WEBVTT

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All right.

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Good afternoon, everyone,

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and thanks for joining today
for episode nine here of

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our Regulatory Updates for
Public Safety webinar series.

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So it's been a couple months.

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The last webinar I
did was back in March.

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And at that time,

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we were talking about multidrone
approvals and operations.

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At that time, the waivers had
just started getting issued.

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And since then, as kind of just
a side note to start the webinar,

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we've got about sixty
agencies now with approvals,

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which is awesome to see.

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And even better is many of
those agencies are now starting

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to incorporate multi drone
operations in just day to day ops.

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So it's been awesome to see
that and see that kind of new

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concept growing,

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but that's not what we're
here to talk about today.

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Today is going to be about
kind of choosing a path and the

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differences and similarities
between Part ninety one and

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Part one hundred seven.

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And really the focus of
the webinar here today

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will be on these
public safety waivers

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which are mostly streamlined at
this point and how these, you know,

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today there's essentially a
waiver for both regulations.

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There's a public safety
streamlined waiver for Part

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ninety one and for
Part one hundred seven.

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And so we're basically gonna
just take the hour to kind of

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talk about how they're the
same, how they're different,

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so things like what are the
eligibility requirements,

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how do you get them,

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what are the similarities
and differences in the actual

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approvals themselves, and
like what that might mean for

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your actual operations.

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And then there's we'll
talk about some other additional

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kind of considerations.

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These would be extra approvals kind
of on top but things like

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airspace authorizations
to flying zero grids,

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multi drone, we will come
back to that as well.

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So without further ado, let's kind
of get into the material here.

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But first,

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I just kind of want to have a
little fun and do kind of test

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you all to see see
who's watching.

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So I'm gonna kind of put up a

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graphic, two graphics, and I I'll
give you, like, fifteen seconds.

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I just kinda want you all to
look and see if you can spot

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the differences here.

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So let's go with the first one
and I'm just going to kind of

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count the ten in my head and
then we'll reveal the answer.

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Okay so at first glance it's
kind of like the Spider Man

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meme like wait.

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These are both Kawas actually.
They're both waivers.

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They both look the
same cover letter wise.

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They're both signed by the FAA.

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But this one, hopefully,

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you kinda spotted that the
difference here is one is a

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part ninety one waiver.

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One is a Part one
hundred seven waiver.

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So that's really
the main difference.

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There's also a small difference
in the number of provisions

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each waiver has,

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and we'll talk more about that
later about like why those

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numbers are different.

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But yeah, one is a
part ninety one waiver,

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one's a part one
hundred seven waiver.

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So that's the main difference
here. So let's do another one.

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Let's kind of count to
ten again in my head here.

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Alright.

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I probably should have had
a little live poll going,

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but we just want to
keep it simple today.

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So here is the
difference for this one.

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So mostly the same verbiage here
and this is one of the

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provisions out of the Part one
hundred seven and ninety one waivers.

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One kind of uses the term
responsible person and then it

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speaks to Part one
hundred seven regulations.

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One uses the term operator
and speaks to part ninety one

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regulations.

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Everything else is identical
though between the two really.

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Alright so let's
do one more here.

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Okay. And this one's
a little bit shorter.

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So this one's kind
of a trick question.

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Another meme. I like the office.

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It's kind of the corporate
needs you to find the

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difference between the
two and they're the same.

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And I realize my
head's blocking that,

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but they're the same provision.

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Number is different,

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but that's effectively a meaningless
difference at this point.

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The verbiage is the same.

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You have to have FCC approved
transmitters flowing under these waivers.

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And this screenshot is one
is Part one hundred seven,

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one is Part ninety one again.

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So

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throughout the hour
here ahead of us,

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I kind of want to just throw
out an overarching theme to

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start and that will kind of frame
this all for you, for everybody.

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So the difference between Part
ninety one and Part one hundred

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seven public safety waivers
is there's actually more

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similarities than differences.

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So kind of keep that
in mind going forward.

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I'm going to kind of I will
like outline some differences

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and kind of technicalities
between the two but in the big

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picture these waivers
are very, very similar.

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Okay, and then I'll
kind of just spoil the

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question as well at the front
here again to just kind of help

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everybody frame this as I go
through things in more detail.

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So if you're an agency kind
of trying to decide like

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which should I do or what's the
benefits of one over the other,

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in terms of just like the
simplest way to think about it,

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this is kind of what
I would recommend.

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So I would just think about
what type of entity am I.

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If I'm a government entity,

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I would recommend Part ninety
one as kind of the most just

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streamlined path to getting these
waivers and getting operational.

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If you're not a
government entity,

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it's kind of a trick question.

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You really only have one option.

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You have to fly under
Part one zero seven.

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So the government
entities do have a choice.

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They could fly under
either one in most cases,

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but I recommend Part ninety one.

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And then if you're not
a government entity,

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you fly under Part
one hundred seven.

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So that's just kind of the
simplest way to think about it.

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And as we go through the
materials here I'll start to

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kind of just point out
some of these differences,

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where they matter, where
they don't and so on.

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Okay so let's just kind of
start doing like side by side

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comparison here a
little bit of the two.

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And again, I'm focusing
initially here on just the

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public safety standard
two hundred foot waivers.

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So this is your single drone
waiver, one pilot to one drone,

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and this is a waiver you can
generally get quite quite easy.

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There's streamlined
processes for that.

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Okay.

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So eligibility is kind of one of the
first things you have to think about,

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and I already alluded to it
in that that previous graphic.

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But to get a part
ninety one waiver,

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you have to be two things.

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You have to be a public safety
organization and a public

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aircraft operator.

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For part one zero seven,

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you only have to be a
public safety organization.

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So that's where if you're
not a government entity,

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if you're not a public
aircraft operator,

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that's really the
only choice for you.

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And I've covered these
definitions on previous

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webinars and obviously the FAA
has lots of material on this.

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So I'm going kind of skip the
detailed definition here and

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you can refer back to
the material there.

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But yeah, and in this initial section
I'm going kind of just highlight

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the differences in that gold
text there to just sort of make

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them pop so you
all can see that.

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Okay so once you've decided or
kind of determined what type of

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interviewer you are and now
you've got to go get a waiver,

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this is the documentation that
you have to put together to

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actually submit to the
FAA for this waiver.

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So

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both the Part ninety one
and the one hundred seven,

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they require a responsible person
to complete a set of documents.

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For Part ninety one,

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you're going to fill out a
seven thousand seven hundred

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eleven form, a waiver checklist,

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and a letter as a
concept of operation.

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Whereas under Part
one hundred seven,

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you're going to do just
the checklist and letter.

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So seven thousand seven hundred
eleven is a unique form to ninety one.

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It's a difference.

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I wouldn't say it's a
meaningful difference though.

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It's just kind of a form
to put your information

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and sign it.

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And who is this
responsible person?

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This is the same between
the two but I want to just

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highlight this too as
just a common kind of

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question that I get when
talking to agencies.

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So the responsible person,

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there needs to be one of these
regardless of whether you do

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Part one hundred
seven or ninety one.

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And from the FAA's checklist,

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their definition is this is
a person that accepts direct

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responsibility for safety of
the operations under the waiver.

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They're kind of like that
organization's designee for

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managing the operations
under the waiver.

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And the FAA's checklist goes
on further to say like this is

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typically a chief assistant
chief chief pilot type of role.

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I find most agencies don't,

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they're not designating
staff to fill like

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this type of traditional
aviation role, chief pilot,

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so I tend to focus agencies
on the gold text there of it's

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just a senior level person who's
going to be accountable to the FAA.

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And so a few more recommendations
on the right side,

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you know we recommend that this
person has a working knowledge

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of the drone program.

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Don't go too high in the
organization where you know

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like the chief for example,

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if they're not kind of
following the program and they

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don't understand it like day to day
ops I wouldn't pick that person.

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And then this person does need
to have some authority and

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standing in the agency to be
accountable for it and finally

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they don't need a
remote pass certificate

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so it doesn't need to be
somebody that has one.

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But yeah, think about who this is
in your agency if you haven't gotten

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the waiver yet this person
would sign those documents and

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then become responsible.

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And going to talk about responsibilities
in a couple of

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slides here later,

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so we'll come back to this
responsible person concept.

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Okay.

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And then once you've
got the documents ready,

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what do you do with them?

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Where do you send them
to request the waiver?

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So under Part ninety one,

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you're going to just email them
to the FAA and typically the

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FAA will respond
in a week or two.

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It's a pretty quick turnaround.

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Part one hundred seven is
a little bit different.

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You're going to send the
documents into a FA portal.

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So you'll create an account and
you'll kind of go through the

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application process
in the portal.

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And once you've submitted it,

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it typically takes a little bit
longer for the FAA to review

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these, but still quite fast,
typically less than a month,

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but often a week or two as well.

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So some differences,

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but I would say
in the big picture

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these don't matter enough to
like change how you should

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think about getting
one over the other.

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All right. And then now
let's get into the approval.

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So you get the waiver.

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Now you're kind of thinking
about how to go operate

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and comply with
all the provisions.

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So again, kind of
back to that theme,

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these are more similar
than different.

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So in the big picture,
these two waivers,

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they effectively allow
you to do the same

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thing, the same
type of operations.

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So for for both,

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you can do four hundred foot
visual line of sight operations.

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And for part one hundred seven,

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that's just standard
part one hundred seven.

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It's not, like, waived,

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but that's just kind
of worth calling out.

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Under Part ninety one,

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there's actually a provision
that says you can do this.

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So both of them would allow
you to do visual line of sight

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00:12:24.555 --> 00:12:27.155
operations still up
to four hundred feet.

246
00:12:27.195 --> 00:12:29.595
Both of them will allow you
to do beyond visual line of sight

247
00:12:29.595 --> 00:12:31.410
operations up to
two hundred feet.

248
00:12:31.410 --> 00:12:34.370
And that provision
shown on the right side,

249
00:12:34.370 --> 00:12:37.290
it's actually verbatim
the same between the two.

250
00:12:37.570 --> 00:12:41.410
And both waivers allow you to
do these things nationwide,

251
00:12:41.410 --> 00:12:45.685
either in uncontrolled airspace
or in controlled airspace as

252
00:12:45.685 --> 00:12:49.565
long as you're below the
UAS facility map altitudes.

253
00:12:53.285 --> 00:12:54.965
And then drone requirements

254
00:12:54.965 --> 00:12:56.620
wise kind of the same thing.

255
00:12:56.620 --> 00:12:58.700
They're generally the
same requirements.

256
00:12:58.700 --> 00:13:01.420
So you have to fly less than
one hundred miles an hour,

257
00:13:01.420 --> 00:13:03.660
you have to use under
fifty five pound drones and those

258
00:13:03.660 --> 00:13:05.740
drones have to have anti
collision lighting and remote

259
00:13:05.740 --> 00:13:06.780
ID.

260
00:13:06.780 --> 00:13:08.540
When you're flying beyond
visualized site you have to

261
00:13:08.540 --> 00:13:12.335
have a method of receiving ADS
B and when you're flying over

262
00:13:12.335 --> 00:13:16.175
people you need for bigger
drones at least you need a

263
00:13:16.175 --> 00:13:19.455
compliant parachute system and
then there's kind of a point

264
00:13:19.455 --> 00:13:22.175
eight eight pound threshold
where as long as they're under

265
00:13:22.175 --> 00:13:25.855
that and you have a method
of preventing the props from

266
00:13:25.855 --> 00:13:29.990
lacerating humans you can also
operate those over people.

267
00:13:29.990 --> 00:13:32.630
So more or less the
same requirements.

268
00:13:32.630 --> 00:13:33.670
The gold text here,

269
00:13:33.670 --> 00:13:36.310
the one kind of difference
probably between the two is

270
00:13:36.310 --> 00:13:39.670
Part ninety one has a limited
exception in emergency

271
00:13:39.670 --> 00:13:42.910
situations where you can fly over
people without the parachute.

272
00:13:43.615 --> 00:13:45.615
But I would say at this point,

273
00:13:45.615 --> 00:13:49.215
we really strongly encourage
the use of the parachute.

274
00:13:49.215 --> 00:13:52.975
It's a great product and really
for dock based systems it's

275
00:13:52.975 --> 00:13:54.815
kind of part of the
standard packaging anyway.

276
00:13:54.815 --> 00:13:58.140
So we really encourage agencies
to use the parachute anyways

277
00:13:58.140 --> 00:14:01.900
but you know on a kind of just
technical level that limited

278
00:14:01.900 --> 00:14:07.380
exception does exist under Part ninety
one and not under Part one and seven.

279
00:14:10.985 --> 00:14:14.265
Okay and then record
keeping and reporting,

280
00:14:14.265 --> 00:14:16.105
again more or less the same,

281
00:14:16.105 --> 00:14:18.545
one kind of small difference but

282
00:14:18.585 --> 00:14:19.865
the responsible person,

283
00:14:19.865 --> 00:14:22.980
they're going to be responsible for
maintaining a record of training,

284
00:14:22.980 --> 00:14:25.780
of pilots and drones flying
under the waiver of things like

285
00:14:25.780 --> 00:14:28.420
site surveys and
monthly flight time.

286
00:14:28.420 --> 00:14:30.980
And then they're responsible
for reporting accidents and

287
00:14:30.980 --> 00:14:33.740
incidents to the NTSB and FAA.

288
00:14:33.780 --> 00:14:37.380
One kind of common thing
I see from agencies

289
00:14:37.380 --> 00:14:41.135
is they're not aware of the
NTSB reporting requirements.

290
00:14:41.135 --> 00:14:44.255
These actually apply
kind of drone wide.

291
00:14:44.255 --> 00:14:46.815
Like, if you're flying just
under Part one hundred seven,

292
00:14:46.815 --> 00:14:49.695
these NTSB reporting requirements
still apply to you, actually.

293
00:14:49.695 --> 00:14:50.615
So

294
00:14:51.940 --> 00:14:54.260
getting the waiver is kind of a
good reminder that you have to

295
00:14:54.260 --> 00:14:57.460
do this and then the FAA
has their kind of reporting

296
00:14:57.460 --> 00:14:59.660
requirements on top of that.

297
00:14:59.940 --> 00:15:00.900
There's one difference.

298
00:15:00.900 --> 00:15:02.355
So under Part one hundred seven,

299
00:15:02.355 --> 00:15:04.915
and this is just because Part
one hundred seven has this

300
00:15:04.915 --> 00:15:08.995
regulation one hundred seven point
nine where you have to

301
00:15:08.995 --> 00:15:12.555
report this is kind of the
five hundred dollars threshold

302
00:15:12.835 --> 00:15:15.875
or if you cause damage over that
amount you have to report it.

303
00:15:15.875 --> 00:15:18.800
So Part one hundred seven has
the additional one hundred

304
00:15:18.800 --> 00:15:22.400
seven point nine reporting requirement
that Part ninety one doesn't,

305
00:15:22.400 --> 00:15:25.720
but that's really the only
difference between the two.

306
00:15:30.255 --> 00:15:33.935
Okay and so yeah,
again just to hammer it

307
00:15:33.935 --> 00:15:35.695
home, like very similar.

308
00:15:35.695 --> 00:15:38.815
They're both going to allow
you to do the same types of

309
00:15:38.815 --> 00:15:42.615
operations, to do DFR,
to do tactical operations

310
00:15:43.040 --> 00:15:46.200
with any drone really that
meets those requirements.

311
00:15:46.320 --> 00:15:48.320
So then are there differences?

312
00:15:48.320 --> 00:15:50.600
Yes, there are some differences.

313
00:15:50.640 --> 00:15:54.320
Some of these differences
actually do have like an impact

314
00:15:54.320 --> 00:15:58.145
on your operations and some of them
are just technicalities, really.

315
00:15:58.145 --> 00:16:00.545
So, we'll kinda talk about a few

316
00:16:00.545 --> 00:16:04.305
differences here, and I'm gonna
kinda go in order of, like,

317
00:16:04.305 --> 00:16:07.425
things that matter to your
operations and then things that

318
00:16:07.425 --> 00:16:10.265
are just kinda technicalities
towards the end.

319
00:16:13.790 --> 00:16:17.710
Okay, so the first one is the
standard weather minimums.

320
00:16:17.710 --> 00:16:22.830
So this has actually been just a
recent change under Part ninety one.

321
00:16:22.830 --> 00:16:25.855
So now if you apply for
just standard two hundred

322
00:16:25.855 --> 00:16:27.695
foot Part ninety one waiver,

323
00:16:27.695 --> 00:16:30.415
you're going get a standard
weather minimum of one statute

324
00:16:30.415 --> 00:16:31.855
mile and clear clouds.

325
00:16:31.855 --> 00:16:34.415
So you just have to have one
mile visibility and just stay

326
00:16:34.415 --> 00:16:36.575
out of the clouds essentially,

327
00:16:36.575 --> 00:16:38.735
which allows you to fly in
a little bit more inclement

328
00:16:38.735 --> 00:16:42.130
weather if there's like light
rain or kind of some lower

329
00:16:42.130 --> 00:16:45.010
ceilings on occasion.

330
00:16:45.010 --> 00:16:49.170
This may give you a couple extra days
a year that you can operate under.

331
00:16:49.170 --> 00:16:52.210
Part one hundred seven still
has just like your standard

332
00:16:52.210 --> 00:16:56.645
three miles and five hundred foot
below clouds weather requirements.

333
00:16:56.645 --> 00:16:59.925
So small difference here,
but this may, you know,

334
00:16:59.925 --> 00:17:02.205
have an impact on
your operations.

335
00:17:06.170 --> 00:17:10.250
Okay. Qualifications,
training, and airworthiness.

336
00:17:10.250 --> 00:17:14.010
So now we're the next couple
are are start to get a little

337
00:17:14.010 --> 00:17:18.410
bit more, you know,
complicated in-depth, nuanced.

338
00:17:18.410 --> 00:17:21.170
So under Part ninety one,

339
00:17:21.185 --> 00:17:25.345
your agency is really just
responsible for self certifying

340
00:17:25.345 --> 00:17:26.065
these two things.

341
00:17:26.065 --> 00:17:30.065
So you're going to self certify
your pilots and you're going to

342
00:17:30.065 --> 00:17:33.185
self certify that the
aircraft are airworthy.

343
00:17:33.185 --> 00:17:36.650
Because under just kind of
standard Part ninety one

344
00:17:36.650 --> 00:17:39.770
regulations aircraft have to
have airworthiness certificates

345
00:17:39.770 --> 00:17:43.130
and those are issued by the
FAA but as a public aircraft

346
00:17:43.130 --> 00:17:47.010
operator you can self
certify that airworthiness.

347
00:17:47.050 --> 00:17:48.850
Under Part one hundred seven,

348
00:17:49.045 --> 00:17:53.765
a little bit different in kind of the
verbiage and the actual requirements.

349
00:17:53.765 --> 00:17:57.045
So pilots must have a
remote pilot certificate.

350
00:17:57.045 --> 00:17:59.685
That's non negotiable.
You've to have it.

351
00:17:59.685 --> 00:18:01.925
But then don't forget, you know,

352
00:18:01.925 --> 00:18:05.130
the responsible person is
still responsible for ensuring pilots

353
00:18:05.130 --> 00:18:07.690
have the knowledge and skills
to do beyond the line of sight

354
00:18:07.690 --> 00:18:11.050
operations and to understand
the waiver and so on.

355
00:18:11.050 --> 00:18:14.410
So it's kind of a remote
pilot plus type of model.

356
00:18:14.410 --> 00:18:16.245
You've to have that
SERP but then the

357
00:18:16.245 --> 00:18:19.125
responsible person is still
responsible for kind of adding

358
00:18:19.125 --> 00:18:22.285
some extra training and
knowledge on top of that.

359
00:18:22.805 --> 00:18:25.605
And then as far
as the drone goes,

360
00:18:25.605 --> 00:18:27.765
it's again slightly different.

361
00:18:27.765 --> 00:18:31.430
There's no concept of aircraft
airworthiness in Part one hundred seven.

362
00:18:31.430 --> 00:18:34.630
What the regulations say is
that the pilot is responsible

363
00:18:34.630 --> 00:18:37.910
for ensuring the aircraft is
in a safe condition for operation.

364
00:18:37.910 --> 00:18:40.950
That's kind of the term that's
used in Part one hundred seven.

365
00:18:40.950 --> 00:18:44.425
So before every flight,
the pilot should be

366
00:18:44.425 --> 00:18:45.945
doing their
preflight activities,

367
00:18:45.945 --> 00:18:50.145
making sure the drone is
being maintained, and so on.

368
00:18:50.505 --> 00:18:54.345
So on paper, these two things
kind of look different, right?

369
00:18:54.345 --> 00:18:56.905
There's a self certification
model and then there's kind of

370
00:18:56.905 --> 00:19:03.370
this Remote Pilot Plus and remote
pilot responsibility for airworthiness.

371
00:19:03.490 --> 00:19:07.090
I would kind of encourage
agencies to think about this a

372
00:19:07.090 --> 00:19:07.810
little bit differently.

373
00:19:07.810 --> 00:19:10.050
I would encourage them to
think about these two things actually

374
00:19:10.050 --> 00:19:12.450
the same in a sense.

375
00:19:12.450 --> 00:19:16.895
So if you kind of step
back and just remove the

376
00:19:16.895 --> 00:19:18.655
the words on screen
for a second,

377
00:19:18.655 --> 00:19:21.695
I think we could all agree that
the goal is just to ensure that

378
00:19:21.695 --> 00:19:25.375
pilots, when they're flying
drones, are are safe.

379
00:19:25.375 --> 00:19:27.055
They're following the
waiver provisions.

380
00:19:27.055 --> 00:19:28.695
They're getting
the mission done,

381
00:19:28.990 --> 00:19:32.750
and we wanna be training those
pilots to to do those things.

382
00:19:32.750 --> 00:19:35.710
So if we can all agree that
just we wanna make sure pilots

383
00:19:35.710 --> 00:19:38.030
are trained and
proficient and safe,

384
00:19:38.030 --> 00:19:40.070
that's the most important thing.

385
00:19:40.190 --> 00:19:43.085
And so then if you add
back in these terms,

386
00:19:43.085 --> 00:19:45.485
it kind of starts to
matter a little bit less.

387
00:19:45.485 --> 00:19:46.045
Right?

388
00:19:46.045 --> 00:19:48.605
Just because a pilot gets
a remote pilot certificate

389
00:19:48.605 --> 00:19:52.685
doesn't mean they're proficient
and safe and ready to do the

390
00:19:52.685 --> 00:19:54.885
ambush line sight
ops under a waiver.

391
00:19:56.170 --> 00:19:57.290
And similarly,

392
00:19:57.290 --> 00:20:00.250
just because you can do self
certification doesn't mean like

393
00:20:00.250 --> 00:20:02.650
just give the drone to
somebody and let them go.

394
00:20:02.650 --> 00:20:04.890
You still need to make sure
they're trained and safe and

395
00:20:04.890 --> 00:20:05.770
following the waiver.

396
00:20:05.770 --> 00:20:09.530
So I would kind of stress that
just the most important thing

397
00:20:09.530 --> 00:20:11.125
is in your agency,

398
00:20:11.125 --> 00:20:13.765
think think about what
your training program is.

399
00:20:13.765 --> 00:20:16.325
Think about is it covering
all the the proficiency,

400
00:20:16.325 --> 00:20:20.365
the knowledge, the skills, and
just document that training.

401
00:20:20.645 --> 00:20:23.525
And that is gonna kinda
satisfy these two things. Yes.

402
00:20:23.525 --> 00:20:26.890
You gotta go get the Remo PODS
certificate under Part one hundred seven.

403
00:20:26.890 --> 00:20:29.250
Again, that's kind
of a nonnegotiable,

404
00:20:29.930 --> 00:20:33.210
you've to make sure you're
doing training on top of that.

405
00:20:33.210 --> 00:20:35.290
And then similarly
with the drones, right?

406
00:20:35.290 --> 00:20:38.785
So again, the goal is just
to have kind of ready to

407
00:20:38.785 --> 00:20:42.145
go healthy drones that are
being maintained and checked.

408
00:20:42.145 --> 00:20:44.865
So follow the OEM
recommendations,

409
00:20:44.865 --> 00:20:49.025
do your preflight checks, do your
postflight checks, and so on.

410
00:20:49.025 --> 00:20:51.585
And we have a lot of great
written documentation on, like,

411
00:20:51.585 --> 00:20:55.440
what our maintenance intervals
are, how to do the maintenance,

412
00:20:55.560 --> 00:20:58.040
how to do the check play after
the maintenance, and so on.

413
00:20:58.040 --> 00:21:01.240
So there's a lot of
resources out there if you're operating

414
00:21:01.240 --> 00:21:05.080
X10s for you to to
have a good kind of

415
00:21:05.080 --> 00:21:08.375
airworthiness slash
maintenance program.

416
00:21:08.495 --> 00:21:10.655
And I brought the waiver
provision back up.

417
00:21:10.655 --> 00:21:11.855
I know it's small print,

418
00:21:11.855 --> 00:21:16.015
this is just a call out back
to that responsible person one.

419
00:21:16.015 --> 00:21:18.375
Actually let me see if
I can find it quick.

420
00:21:18.490 --> 00:21:20.410
This provision right here.

421
00:21:20.410 --> 00:21:22.730
So it kind of goes
back to this, right?

422
00:21:22.730 --> 00:21:26.010
For both waivers, the
responsible person and the

423
00:21:26.010 --> 00:21:28.490
operator are responsible for
making sure the operator is

424
00:21:28.490 --> 00:21:31.050
trained, they're
informed of the waiver,

425
00:21:31.050 --> 00:21:33.015
they're informed of the
regulations and so on.

426
00:21:33.015 --> 00:21:36.615
So it kind of ends up again
just like being similar in the

427
00:21:36.615 --> 00:21:38.495
end instead of different.

428
00:21:42.295 --> 00:21:43.095
Okay.

429
00:21:43.095 --> 00:21:47.015
And now this is in
that same vein, right?

430
00:21:47.015 --> 00:21:52.090
This is kind of another thing
I hear where there's maybe a

431
00:21:53.090 --> 00:21:57.650
kind of perspective that
under Part one hundred seven,

432
00:21:57.650 --> 00:22:00.050
it's like kind of all on the
pilot and they're responsible

433
00:22:00.050 --> 00:22:02.930
for everything and, like, the
agency's kind of shielded,

434
00:22:02.930 --> 00:22:05.445
in a sense, from
liability and then, like,

435
00:22:05.445 --> 00:22:06.725
vice versa on Part ninety one,

436
00:22:06.725 --> 00:22:08.845
it's kind of all
on the operator.

437
00:22:09.605 --> 00:22:14.325
So, again, I kind of encourage
shifting the thinking

438
00:22:14.325 --> 00:22:15.445
around this a little bit.

439
00:22:15.445 --> 00:22:18.610
So, yes, in the waiver,

440
00:22:18.610 --> 00:22:20.130
there's different
terms being used.

441
00:22:20.130 --> 00:22:21.330
So under Part ninety one,

442
00:22:21.330 --> 00:22:24.530
it's the operator's
responsible for x, y, z,

443
00:22:24.530 --> 00:22:26.690
or the operator must do this.

444
00:22:26.690 --> 00:22:28.690
And then similarly on
Part one hundred seven,

445
00:22:28.690 --> 00:22:33.265
it's the responsible person's
responsible, must do this, and so on.

446
00:22:34.905 --> 00:22:36.825
But, yeah, I've, again,

447
00:22:36.825 --> 00:22:38.665
just kind of similar
to the previous slide,

448
00:22:38.665 --> 00:22:41.625
I would kind of encourage
you to think about there's really

449
00:22:41.625 --> 00:22:44.460
like a shared responsibility
model going on here.

450
00:22:44.460 --> 00:22:46.940
It's not just the
pilot's responsibility,

451
00:22:46.940 --> 00:22:49.340
or it's not just the
responsible person,

452
00:22:49.340 --> 00:22:52.060
or just the operator, and so on.

453
00:22:52.060 --> 00:22:54.620
So if we go, can I get
the next slide up here?

454
00:22:54.620 --> 00:22:55.700
So

455
00:22:56.300 --> 00:22:58.420
I don't think it's
a perfect graphic,

456
00:22:58.785 --> 00:23:01.425
but it's kind of what I came
up with to just try and kind of

457
00:23:01.425 --> 00:23:03.025
get this point across right.

458
00:23:03.025 --> 00:23:04.105
So

459
00:23:05.105 --> 00:23:09.345
there's kind of the goal again just
in the big picture is safe operations.

460
00:23:09.345 --> 00:23:11.745
We want to be safe, we want
to be following the waiver,

461
00:23:11.745 --> 00:23:13.425
getting the mission done.

462
00:23:13.425 --> 00:23:16.970
And so there's these two
parties have to both kind of do

463
00:23:16.970 --> 00:23:19.130
their part, and they're
responsible for different things.

464
00:23:19.130 --> 00:23:22.090
So the operatorresponsible
person,

465
00:23:22.090 --> 00:23:24.250
because really the responsible
person is just like the

466
00:23:24.250 --> 00:23:28.345
designee, the point person
on behalf of the operator.

467
00:23:28.345 --> 00:23:30.585
They're responsible for
training the pilots,

468
00:23:30.585 --> 00:23:31.945
making sure they
understand the waiver,

469
00:23:31.945 --> 00:23:34.305
they're familiar with regs, etc.

470
00:23:34.345 --> 00:23:38.585
They're going to likely be
the one to respond to FAA

471
00:23:38.585 --> 00:23:40.585
inquiries or like
surveillance activities.

472
00:23:40.585 --> 00:23:44.080
If there's a ramp check,
this person might lead that.

473
00:23:44.080 --> 00:23:47.120
They're responsible for
reporting and so on.

474
00:23:47.120 --> 00:23:50.880
So they're kind of responsible
for things like before and

475
00:23:50.880 --> 00:23:54.360
after the flight, if that
maybe helps frame it too.

476
00:23:54.415 --> 00:23:57.135
And then the remote pilot on
the other hand is responsible

477
00:23:57.135 --> 00:24:00.495
for like takeoff to landing
and then the activities kind of

478
00:24:00.495 --> 00:24:03.135
directly before and after that.

479
00:24:03.135 --> 00:24:05.695
So they're going to
launch the drone,

480
00:24:05.695 --> 00:24:08.320
they've got to make sure they
got the return behavior set,

481
00:24:08.320 --> 00:24:11.120
the anti collision lights on,
they're at two hundred feet,

482
00:24:11.120 --> 00:24:12.880
they're giving away
crewed aircraft, etc.

483
00:24:12.880 --> 00:24:16.400
So their responsibilities
are kind of primarily just

484
00:24:16.400 --> 00:24:18.440
directly before

485
00:24:19.040 --> 00:24:20.600
takeoff to landing.

486
00:24:21.165 --> 00:24:23.645
There's likely some overlap
in the middle, right,

487
00:24:23.645 --> 00:24:25.725
so they're both going to
probably help with some

488
00:24:25.725 --> 00:24:27.645
airworthiness activities.

489
00:24:27.645 --> 00:24:30.765
You know, the operator is going buy
the props and maybe the remote pod

490
00:24:30.765 --> 00:24:35.320
goes and puts them on
when the intervals hit.

491
00:24:35.320 --> 00:24:36.680
Or the record keeping, right?

492
00:24:36.680 --> 00:24:39.000
So the remote pod is going to fill
out some records after flight,

493
00:24:39.000 --> 00:24:42.760
but then their operator is
going to report those as needed.

494
00:24:42.760 --> 00:24:43.760
So

495
00:24:44.280 --> 00:24:47.560
yeah, hopefully that kind of gets
my point across here that there's

496
00:24:47.560 --> 00:24:49.840
really like shared
responsibility.

497
00:24:49.935 --> 00:24:51.615
It's not just one or the other.

498
00:24:51.615 --> 00:24:55.375
It's not just the pilot's job or
just the RP's job or operator.

499
00:24:55.375 --> 00:24:59.055
And so both parties have to do
their part to make sure we're

500
00:24:59.055 --> 00:25:00.895
doing safe compliant operations.

501
00:25:00.895 --> 00:25:04.430
And these two ultimately kind
of become the same again at the

502
00:25:04.430 --> 00:25:05.910
end of the day.

503
00:25:09.070 --> 00:25:11.670
Alright. Okay.

504
00:25:11.710 --> 00:25:14.670
And then one more at the
end just kind of for fun.

505
00:25:14.670 --> 00:25:16.590
I alluded to this before, right?

506
00:25:16.590 --> 00:25:19.225
So Part ninety one
has more provisions,

507
00:25:19.225 --> 00:25:20.985
thirty eight provisions.

508
00:25:20.985 --> 00:25:24.065
Part one hundred seven has
twenty nine provisions.

509
00:25:24.105 --> 00:25:27.545
This is not a meaningful
difference or something you

510
00:25:27.545 --> 00:25:31.545
should be thinking about when you're
choosing or deciding how to operate.

511
00:25:31.545 --> 00:25:34.370
So why does Part ninety
one have more regulations?

512
00:25:34.370 --> 00:25:37.250
It's just simply because Part
ninety one was not written for

513
00:25:37.250 --> 00:25:40.450
drone operations in mind and
the FAA has to do a little bit

514
00:25:40.450 --> 00:25:44.610
more waiving to kind of make it
match with Part one hundred seven.

515
00:25:44.610 --> 00:25:46.945
So there's two examples but

516
00:25:46.945 --> 00:25:48.305
there's many more.

517
00:25:48.305 --> 00:25:49.905
For example Class B airspace.

518
00:25:49.905 --> 00:25:53.745
So under if you're
flying in like an

519
00:25:53.745 --> 00:25:57.345
airplane, the pilot actually
has to call ATC before they

520
00:25:57.345 --> 00:25:59.640
enter Bravo airspace
and get clearance.

521
00:25:59.640 --> 00:26:01.240
Has to be an explicit thing.

522
00:26:01.240 --> 00:26:05.800
You're cleared to enter this airspace
and that's every single time.

523
00:26:05.800 --> 00:26:10.040
So that obviously like doesn't make
a lot of sense for drones

524
00:26:10.040 --> 00:26:12.920
and so the FAA basically just
waives that requirement for

525
00:26:12.920 --> 00:26:15.925
drones and instead you
just stay at, you know,

526
00:26:15.925 --> 00:26:18.165
four hundred foot or two
hundred foot or below the grid

527
00:26:18.165 --> 00:26:19.365
numbers, whatever those are,

528
00:26:19.365 --> 00:26:23.605
and that's sufficient to keep
keep everybody safe and separated.

529
00:26:23.605 --> 00:26:26.085
Four hundred foot
is another example.

530
00:26:26.085 --> 00:26:29.420
So part one zero seven has four
hundred foot operations built in.

531
00:26:29.420 --> 00:26:31.420
That's like what the
rule is written for.

532
00:26:31.420 --> 00:26:33.740
They don't need to waive
it, but part ninety one,

533
00:26:33.740 --> 00:26:38.340
they have to create a provision to allow
you to do that under part ninety one.

534
00:26:40.605 --> 00:26:41.845
Okay.

535
00:26:43.565 --> 00:26:47.485
Yeah and please if you do have
questions we're monitoring the chat.

536
00:26:47.485 --> 00:26:50.525
Throw them in and
we'll try and get them

537
00:26:50.525 --> 00:26:52.005
answered for you.

538
00:26:52.685 --> 00:26:53.805
Other considerations.

539
00:26:53.805 --> 00:26:56.470
So now I'm going
kind of just move

540
00:26:56.470 --> 00:26:59.150
on to like the
additional things,

541
00:26:59.510 --> 00:27:03.070
those additional approvals,
airspace authorizations, etc.

542
00:27:03.590 --> 00:27:06.470
So firstly, airspace
authorizations.

543
00:27:06.470 --> 00:27:10.495
So again, the waivers that
you get, the standard waiver,

544
00:27:10.495 --> 00:27:13.855
it allows you to fly
below the facility map

545
00:27:13.855 --> 00:27:17.215
altitudes without any kind
of additional approval.

546
00:27:17.215 --> 00:27:21.095
The waiver is the authorization
to fly below the grids.

547
00:27:21.180 --> 00:27:23.420
If you wanna fly
above the grids,

548
00:27:23.420 --> 00:27:24.780
you have kinda two options.

549
00:27:24.780 --> 00:27:26.140
You can get an SGI,

550
00:27:26.140 --> 00:27:30.540
but SGIs are really for just
kind of emergency purposes and

551
00:27:30.540 --> 00:27:31.740
they're case by case.

552
00:27:31.740 --> 00:27:34.260
So it's not really
a good way to do

553
00:27:34.275 --> 00:27:35.475
routine operations.

554
00:27:35.475 --> 00:27:38.595
So if you want to routinely
fly above a grid number,

555
00:27:38.595 --> 00:27:40.835
you need an airspace
authorization.

556
00:27:40.835 --> 00:27:43.795
And so the process is a
little bit different between the two.

557
00:27:43.795 --> 00:27:45.555
For Part ninety one,

558
00:27:45.555 --> 00:27:48.155
you're going to submit
that request in CAHPS

559
00:27:48.310 --> 00:27:51.110
And kind of generally the
process then is you have to go

560
00:27:51.110 --> 00:27:53.110
get a public declaration letter,

561
00:27:53.110 --> 00:27:55.990
you submit that to the
FAA to get CAHPS access,

562
00:27:55.990 --> 00:27:59.950
so they create your account
for you and give you access.

563
00:27:59.990 --> 00:28:03.190
And then you have to
kind of put the application together

564
00:28:03.190 --> 00:28:05.465
and submit it in CAHPS.

565
00:28:05.745 --> 00:28:07.905
Part one hundred seven,
a little bit different.

566
00:28:07.905 --> 00:28:10.305
You submit those in DroneZone.

567
00:28:10.305 --> 00:28:13.105
And DroneZone is the same place
that you register your drones.

568
00:28:13.105 --> 00:28:15.345
You might already
have an account here.

569
00:28:15.345 --> 00:28:16.145
And so generally,

570
00:28:16.145 --> 00:28:17.985
you're just going to create an
account if you don't have one

571
00:28:17.985 --> 00:28:20.740
yet and then submit
your request there.

572
00:28:21.260 --> 00:28:25.420
I would say this is probably
the one downside of Part

573
00:28:25.420 --> 00:28:28.460
ninety one that's left
really is the CAHPS portal.

574
00:28:28.460 --> 00:28:31.820
So I know some of you on the
webinar have likely been in

575
00:28:31.820 --> 00:28:34.020
CAHPS. You know what
I'm talking about.

576
00:28:34.285 --> 00:28:35.885
It's not the nicest website.

577
00:28:35.885 --> 00:28:39.445
But we do have guides, and
we'll help you get through it.

578
00:28:39.485 --> 00:28:41.485
And it's similar for Part
one hundred seven as well.

579
00:28:41.485 --> 00:28:42.565
So

580
00:28:43.085 --> 00:28:45.965
the process is a little bit
more difficult than a Part

581
00:28:45.965 --> 00:28:50.660
ninety one, but agencies
definitely navigate through it.

582
00:28:50.660 --> 00:28:53.780
Both of them take about
sixty or up to sixty days,

583
00:28:53.780 --> 00:28:54.260
I should say.

584
00:28:54.260 --> 00:28:57.140
Some go much faster,
some go a little slower.

585
00:28:57.140 --> 00:28:59.220
And then the approval,
once you get it,

586
00:28:59.220 --> 00:29:01.180
they're effectively identical.

587
00:29:02.395 --> 00:29:05.915
So yeah, there's no real
differences once you get through the

588
00:29:05.915 --> 00:29:09.955
process, just a little bit
of difference along the way.

589
00:29:13.355 --> 00:29:15.115
All right, and then multi drone.

590
00:29:15.115 --> 00:29:17.410
So as I mentioned to
start the webinar,

591
00:29:17.410 --> 00:29:22.170
multi drone waivers are definitely
now an option for agencies.

592
00:29:22.210 --> 00:29:23.890
And so for Part ninety one,

593
00:29:23.890 --> 00:29:25.970
if you want to request
a multi drone waiver,

594
00:29:25.970 --> 00:29:29.690
it's a similar streamlined process
to the single drone request.

595
00:29:29.885 --> 00:29:35.085
So the RPE is going to
complete a set of documents.

596
00:29:35.085 --> 00:29:37.885
That set of documents is
going to be a little bit more

597
00:29:37.885 --> 00:29:40.765
comprehensive than the two
hundred foot single drone

598
00:29:40.765 --> 00:29:43.565
waiver and like if you're
working with me we're going to

599
00:29:43.565 --> 00:29:46.470
provide you with a more
comprehensive concept of

600
00:29:46.470 --> 00:29:49.430
operation and some answers
to some questions and so on.

601
00:29:49.430 --> 00:29:52.790
So we put together kind of the
multidrome material for you and

602
00:29:52.790 --> 00:29:55.510
then you fill out the seven
thousand seven hundred eleven

603
00:29:55.510 --> 00:29:57.270
and checklist and submit it all.

604
00:29:57.270 --> 00:30:01.585
So those get emailed to the FAA
and then they do take a little

605
00:30:01.585 --> 00:30:05.145
bit longer, so just kind
of a heads up for agencies.

606
00:30:05.425 --> 00:30:09.425
Maybe waiting a month or two
months for a multi drone waiver

607
00:30:09.425 --> 00:30:12.945
and that's kind of standard
timelines at this point under

608
00:30:12.945 --> 00:30:14.105
Part ninety one.

609
00:30:14.760 --> 00:30:16.800
For Part one hundred seven,

610
00:30:17.480 --> 00:30:20.760
it's definitely possible to get
multidrug waivers under Part

611
00:30:20.760 --> 00:30:23.960
one hundred seven, but there's
no streamlined process yet.

612
00:30:23.960 --> 00:30:26.200
The FAA is kind of still
working through that.

613
00:30:26.200 --> 00:30:29.785
So really what it looks like
is just going through like the

614
00:30:29.785 --> 00:30:32.665
normal part one zero
seven waiver process.

615
00:30:32.665 --> 00:30:36.745
So you're gonna be expected
to put together a full concept

616
00:30:36.745 --> 00:30:41.960
of operation and answer all
the FAA's WSEG questions.

617
00:30:42.000 --> 00:30:43.200
Those questions, by the way,

618
00:30:43.200 --> 00:30:47.040
it's like the FAA's just
published the questions for the

619
00:30:47.040 --> 00:30:48.560
regulations one hundred seven,

620
00:30:48.560 --> 00:30:50.680
three thousand one
hundred thirty five,

621
00:30:50.720 --> 00:30:52.960
and if you do weather,
fifty one as well.

622
00:30:52.960 --> 00:30:55.505
But they have some questions
that they ask and you're

623
00:30:55.505 --> 00:30:59.105
expected to provide answers to
those questions as part of this

624
00:30:59.105 --> 00:31:01.065
application process.

625
00:31:01.345 --> 00:31:04.785
You would submit everything
through that FAA Aviation

626
00:31:04.785 --> 00:31:06.065
Safety Hub portal again.

627
00:31:06.065 --> 00:31:09.960
That's the same portal as
the single drone waiver.

628
00:31:09.960 --> 00:31:14.600
And then I would estimate maybe
two to three months is kind of

629
00:31:14.600 --> 00:31:17.440
the normal Part one hundred
seven processing time.

630
00:31:17.800 --> 00:31:21.240
So again, not terribly
different than Part ninety one,

631
00:31:21.240 --> 00:31:24.975
but I'd say Part ninety one is just
a bit more streamlined right now.

632
00:31:25.255 --> 00:31:28.415
But we can help you get
the waiver either way

633
00:31:29.095 --> 00:31:30.535
and get you final with Multi

634
00:31:30.535 --> 00:31:33.810
Drone.

635
00:31:33.810 --> 00:31:36.450
Alright and then four hundred
foot operations is actually

636
00:31:36.450 --> 00:31:37.970
very similar to multidrome.

637
00:31:37.970 --> 00:31:41.090
So if you have a
detect and avoid

638
00:31:41.090 --> 00:31:44.370
system that's capable of
detecting aircraft without ADS

639
00:31:44.370 --> 00:31:48.125
B that is a requirement but if
you have that system D Drone

640
00:31:48.125 --> 00:31:52.805
Beyond would be an example and
we work very closely with Axon

641
00:31:53.245 --> 00:31:56.565
to get that system
integrated with ours.

642
00:31:56.845 --> 00:31:59.325
You can request the four
hundred foot waiver then so you

643
00:31:59.325 --> 00:32:01.940
are not limited to any more to
two hundred foot when you're

644
00:32:01.940 --> 00:32:04.300
doing beyond visualized
site operations.

645
00:32:04.580 --> 00:32:07.220
So for part ninety one it's
a similar streamlined process

646
00:32:07.220 --> 00:32:10.700
again just there's a
set of documentation

647
00:32:11.140 --> 00:32:15.500
and you email that to the FAA
and you wait a month or two.

648
00:32:15.925 --> 00:32:18.485
Part one hundred seven,
just like multidrone,

649
00:32:18.485 --> 00:32:22.165
not quite as streamlined so
you'd end up submitting kind of

650
00:32:22.165 --> 00:32:24.805
a full application package
and then submitting it in the

651
00:32:24.805 --> 00:32:28.685
portal and waiting maybe
two to three months.

652
00:32:31.950 --> 00:32:33.430
All right.

653
00:32:34.430 --> 00:32:36.830
I'm just kind of looking at the
questions that come in and I

654
00:32:36.830 --> 00:32:41.550
missed one for two slides ago so let
me just kind of hit it live here.

655
00:32:41.550 --> 00:32:43.230
So kind of the question is,

656
00:32:43.230 --> 00:32:45.710
are these aerospace
authorizations different than

657
00:32:45.710 --> 00:32:49.565
Lance? And the answer is yes.

658
00:32:49.565 --> 00:32:51.565
So well, yes, sort of.

659
00:32:51.565 --> 00:32:54.125
So LAANC has kind of two things.

660
00:32:54.125 --> 00:32:57.805
There's like the immediate as
long as you're flying below

661
00:32:57.805 --> 00:33:00.210
the grid, you basically
get immediate approval.

662
00:33:00.210 --> 00:33:01.410
But Lance also has, like,

663
00:33:01.410 --> 00:33:03.290
a further coordination

664
00:33:04.290 --> 00:33:05.970
version where so
this would be, like,

665
00:33:05.970 --> 00:33:09.690
if you wanna fly in zero grids
or above the the grids as well,

666
00:33:10.130 --> 00:33:12.730
and you have to go into
DroneZone and submit it.

667
00:33:12.925 --> 00:33:15.645
That's that's the part one
zero seven version here.

668
00:33:15.645 --> 00:33:17.805
So for part one zero seven,

669
00:33:17.805 --> 00:33:21.565
aerospace authorizations are similar
whether you're public safety or not.

670
00:33:21.565 --> 00:33:23.325
If you wanna fly above
the grid, essentially,

671
00:33:23.325 --> 00:33:26.725
you have to submit one of these
manual aerospace authorizations.

672
00:33:26.930 --> 00:33:28.450
And then Part ninety one,

673
00:33:28.450 --> 00:33:31.650
LAANC doesn't apply to Part
ninety one, like, at all.

674
00:33:31.650 --> 00:33:36.330
There's no construct of
LAANC in Part ninety one, so

675
00:33:36.850 --> 00:33:40.725
that's why the waivers just include
the ability to fly below the grids.

676
00:33:40.725 --> 00:33:42.805
And then if you want to
fly above the grids you have to

677
00:33:42.805 --> 00:33:45.405
submit a CAPS request.

678
00:33:46.165 --> 00:33:49.365
So hopefully that answers that
question. It's a good one.

679
00:33:49.365 --> 00:33:52.805
It's actually kind of a common
question too so I'm glad this

680
00:33:52.805 --> 00:33:56.445
person asked like Lance
just does not apply

681
00:33:56.460 --> 00:33:59.780
really to be on visual line
of sight operations at all

682
00:33:59.820 --> 00:34:02.540
but it certainly doesn't apply
to Part ninety one either.

683
00:34:02.540 --> 00:34:06.540
It's really only a system for
visual line of sight Part one

684
00:34:06.540 --> 00:34:08.540
hundred seven operations.

685
00:34:08.540 --> 00:34:11.540
Everything else is going to
go in these two portals here.

686
00:34:14.105 --> 00:34:14.825
All right.

687
00:34:14.825 --> 00:34:16.225
And then

688
00:34:16.745 --> 00:34:19.945
there is another question
I think I'll hit it too.

689
00:34:19.945 --> 00:34:21.705
It's kind of relevant
to this topic.

690
00:34:21.705 --> 00:34:25.505
So can we request
multiple waivers on one application

691
00:34:25.590 --> 00:34:26.710
for Part ninety one,

692
00:34:26.710 --> 00:34:29.670
or does each waiver need
to be its own application?

693
00:34:29.670 --> 00:34:33.150
I would do just one.

694
00:34:33.510 --> 00:34:35.510
When you make an
application to the FAA,

695
00:34:35.510 --> 00:34:38.230
you're asking for kind
of one waiver in a sense.

696
00:34:38.230 --> 00:34:41.710
You could ask for whatever
you want in that waiver.

697
00:34:42.525 --> 00:34:45.565
You could ask to fly at one
thousand feet or four hundred

698
00:34:45.565 --> 00:34:47.245
feet or two hundred feet
or anything like that.

699
00:34:47.245 --> 00:34:51.005
But the streamlined waivers
that we're kind of talking

700
00:34:51.005 --> 00:34:54.965
about here that get approved
in a week or two or one month,

701
00:34:55.000 --> 00:34:58.600
Those are limited to like
the specific concepts here.

702
00:34:58.600 --> 00:35:02.760
Either you fly at two hundred feet
with ADS B or you fly at

703
00:35:02.760 --> 00:35:05.800
four hundred feet with
DA system and so on.

704
00:35:05.800 --> 00:35:10.785
So as long as you're asking for what
these kind of standard waivers allow,

705
00:35:10.785 --> 00:35:12.785
then you'll get these
waivers and these timelines.

706
00:35:12.785 --> 00:35:14.785
If you're asking for
something outside of, like,

707
00:35:14.785 --> 00:35:18.385
the scope of what we're talking
here, then the FAA has to do,

708
00:35:18.385 --> 00:35:21.265
like, their full kind
of normal just review,

709
00:35:21.265 --> 00:35:22.985
lengthy review process.

710
00:35:24.010 --> 00:35:27.770
And the outcome of each
request is typically just like

711
00:35:27.770 --> 00:35:30.850
one waiver that allows you to do

712
00:35:31.130 --> 00:35:32.850
XYZ.

713
00:35:36.010 --> 00:35:38.850
And maybe as a follow-up to

714
00:35:39.365 --> 00:35:41.445
yeah, let me add kind of
one more thing to that.

715
00:35:41.445 --> 00:35:46.005
So, agencies, like, you can
ask for more than one waiver,

716
00:35:46.005 --> 00:35:49.925
and that happens pretty
commonly with the single drone

717
00:35:49.925 --> 00:35:51.885
to multi drone transition.

718
00:35:52.130 --> 00:35:55.890
So we always kind of recommend
agencies start by getting a

719
00:35:55.890 --> 00:36:00.770
single drone waiver, and that's going
to be kind of one signed approval.

720
00:36:00.770 --> 00:36:04.065
And then the multi drone
waiver, once you request it,

721
00:36:04.065 --> 00:36:07.585
it will be another it'll
be a new, like, separate approval.

722
00:36:07.585 --> 00:36:11.265
So you'd end up actually with
two waivers and then you have

723
00:36:11.265 --> 00:36:12.865
to decide before you fly, like,

724
00:36:12.865 --> 00:36:15.585
which waiver am I flying
under and comply with it.

725
00:36:15.585 --> 00:36:19.225
So maybe that was the other
angle for that question.

726
00:36:23.380 --> 00:36:25.180
Okay, so

727
00:36:25.780 --> 00:36:28.340
kind of moving on to and this
is still just in the other

728
00:36:28.340 --> 00:36:30.540
considerations category,

729
00:36:30.580 --> 00:36:33.460
I thought it would be worth
putting this in here to just

730
00:36:33.460 --> 00:36:36.885
kind of get agencies thinking
a little bit about this,

731
00:36:36.885 --> 00:36:39.925
is like what does the future
look like for both of these and

732
00:36:39.925 --> 00:36:44.525
should that impact which type
of waiver you get or not?

733
00:36:44.805 --> 00:36:46.645
So here's just kind of
some thoughts on it.

734
00:36:46.645 --> 00:36:49.685
Again, there's kind of no wrong
answer right now as long as you're

735
00:36:49.685 --> 00:36:51.020
eligible for them.

736
00:36:51.020 --> 00:36:53.980
But part one hundred eight
kind of is on the horizon.

737
00:36:53.980 --> 00:36:55.740
We've we've you know,

738
00:36:55.740 --> 00:36:58.140
if you're you're curious about
learning more about that,

739
00:36:58.140 --> 00:36:59.340
reach out to us.

740
00:36:59.340 --> 00:37:02.860
There's plenty of material out
there as well kinda dissecting

741
00:37:02.860 --> 00:37:05.775
the NPRM and read
the NPRM itself,

742
00:37:05.775 --> 00:37:06.815
definitely encourage that.

743
00:37:06.815 --> 00:37:10.415
But the NPRM does have a
little bit of insight, right,

744
00:37:10.415 --> 00:37:14.095
into what's going to happen
potentially with these two waivers.

745
00:37:14.095 --> 00:37:15.935
The rule was just proposed,

746
00:37:15.935 --> 00:37:18.095
it's not final yet
so this could change,

747
00:37:18.095 --> 00:37:20.640
but for Part ninety one,

748
00:37:20.640 --> 00:37:25.840
the NPRM more or less proposed
to leave Part ninety one alone.

749
00:37:25.840 --> 00:37:28.400
Like we're going to let Part
ninety one operations continue

750
00:37:28.400 --> 00:37:29.360
as they always have.

751
00:37:29.360 --> 00:37:31.880
That's a quote out of the NPRM.

752
00:37:32.775 --> 00:37:34.615
And then for Part
one hundred seven,

753
00:37:34.615 --> 00:37:35.655
it's kind of the opposite.

754
00:37:35.655 --> 00:37:39.415
The FAA is proposing to
amend one hundred seven to

755
00:37:39.415 --> 00:37:43.855
remove the ability to get Part
one hundred seven BV loss waivers.

756
00:37:44.455 --> 00:37:48.575
Now we expect some kind of
transition period so that

757
00:37:48.640 --> 00:37:51.440
operators have time to go from
Part one hundred seven to Part

758
00:37:51.440 --> 00:37:52.760
one hundred eight,

759
00:37:53.120 --> 00:37:56.000
but I think the most likely
thing is Part one hundred seven

760
00:37:56.000 --> 00:37:59.640
BVLS waivers are gonna go away
eventually. They'll sunset.

761
00:38:01.215 --> 00:38:05.055
So Part ninety one might have
a little bit more, you know,

762
00:38:05.055 --> 00:38:09.295
of a future proofness to
it, but there's still, you know,

763
00:38:09.295 --> 00:38:10.175
the jury's still out.

764
00:38:10.175 --> 00:38:11.935
We have to see what
the final rule says,

765
00:38:11.935 --> 00:38:13.655
and then we'll know for sure.

766
00:38:14.100 --> 00:38:17.980
So take that just
into consideration.

767
00:38:18.020 --> 00:38:22.180
The other thing is I know some
agencies out there are a little

768
00:38:22.180 --> 00:38:26.700
nervous about this self certification
idea under Part ninety one.

769
00:38:27.075 --> 00:38:28.355
And whether you're
nervous or not,

770
00:38:28.355 --> 00:38:31.515
if you're flying under Part
ninety one, you're doing it.

771
00:38:32.035 --> 00:38:34.995
But if you read the Part one
hundred eight kind of training

772
00:38:34.995 --> 00:38:37.755
and licensing requirements,

773
00:38:38.275 --> 00:38:40.640
I would say actually that Part
one hundred eight has more in

774
00:38:40.640 --> 00:38:43.920
common with Part ninety one
self certification than it does

775
00:38:43.920 --> 00:38:45.120
with Part one hundred seven.

776
00:38:45.120 --> 00:38:48.320
So under Part one hundred
eight, as proposed at least,

777
00:38:48.320 --> 00:38:51.765
there's no pilot certificates,
there's no tests, there's,

778
00:38:51.765 --> 00:38:55.125
nothing equivalent
to the remote pilot

779
00:38:55.125 --> 00:38:58.325
certificate under
one hundred seven.

780
00:38:58.325 --> 00:39:03.205
Instead, the FAA has a
section on training and they

781
00:39:03.205 --> 00:39:06.160
would expect your training
to cover certain topics,

782
00:39:06.160 --> 00:39:09.040
and the MPRN actually has a list
of those topics right in there.

783
00:39:09.040 --> 00:39:12.560
There's a knowledge chunk
and then a skills chunk.

784
00:39:12.560 --> 00:39:16.720
So you will be expected
to know certain things,

785
00:39:16.720 --> 00:39:19.760
but the idea is to kind of put
that on the operator to make

786
00:39:19.760 --> 00:39:23.085
sure they're training their
pilots and covering those things.

787
00:39:23.085 --> 00:39:27.085
So it's more of kind of a
corporate training model

788
00:39:27.085 --> 00:39:29.605
than an FAA training model.

789
00:39:29.645 --> 00:39:32.765
And so I would kind of argue
it has a little bit more in common

790
00:39:32.765 --> 00:39:35.045
with the self
certification model

791
00:39:35.670 --> 00:39:39.590
and less part one hundred seven
but again it's a proposed rule

792
00:39:39.590 --> 00:39:42.550
so we have to see what the
final rule says and we'll kind

793
00:39:42.550 --> 00:39:45.670
of go from there but I
guess I'm just kind of encouraging

794
00:39:45.670 --> 00:39:47.310
agencies

795
00:39:47.830 --> 00:39:52.885
to kind of think about
just I need to have safe,

796
00:39:52.885 --> 00:39:56.005
proficient operators and I got
to make sure I'm training them

797
00:39:56.005 --> 00:39:59.765
to do that and kind of not put
so much weight on that remote

798
00:39:59.765 --> 00:40:05.030
pod certificate as, like,
the thing that covers me.

799
00:40:07.950 --> 00:40:09.430
All right.

800
00:40:09.710 --> 00:40:12.590
So I'm going to kind of put
this table and I'm just going

801
00:40:12.590 --> 00:40:13.550
to leave it up for a second.

802
00:40:13.550 --> 00:40:14.910
I don't want to
rehash everything,

803
00:40:14.910 --> 00:40:18.935
but these webinars are recorded and
then they'll be available afterwards.

804
00:40:18.935 --> 00:40:21.135
You can go back and replay this.

805
00:40:21.415 --> 00:40:25.495
This is just kind of a table
summary of the similarities and

806
00:40:25.495 --> 00:40:28.975
differences between PART ninety one and
one hundred seven that we just covered.

807
00:40:29.350 --> 00:40:32.550
And so if you're looking at
this webinar later you can just

808
00:40:32.550 --> 00:40:36.750
kind of pause it and keep this
slide up to read through it.

809
00:40:36.950 --> 00:40:39.110
But you know again
overarching theme,

810
00:40:39.110 --> 00:40:40.950
more similarities
than differences.

811
00:40:40.950 --> 00:40:43.965
Yes there are a couple kind
of just technicalities and

812
00:40:43.965 --> 00:40:48.445
differences between the two,
but they're very similar and

813
00:40:48.445 --> 00:40:50.605
you really can't go
wrong at this point.

814
00:40:50.605 --> 00:40:53.565
But if you want
just a way to think

815
00:40:53.565 --> 00:40:56.525
about it and keep it simple,
go back to the entity thing.

816
00:40:56.525 --> 00:40:58.325
So if I'm a government entity,

817
00:40:58.900 --> 00:41:00.420
go part ninety one.

818
00:41:00.420 --> 00:41:02.500
If I'm not a government entity,

819
00:41:02.500 --> 00:41:04.700
I've got to fly a
one hundred seven.

820
00:41:08.420 --> 00:41:09.660
All right.

821
00:41:11.005 --> 00:41:15.045
And that's kind of
it for content wise.

822
00:41:16.845 --> 00:41:18.285
So, yeah, let's look.

823
00:41:18.285 --> 00:41:21.205
Let's see if there's any
other questions here.

824
00:41:23.890 --> 00:41:27.490
And yeah, definitely feel
free if you have questions,

825
00:41:27.490 --> 00:41:29.090
go ahead and throw
them in there.

826
00:41:29.090 --> 00:41:30.290
We've got at least one here.

827
00:41:30.290 --> 00:41:34.610
So the question is how does
the Partner Any one waiver apply to

828
00:41:34.610 --> 00:41:35.810
tribal governments?

829
00:41:35.810 --> 00:41:37.450
Is it the same

830
00:41:38.565 --> 00:41:39.685
or not?

831
00:41:39.685 --> 00:41:40.765
So

832
00:41:42.645 --> 00:41:45.525
I would, let's see,
I'm just gonna go

833
00:41:45.525 --> 00:41:46.645
back one slide.

834
00:41:46.645 --> 00:41:50.885
It's really no different
at the end of the day.

835
00:41:50.885 --> 00:41:52.790
So if you're a
tribal government,

836
00:41:52.790 --> 00:41:55.950
you should still qualify
for Part ninety one,

837
00:41:56.310 --> 00:41:58.590
kind of being a
government entity.

838
00:41:59.190 --> 00:42:02.670
And then if you're not,
if you're, you know,

839
00:42:04.070 --> 00:42:07.030
we've worked with like one
customer I could think of that

840
00:42:07.030 --> 00:42:11.645
was part of kind of some tribal

841
00:42:11.645 --> 00:42:13.805
businesses but not
government entity.

842
00:42:13.805 --> 00:42:16.605
So we ended up getting them a Part
one hundred seven waiver instead.

843
00:42:16.605 --> 00:42:20.765
So I think the simplest answer
is like this still applies just

844
00:42:20.765 --> 00:42:22.930
if you're part of tribal
government you should be able

845
00:42:22.930 --> 00:42:24.050
to do Part ninety one.

846
00:42:24.050 --> 00:42:26.490
If not, do Part
one hundred seven.

847
00:42:27.170 --> 00:42:30.130
It is on you to make that
determination to be clear.

848
00:42:30.130 --> 00:42:31.130
So

849
00:42:31.730 --> 00:42:34.530
there's some FAA
guidance out there.

850
00:42:34.530 --> 00:42:37.250
There's an advisory circular
that kind of talks about public

851
00:42:37.250 --> 00:42:39.625
aircraft and references U.

852
00:42:39.625 --> 00:42:43.865
S. Code for who and who doesn't
meet those qualifications.

853
00:42:43.865 --> 00:42:46.625
I would definitely
encourage just reading those

854
00:42:46.905 --> 00:42:50.065
and then making that
determination and moving forward.

855
00:42:50.600 --> 00:42:53.800
But yeah, just because you're tribal
doesn't necessarily exclude you

856
00:42:53.800 --> 00:42:57.520
from either one of
these out the gate.

857
00:43:02.360 --> 00:43:03.520
All right.

858
00:43:06.415 --> 00:43:09.175
I think that's it for questions.

859
00:43:09.295 --> 00:43:11.695
We're going to end a little
bit early potentially today and

860
00:43:11.695 --> 00:43:13.815
give some people some time back.

861
00:43:14.495 --> 00:43:18.015
I'll throw kind of one thing
out as we close and just got a

862
00:43:18.015 --> 00:43:19.415
couple extra minutes.

863
00:43:20.090 --> 00:43:23.530
If you're an agency out there
and like you just kind of

864
00:43:23.530 --> 00:43:27.210
listen to my webinar and you're
going I'm not sure if I have

865
00:43:27.210 --> 00:43:29.930
like you know I'm the
responsible person I don't know

866
00:43:29.930 --> 00:43:31.570
if I have everything in place.

867
00:43:32.225 --> 00:43:36.305
So we we actually have
now kind of a kind of like

868
00:43:36.305 --> 00:43:38.065
a checklist that
we can give you.

869
00:43:38.065 --> 00:43:40.785
Just reach out. We can
give you this checklist.

870
00:43:40.785 --> 00:43:43.265
And it goes through kind
of the requirements,

871
00:43:43.265 --> 00:43:45.265
and really it's a lot of
things we just talked about,

872
00:43:45.265 --> 00:43:47.225
but it's kind of in
a checklist form.

873
00:43:47.320 --> 00:43:51.640
So yeah, and we put this
together to just help agencies

874
00:43:51.640 --> 00:43:55.560
self assess, like do
I have everything in

875
00:43:55.560 --> 00:43:58.920
place that I should
be per my waiver,

876
00:43:58.920 --> 00:44:01.160
per the FAA
requirements, and so on.

877
00:44:01.160 --> 00:44:04.035
So yeah it's just a
two page checklist.

878
00:44:04.035 --> 00:44:06.355
It really just covers all the
requirements in your waiver

879
00:44:06.355 --> 00:44:08.115
that you should
be doing already.

880
00:44:08.115 --> 00:44:12.795
But if you'd like it in a nice
kind of checklist format we can

881
00:44:12.915 --> 00:44:15.755
get that to you right away
if you just reach out.

882
00:44:19.530 --> 00:44:22.290
A final question rolling in,

883
00:44:22.730 --> 00:44:23.690
I think surgeons,

884
00:44:23.690 --> 00:44:26.690
so how far out from Part
one hundred eight are we?

885
00:44:27.530 --> 00:44:29.090
I don't know.

886
00:44:29.290 --> 00:44:30.810
It's hard to predict.

887
00:44:30.810 --> 00:44:33.605
It's moving through
its processes.

888
00:44:33.605 --> 00:44:36.485
We kinda keep getting updates
that it's going from this

889
00:44:36.485 --> 00:44:39.565
office to the next and just
working through the process.

890
00:44:40.565 --> 00:44:42.805
You know, maybe by
the end of the year,

891
00:44:42.805 --> 00:44:45.285
we'll have a a published rule,

892
00:44:45.285 --> 00:44:47.930
but do keep in mind just
when the when the rule gets

893
00:44:47.930 --> 00:44:51.050
published, there's likely to be
some kind of transition period,

894
00:44:51.050 --> 00:44:52.930
maybe a year,

895
00:44:53.610 --> 00:44:54.730
eighteen months.

896
00:44:54.730 --> 00:44:55.930
We'll see what it says.

897
00:44:55.930 --> 00:44:57.130
But but, yeah,

898
00:44:57.130 --> 00:45:00.255
the the rule will get
published hopefully this year,

899
00:45:00.255 --> 00:45:02.415
and then there'll be kind
of a transition period where

900
00:45:02.415 --> 00:45:06.095
everybody will be reading the rule
and getting their act together.

901
00:45:06.095 --> 00:45:07.135
That will be, you know,

902
00:45:07.135 --> 00:45:09.855
Skydio as well to make sure our
drones meet the requirements,

903
00:45:09.855 --> 00:45:12.735
and then we'll all kinda
transition into part one zero

904
00:45:12.735 --> 00:45:15.440
eight, or we'll
continue, you know,

905
00:45:15.440 --> 00:45:19.080
operating under part ninety one
as long as that's still an option.

906
00:45:19.120 --> 00:45:22.040
So good question.
Hard to predict.

907
00:45:22.320 --> 00:45:23.640
Hopefully soon.

908
00:45:27.195 --> 00:45:28.635
Okay, no more questions.

909
00:45:28.635 --> 00:45:31.595
Let's just call it early,
give everybody some time back.

910
00:45:31.595 --> 00:45:35.355
So thanks again though for
joining the webinar and don't

911
00:45:35.355 --> 00:45:38.155
forget the previous
webinars are all available.

912
00:45:38.155 --> 00:45:39.835
You can go back and
watch them at any time.

913
00:45:39.835 --> 00:45:42.526
They're gonna all be in the
same place in addition to this

914
00:45:42.526 --> 00:45:44.366
episode nine once we get it up.

915
00:45:44.366 --> 00:45:46.446
So thanks everybody
for the time,

916
00:45:46.446 --> 00:45:47.566
and we'll see you
on the next one.

917
00:45:47.566 --> 00:45:48.806
Stay safe.