Certificate of Authorization vs. Part 107

Unmanned Aircraft Systems (sUAS) allow first responders an aerial perspective on a situation that can provide critical feedback and make their jobs safer. There are two ways for first responders to be approved to fly aircraft in the national airspace.

In August 2016, the FAA’s new policy 14 CFR Part 107 was implemented, which opened the door for many commercial UAV operators. Under the part 107, a pilot must take and pass the Remote Pilot in Command (PIC) test through an FAA certified testing center. Once passed the certified PIC can fly with certain restrictions. If their intended operations do not fall within the restrictions, they can petition the FAA through a waiver process showing how they will safely conduct the waiver-able operation. A Remote PIC airman’s certificate must be renewed every two years.

     As a public entity/first responder the FAA is urging departments to go through the Certificate of Authorization (COA) process. There are two different types of COA’s, a Blanket COA and a Jurisdictional COA. Due to the operational limitations, most departments will need a jurisdictional COA. COA’s are a tiered approach. First a department must secure a blanket COA, then a jurisdictional. The blanket COA allows flight operations nationwide, and the jurisdictional allows local operations. When applying for the jurisdictional, a department is showing the FAA how that department will safely conduct operations in the national airspace laying out the conditions the department will operate under. The COA must be renewed every two years, however the renewal process is streamlined.

The Federal Aviation Administration has encouraged departments to move down the path of the COA. There are many benefits for a department or public entity to operate under the COA process. First, the department can get approved for all desired flight operations right from the start. Under the Part 107, the entity must submit waivers for each special flight operation they wish to conduct. In the long run it will save the department time and money in applying through the COA process. Secondly, through the COA process a department can specify its own training standards for its pilots. This is especially important when conducting operations in controlled airspace. The department can determine its advanced training criteria to fly safely. Lastly, case law has not dictated where the liability will fall if a public entity is operating under the Part 107 as a Civil Operator.

Mishigami Group can help with your organizations program development needs, contact mrybar@mishigamigroup.com for more information.

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