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Can I1 red & green lights be seen 3 miles away during twilight?

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FAA 14 CFR Part 107.29 now requires that UAS' may not be operated at night, but may be operated during civil daylight as long as the UAV "has lighted anti-collision lighting visible for at least 3 statute miles." 1) Are the current red & green LEDs on the Inspire 1 large and bright enough to be seen 3 miles away during twilight? 2) If not, what solutions are being employed?
 
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FAA 14 CFR Part 107.29 now requires that UAS' may not be operated at night, but may be operated during civil daylight as long as the UAV "has lighted anti-collision lighting visible for at least 3 statute miles." 1) Are the current red & green LEDs on the Inspire 1 large and bright enough to be seen 3 miles away during twilight? 2) If not, what solutions are being employed?

At least three miles away, almost 16000 ft. I get the feel the FAA would rather you didn't fly during hours of darkness. A light which projects out three miles sounds like a fixture that's fairly large and quite powerful, similar those used on commercial aircraft, however I'm not entirely sure about this.
I basically only fly within the 30 minute Dawn/Dusk guidelines, and use a couple small lightweight LED lights by Lezyne which are definitely brighter that those provided with my Inspire. They are advertised to produce up to 160 Lumens for (5)hrs. at the brightest flash setting, however even with that power rating I'm not quite certain you would be able to visually see the lights (3)miles out. Well maybe with superman's eyesight. : ) An interesting test I may want to perform at some point though.
 
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The performance based standards say that lights aren't needed if a system is in place that can avoid all non-participating aircraft.

I wonder if that is what the folks did who have already been approved.
 
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