Who sees the traffic when I can't?

Know what detect-and-avoid means in a VLOS operation, when Standard 922.10 requires a technological solution instead, the one means of complying that is a person rather than a sensor, and what an FPV system costs you.

Detect and avoid is the obligation that changes character with the operation. In VLOS it is a practice the pilot performs; in BVLOS it is a capability the system must have. Std 922.10 AIM 3.2.6

• You know whether the operation is VLOS or BVLOS, because the DAA requirement turns on it. Std 922.10
• You know whether a visual observer is part of the operation, because that decides which route to compliance is open to you. Std 923
• You know whether the aircraft is flown by FPV, because that changes what the pilot can see around them. AIM 3.2.26

When flying an RPA within VLOS, pilots practise detect-and-avoid as the primary method of minimising the risk of collision with other aircraft. AIM 3.2.6

What it requires is specific, and it is not staring at the screen: the pilot must look away from the control station and become aware of their aircraft and the surrounding environment. AIM 3.2.6

The AIM also lists the other tools available: hearing an approaching aircraft, monitoring a local ATC frequency, and using transponder or ADS-B monitoring devices. AIM 3.2.6

That list matters because it names what the visual sense alone does not cover. The eye is limited by atmospheric conditions, glare, lighting and more, which is why the AIM devotes a section to visual scanning technique. AIM 3.2.6 AIM 3.2.6

The DAA standard is required for all BVLOS operations. In the BVLOS domain operators cannot rely on human vision to mitigate the risk of collision with another aircraft, so they are required to have a technological solution for detecting and avoiding manned aircraft that may be found in their operational area. Std 922.10

The technologies the standard contemplates are radar, ADS-B, electro-optical/infrared sensors, or a combination. Std 922.10

Note how the requirement is worded: it is about detecting and avoiding manned aircraft, because those are the traffic that cannot be expected to see and avoid a small remotely piloted aircraft in time. Std 922.10

DAA is also one of the standards a manufacturer declares the system against, which is where the requirement stops being advice. The AIM lists Standard 922.10 — Detect, Alert and Avoid among the declarations required for a small RPA BVLOS operation, and its declaration page is where the set of required standards is collected. AIM 3.4.4

The only exception to the technological requirement is operations that use Visual Observer DAA — VODAA, under Standard 923. Those operations carry specific procedural and operational restrictions, and they allow visual observers to monitor for incoming traditional aircraft while not being able to see the RPA itself. Std 922.10 Std 923

The framework is deliberate about this: Visual Observer DAA is a means of complying with Standard 922.10. Effectively, the visual observer becomes the detect and avoid system for the operation. Std 922.10

That is the same carve-out the declaration rules make. A pilot may operate without a declaration in respect of the section 922.10 requirement if a visual observer maintains unaided visual contact with the airspace sufficient to detect conflicting air traffic and other hazards and to take action to avoid them, in accordance with Standard 923. CAR 901.95 Std 923

So the observer route is not a gap in the rule; it is the rule's other implementation, with the procedural limits in Standard 923 attached. Std 923

From the DAA standpoint, airspace is classified into Air Risk Class categories, which represent the relative probability of encountering an aircraft in a given airspace. The information used to determine an operational volume's ARC classification includes the ATC airspace classification (Class A, B, C, D, E, F or G) and the proximity to the nearest aerodrome, among other things. Std 922.10

The standard points to Advisory Circular AC 903-001 for how those classifications are assigned. Std 922.10

FPV offers an immersive piloting experience but cuts the pilot off from their surroundings and greatly affects detect and avoid capability — that is, the pilot's ability to scan for other aircraft. AIM 3.2.26

The consequence is stated as a requirement: if you are using an FPV system that reduces the pilot's field of view, visual observers must be used, and the number needed depends on the complexity and the area of the operation. AIM 3.2.26

There is a second consequence that is easy to overlook: the area surrounding the pilot should also be safe and free of hazards, because FPV prevents the pilot from being aware of their own surroundings as well. AIM 3.2.26

Situation	Detect and avoid
VLOS operation	The pilot practises DAA: look away from the control station, scan, and use hearing, ATC frequency, ADS-B AIM 3.2.6
BVLOS operation	Standard 922.10 requires a technological solution — radar, ADS-B, EO/IR or a combination Std 922.10
BVLOS with Visual Observer DAA	The observer is the DAA system, under Standard 923's restrictions Std 923
BVLOS with a visual observer meeting the Standard 923 conditions	No declaration is needed for the 922.10 requirement CAR 901.95
FPV that reduces the pilot's field of view	Visual observers must be used; the number depends on complexity and area AIM 3.2.26
Any FPV operation	Keep the area around the pilot safe: FPV hides that too AIM 3.2.26

Warning FPV is not a camera choice with no operational consequence. If it reduces the pilot's field of view, visual observers are required — and the pilot is no longer the person performing detect-and-avoid, so the operation's collision protection now depends on someone else being positioned and briefed to do it. AIM 3.2.26

Symptom	Likely cause	What to do
Your BVLOS operation has no DAA solution	922.10 is required for all BVLOS operations	Provide one, or use Visual Observer DAA under Standard 923 Std 922.10
You assumed goggles are fine because VLOS is maintained by an observer	FPV that reduces your field of view requires visual observers	Position and brief them AIM 3.2.26
Nobody is watching the airspace while you watch the screen	DAA requires looking away from the control station	Assign the scan, or do it yourself AIM 3.2.6
You want the observer to be your DAA system	That is VODAA, and it has procedural restrictions	Comply with Standard 923 Std 923
You are unsure what risk your airspace carries	Airspace has an ARC classification	Consider the ATC class and proximity to aerodromes Std 922.10
Your spotter is watching the aircraft, not the sky	Visual Observer DAA watches for other traffic	Brief the task explicitly Std 923

Practise: Detect, alert and avoid

Practise: Vision/visual scanning techniques

• AIM RPA 3.4.4 — RPAS Safety Assurance Declaration

• CAR 901.95 — Declaration — Permitted Operations

• Standard 922 s.922.10 — Detect, Alert and Avoid Systems

• Standard 923 — Vision-Based Detect and Avoid

• AIM RPA 3.2.6 — Detecting and Avoiding Traffic

• AIM RPA 3.2.26 — First-person View (FPV) Devices

• Consolidation: CARs current to 2026-09-21