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Part 107 night operations: lights, twilight and the test

Can you shoot a twilight listing or finish a roof job after sunset? What Part 107 needs at night: the April 2021 training rule, lights and line of sight.

Say a real estate agent wants that glowing twilight shot of a listing, with the windows lit and the sky going orange. Or a roof job runs long and the sun drops before you’ve got the last side. Either way, you need to know whether you can keep flying. Under Part 107 you don’t need a waiver to fly at night. You need two things: the right training date on your record and the right lights on your aircraft. A lot of older material still says otherwise, so it’s worth getting this straight for the test and for the job.

The two conditions in §107.29(a)

To fly at night, 14 CFR 107.29(a) requires both of these:

  1. Training date. The remote PIC (the pilot in command) completed the initial knowledge test or training under §107.65 after April 6, 2021.
  2. Lighting. The small unmanned aircraft has lighted anti-collision lighting, visible for at least 3 statute miles, with a flash rate sufficient to avoid a collision.

You may turn the lights down if that’s safer, but you may not turn them off.

Why April 6, 2021

That’s the day the FAA added night operations, operations over people and Remote ID to the knowledge test. The regulation requires the initial test or training to have been completed after April 6, 2021. On the same day, the old recurrent test was replaced by online recurrent training.

If you were certificated earlier, you get night privileges by completing the current recurrent training. Recurrent training finished before April 6, 2021 doesn’t count. AC 107-2A explains that the current test and recurrent training both cover night physiology and night visual illusions.

The free course for most pilots is “Part 107 Small UAS Recurrent (ALC-677)”. Our guide to Part 107 recurrent training explains how it works.

Day, twilight, night

PeriodDefinition (outside Alaska)Lighting requirement
DayOfficial sunrise to official sunsetNone required
Civil twilight30 minutes before official sunrise, and 30 minutes after official sunsetAnti-collision lighting visible 3 SM
NightEnd of evening civil twilight to start of morning civil twilightAnti-collision lighting visible 3 SM, plus post-April 6, 2021 training

In Alaska, civil twilight follows the Air Almanac instead of the 30-minute rule.

“Night” comes from 14 CFR 1.1: the time between the end of evening civil twilight and the beginning of morning civil twilight, as published in the Air Almanac and converted to local time.

This is where the twilight listing shot lives, and it’s also a favorite test angle. Flying 20 minutes after sunset is civil twilight, so lighting is required, but the post-2021 training requirement applies only at night.

About those lights

The rule sets a performance standard: the lights must be visible for 3 statute miles and flash fast enough to avoid a collision. AC 107-2A says you may rely on the manufacturer’s statement that a light meets 3 SM, but you’re still responsible for checking that it works and is visible where you’re flying.

The option to dim exists for a practical reason. AC 107-2A notes that a bright strobe close to the pilot can make it harder to judge the aircraft’s position, speed, attitude or altitude.

During the day, §107.29 doesn’t require lighting, and the AC says lighting is generally not effective for daytime collision avoidance. You can still leave lights on if you like.

Seeing the aircraft after dark

The line-of-sight rule doesn’t relax at night. The remote PIC and the person at the controls, or a visual observer, must be able to see the aircraft with unaided vision (glasses or contacts are fine). They have to be able to tell its location, attitude, altitude and direction, watch for traffic and hazards, and make sure it endangers no one.

AC 107-2A is direct about what doesn’t satisfy that at night: you can’t rely only on the anti-collision lights, the ground control station’s telemetry, or both together. It says you may need to restrict the area you fly in almost all cases. Binoculars may be used only momentarily, and a first-person-view feed never counts as line of sight.

On a roof job that means keeping the drone closer than you would at noon, even if the screen shows it perfectly. Visibility still has to be 3 statute miles from the control station, and at night that’s the distance at which prominent lighted objects can be seen.

A night preflight

The regular preflight rules in §107.49 still apply, and some items get harder in the dark. Before the flight:

  • Walk the site in daylight if you can, noting wires, trees and structures you won’t see later.
  • Brief everyone involved on emergency procedures, roles and how you’ll communicate without eye contact.
  • Confirm control links and that you have enough battery for the planned flight time.
  • Check that the anti-collision lights work, are visible for 3 statute miles and have a flash rate sufficient to avoid a collision.
  • Check NOTAMs and flight restrictions, and get airspace authorization where required.

The daylight walk is our advice, not a rule. Everything else on that list traces to Part 107. For a twilight listing, the easy version is to arrive while it’s still light, fly your daytime shots, and use that time to walk the property.

Hazards you can’t see at night

Obstacles you’d spot easily in daylight get hard to see after dark. The FAA’s Chart Users’ Guide warns that wind turbine blade tips aren’t lit, and that the lights on the hub can in some cases sit 200 to 300 feet below the tip. The ACS also lists ground structures and their lighting, and hazards on the ground with no lighting, as knowledge elements next to the night equipment items.

The weather minimums don’t change at night either. You still need 3 statute miles of visibility and must stay 500 feet below and 2,000 feet horizontally from clouds. Every other aircraft still has the right of way.

Waivers and old approvals

Anti-collision lighting at night and during civil twilight is on the list of rules the FAA can waive under §107.205. To get a waiver you have to fully describe the operation and show it can be done safely.

Old night waivers are no longer usable. Since May 17, 2021, no one may fly at night under a certificate of waiver issued before April 21, 2021.

What the test asks

The ACS (the FAA’s list of what the test can cover) includes operator equipment for night flight, manned aircraft lighting and small UAS lighting requirements as knowledge elements under airspace operational requirements. Expect questions on the 3 SM lighting standard, the twilight window, whether a pilot trained in 2020 can fly at night, and whether a light may be dimmed or switched off.

The 2016 FAA Study Guide doesn’t include night operation at all, so don’t lean on it for this topic. Work from the regulation and AC 107-2A instead.

For every limit in one place, use the Part 107 rules cheat sheet. If an evening event puts people under your flight path, the category rules apply too, and they’re covered in operations over people.

Check yourself

Take the free 20-question practice test. It gives you a score by area, so you’ll see whether rules like these have stuck. When you want the full course, Liftoff is $49 once with lifetime access, and every answer cites its FAA or eCFR source. You can see what’s included.

If you’re still deciding whether drone work is for you, start with how to become a drone pilot, or check whether you need a drone license for the flying you have in mind.