Episode 3: FAA Part 91 BVLOS Waiver Overhaul- What It Means for Your Drone Program Replay

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.

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Alright. Welcome, everybody. Welcome to another regulatory updates for public safety webinar. Jakee Stoltz from the Skydio regulatory team.

And, for the next forty five minutes or so, we are going to talk about a new process for part ninety one, the non-visual line of sight waivers. So it's gonna be, kind of a jam packed, forty minutes or so of content, and then we'll try and leave some time at the end for your questions.

So before we get into the the process and the steps and everything, I wanted to kind of provide a little bit of context for how we got to this point. So what are what is a little bit of the history and and some of the old process? You know, it's a new process, but there used to be a process that preceded this. So, you know, I I could probably look back well over, you know, five, six, seven years to kind of some early work that was being done to enable this kind of operation. But from a public safety perspective, like, there's a kind of clear start point, back in September of twenty twenty four, and that was New York City Police Department's, revolutionary FAA approval to do DFR operations across their entire city.

And for the first time, this approval was based on just operating at lower altitudes and using ADS B technology. So it didn't require, other types of detect and avoid technology.

So with a single approval, the NYPD was able to do kind of do and scale their DFR program across eighty five percent of their city, in one shot. So, it's really big moment for for them, and for the industry as well.

And then a couple months later, in December twenty twenty four, Las Vegas Metropolitan Police Department and Oklahoma City Police Department also received similar approvals.

And this started to show that the the concept that NYPD and and and developed was scalable. So, it wasn't just a one off in New York City.

This this type of approval was possible in other parts of the country, in different types of airspace, different environments, and so on. So and Oklahoma City Police Department's approval was particularly noteworthy because it it marked a transition from requiring a certain type of airspace, these Mode C Veils, as you may have heard us previously talk about, to the term congested area. But, essentially, this Oklahoma's approval kinda set the stage for this approval to be possible over any city or town or settlement to any congested area, essentially.

And so Oklahoma City's approval really became kind of the blueprint for the FAA moving forward. And so that that blueprint became, kind of three things from a safety case perspective. So you just had to operate at lower altitudes. We call this kinda shielded operations for DFR, but, really, what that means is just operating, at or below two hundred feet AGL.

And by operating at that altitude, the only additional airspace awareness technology required is ADS B in, which for Skydio and 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, you know, six or seven months or so, agencies across the country really have gotten these approvals. So I wanna just give a shout out to all the agencies that have already gotten this type of approval.

We're proud to have supported over twenty five of those agencies, kinda 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 couldn't staff it. You couldn't pay for a contractor or so on.

You can now kinda start a program without that requirement anymore.

Or there was agencies that had DFR programs but were maybe limited in in kind of the number or the scale of deployment. So they maybe had enough to staff one rooftop or, hire a contractor to do that, but now they can scale these programs across the city. So these approvals are having huge impact. We're really proud for those agencies that, have obtained it so far and and looking forward to the future as well.

And so from from this work now kinda helping, over twenty five agencies get these approvals, we've we've seen some trends that I I just kinda wanna share with with everybody to 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 fourteen months to get accomplished. So there's a lot of work that went into that from from the FAA, from NYPD, with our support, and just took a lot of patience. But, after fourteen months of working and 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, you know, process and, period of time there from kind of the initial work to getting approval.

But that happened in about three months. We started cutting that that process time down.

And then earlier this year, number of agencies, you know, probably about half of those that that we showed, on the previous slide there, they were working through the FAA. 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 seventy eight days, which, again, is, like, kinda just right in that kinda typical FAA review times for a Beyond Visual Line of Sight waiver. So, things were actually working pretty well earlier this year. Agencies were getting approvals, and and, things are moving along.

But this new process, really just kind of takes it to a whole new level. And and, really, it's like a speed that's unheard of from the FAA. So, in the last couple weeks, more and more agencies have been getting this approval, and, we're seeing that kind of processing time drop down to average of thirty days or so. And so, it's it's a just, again, an amazing trend from fourteen months down to thirty days in just the span of, like, seven, seven to eight months.

So, so with that, I I do wanna, like, recognize the FAA's work here. I think sometimes they're, you know, blamed for being slow and taking forever and blocking the industry. But, at a 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 twenty four to thirty day, you know, review times now for this type of operation that can be scaled across the country now. So and, particularly, I'd I'd wanna kinda give give recognition kudos to, the FAA's US policy team, and ATO, so AGV, the Eastern Service Center, and, the AFS seven thirty group in flight standards. There is a small team from kind of those branches that really helped get that first approval across the finish line and and helped stand up that initial process.

And then, of course, you know, big big kudos to the the new team in flight standards that has kind of taken over, and really streamlined this process and just made it, you know, much more easy much easier and and much more streamlined and and quick to get approval. So, so, yeah, big big kudos to the FAA on their work on this.

Alright. And so, now we'll get into kinda more of the process itself.

And before I do that, I'm gonna just say a few more housekeeping 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 ninety one operations here. But, you're eligible to fly under part one zero seven 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 ninety one as a public aircraft operator. And so this process and, really, the rest of the webinar is about part ninety one and not about part one zero seven. So just kind of forget part one zero seven for the next thirty minutes or so. This is all about part ninety one.

And then, one more housekeeping item. So this process is evolving, and it's changing. And even in the last three weeks since the FAA, 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 sixteenth, so the day that, I presented it live, I'm gonna refer you to a web page that we've put up, and I'm gonna 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, 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 out of date information.

Alright. And so for this new process, the the term I'd really use is that it's a new process, but it has the same impact. And so, you know, as as kind of a tech company, we we do release notes for our software updates and so on. And so, I I just kinda wanted to use that same framing here.

If you were familiar with the old process, here's sort of the release notes, for this new process just to kinda orient you. If you weren't familiar with the old process, then this may not mean a whole lot. But, and there's this is not an exhaustive list, but I would say there's kinda, like, four, you know, big things worthy of note here. So number one, there's three new forms, that are gonna 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 a terminology change. I would say the the waiver kind of by and large is 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.

So that was removed from this process, which is great. We all love CAPS.

There's some sarcasm in there.

And then finally, there actually are some some minor updates to the waiver itself, so to the the approval that you get. So for example, a NOTAM 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 at the 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 zero seven, you actually get a COA when you get an airspace authorization. So these these things still exist.

Definitely, it's 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 the release notes. But what has stayed the same here is that these approvals still ultimately enable DFR operations and other types of public safety ops. So, they still enable agencies to do beyond the line of sight without visual observers, at scale really over any city, town, or settlement now across the US. And the kind of default approval at two hundred feet just requires ADS B and Sill, and you optionally have the ability to deploy noncooperative detect and avoid technology like a Dedrone beyond to get approval to fly at higher altitudes. So kinda 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 kinda getting into more of the details of what this new process is. I've chosen to kinda break it down into three steps.

And so we're gonna dive into these steps a little bit more. But, these steps are kind of is firstly, the reason I broke it down these three ways is because, the step number two here, which we'll talk about, is actually, there you have to go get sort of an outside counsel to do that for you. So it's kinda broken down by, like, who can do which step or who's responsible.

The 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 the eligibility requirements do cover a pretty 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 this hasn't changed. So if you got a COA in the past, you had to, be eligible for this. And similarly, moving forward to get this certificate of waiver, you still have to be a public aircraft operator.

And so we'll we'll talk more about that in a second. But, like, essentially, you have to be a part of a state government or a 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 kinda note some of the new parts of this process specifically with that little new tag there. But, the FAA also wants to limit this waiver to public safety organizations, for now. And so they've they've pulled a definition of a public safety organization, that's the US code.

And I can just kinda 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 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've determined you're eligible. You're a public aircraft operator. You meet that definition of public safety organization.

Now you need to go get it's called a public declaration letter.

And, hopefully, this is there. It's getting a little spinning sign. But, so you need to go get a public declaration letter. So for state government or, you know, political subdivisions of that government, you cannot self declare this. So that's a key thing. So you cannot self declare that you're a 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 gonna 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 gonna need to go to to those offices and get them to create and sign one of these letters for you.

And the FAA has guidance on this, so I'm not gonna get too deep into this. And and I can't, you know, make a determination of whether your agency qualifies or not.

But the FAA does have some guidance on this. So there's an adviser circular zero zero dash one dot one b. The FAA 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. And so, so, yeah, you use those, FAA resources to help you and your, attorney make this determination.

And for for federal government, if there's anyone, you know, listening that is part of federal government, the public declaration letter is not required for for you, but the FAA may ask for some other evidence, to 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 there. Now you can actually start to put together the set of documents, to actually make the request to the FAA. So what I would recommend before you go filling out all these documents is I would recommend, selecting your con op or selecting kinda which type of request you're gonna make.

And so as mentioned before, there's still the two options that there were before. You can choose to request a a sealed operations type of approval, which means you're gonna fly at a below two hundred feet. You're gonna use ADSD in technology for collision avoidance.

And in that case, you have to fly over congested area, but it it could cover, like, your entire jurisdiction, otherwise.

And, really, that's kind of the FAA's, like, default approval at this point. So if you're not sure which con op or, if you haven't, you know, 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 gonna go down on the left side.

But you have the option to deploy noncooperative detect and avoid technology and request up to four hundred feet AGL.

And so if you're working with a, you know, technology provider like on this already, then you can look at this, four hundred foot type of request.

The the count up you pick does kinda determine how you fill the documents out, and there's actually an additional document that you need to fill out for the four hundred foot request. So I just recommend, kind of going into the process knowing which, type of request you're gonna make before you start filling everything out.

Alright. And then, then you have to put together a set of documents to kinda 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 form seventy seven eleven dash two, 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 ninety one BVLOS waiver checklist now. This is new from the FAA.

A concept of operation document, which really was should have been done before and and we've always done for the the agencies we work with. And then finally, if you are gonna make a request over two hundred 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, let's kinda talk through these forms just a little bit more here. So the first one, the the seventy seven eleven, 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. You know, this form also is used for, like, applicants of airshows and other types of aviation activities. So it's not a 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 ninety one Beyond Vision on a site waiver.

But there's kinda three, I would say, critical parts of this form to fill out.

So there's a box where you're gonna reference the concept of operation.

You could try to type all the concept into that box, but we recommend just doing a separate document. We'll talk about that, in a minute.

Then you'll you'll also know where you're gonna fly, essentially, so kind of the area of operation that you're asking for. And then finally, the the drones that you're asking for. So whichever kind of fleet, you know, if it's one drone or fleet drones, the drones that you intend to fly on on this labor, it lists those.

K. So now to the the PSO letter or the public safety organization letter, that's that, kind of that second eligibility item.

So kinda similarly to the public declaration letter, you're gonna 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 the agency can sign itself. You don't need to go get outside counsel 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 of public safety organization.

You're gonna say that you're asking for this site waiver, some examples of the types of ops you're gonna do, and then, there's ultimately a signature block at the end of that.

K. So you have to put that together and 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 and get some get an understanding of kinda what they're signing up to do or what they're gonna be required to do under the waiver.

So the the checklist goes through about eighteen different provisions, that the the responsible person or the applicant should kinda go through and read and then initial. And by initialing, you're basically saying, like, 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, sorta understand, like, what they're signing up to do. So you'll go through, you'll you'll initial the columns that apply, and then you'll sign at the bottom, and submit that to the FA as well.

K. And then one of the provisions from that checklist, actually, the third one in the list, it it basically states that you're gonna provide a complete description of the operation. This is kind of verbatim what it says. So there's 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, hovers.

And so when you when you go to the website that I'll that I'll show later, we're actually gonna provide kind of a template slash example of a concept of operation document that you can download and start to fill out.

But I think this is a a really kind of key part of the process.

You know, and so so don't overlook this. I think this concept of operation document is kinda your chance as, like, the responsible person for the strong program to kinda, like, go through the the list of things and, like, structure your program, make kinda get up to speed on everything. So it's almost like a good just internal exercise to do to kinda get familiar with all the different parts and, things that your program should have. So, for example, you wanna think about the flight area, the airspace, that you're gonna 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 gonna 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, web page for that, get the tracking numbers, and so on. How are you gonna train your crew?

So, you know, what what are the qualifications? Are you gonna require everybody to get a remote pass certificate? Are you gonna choose some kind of self certification strategy? You know, 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 you wanna submit something to the FAA, but just also internally to kinda help you structure this program that you're that you're about to to implement.

And, again, we'll we're gonna provide a a kinda outline of what this, con op can look like, after when we get to the web page. So you don't necessarily have to start from scratch and kinda use our example to help guide you on this.

Okay. And then the final document is this CMD DAA document. So if you're gonna do if you're gonna request operations up to four hundred feet AGL, then you must deploy some kind of noncooperative detect and avoid technologies. Could be radars. There's camera systems, and so on. You know, Diedre and Beyond would be an example, but there's others. And so when you're deploying that technology, the FAA, is gonna evaluate it to make sure that it's an effective mitigation for aircraft collision avoidance.

And so this this document, the CMD DAA document, is a form that the FAA put together to to help you kind of provide all the necessary information and then to help them, review it in an effective way and and hopefully, kinda streamline their their review process on them as well. So, what I would recommend is that, you know, don't don't try to fill this document out yourself as the public safety agency. I would actually put this document on the technology vendors' kinda shoulders to at least fill out the bulk of it because this is this document is about, like, the DA system itself. Like, how does it 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 kinda specific things about your agency and your locations and where you're gonna deploy this and so on. So, yeah, definitely make this kind of a 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 gonna do the the shield operations below two hundred feet.

Alright. So that's the set of documents, that you should put together for this this new process. So, again, just to, like, quickly recap, you got your public declaration letter, your form seventy seven eleven dash two, the TSO letter, the checklist, and a concept to operation.

And then if you're if you're gonna fly over two hundred 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 gonna 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 ninety one, 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 you back saying, you know, received, and we're working on it. But that yeah. By just by emailing them, that starts the process.

And then kinda one of two things happens. The the FAA may ask for more information or corrections if you, made any kind of error in in some of the documents or but if if everything is good and 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 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 detail as well that I I didn't really get into today. So, what I'm showing here is just like a PDF version of the web page. But but, yeah, if you head to the web page, you'll you'll basically see a detailed guide on this.

In in that web page, there's a 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 this guide really the 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, 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, 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.

Alright.

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 kinda save that for a follow-up webinar where, you know, we can could do kind of a top down of the provisions themselves and what they mean and so on. So, I'm not necessarily gonna cover the approval document itself today, but, again, can certainly answer some questions, on it if there are any.

And so with that, we've got about ten minutes roughly to answer some questions. So just give me a sec to kinda look at the list of questions here.

So, yeah, we'll we'll just kinda start to go down the list here. I see lots of questions, which is awesome. So, Beyond version of site for public sector and private sector. So, like, the question kind of at the core is, have you had any success enabling Beyond version of site in the private sector? So, like, that part one zero seven 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 and entities get part one zero seven waivers. It's like a waiver to one zero seven dot three one.

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 a hundred feet or over critical infrastructure up to two hundred feet. So actually pretty similar to the, the part ninety one approvals that we just covered.

We're 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 wanna do remote operations, there's gonna be a path for you regardless if it's part one zero part one zero seven or part ninety one or kind of what vertical you're in. So so, yeah, I I would leave leave kind of a 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, what is the approval time looking for, law enforcement organizations?

So for this part ninety one, the on-site waiver, I would just estimate about thirty days. This kinda goes back to that, that trend, page that I showed kinda early in the presentation where we basically went from, like, a fourteen month approval down to about thirty days. So what we're seeing at least is this latest round of approvals in the last couple weeks is, taking on average thirty days. So be a good one good one just to kind of bookmark thirty 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 Skydio perspective. With with our technology, you can get a like, this single waiver, this part ninety one waiver would cover all of it. So, really, the requirements you know, you have to meet the requirements for each type. But as long as you're flying below two hundred feet and you're using ADS B, which is built in kind of across our platform, we have ADS B in our DFR command, our our web browser based GCS.

We're bringing ADS B 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 could fly with the controller. You can fly from the dock.

You can fly an X10 that's not in a dock, but but remotely as well. And so kinda all the things are are possible.

Let's see. Small police department that, doesn't necessarily have a need for a full DFR program, but it's looking at getting a waiver for a 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 one zero seven today. So, if you're an agency that's doing kind of exclusively part one zero seven operations today, you could be eligible for this waiver, and it it goes back to some of those eligibility requirements.

I could pull see if I could find that slide here quick.

Yeah. You you do need to meet the requirements for being a public aircraft operator, and you would need to meet the re the definition of a public safety organization. But if you're a small police department, like, you you may meet those those, eligibility requirements.

So, yeah, I would I would say if you're doing ops exclusive in your part one zero seven, 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, like, DFR. So I do wanna make that clear. Like, this would cover any kind of public safety, operation.

So it could be just your kind of tactical use for SWAT or handheld, like, controller based operations, at a fire, whatever.

It kinda covers all those things. So it doesn't matter necessarily if you're, like, a big DFR program or just a a small department.

So another question here, I'm working on a COA application for my agency. I assume the the waiver needs to be requested after the COA is 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 blank a blanket COA, jurisdiction COA, if you're doing tactical BVLOS, if you're doing first responder BVLOS. There's a there's been a couple different types of public safety COAs over the years. But if you're working on one of those, I would pause that work and and take a look at this guide and see if you kinda 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 wanna do. So, it will cover visual line of sight operations under part ninety one as a public aircraft operator. It it even includes, beyond the site with a VO. So kind of the old first responder beyond the site, it includes that. And then you can also include BVLOS without a VO. So, the FAA has has kind of done a a a really great thing and sort of merged all the different types of COAs that 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 and doing that if you, meet the requirements.

With let's see. Yes. Let's keep going with question. We have five more minutes. So, with the two hundred foot DFR operation, is there a limit to distance?

And so, I would say no. Like, not 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 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 the distance you want to?

Does your ADS B solution cover, you know, enough space around the drones that you get alerts of aircraft and so on? For for Skydio, it does. So, like, our ADS B receiver is built in to the X10 itself. So wherever the X10 is, you get a good ADS B 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 and whether you can still meet all the provisions at the the distance you wanna operate.

Let's see. So, kind of a question again about, like, part one zero seven.

So I'll I'll take this chance to to, note that there are some part one zero seven, public safety waiver options.

So the the FAA has kind of a new, public safety obstructed shielding waiver, which kind of, mimics the tactical beyond the line of sight approval that you could get under. So that that part one zero seven waiver is meant more for pilots actually being on scene, but then being able to fly the average line of sight in kind of a smaller area tactically speaking. So, so there are options for operators that want to just operate under part one zero seven, entirely.

There's there's even some kind of, part one zero seven waivers that are allowing DFR now with parachute recovery systems and so on. So, yeah, there there are options.

If you want to just continue flying in your part one zero seven.

But the process we covered today, I'll just say it again, is is a part ninety one operation and a part ninety one waiver.

Advisor circular. So, for the public aircraft operations, that's advisor circular zero zero dash one dot one b as in boy.

And that's noted on our web page. There's a section at the bottom of the web page that has a bunch of references.

So I would look down there. There's a a link to it.

There's also links to, like, the FAA's advisory circular one zero seven dash two, which has good information.

It links out to the FAA's public safety toolkit, which is a good source of information for, public safety specifically.

There's some links to, like, how to register your drones, remote IDs, and so on. So, yeah, look at the bottom of that web page, and there's a whole bunch of references mostly out to FAA material that's, really useful for, learning more.

Alright.

Another kind of question here about, so so do all these changes, like, impact your existing approvals, essentially? So and that and I would reframe it to a really good question. It's like, if I have a COA, do I should I get this new certificate of waiver, or should I just kinda, like, keep using my COAs as they are?

So big picture, like, the COAs that you have, if you have them today, they they're still active. Nothing changed. And so you'd still operate under them and and comply with all the provisions and requirements of those COAs.

But if you would like to kinda transition to this certificate of waiver, you can.

And so you could request this certificate of waiver, and it it kinda 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 you know, if you do do this process and get this new waiver, you may you may see that this new waiver kind of, it it covers all the potential operations that you were probably doing under your own.

You know, I can't say that with certainty because I don't I don't know your 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, so I would recommend, you know, get this new waiver. And then once you do, just kind of evaluate the 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 is really good from just kind of a standardization standpoint, consistency.

You know, the the the pilots only need to really think about one approval instead of, like, a suite of COAs.

So, so, yeah, I I would go through the new process if if I were an agency. Even if you have existing COAs, you know, consider going through this.

Yeah. There's a question about, ADS B on on our x ten. Like, do do you need, like, updated hardware or anything like that? So the ADS B update coming is is just software only.

The x tens 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, ADSD traffic.

We just didn't have that feature on our controller. So the new update will bring ADS B both to the web browser and to the controller. And, essentially, kinda no matter how you're flying an x ten, you'll have airspace awareness around the drone. So, yeah, just software only. No 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 gonna get through them all, unfortunately, but we will try and do some follow-up to to can you can you answer these, and there'll be another webinar.

So maybe just kinda two more here I'll take. So, like, is there a weight limit for, public, UAV, so to speak? So, yeah, fifth fifty five pounds, like, really is still kind of the limit. So so for part one zero seven, it's definitely the limit.

That's like a statutory weight limit.

For part ninety one, you know, there are some pathways, to to get operations to fly higher, weight aircraft.

But generally speaking, like, being below fifty five pounds, is gonna be a lot easier for the FAA to approve, and they're they're kind of they're generally trying to keep some similarities between part one zero seven and these, this part ninety one waiver.

Yeah, fifty five pounds, I'd say, is a general answer, but there are pathways to get approvals to fly heavier drones. So, and then I'll take the last question here. I wanna pick there's one about training and self certification, which is, kind of a subject, near and dear to my heart. So, part ninety one, it does allow you to self certify your flight crews. And so it's actually a bit of a a kind of a a common misunderstanding I see, but, the remote pass certificate that's required under part one zero seven is not actually an FAA requirement under part ninety one and these waivers.

Now most agencies, are choosing to use that remote pilot certificate as kind of a basis for qualifying their operators, and I think that's that's a really good strategy by having all you know, if your pilots all have the remote pilot certificate, that gives you the flexibility to fly under part one zero seven and part ninety one.

But it's not an actual FAA requirement for part ninety one. And so you you could, as an agency, choose to develop, like, a, basically, a training kinda 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 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, oh, I like, these drones are so easy to fly. Like, I just need to tell these guys how to click a button and their operators. I 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 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 for joining and if you're sticking around a few extra minutes for for sticking around.

But, yeah, we'll we're gonna try and do some follow-up. I 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 wanna do follow-up on just, like, the waiver itself and kinda what those provisions mean for your operation, but, we'll 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 the web page and 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 we'll update that. So, with that, fly safe. We'll see you on the next one.