Below is the full text of a comment I have submitted to the FAA regarding the proposed rule on Operation and Certification of Small Unmanned Aircraft Systems (Docket ID: FAA-2015-0150).  I encourage everyone who agrees with my comment to submit it again using copy / paste.  Or modify it as you consider appropriate to express your own take.  Regardless, the more they see specific feedback like this the more likely positive change will occur.

Visual Observers (Tracking ID: 1jz-8hyh-dtrp)

This comment is to specifically address Visual Observer (VO) aspects.  The rule states that a VO "may be used" but is NOT required.  Having visual observers in addition to the pilot in command is desirable, as it typically will enhance the ability to operate the sUAV safely.  
However, the rule virtually negates any incentive to engage even one VO, much less several, by requiring that ALL visual observers AND the operator must be in visual contact with the craft at ALL times.

(1) In order for all VOs to ensure both they and the pilot in command maintain visual contact they will be more likely to be close together.  The closer they are to the person in command and to each other, the more likely lost contact by one will mean lost contact by all.
(2) On the other hand, if you increase the distance between a VO and the pilot in command, you run the risk of one or the other losing contact and needing to suspend operations.

Example Scenario: One operator and two visual observers - If each VO is within 20 ft of the operator they could span a max distance of 40 ft in a line or form a triangle with no side longer than 20 ft.  Within this confined space if either VO loses sight of the craft the operator must suspend operation.  If the pilot loses sight, they must suspend operation.  The VOs might become more of an obstacle for the operator than a benefit.  Why engage one or two additional people in the operation if they only reduce the potential for continued operation?  The more spread apart the VOs and operator are from each other, the more likely one of the VOs will lose sight while the operator and any other VOs still have contact.  But still forcing the operator to suspend operations even though the operator never lost contact.

(a) I think we can all agree the more eyes there are on an sUAV the more likely we are to have safe operations.
(b) The rule should establish parameters which encourage, rather than discourage, including visual observers in any flight operation.
(c) The FAA has cited concerns with regard to facilitating a daisy-chain approach to operations, so we need parameters which prevent or discourage significant visual separation of the operator from the sUAV while enhancing overall operational safety.

I propose the FAA adopt the following with regard to visual observers (VO):

(A) All visual observers engaged in a common flight operation must maintain constant line of sight visual contact with the operator.  This prevents or mitigates a daisy chain approach to extend the distance of the sUAV from the operator to an unsafe or unreasonable degree.
(B) All visual observers engaged in a common flight operation must maintain constant audible contact with the operator and with all other observers.  This could be affected by word of mouth if all people engaged in operation are physically close together.  When line of sight to the operator is possible over longer distances than practical for unassisted voice contact, an electronic communication system may be used to facilitate constant voice contact.
(C) If all VOs and the operator have lost visual contact with the craft, operation must be suspended.

These parameters would encourage the use of Visual Observers (VO) because they never become a liability to independent operation by a single pilot in command.

The above will achieve the "see and avoid" criteria because at least one person engaged in operations sees both the craft and the space surrounding it and can immediately advise the operator as to course of action (drop, climb, stop, etc.) because contact is maintained with the operator.

Below is the full text of a comment I have submitted to the FAA regarding the proposed rule on Operation and Certification of Small Unmanned Aircraft Systems (Docket ID: FAA-2015-0150).  I encourage everyone who agrees with my comment to submit it again using copy / paste.  Or modify it as you consider appropriate to express your own take.  Regardless, the more they see specific feedback like this the more likely positive change will occur.

Visual Observers (Tracking ID: 1jz-8hyh-dtrp)

This comment is to specifically address Visual Observer (VO) aspects.  The rule states that a VO "may be used" but is NOT required.  Having visual observers in addition to the pilot in command is desirable, as it typically will enhance the ability to operate the sUAV safely.  
However, the rule virtually negates any incentive to engage even one VO, much less several, by requiring that ALL visual observers AND the operator must be in visual contact with the craft at ALL times.

(1) In order for all VOs to ensure both they and the pilot in command maintain visual contact they will be more likely to be close together.  The closer they are to the person in command and to each other, the more likely lost contact by one will mean lost contact by all.
(2) On the other hand, if you increase the distance between a VO and the pilot in command, you run the risk of one or the other losing contact and needing to suspend operations.

Example Scenario: One operator and two visual observers - If each VO is within 20 ft of the operator they could span a max distance of 40 ft in a line or form a triangle with no side longer than 20 ft.  Within this confined space if either VO loses sight of the craft the operator must suspend operation.  If the pilot loses sight, they must suspend operation.  The VOs might become more of an obstacle for the operator than a benefit.  Why engage one or two additional people in the operation if they only reduce the potential for continued operation?  The more spread apart the VOs and operator are from each other, the more likely one of the VOs will lose sight while the operator and any other VOs still have contact.  But still forcing the operator to suspend operations even though the operator never lost contact.

(a) I think we can all agree the more eyes there are on an sUAV the more likely we are to have safe operations.
(b) The rule should establish parameters which encourage, rather than discourage, including visual observers in any flight operation.
(c) The FAA has cited concerns with regard to facilitating a daisy-chain approach to operations, so we need parameters which prevent or discourage significant visual separation of the operator from the sUAV while enhancing overall operational safety.

I propose the FAA adopt the following with regard to visual observers (VO):

(A) All visual observers engaged in a common flight operation must maintain constant line of sight visual contact with the operator.  This prevents or mitigates a daisy chain approach to extend the distance of the sUAV from the operator to an unsafe or unreasonable degree.
(B) All visual observers engaged in a common flight operation must maintain constant audible contact with the operator and with all other observers.  This could be affected by word of mouth if all people engaged in operation are physically close together.  When line of sight to the operator is possible over longer distances than practical for unassisted voice contact, an electronic communication system may be used to facilitate constant voice contact.
(C) If all VOs and the operator have lost visual contact with the craft, operation must be suspended.

These parameters would encourage the use of Visual Observers (VO) because they never become a liability to independent operation by a single pilot in command.

The above will achieve the "see and avoid" criteria because at least one person engaged in operations sees both the craft and the space surrounding it and can immediately advise the operator as to course of action (drop, climb, stop, etc.) because contact is maintained with the operator.