Sponsored by Skyward, Marcos Osorno, CTO —
Until now, everyone from sole proprietors to major corporations has had to either operate illegally or apply for specific permission from the FAA via a 333 Exemption, a time-consuming and expensive process that has left some businesses waiting for months to receive approval.
The new operational rules for routine commercial use of drones, titled Part 107, will take effect in late August.
It’s hard to overstate what this means for the commercial drone industry. Part 107 gives official support to businesses of all sizes that want to use drones to serve their customers more efficiently, improve worker safety, and innovate in ways that we can’t yet imagine. Part 107 means that drones are now just another means of doing business in the United States, on par with computers, factories, semi-trucks, and retail stores.
Most importantly, Part 107 lays out rules of the road for everyone to follow, and standardizes the processes and training requirements associated with commercial drone operations.
Part 107 also lowers the barrier to entry for businesses that haven’t yet launched drone ops, and it makes ongoing compliance much easier with respect to pilot training, airworthiness, and reporting. See our page of resources on Part 107 for more information.
| Topic | General 333 and Blanket COA Based on April 2016 Blanket COA and Exemption No. 15857 retrieved from FAA.gov on April 27, 2016. |
Part 107Based on the FAA’s Summary of Part 107, which will take effect in late August. |
| Initial training | At least a sport-pilot’s license and current flight review | Pass an initial aeronautical knowledge test at an FAA-approved knowledge testing center; or Hold a Part 61 pilot certificate other than student pilot, complete a flight review within the previous 24 months, and complete a small UAS online training course provided by the FAA. |
| Recurrent training | Biennial flight review | Pass a recurrent aeronautical knowledge test every 24 months; or hold a part 61 pilot certificate other than student pilot, satisfy the certificate flight review requirements, and complete an online training course every 24 months. |
| Medical certificate | FAA medical certificate | Pilots must ensure that they don’t have any condition that would interfere with safe drone operation. |
| Crew size | At least 2: Pilot + visual observers | 1 pilot with a remote pilot airman certificate with a small UAS rating; or 2 crew members, with the operator under the direct supervision of a person who holds a remote pilot certificate (remote pilot in command). |
| Flight restrictions | Must not operate in:
Special permission for airports in controlled airspace and certain airports in uncontrolled airspace.
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Must not operate in:
Prior authorization needed from air traffic control when in controlled airspace (Class B, C, D and airport Class E)
|
| Time of day | Daylight hours only | Only between official sunrise and sunset, with anti-collision lights used during civil twilight (dusk and dawn). |
| Weight limit | 55 pounds | 55 pounds |
| Speed limit | 100 miles per hour | 100 miles per hour |
| Weather | 3 mile visibility, 500 feet below clouds, 2000 feet horizontally away from clouds | 3 mile visibility, 500 feet below clouds, 2000 feet horizontally away from clouds |
| Height limit | 400 feet | 400 feet above ground level; if you’re flying within a 400-foot radius of a structure, you can fly higher, but not more than 400 feet above the structure’s immediate uppermost limit. |
| Visual line of sight | Required | Required |
| Operation from a moving vehicle | Not allowed | Allowed if from ground or water vehicles in sparsely populated areas and not transporting property for compensation or hire |
| Operation above people | Not allowed if not participating or under covered structure providing protection | Not allowed if not participating or under covered structure providing protection or if in a moving vehicle |
| Operation of multiple UAVs at the same time | Not allowed | Not allowed |
| Buffer | At least 500 feet from other property | No buffer |
| Aircraft registration | Required | Required |
| Aircraft allowed | Specified by FAA | Any aircraft under 55 pounds |
| NOTAM filing | Yes | No |
| Monthly COA reporting | Yes | No |
| Incident reporting | Yes | No later than after 10 days of a serious injury to any person or any loss of consciousness or damage greater than $500. |
Regarding training requirements under Part 107
Some leading commercial drone operators have told us that their best and most experienced UAV pilots don’t have pilot’s licenses. Drone pilots with hundreds of flight hours gained in the military or as devoted hobbyists have technically been forbidden from flying commercially. Part 107 takes that barrier away, which is good news.
Other companies have told us that they will still require all of their UAV pilots to hold pilot’s licenses for insurance and safety reasons.
What isn’t changing
Part 107 will lower barriers and encourage innovation and wider adoption. But it won’t create a free-for-all. Clients, especially corporations, will still demand a high level of professionalism, proof of sound operating processes, insurance, and a demonstrated safety record.
And looking ahead, increased competition will likely mean that drone service providers will have to become even more professional in order to set themselves apart from the competition.
Whether you’re a sole proprietor with a wedding photography business, a small enterprise specializing in volumetric surveys, or a world-famous cable news network, a successful UAV operation will depend on safety, scalable processes, and outstanding customer service.
Looking forward
Launching a commercial operation in a new (and highly regulated) market requires calculated choices about business goals, the regulatory environment, the competitive landscape, and timing.
And Part 107 doesn’t address every use case that businesses will want to pursue, including flying beyond visual line of sight or at night. But it doesn’t mean those activities are off the table.
There are multiple ways for businesses to continue to innovate. In fact, Part 107 specifically mentions that operators can seek waivers for other activities by working directly with the FAA. By using a comprehensive system of record, like Skyward, businesses will be able to prove to regulators that a program is safe, well-conceived, and follows a standard process.
At Skyward, we’re committed to tailoring our platform based on our customers’ feedback and business needs, in addition to changing regulations.
What we don’t know yet
These are the questions we don’t have the answers to now:
- When will training centers open?
- If I’ve already submitted my 333 and am waiting for it, what should I do?
- Reporting requirements? If I have a 333 and continue to operate under its terms, do I still need to submit monthly COA reports?
We’ll be having a webinar on July 20 to discuss the business implications of 107 and answer these and many more questions. Jim Williams, Principal and Co-chair of the UAS Practice at Dentons and former Manager of the FAA’s Unmanned Aircraft Systems Integration Office will join me and Skyward CEO Jonathan Evans.
Feel free to email us at [email protected] or reach out to us on Twitter (@SkywardIO) with more questions and we’ll do our best to answer them during the webinar.
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