Visual Observers and Their Role
A visual observer isn't just an extra set of eyes standing nearby ? 14 CFR 107.33 imposes specific, enforceable duties on how a visual observer must be used once the remote pilot in command decides to designate one. This lesson covers exactly what those duties are: continuous communication, genuine visual capability under 107.31, and active airspace-scanning coordination.
Effective communication at all times
The remote pilot in command, the person manipulating the flight controls, and the visual observer must maintain effective communication with each other at all times during the flight. The regulation doesn't specify a particular method ? radio, hand signals, or simple verbal communication for a close-proximity crew can all satisfy this, as long as it is genuinely effective for conveying safety-relevant information in real time, not just theoretically possible.
Genuine visual capability, not just presence
The remote pilot in command must ensure the visual observer can actually see the unmanned aircraft as required under 107.31 ? the same unaided-vision standard covered in Lesson E. A person designated as a visual observer who cannot actually see the aircraft (due to obstruction, distance, or any other reason) is not fulfilling the role in a way that satisfies the regulation, regardless of their formal designation.
Active airspace scanning and position awareness
Beyond simply watching the aircraft, the remote pilot in command, person manipulating the controls, and visual observer must together scan the airspace where the aircraft is operating for any potential collision hazard, and maintain awareness of the aircraft's position through direct visual observation. This is an active duty, not a passive one ? a visual observer's job includes genuinely looking for approaching manned aircraft, not just confirming the drone itself hasn't wandered off course.
No certificate required to serve as a visual observer
Unlike the remote pilot in command, a person serving as a visual observer is not required to hold a Remote Pilot Certificate. Any person the remote pilot in command designates and properly briefs can serve in the role, as long as they can genuinely satisfy the communication, visual-capability, and coordination duties above. This makes visual observers a practical way to add a second set of properly-briefed eyes to a flight ? for example during FPV operations (Lesson E) ? without needing a second certificated pilot on site.
Real-world scenario: an inspection near a small airfield
A pilot is inspecting solar panels near a rural airstrip with occasional light-aircraft traffic. Rather than relying solely on their own attention while also managing the controls, the pilot designates a colleague as a visual observer, briefs them on hand signals for "aircraft approaching" and "clear to continue," and positions them with an unobstructed view of both the drone and the surrounding sky. Throughout the flight, the two maintain constant visual and verbal contact ? when the observer spots a small aircraft on approach to the airstrip, a quick verbal call lets the pilot immediately descend and move clear well before any actual conflict develops.
The three coordinated duties 14 CFR 107.33 imposes on a visual observer working with the flight crew.
View Larger| Duty | What it requires | Shared with | Regulation |
|---|---|---|---|
| Communication | Effective communication maintained at all times | RPIC and person manipulating controls | 14 CFR 107.33(a) |
| Visual capability | Able to see the aircraft per 107.31's unaided-vision standard | Ensured by the RPIC | 14 CFR 107.33; 107.31 |
| Airspace scanning | Actively scan for potential collision hazards | RPIC and person manipulating controls | 14 CFR 107.33(b) |
| Position awareness | Maintain awareness of the aircraft's position via direct visual observation | RPIC and person manipulating controls | 14 CFR 107.33(c) |
Briefing and positioning a visual observer before flight
A designated visual observer needs an actual briefing, not just a verbal "keep an eye out."
Choose a communication method that will genuinely work throughout the flight
Radios for longer distances; clear hand signals or verbal calls for close-proximity crews.
Position the observer where they have a genuinely unobstructed view of the aircraft
Confirm the observer can actually see the drone from their position ? not just assume it based on general proximity.
Brief the observer on what to scan for and how to report it
Cover both aircraft-position awareness and active scanning for other air traffic or hazards, with a clear, simple way to flag a concern immediately.
Maintain communication throughout, not just at the start
Effective communication is a continuous requirement ? check in periodically rather than assuming silence means everything is fine.
| Mistake | Why it happens | Correct understanding | Regulation / source |
|---|---|---|---|
| "A visual observer must hold a Remote Pilot Certificate." | Assuming every flight-crew role requires FAA certification | No certificate is required to serve as a visual observer, only that the duties under 107.33 are genuinely met. | 14 CFR 107.33 |
| "Anyone standing near the pilot automatically counts as a visual observer." | Confusing informal presence with the designated, briefed role | A visual observer must be specifically designated and must actually fulfill the communication, visual-capability, and scanning duties. | 14 CFR 107.3; 107.33 |
| "A visual observer's only job is watching the drone itself." | Overlooking the broader airspace-scanning duty | The visual observer must also actively scan the surrounding airspace for potential collision hazards, not just track the aircraft. | 14 CFR 107.33(b) |
Does a visual observer need a Remote Pilot Certificate?
No. The role has no certification requirement, though the person must genuinely be able to perform the communication, visual-capability, and airspace-scanning duties under 107.33.
Is a visual observer required on every Part 107 flight?
No. A visual observer is one of two ways to satisfy the VLOS requirement ? the other is the remote pilot in command and person manipulating the controls maintaining VLOS together. A visual observer becomes necessary specifically when neither of those two can independently maintain VLOS, such as during FPV operations.
What communication method satisfies the "effective communication" requirement?
The regulation does not mandate a specific method ? radios, hand signals, or verbal communication can all work, as long as they are genuinely effective for conveying safety information throughout the flight.
Test Your Knowledge
Answer the questions below to check your understanding. Every answer can be found in the lesson above.