FAA Part 91 BVLOS Waiver Overhaul - What It Means for Your Drone Program
FAA policy for public safety is shifting fast—and it just got a lot easier to start or scale your Drone as First Responder (DFR) program. The FAA has created a new waiver process for public safety operations - offering a streamlined path to obtaining a Part 91 BVLOS Certificate of Waiver (COW). The process cuts approval times in half, offers a path to fly above UAS Facility Map altitudes, and doesn’t even require a CAPS application! Join regulatory expert Jakee Stoltz as he breaks down exactly how the new process works and what it means for your agency.
Whether you’re launching a new program or expanding advanced operations, this session will give you the clarity and confidence to navigate the latest FAA process updates. Don’t miss it.
Also see the recordings of Episode 2: NYPD's Groundbreaking Waiver - Live Q&A and ADS-B Guidance where Jakee breaks down ADS-B technology and its role in safe drone operations.
And Episode 1: NYPD’s Groundbreaking Waiver - Leading the Next Era of DFR the explainer video that started it all by explaining Shielded Operations and the FAA decision to allow drones to navigate around structures and obstacles in urban environments.
- >> All right. Welcome, everybody.
- Welcome to another regulatory updates for public safety webinar,
- Jakey Stoltz from the SkyDio regulatory team.
- For the next 45 minutes or so,
- we are going to talk about a new process for
- part 91 beyond the giant site waivers.
- So it's going to be jam-packed 40 minutes or so of content,
- and then we'll try at least some time at the end for your questions.
- So before we get into the process and the steps and everything,
- I wanted to provide a little bit of context for how we got to this point.
- So what is a little bit of the history and some of the old process?
- It's a new process, but there used to be a process that preceded this.
- So I could probably look back well over five,
- six, seven years to some early work that was being done to enable this
- operation.
- But from a public safety perspective,
- there's a clear start point back in September of 2024,
- and that was New York City Police Department's revolutionary FAA approval to do
- DFR
- operations across their entire city.
- For the first time,
- this approval was based on just operating at lower altitudes and using ADSB
- technology,
- so it didn't require other types of detecting avoid technology.
- But with a single approval, the NYPD was able to do in scale their DFR program
- across 85% of their city in one shot.
- So it's a really big moment for them and for the industry as well.
- And then a couple months later, in December 2024,
- Las Vegas Metropolitan Police Department and Oklahoma City Police Department
- also received similar approvals.
- And this started to show that the concept that NYPD and
- an Austin FAA developed was scalable.
- So it wasn't just a one-off in New York City.
- This type of approval was possible in other parts of the country,
- in different types of airspace, different environments, and so on.
- So in Oklahoma City Police Department's approval was particularly noteworthy
- because it marked the transition from requiring a certain type of airspace.
- These moatsy veils, as you may have heard us previously talk about,
- to the term congested area.
- But essentially, this Oklahoma's approval kind of set the stage for
- this approval to be possible over any city or town or settlement to any congest
- ed area essentially.
- And so Oklahoma City's approval really became kind of a blueprint for
- the FAA moving forward.
- And so that blueprint became kind of three things from a safety case
- perspective.
- So you just had to operate at lower altitudes.
- We call this kind of shielded operations for DFR.
- But really what that means is just operating at a low of 200 feet AGL.
- And by operating at that altitude, the only additional airspace awareness
- technology required is ADSB-IN, which for
- Skydio and our DFR command platform, that's just built in technology.
- There's no extra hardware or software or anything like that required.
- And then the third piece is operating over congested areas.
- And so from that blueprint, in the last six or seven months or so,
- agencies across the country really have gotten these approvals.
- So I want to just give a shout out to all the agencies that have already
- gotten this type of approval.
- We're proud to have supported over 25 of those agencies kind of working
- through this process and getting this approval.
- And really what that means for
- agencies across the country now is you're either able to start a DFR program.
- So if you were maybe hesitant to start before because of this visual
- observer requirement, you either couldn't staff it, you couldn't pay for
- a contractor or so on, you can now kind of start a program without that
- requirement anymore, or there was agencies that had DFR programs, but
- were maybe limited in kind of the number of the scale of deployment.
- So they maybe had enough to staff one rooftop or a higher contractor to do that
- .
- But now they can scale these programs across the city.
- So these approvals are having a huge impact.
- We're really proud for those agencies that have obtained it so far and
- looking forward to the future as well.
- And so from this work now kind of helping
- where 25 agencies get these approvals, we've seen some trends that I just kind
- of want to share with everybody to showcase really like the amazing work
- being done by the FAA here.
- And at a macro level, like how fast the FAA has actually moved in enabling this
- .
- So going back to NYPD's approval in September,
- that approval actually took 14 months to get accomplished.
- So there's a lot of work that went into that from the FAA, from NYPD,
- with our support, and just took a lot of patience.
- But after 14 months of working and collaborating on that,
- we were able to get it done with them.
- The next two approvals, so Las Vegas and Oklahoma City,
- those took about nine months.
- So again, it started to show some scale, but still quite a long process
- and a period of time there from kind of the initial work to getting approval.
- But that happened in about three months.
- We started cutting that process time down.
- And then earlier this year, a number of agencies,
- you know, probably about half of those that we showed on the previous slide
- there,
- they were working through the FAA's, I'll call it the old process,
- but really just like the process that existed before this new one.
- The process actually kind of stabilized and it was becoming consistent,
- and actually just kind of in line with standard FAA review times.
- So about a dozen agencies got approvals in average, 78 days,
- which again is kind of just right in that kind of typical FAA review times
- for a beyond visualizing waiver.
- So things were actually working pretty well earlier this year.
- Agencies were getting approvals and things were moving along.
- But this new process really just kind of takes it to a whole new level
- and really it's like a speed that's unheard of from the FAA.
- So in the last couple of weeks, more agencies have been getting this approval
- and we're seeing that kind of processing time drop down to an average of 30
- days or so.
- And so it's just again, an amazing trend from 14 months down to 30 days
- in just a span of like 77 to eight months.
- So with that, I do want to recognize the FAA's work here.
- I think sometimes they're blamed for being slow and taking forever and blocking
- the industry.
- But at kind of a big picture here, like this progress is incredible.
- We went from the only way to do DFR was with a visual observer prior to
- September of 24
- to 30 day review times now for this type of operation
- that can be scaled across the country now.
- So in particularly, I'd want to kind of give recognition kudos
- to the FAA's U.S. policy team, NATO, so AGV, the Eastern Service Center,
- and the AFS Center, 30 Group and Flight Standards.
- There is a small team from kind of those branches
- that really helped get that first approval across the finish line
- and helped stand up that initial process.
- And then of course, big kudos to the new team and flight standards
- as kind of taken over and really streamlined this process
- and just made it much easier and much more streamlined and quick to get
- approval.
- So yeah, big kudos to the FAA on their work on this.
- All right, and so now we'll get into kind of more of the process itself.
- And before I do that, I'm going to just say a few more
- and how steeping things, some important context things for this.
- So firstly, it's just worth kind of stating
- that there are two types of kind of two regulations
- that public safety agencies can operate under.
- And that's assuming you qualify for the Part 91 operations here,
- but you're eligible to fly under Part 107 as a commercial operator.
- And that's kind of just like the default set of small UAS rules
- for essentially any operator in the US.
- But then public safety agencies have the ability as well to fly under Part 91
- as a public aircraft operator.
- And so this process and really the rest of the webinar is about Part 91
- and not about Part 107.
- So just kind of forget Part 107 for the next 30 minutes or so.
- This is all about Part 91.
- And then one more housekeeping item.
- So this process is evolving and it's changing.
- And even in the last three weeks since the FA kind of created this new process,
- there's just been small little incremental changes happening.
- So if you're watching the webinar today,
- you're receiving the most up-to-date information.
- But if you're watching this webinar after April 16th,
- so the day that presented it live, I'm going to refer you to a web page
- that we've put up and I'm going to share a link to that at the end.
- But we're going to maintain the web page as kind of the most up-to-date
- information
- as this process evolves.
- But if you're watching the webinar as a replay,
- I just know there may be some content in this webinar that becomes out of date.
- So just please go to the web page to get the most update information.
- All right. And so for this new process, the term I'd really use is that it's a
- new process,
- but it has the same impact.
- And so as a tech company, we do release notes for our software updates and so
- on.
- And so I just kind of wanted to use that same framing here.
- If you were familiar with the old process, you're sort of the release notes for
- this new process,
- just to kind of orient you.
- If you weren't familiar with the old process, then this may not mean a whole
- lot.
- But and this is not an exhaustive list, but I would say there's kind of like
- four
- big things worthy of note here.
- So number one, there's three new forms that are going to help applicants
- navigate the process.
- And we'll talk about those forms here in a minute.
- These approvals are now issued as certificates of waiver or cows instead of a
- coa.
- So it's just kind of a terminology change.
- I would say that the waiver kind of by and large is the same thing.
- It kind of allows the same stuff, but it's a different term.
- Caps is not required anymore.
- So caps was the online system that you'd actually have to go into to request
- these coas.
- So that was removed from this process, which is great.
- We all love caps.
- There's some sarcasm there.
- And then finally, there actually are some minor updates to the waiver itself.
- So to the approval that you get.
- So for example, a noting is not required anymore.
- The reporting requirements have been simplified.
- And there is an option now to obtain a coa to do routine operations above the
- facility and
- map altitudes.
- And it's worth noting that like coas haven't gone away.
- So coas still exist.
- They're still being issued.
- If you fly under part one of seven, you actually get a coa when you get an
- airspace
- authorization.
- So these things still exist.
- Def is just kind of transition this type of waiver into a cow instead of a coa.
- So a little bit different terminology, but kind of the same thing at the end of
- the day.
- And so that's the new stuff kind of release notes, but what has stayed the same
- here is that
- these approvals still ultimately enable DFR operations and other types of
- public safety apps.
- So they still enable agencies to do beyond design a site with output observers
- at scale, really over any city town or settlement now across the US.
- And the kind of default approval at 200 feet just requires ADSB and still.
- And you optionally have the ability to deploy it on cooperative detect and
- avoid technology,
- like a D drone beyond to get approval to fly at higher altitudes.
- So kind of by and large, the outcome of this process, the approval itself still
- really
- enables the same things that it did before.
- Okay, so this is the process.
- So now we're kind of getting into more of the details of what this new process
- is.
- I've chosen to kind of break it down into three steps.
- And so we're going to dive into these steps a little bit more, but the steps
- are kind of
- firstly, the reason I broke it down in these three ways is because the step
- number two here,
- which we'll talk about is actually you have to go get sort of an outside
- council to do that for
- you. So it's kind of broken down by like who can do which step or who's
- responsible.
- The drone program manager of your agency can do two out of these three steps,
- but then
- step two in the middle does require external support. So let's get into it here
- .
- Okay, so first you need to determine if you're eligible for this kind of waiver
- .
- So not everybody may qualify, but for public safety agencies, the eligibility
- requirements
- do cover a pretty large swath of operators. So kind of the two things you
- should think about is
- number one, are you eligible to do public aircraft operations? And this hasn't
- changed.
- So if you got a co-in the past, you had to be eligible for this and similarly
- moving forward
- to get this certificate of waiver yourself to be a public aircraft operator.
- And so we'll
- talk more about that in a second, but like essentially you have to be a part of
- a state
- government or federal government. So you have to be kind of a government
- operator
- to be eligible for this. Secondly, and this is the new thing. So I've tried to
- kind
- of note some of the new parts of this process specifically with that little new
- tag there,
- but the FA also wants to limit this waiver to public safety organizations for
- now.
- And so they've pulled a definition of a public safety organization, some US
- code.
- And I can just kind of read that definition here really quick, but PSO means a
- public safety
- organization that primarily engages in activities related to the safety and
- well-being of the general
- public. This can include law enforcement, fire departments, EMS, and other
- organizations. So
- it's a pretty broad definition, but you do need to meet that to be eligible for
- this type of waiver.
- Okay, so you determine your eligible, your public aircraft operator,
- you meet that definition of public safety organization. Now you need to go get
- called a public declaration letter, and hopefully this is getting a little
- spinning sign, but
- so you need to go get a public declaration letter. So for state government or
- political
- subdivisions of that government, you cannot self declare this. So that's a key
- thing. So you
- cannot self declare that your public aircraft operator. To do this, to get this
- letter, you need to go
- to an entity that is in a position to determine if you're eligible or not. So
- for like city,
- that's going to be a city attorney, county, a county attorney. If you're a
- state agency that
- probably means your state AG's office, but you're going to need to go to those
- offices and get them
- to create and sign one of these letters for you. And the FA has guidance on
- this,
- so I'm not going to get too deep into this, and I can't make a determination of
- whether
- your agency qualifies or not, but the FA does have some guidance on this. So
- there's an
- advisory circular 00-1.1b. The FA also has a one-pager now on what this public
- declaration
- letter needs to contain, some guidance on that. There's some examples out there
- that we can share
- as well. So yeah, use those FA resources to help you and your attorney make
- this termination.
- And for federal government, if there's anyone listening that is part of federal
- government,
- the public declaration letter is not required for you, but the FA may ask for
- some other
- evidence to kind of make a determination that you are the federal government.
- So just a note
- for that group. Okay, and so now you've determined eligibility. You've gotten
- your public declaration
- letter. Now you can actually start to put together the set of documents to
- actually make the request
- to the FA. So what I would recommend before you go filling out all these
- documents is I would
- recommend selecting your con app or selecting kind of which type of requests
- you're going to make.
- And so as mentioned before, there's still the two options that there were
- before. You can choose
- to request a sealed-out operations type of approval, which means you're going
- to fly at a
- below 200 feet. You're going to use ADSB in technology for occlusion avoidance.
- And in that
- case, you have to fly over congested area, but it could cover like your tire
- jurisdiction
- otherwise. And really that's kind of the FA's like default approval at this
- point. So if you're
- not sure which con app or if you haven't maybe investigator or done work with
- like a technology
- vendor on the detect and avoid technology side, like this is probably the path
- you're going to go
- down on the left side. But you have the option to deploy non-cooperative detect
- and avoid technology
- and request up to 400 feet agile. And so if you're working with a technology
- provider like D join
- honest or ready, then you can look at this 400 foot type of request. The con
- app you pick does kind
- of determine how you fill the documents out. And there's actually an additional
- document that you
- need to fill out for the 400 foot request. So I just recommend kind of going
- into the process
- knowing which type of request you're going to make before you start filling
- everything out.
- All right. And then you have to put together a set of documents to kind of
- actually make the
- request. So the first document we've already talked about, you need that public
- declaration
- letter, you'll ultimately send that to the FAA as part of your request. But
- there's four or
- potentially five other documents that you should think about. So the FAA forms
- 77-11-2.
- There's a public safety organization letter, which is separate than the public
- declaration
- letter. This is a new part. We'll talk about that in a second. There's a part-
- 91-dv-last waiver
- checklist now. This is new from the FAA. A concept of operation document, which
- really should have
- been done before, and we've always done for the agencies we work with. And then
- finally, if you
- are going to make a request over 200 feet, then you need to put together a what
- 's called a CMDEDA
- document or a criteria for making decisions. Use that acronym.
- So let's kind of talk through these forms just a little bit more here. So the
- first one,
- the 77-11, this is just an FAA form for applicants requesting a certificate of
- waiver authorization.
- So this is a required part of the process. You can go download this form
- directly from the FAA.
- And you'll fill it out. Not all of the form is applicable to drone operations.
- This form also
- is used for applicants of air shows and other types of aviation activities. It
- 's not necessarily
- like a drone-specific waiver form. But you'll fill out some contact information
- that you're asking for a part and you want to be on the site waiver. But there
- 's kind of three,
- I would say, critical parts of this form to fill out. So there's a box where
- you're going to
- reference the concept of operation. You could try to type all the concepts into
- that box,
- but we recommend just doing a separate document. We'll talk about that in a
- minute.
- Then you'll also know where you're going to fly, essentially, so kind of the
- area of operation
- that you're asking for. And then finally, the drones that you're asking for. So
- whichever kind
- of fleet, one drone or fleet of drones, the drones that you intend to fly on
- this later, you'll list those.
- Okay. So now to the PSO letter or the public safety organization letter, that's
- kind of that
- second eligibility item. So kind of similarly to the public declaration letter,
- you're going to
- create a letter that states that you do meet that definition. But unlike the
- public declaration
- letter, this is a letter that you, the, you know, the drone program manager or
- the agency can sign
- itself. You don't need to go get outside council or an attorney to do this for
- you. So this letter,
- kind of in a nutshell, will just like state your agency's name. It will state
- that you meet this
- definition, a public safety organization. You're going to say that you're
- asking for this
- down by site waiver. Some examples of the types of ops you're going to do. And
- then there's
- ultimately a signature block at the end of that. I see I'll put that together
- and sign it and
- submit it with the package. Next, there is a waiver checklist. So this is also
- a new document.
- The FAA developed this to help applicants kind of submit all the necessary
- information and get some
- getting an understanding of kind of what they're signing up to do or what they
- 're going to be
- required to do under the waiver. So the checklist goes through about 18
- different provisions
- that the responsible person or the applicant should kind of go through and read
- and then
- initial. And by initially, you're basically saying, yes, I will do this as part
- of the waiver. And the
- waiver ultimately restates a lot of these provisions as well. But yeah, it's
- just kind of a checklist
- that helps applicants sort of understand like what they're signing up to do. So
- you'll go through,
- you'll initial the columns that apply, and then you'll sign at the bottom and
- submit that to the
- FAA as well. Okay, and then one of the provisions from that checklist actually,
- the third one in
- the list, it basically states that you're going to provide a complete
- description of the operation.
- This kind of verbatim what it says. So there's no kind of specific FAA required
- way to do this,
- but what we recommend is creating what's called a concept of operation document
- .
- And you can see on the table of contents on the right here, kind of what this
- concept of operation
- covers. And so when you go to the website that I'll show later, we're actually
- going to provide
- kind of a template/example of a concept of operation document that you can
- download and start to fill
- out. But I think this is a really kind of key part of the process. And so don't
- overlook this.
- I think this concept of operation document is kind of your chance as like the
- responsible person
- for the strong program to kind of like go through the list of things and like
- structure your program
- and kind of get up to speed and everything. So it's almost like a good just
- internal exercise to do
- to kind of get familiar with all the different parts and things that your
- program should have.
- So for example, you want to think about the flight area, the airspace that you
- 're going to be
- operating in. Are there control air spaces? Are there small airports, heliports
- ? You know,
- it's just kind of like an exercise of getting familiar with all that. Get
- familiar with the
- type of drones that you're going to operate. You know, do they have parachute
- recovery systems or
- not? Are you using a docking station or not? Does it have remote ID? You know,
- actually check the
- FAA's webpage for that. Get the tracking numbers and so on. How are you going
- to train your crew?
- So, you know, what are the qualifications? Are you going to require everybody
- to get a remote pass
- certificate? Are you going to choose some kind of self-certification strategy?
- What is your training
- in either of those scenarios? And so on. So this document is really useful to
- just kind of like
- help you work through all those things, like think about them, think through
- them,
- write some things down, document it, and then ultimately this gets submitted to
- the FAA so that
- they kind of understand what you're doing. But yeah, I would say don't overlook
- this document.
- I think it's a really good exercise, both because you want to submit something
- to the FAA, but just
- also internally to kind of help you structure this program that you're about to
- implement.
- And again, we're going to provide a kind of outline of what this kind of can
- look like
- after when we get to the webpage. So you don't necessarily have to start from
- scratch and kind
- of use our example to help guide you on this. Okay. And then the final document
- is this CMD/DDA
- document. So if you're going to do, if you're going to request operations up to
- 400 feet AGL,
- then you must deploy some kind of non-cooperative detect and avoid technology.
- It could be radars,
- there's camera systems, and so on. You know, Didrome Beyond would be an example
- , but there's others.
- And so when you're deploying that technology, the FAA is going to evaluate it
- to make sure
- that it's an effective mitigation for aircraft collision avoidance. And so this
- document,
- the CMD/DDA document is a form that the FAA put together to help you kind of
- provide all the
- necessary information and then to help them review it in an effective way and
- hopefully
- kind of streamline their review process of them as well. So what I would
- recommend is that,
- you know, don't try to fill this document out yourself as the public safety
- agency. I would
- actually put this document on the technology vendors, kind of shoulders, to at
- least fill out the bulk
- of it, because this document is about like the DA system itself, like how does
- that function,
- what are the FCC IDs, and so on. So this really should be a document that's
- probably filled out
- by your technology vendor primarily, and then maybe with your support on kind
- of specific
- things about your agency and your locations and where you're going to deploy
- this and so on.
- So yeah, definitely make this kind of a team effort with your technology
- provider and don't try to
- do it all yourself. And again, just worth noting that this document is not
- required
- if you're just going to do the shielded operations below 200 feet.
- All right, so that's the set of documents that you should put together for this
- new process.
- So again, just to like quickly recap, you got your public declaration letter,
- your form 7711 dash to the TSO letter, the checklist, and a concept of
- operation.
- And then if you're if you're going to fly over 200 feet, you got that that DA
- document as well.
- So you take these five or six documents and you send them to the FAA at this
- email address on
- the screen here. So you can write this down, but this is also going to be in
- our web page guide
- as well. And you just indicate that you're asking for one of these public
- aircraft operation
- public safety organization, part 91 of the Amazon estate waivers. You attach
- all these documents
- and then you send that. And by sending the email that actually starts the FAA's
- review process,
- they may email you back saying, you know, received and we're working on it, but
- that,
- yeah, by just by emailing, then that starts the process.
- And then kind of one of two things happens that the FAA may ask for more
- information or
- corrections if you made any kind of error in some of the documents or. But if
- everything is good
- and when they've done the review and they approve it, the approval actually
- just comes back to you
- via email. So it's just like a direct email process now submit application and
- the FAA emails
- a waiver back. So no more caps, no more other steps. It's just really simple
- and straightforward.
- Okay, so let's get to the next page here. So we put together a web page that
- covers the process
- that I just outlined. So those three steps, all the documents, and there's
- additional details
- well that I didn't really get into today. So what I'm showing here is just like
- a PDF version of
- the web page. But if you head to the web page, you'll you'll basically see a
- detailed guide on this.
- In that web page, there's a spot as well to send an email to the regulatory
- team to get a set of
- forms and templates and like examples. And you can also get this PDF version if
- you'd rather have that.
- But yeah, this guide really, the goal was to make it detailed enough that if
- you're interested in
- getting this waiver, you could start this process today. And there should be
- enough detail for you
- to just work through it. Hopefully by yourself is actually the goal. So yeah,
- if you if you're
- interested in getting this waiver, if you're interested in doing DFR, I would
- recommend, you know, get
- off this webinar. And if you're motivated to get started right away, go
- determine your eligibility,
- go get that public declaration letter, and then get your documents put together
- to make the request
- to the FAA. All right. Okay. And then, you know, what does the call allow? So I
- can certainly answer
- questions about like the actual approval itself, like what are the provisions
- and so on. But I
- actually wanted to kind of save that for a follow up webinar where, you know,
- we can do kind of a
- talk down of the provisions themselves and what they mean and so on. So I'm not
- necessarily going
- to cover the approval document itself today, but again, can certainly answer
- some questions
- on it if there are any. And so with that, I've got about 10 minutes roughly to
- answer some questions.
- So just give me a sec to kind of look at the list of questions here.
- So yeah, we'll just kind of start to go down the list here. I see lots of
- questions, which is
- awesome. So beyond Virginia site for public sector and private sector. So like
- the question kind of
- at the core is, have you had any success enabling beyond the line site in the
- private sector? So
- like that part 107 category, really, if you're not a public aircraft operator.
- And the answer is yes,
- we've had a lot of success helping customers and entities get part 107 waivers.
- It's like a waiver
- to 107.31. There's some others, but examples include like for utilities, we've
- had a lot of
- success getting approvals to do remote operations, either up to 100 feet or
- over critical infrastructure
- up to 200 feet. So actually pretty similar to the part, any one approvals that
- we discovered,
- where we're seeing success with like construction or security use cases getting
- these approvals as
- well. I would say like at this point, if you want to do remote operations,
- there's going to be a
- path for you regardless of it's part 107 or part 91 or kind of what vertical
- you're in. So yeah,
- I would leave leave kind of general answer like that. And if you're interested
- in learning more
- like about your specific use case, feel free to reach out and we can talk about
- your specific
- options. So next question was the approval time looking for law enforcement
- organizations.
- So for this part 91, down to the last site waiver, I would just estimate about
- 30 days. This kind of
- goes back to that trend page that I showed kind of early in the presentation,
- where we basically
- went from like a 14 month approval down to about 30 days. So what we're seeing
- at least is this
- latest round of approvals in the last couple of weeks is taking on average 30
- days. So
- be a good one. Good one just to kind of bookmark 30 days as a reference.
- Does the waiver only cover DFR with a docking station or can you also get a
- waiver with a
- controller? So I'll answer kind of from from a skydial perspective with with
- our technology,
- you can get a like this single waiver, this part 91 waiver would cover all of
- it. So
- really the requirements, you know, you have to meet the requirements for each
- site, but as long as you're flying below 200 feet and you're using ADSD, which
- is built in
- kind of across our platform, we have ADSB in our DFR command, our web browser
- based GCS,
- we're bringing ADSB to our controller in our next update this week. So as long
- as you're using
- those things and kind of meeting the provisions of the waiver, you can fly with
- the controller,
- you can fly from the dock, you can fly an X10 that's not in a dock, but
- remotely as well.
- And so kind of all the things are possible.
- Let's see small lease department that doesn't necessarily have a need for full
- DFR program,
- but it's looking at getting a waiver for Beyond Visual Site during emergency
- operations.
- Yeah, I would say like this is possible, like there's a note here too that we
- operate under
- part 107 today. So if you're an agency that's doing kind of exclusively part
- 107 operations today,
- you could be eligible for this waiver and it goes back to some of those
- eligibility requirements,
- I could pull, see if I can find that slide here quick.
- You do need to meet the requirements for being a public aircraft operator and
- you would need to
- meet the definition of a public safety organization, but if you're a small
- police department, you may
- meet those eligibility requirements. So yeah, I would say if you're doing ops
- exclusive in
- part 107, just consider if you're eligible for these two things. And if you are
- , you can get this
- approval. And this approval is not limited to DFR. So I do want to make that
- clear, like this would
- cover any kind of public safety operation. So it could be just your kind of
- tactical use for
- slot or handheld, like controller based operations at a fire, whatever, it kind
- of covers all those
- things. So it doesn't matter necessarily if you're like a big DFR program or
- just a small department.
- So another question here, I'm working on a co-application for my agency. I
- assume the waiver
- needs to be requested after the COA has approved. So kind of the straight
- answer is no. If you're
- working on a COA today, what I would recommend is kind of putting pause on any
- of the COA work
- you're doing. So, and that could include like, you know, your blanket COA,
- jurisdictional COA.
- If you're doing tactical BVOS, if you're doing first responder BVOS, there's
- been a couple
- different types of public safety codes over the years. But if you're working on
- one of those,
- I would pause that work and take a look at this guide and see if you kind of
- meet all the requirements.
- Because if you do, you can just ask for this waiver and that will more or less
- cover like all
- the types of operations, the public safety operations that you want to do. So
- it will cover
- visualized site operations under part 91 as a public aircraft operator. It even
- includes
- Beyond the Genia site with a VEO. So kind of the old first responder, Beyond
- the Genia site,
- it includes that. And then it also includes BVOS without a VEO. So the FAA has
- kind of done a
- really great thing and sort of merged all the different types of COAs that used
- to be for
- public safety into one new approval. So yeah, I would recommend pausing and
- just looking at this
- new process and doing that if you meet the requirements. With, let's see, yes,
- we'll just
- keep going the question. We have five more minutes. So with the 200 foot DFR
- operation,
- does there are a limit to distance? And so I would say no, like not in a
- regulatory sense.
- So there's not a, there's not a provision in these waivers that says, you know,
- max light distance of two miles. So there's no kind of regulatory limit per se
- and you just
- need to consider things like battery endurance, you know, your connectivity. Do
- you have a link
- to go out the distance you want to? Does your ADSB solution cover, you know,
- enough space around
- the drone so that you get alerts of aircraft and so on? For Skydio, it does. So
- like our ADSB
- receiver is built in to the X10 itself. So wherever the X10 is, you get a good
- ADSB reception around it.
- So yeah, it's, there's not kind of a waiver limit per se. It's just based more
- on like the
- capabilities of the vehicle and whether you can still meet all the provisions
- at the
- distance you want to operate. Let's see. So kind of a question again about like
- part 107.
- So I'll take this chance to, to note that there are some part 107, public
- safety waiver options.
- So the DFA has kind of a new public safety obstructed shielding waiver, which
- kind of
- mimicked the tactical Beyond Visualizing Site approval that you could get under
- a cover. So
- that that part 107 waiver is meant more for pilots actually being on scene, but
- then being able to
- fly Beyond Visualizing Site in kind of a smaller area tactically speaking. So
- so there are options
- for operators that want to just operate under part 107 entirely. There's there
- 's even some kind of
- part 107 waivers that are allowing DFR now with parachute recovery systems and
- so on. So yeah,
- there are options if you want to just continue flying under part 107. But the
- process we covered
- today, I'll just say again is, is a part 91 operation and a part 91 waiver.
- Advisory Circular, so for the public aircraft operations, that's advisory
- circular 00-1.1b as
- in boy. And that's noted on our webpage. There's a section at the bottom of the
- webpage that has
- a bunch of references. So I would look down there. There's a link to it. There
- 's also links to like
- the FA's advisory circular 107-2, which has good information. It links out to
- the FA's public safety
- toolkit, which is a good source of information for public safety specifically.
- There's some links
- to like how to register drones, remote IDs, and so on. So yeah, look at the
- bottom of that webpage,
- and there's a whole bunch of references mostly out to FA material that's really
- useful for learning
- more. All right. Another kind of question here about, so do all these changes
- like impact your
- existing approvals essentially? And I would reframe it to a really good
- question is like,
- if I have a COA, should I get this new certificate of waiver, or should I just
- kind of like keep
- using my coas as they are? So big picture, like the coas that you have, if you
- have them today,
- they're still active. Nothing changed. So you'd still operate under them and
- comply with all the
- provisions and requirements of those coas. But if you would like to kind of
- transition to this
- certificate of waiver, you can. And so you could request this certificate of
- waiver, and it kind of
- doesn't matter if you have coas, you know, or not, like this is sort of a
- standalone process that
- you can just start and work through. And you may find that once you get, if you
- do do this process
- and get this new waiver, you may see that this new waiver kind of, it covers
- all the potential
- operations that you were probably doing under your own coas. You know, I can't
- say that with
- certainty, because I don't know your coas in and out like you all do. But this
- new waiver
- probably covers all the operations that you were doing under those old coas. So
- I would recommend,
- you know, get this new waiver. And then once you do just kind of evaluate the
- approvals you have,
- and you may be able to like let some of the old coas expire or cancel them even
- and just kind of
- standardize all your operations under one approval, which is really good from
- just kind of standardization
- standpoint, consistency, you know, that the pilots only need to really think
- about one approval instead
- of like a suite of coas. So yeah, I would go through the new process if I were
- an agency,
- even if you have existing coas, you know, consider going through this.
- Yeah, there's a question about ADSB on Honor X10. Like, do you need like
- updated hardware or
- anything like that? So the ADSB update coming is just software only. The X10s
- all have the
- hardware in them already. And if you've been flying an X10 over the DFR command
- , the web browser,
- you would have already seen like ADSB traffic. We just didn't have that feature
- on our controller.
- So the new update will bring ADSB both to the web browser and to the controller
- ,
- essentially kind of no matter how you're flying an X10, you'll have their space
- awareness around
- the drum. So yeah, just software only, you know, no need for any hardware
- updates.
- Okay, maybe let's just do like one or two more. I mean, there's so many
- questions here. We're
- not going to get through them all unfortunately, but we will try and do some
- follow up to can you
- answer these and they'll be another webinar. So maybe just kind of two more
- here I'll take.
- So like, is there a weight limit for public UAV, so to speak? So yeah, 55
- pounds, like really is
- still kind of the limit. So for part one of seven, it's definitely the limit.
- That's like a statutory
- weight limit. For part 91, you know, there are some pathways to get operations
- to fly
- fire weight aircraft. But generally speaking, like being below 55 pounds is
- going to be a lot
- easier for the FAA to approve and they're kind of they're generally trying to
- keep some similarities
- between part one seven and these this part 91 waiver. Yeah, 55 pounds, I'd say
- is a general answer,
- but there are pathways to get approvals to fly heavier drones.
- And then I'll take the last question here. I want to pick there's one about
- training and
- self-certification, which is kind of a subject near and dear to my heart. So
- part 91, it does allow
- you to self-certify your flight crews. And so it's actually a bit of a kind of
- a common misunderstanding
- I see, but the remote pass certificate that's required in a part one of seven
- is not actually
- an FAA requirement under part 91 and these waivers. Now most agencies are
- choosing to use that remote
- pass certificate as kind of a basis for qualifying their operators. And I think
- that's that's really
- good strategy by having all, you know, if your pilots all have the remote pass
- certificate that
- gives you the flexibility to fly under part one of seven and part 91. But it's
- not an actual FAA
- requirement for part 91. And so you could as an agency choose to develop like a
- basically a
- training kind of curriculum and strategy for self-certifying your operators.
- But what I would
- caution is that self-certification is not a, you should not view it as like a
- shortcut, right? So
- if you're self-certifying your flight crews, they should all still have the
- appropriate knowledge
- and skills to operate a drone in the national airspace. So you're still
- operating an aircraft
- for the FAA's definition. So don't look at self-certification as like a
- shortcut or,
- you know, like these drones are so easy to fly. Like I just need to tell these
- guys how to
- click a button in their operators. I think you should still, you know, train
- these operators to
- be kind of professional pilots. But you could choose to kind of do your own,
- you know, you
- create your own strategy around that. Or you can do kind of what most agencies
- are doing and just
- require that remote pass certificate as kind of that minimum requirement.
- Okay. So yeah, we're a few minutes over. So I thank everybody for joining. And
- if you're
- sticking around a few extra minutes for sticking around. But yeah, we're going
- to try and do some
- follow-up. I know there's just a bunch of questions we didn't get to. So either
- we'll just reach out
- or there will be, you know, some more webinars coming up. Like I said, I want
- to do
- follow-up on just like the waiver itself and kind of what those provisions mean
- for your
- operation. But we'll try and get these questions answered as well. So with that
- again, you know,
- huge thanks for joining. And then hopefully you find the webpage and the guide
- useful.
- Send us feedback if you do see like errors or just things we could do better in
- that guide.
- Please let us know and we'll update that. So with that, fly safe. We'll see you
- in the next one.
Watch Time
48 Mins 26 Secs
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