification processes.‑approved Flight Manual (or Administrator direction) does not prohibit it^[2].
• Outside closed/restricted sites, operations over moving vehicles are limited to transit only (no sustained flight) for Categories 1–3 when those occupants are not directly participating. Again, Category 4 may be eligible if not prohibited by its operating limitations. A VOVisual ObserverCloseA person who helps the remote PIC see and avoid hazards during a drone operation.’s participation does not change the “no sustained flight” rule in public areas—plan routes so any crossings of roads or traffic are brief and compliant^[2].

Practical implication: When using a VOVisual ObserverCloseA person who helps the remote PIC see and avoid hazards during a drone operation. near public roads, prebrief the VOVisual ObserverCloseA person who helps the remote PIC see and avoid hazards during a drone operation. to call out traffic conflicts early, so the remote pilot can time crossings as brief, compliant “transit only” segments. If mission needs require lingering over traffic, relocate to a closed/restricted site with access control and notification, or change the operation/category plan to one that is eligible under the applicable operating limitations^[2][4].

Category 4 Maintenance/Records Still Apply

If operating a Category 4 aircraft with an FAAFederal Aviation AdministrationCloseThe U.S. aviation regulator responsible for Part 107 rules, airspace, and pilot certification processes.‑issued airworthiness certificate under Part 21 in accordance with Part 107, Parts 43 and 91 do not apply; instead, § 107.140 governs. The owner is responsible for maintenance and records retention per § 107.140(c), though these responsibilities may transfer to the operator by agreement. These obligations are independent of whether a VOVisual ObserverCloseA person who helps the remote PIC see and avoid hazards during a drone operation. is used and must be satisfied for Category 4 eligibility and continued compliance^[3].