Episode 4: FAA Part 91 BVLOS Waiver Deep Dive - What You Can (and Can’t) Do

Hey, everyone. Welcome back to another webinar, regulatory updates for public safety. I'm Jakee Stoltz on the Skydio regulatory team.

Thanks for taking the next hour out of your day to hear me talk a little bit more about part ninety one, Beyond Visual Line of Sight Operations.

So, two months ago, the last webinar I did, I talked about the new process that the FAA put in place for these waivers and, basically, like, how to get one and just kind of, information about the process itself.

But since that last webinar, we've had a bunch of new agencies getting this approval. And so, the webinar today for the next hour or so is going to be about the waiver itself or the COA. So if you're one of the agencies that received one since then, we're gonna kinda dive in. And if you don't have one yet, this may still be just useful for you to kinda get a preview of what you could get. So we'll jump into it here.

So before I talk about the waiver itself, I just wanna give some updates on basically, like, the last two months—how things have been going, what trends are we seeing, and so on. So the first thing is just a congratulations to all the Skydio customers that have received this Beyond Visual Line of Sight waiver.

So we're over fifty now, kind of covering about half the states in the US here.

So it's just awesome to see kind of the scale that and the impact that these waivers are having across the US.

And then the last webinar I did, I showed a chart here that just kinda showed the trend of the waivers. And, basically, like, how did we even get to this point? So, again, it kinda all started back about nine, ten months ago now with NYPD getting approval. That approval took a year plus—just kind of this big effort.

But the good news was, in the last webinar, the process had come down all the way to about an average of thirty days, which is just really incredibly fast for the FAA. So they deserve a lot of credit for really streamlining the process and helping public safety agencies get these approvals.

But since then, it's really kind of gone just one more step beyond that. So, just in the last two months, the average time has been six days from submission to approval.

And we've seen approvals get turned around in one day, so sometimes they even come faster than this, but this is just the average. So you can plan about a week or less to get this approval when you do submit it.

And it is worth noting that that timeline just really applies to, like, the two hundred foot types of approvals.

The four hundred foot approvals are still taking a little bit longer, so just keep that in mind.

And then, broadly speaking—so I mentioned, you know, the map was just kind of Skydio customers that we've been supporting with this waiver—but broadly speaking, about three hundred agencies now have received this approval, again just in the last two months. These are mostly all, you know, two hundred foot approvals. But, again, I just wanna give huge kudos to the FAA for really streamlining the process. They kind of took it into a whole other gear in the last two months.

And so we're grateful for their work on this and just keeping the momentum going.

Okay. So if you haven’t worked through this process yet or gotten your waiver, I would definitely recommend you do that. The time is now. These things are getting approved really quickly, so I just recommend not waiting.

And to help you do that, we do have a guide available—you can head to this website here. I’ll just kind of leave it on the screen for a couple seconds.

And the website covers basically a start-to-finish guide on how to get the waivers.

You can even email us to get some forms and templates and examples and things like that to make it even easier for you.

So again, head over to that website and get your waiver today, right? I feel like a salesman, but really, it’s just super easy to do, and it can really enable your program to do advanced operations.

Okay. So just some updates, but now we’ll actually get into the waiver itself and talk about some of the provisions, what you can do, what you can’t do, things to think about, gotchas, and so on.

There are three quick notes I want to convey before I jump into the provisions and what you can do. So just a reminder that this is a Part 91 operation and a Part 91 approval. It’s not Part 107. There are a lot of similarities to Part 107, but this is kind of a separate thing altogether.

So keep that in mind as we go through.

I’m going to focus the review ahead on the 200-foot approvals because that again is the majority of approvals that’s happening out there.

If you have a 400-foot approval or you’re interested in getting one, this is still going to be useful for you. There are a lot of provisions that are basically identical between the two types of approvals.

The 400-foot approvals just have some extra provisions regarding detect and avoid technology.

So it’s still going to be valuable for everybody, but the text I’m going to focus on is the 200-foot approvals.

You’re going to see in some of the slides little pink numbers next to the text. These pink numbers are basically the provisions in the waiver itself. So if you have a waiver, you could pull it up and put it side-by-side with the webinar and follow along. You could sort of cross-reference what I’m saying compared to the text the FAA uses in the waiver.

Because I copied some of the text out of the waiver, but this is not a line-by-line reading of the waiver itself. So it might be useful just to cross-reference.

If you don’t have the waiver yet, we’re going to share a link to a sample waiver. The waivers have largely stabilized at this point. They’re not changing on a week-by-week basis like they used to. You can download this example; I’ve wiped the agency information.

So if you don’t have one yet, you could grab that sample and follow along as well and just get a preview of what you’d be able to get.

Alright.

So the first kind of two things that I wanna talk about is just, like, what does this, waiver actually allow you to do? Like, what kinds of operations?

And so I'm actually first gonna start off with visual line of sight. So this waiver does include the ability to do visual line of sight operations.

That's provision ten if you're following along.

And it's it's a pretty short and sweet provision, but, basically, it says you can do visual line of sight operations up to four hundred feet AGL, and that's an uncontrolled airspace, or up to the UAS facility map altitude and controller space.

So it kinda largely just mimics part one zero seven, and the visual line of sight operations you do under part one zero seven. But, again, it's a part ninety one, operation instead.

And, I do wanna kind of briefly just get on, like, what visual line of sight even is because there's some misunderstanding out there about what visual line of sight kinda means. So visual line of sight is an operation where all the the flight crew members can see the drone throughout the flight. So this includes your pilot in command, the visual observer, if you're using one, and the person manipulating the controls, again, if you're using one. So it's a little bit, of a kind of obvious scenario in the picture here, but, a visualized site operation would kinda look like this if you're using all three roles. So you'd you'd have everybody kind of standing together within earshot of each other. Everybody has a view of the sky and the drone, and you're kinda working as a a flight crew. So that's visual line of sight.

Something that's missing from this waiver now is actually the ability to do beyond the line of sight with a visual observer.

So this was a a fairly recent change. The FAA decided to remove this kinda option from the waivers.

And they're also, I believe at this point, the intent is for no further kind of beyond baseline sight with VO COAs to be issued. So this would be like the old first responder beyond baseline sight if if you're familiar with that term.

This concept has basically been retired for public safety at this point. So, so if you're planning on doing an operation where you wanted to have, like, the person or the the PIC or the person manipulating the controls indoors, but then a visual observer outdoor scanning airspace, that's no longer included with this waiver, and it's not a visual line of sight operation either. That would be considered beyond visual line of sight. So just something to keep in mind. If you have the waiver, it's probably still active. So it's not like the FAA kinda went out proactively. It just, like, canceled everything.

But just know that you probably won't be able to get that renewed. Or if you were just planning on getting that type of approval, that's really not, an option anymore.

Okay. And then the waiver, of course, allows some kind of beyond the line of sight operation, and this is without a visual observer. So and this, of course, is kind of the main reason that most people are getting these waivers. So we'll dive into it here. And this is provision eleven if you're following along. So there's kind of those little pink numbers on the left side.

So the first thing to know about the BeyondAge site, approval is that, without a VO, you can fly up to two hundred feet AGL.

And then there is a small kind of carve out as well to fly above two hundred feet AGL as long as you're within fifty foot of an obstruction or an object or some kind of some kind of thing that would be, dangerous to crude aircraft if they were to hit it.

And in the graphic, this is kind of this, little, you know, green area that you see above this, structure.

So, again, you know, maybe a scenario I'll just kinda try and give one. There's probably many scenarios here. But let's say you had a roof alarm, on top of a twenty five story building. So it's maybe a two hundred fifty, three hundred foot tall building, and you need to get to the top of that building to check that roof alarm. So this waiver does allow you to kinda go up. You have to stay pretty close to the building, but it does allow you to go above two hundred feet in that scenario.

And then once you leave that, that roof line, you'd come back down to two hundred feet.

So hopefully that's clear.

And then just like visual line of sight operations, the maximum altitude is limited to the UAS facility map altitude in controlled airspace.

So if you have a two hundred foot grid or a hundred foot grid or fifty foot zero, whatever that grid number is, that becomes your maximum altitude kinda regardless of the other capabilities.

K. So that's the first thing. And, you know, I'll kind of take a a tangent here on Skydio specific. So with an x ten, if you're operating an x ten, this waiver actually allows you to operate that x ten beyond the line of sight in multiple different ways. So, if you're flying from a controller doing more of, like, a tactical operation, you can fly beyond the sight. And this would actually cover, like, the tactical beyond the sight concept.

I didn't specifically call it out before, but, like, tactical beyond the sight is not really a a specific waiver you can get anymore either because this one kind of covers that scenario, just inherently. So if you could launch an X-ten with a controller, and as long as you keep that drone below two hundred feet and use the ADS B built in, you can fly it behind buildings. You can fly it a little bit, further distance and so on.

And then you could also, launch an x ten from the street, so to speak, but then commandeer it and fly it remotely from a remote location. So it's kind of like a dockless remote operation.

That's allowed.

And then finally, of course, like, the dock based, operation is is included as well. So you can just launch an x ten out of a dock and fly it remotely without anybody, standing outside.

Okay. So now kind of moving on, from those two concepts.

Really, the rest of these topics I talk about kind of apply to both of those, both your visual line of sight and your beyond visual line of sight operations.

So one one thing that the FAA did in these recent waivers is they actually made ADS B a requirement for all operations and even visual on a site, which is a little bit different than you than you might be used to.

But the FAA is just kind of seeing the value of having that airspace awareness in a method that's different than than visual sight because, we all know visual sight is maybe not kind of the best, way to see and avoid aircraft. So ADS B is really a great safety layer on top of that even in visual line of sight scenarios, to know what's around you. So the the waiver kinda speaks to two technical requirements for your ADS B solution.

The first one is that the receiver must be capable of, receiving both types of ADS B out frequencies, nine seventy eight and ten ninety megahertz.

So, just check the technical specs of the ADS B solution, you know, you're looking at, and then it'll it should tell you, if it picks up one or both of those, frequencies and the requirements that it that it picks up both.

And then the other technical requirement is that it must be a local sensor or an FAA approved UTM third party data service provider, which does have a have a have a special meeting. But I've I've kinda chosen to give a few examples here of, different solutions out there. So, Skydio, we've we've basically got got you covered if you're flying, the Skydio x ten, and or the x ten dock.

The x ten itself has a receiver built in, so that's a local sensor that receives both frequencies.

The Xtendoc has a ground receiver in the external radio kit, also a local sensor that picks up both frequencies.

If you're using something like a Deepgram Beyond, system, their system has built in, ADS B receivers, included, so that also would cover you.

And then examples of, options that are not necessarily compliant with this requirement is things like FlightAware, FlightWriter twenty four, and even something like ForeFlight, which I really love ForeFlight. I I've used it, flying crewed aircraft in the past. It's a great app, but it doesn't meet the requirements for ADS B. And some of the some of the reasons, like, these bottom three are not necessarily approved are, they're they're kind of based more on, like, crowdsourced, receivers.

So you don't necessarily have guaranteed coverage at the low altitudes that we really care about around the drone. There may be latency things. You don't necessarily know, like, is the aircraft shown on Flightrare twenty four exactly where it is in real life? Is there a delay?

It doesn't really tell you.

And, also, there's just no integration between, like, the ground control station and these pieces of software. So they're also, like, a little bit hard to use to kind of know exactly how close an aircraft is to your to your drone. So which leads me to the next part. So the waiver doesn't talk really about how to use the ADSD. So let's assume you have a system that meets those two requirements.

There's more to it than that. It's like, how do you actually use it now to avoid aircraft and and keep a safe distance? So, so I would encourage you to think about, like, the system that I'm choosing, you know, if it's not a a Sky UX ten, is the data easy to understand, especially by a pilot that might be focused on the video and the mission, and maybe not necessarily have workload or time to kind of watch airspace maps carefully. You know? Is it is the altitude in meters or feet? Does it show kind of exactly how far away those aircraft are from your drone and so on?

Does the system include alerts? So, if it doesn't include alerts, you might have to spend more time kinda watching that map carefully. But, maybe it has some alerts that warn you when aircraft do get close, and you should pay attention to that. Skydio has this built in.

And then do those alerts give you enough time to react? So it's one thing to kind of get an alert, but do you have enough time to assess the situation, maneuver the aircraft out of the way if you need to, and so on? So, actually, think about just how you're gonna use that ADS B data. You wanna make sure you have it and it meets the requirements of the waiver and then kind of think about how a pilot's actually gonna use it.

Okay. And speaking of things that are required for all operations, anti collision lighting is another one of those things. So I just have one slide on this quick call out, but, anti collision lights long been a requirement for night operations.

But for day operation, under this waiver, the anti collision lighting is also a requirement. So, basically, just turn your drone's strobe lights on at all times at this time.

Okay. So now let's get into, a little bit more on airspace.

And I previously mentioned that, you know, these UIS facility maps are kind of the maximum altitude for operations, both visual line of sight and beyond the line of sight.

So just getting into that a little bit more here. So if you're gonna fly below the facility map altitudes, this waiver is basically your your built in airspace authorization. And if you actually look carefully, the the title of these approvals is certificate of waiver and authorization.

So it's kind of both together. And then on the second page, there is kind of a bolded statement about this waiver serves as an authorization to fly and control airspace. So bottom line is that if you're gonna fly and control airspace below the facility map grids, you're approved, and there's basically nothing kinda extra needed. So you don't need to get LAANC.

We could apply to part ninety one anyways. That's kind of a one zero seven dot four one thing.

You don't need to do radio communication or or communicate, like, with a tower anyway.

You don't need any kind of extra airspace clearance, to fly in there. So you're basically allowed to just fly below the facility map grids and control airspace, and this waiver allows that.

So if you wanna fly above the facility map altitudes, and I know this is a a pretty, hot topic for many agencies because you, you know, you might be impacted by, like, areas of zero grid, which effectively are kind of no fly zones at this point because you can't fly above zero.

So if this is you, if you have, airspace and grids that that kind of are blocking operations in certain parts of your jurisdiction, you have two options, and the waiver covers this. So the first option is to use the SGI process, the special government interest process.

And so these are approvals that you can get, kind of a case by case basis for emergency scenarios or, like, exit and circumstances, things like that.

So these are these are not necessarily you can't use them for, like, routine operations or you can't necessarily get them, like, proactively like you're planning for an operation.

It has to be kind of real time for emergencies.

And I've put a link here, to the FAA's website about this so you can go, go there and kinda read a little bit more. The FAA's website also has the form, on that website that you would use to, request these these types of approvals.

So that's one option.

It has some some drawbacks, but it can be used to get access to, airspace that you wouldn't otherwise be able to fly in in emergency scenarios.

So the second process is, provision number twelve. There's basically a provision that says if you wanna fly above the US facility maps or above four hundred or kinda in any airspace that you're not otherwise allowed in, you can request an airspace authorization through CAPS.

So the purpose of this is to enable, like, more routine operations in certain parts of your jurisdiction that might be covered by this.

Unfortunately, there's FA is still developing the process to actually approve these things.

So, I don't have a lot of information to share at this point. We will definitely share as soon as we know. We've been supporting some agencies who have submitted requests, and we've kinda worked with airports, but we just don't have, kind of approvals and a process necessary to share on us. So, more to come, but I would say just kind of what's important for you to know today is that, we do expect there to be a path forward to getting into routinely getting into some of these, areas of airspace that are otherwise kind of blocked by these facility map grids.

Okay. So that's that's like controlled airspace basically and and kind of your your limitations within that. But there's also heliports and other, uncontrolled airports that, don't have facility map altitudes. And so, therefore, you might be asking, like, how do I fly near the heliport in town? You know, can I fly near the heliport in town, or are there restrictions around that?

So I'm gonna kinda lead this off with an example, from some recent operations. So, I was in Elgin, Illinois, supporting kind of a doc trial there.

Awesome agency to work with, by the way, so Elgin, if you're on. It's great to to be with you guys for a week there. So, you know, just just looking at their airspace situation on a website like FAA UAS and visualize it, It's all uncontrolled airspace, all class g. There's really no airports, in their jurisdiction.

There are some kinda nearby, but there's really no impacts. So, from an airspace perspective, there's, like, no restrictions. You know, they can fly up to four hundred feet, visualize the site. They can fly up to two hundred feet, damage on the site.

It's no problem.

But, if you look closer and use some different tools like exceptionals or the FAA's airport database, you can actually see that there are a couple hospitals with heliports in in and kind of nearby their jurisdiction.

Now the the Elgin PD, they knew about these, so they've been doing turn operations, in the past. And and to their credit, they knew these were there. They they asked about them. We talked about them in the site survey.

But you should as an agency, as you're kind of prepping a program or or scaling it up, you should be aware of these teleports, because they don't always show up on, like, the US visualize it, page.

So if if you have this situation, basically, like, kind of what what should you do? So the waiver has three catchalls, I would say. The the waiver doesn't explicitly tell you what you can and can't do around these, but they there are three catchalls that you should be, aware of. So the first one and this is provision twenty one and twenty two, again, if you're following along. So the first one is that, regardless of the operation and where you are, the PIC must have situational awareness of air traffic and not pose a collision hazard. So that's kind of a catchall.

Next, the PIC must ensure there's always a safe operating distance between their drone and other aviation activities.

And then, finally, the drone must not be operated in a manner that interferes with operations at any airport, heliport, or seapull base.

So if I you know, again, kind of going back to this example, like, what what the PD did here, and this is these are just kind of suggestions. I don't I don't think there's necessarily one size fits all here. But what they chose to do is actually just put a geofence around these two, heliports.

And so that way and and this is a relatively small geofence. You know? We're we don't not talking necessarily one, two, three miles like some of the standoff distances that we've seen in the past. But, they decided to put a geofence, just to kind of keep keep this, you know, keep the the operator mindful of where these areas are, prevent kinda inadvertent flight, directly over the heliport.

But other scenarios are just suggestions. Like, you could do outreach to these hospitals just to try and learn a little bit more. Like, often do you have, you know, medevacs coming in and out? What kind of flight paths do they have?

And you could share some information about what you're doing with them.

You should include these locations in your preflight review. So just kind of being always mindful of where these are. And, even if you don't geofence them, at least you're mindful, okay. There's a help port there, so I should be kind of extra cautious, really keeping an eye maybe on the, ADS B data because a lot of medevacs do have ADS B out.

Or like I said, you can you can use geofencing. That's an option in our system and many others to, just prevent kinda inadvertent flight over these areas. So, yeah, and if you've got other ideas or or you've, kind of worked worked things out with your, local heliports, you know, would love to hear about it so you can share some examples or or, stories in the chat or or just reach out to us otherwise. So, again, I don't think there's necessarily one size fits all here, but it is your responsibility, your agency, and your pilot's responsibility to give way to, helicopters and such flying in and out of these places.

Okay.

A few just final quick notes about airspace. So this is just kinda like the parking lot category of a few other things to be mindful of.

So number one is that you do still need an additional special authorization to fly in prohibited areas, restricted areas.

TFRs as well would would be included in that. So, like, one, common thing is the national UAS security restricted areas, kind of those red hatched areas you might see on, UAS and utilize it. So you'd need some kind of extra approval or authorization to fly in those. Swaver doesn't cover that.

And then, it's worth noting when you're doing Beyond Visual Analytics site without a VO, your flight off two is still limited to two hundred feet AGL or the fifty foot from structures even if you're in a grid that's higher. So let's say you're, like, in a three hundred foot grid in your controlled airspace.

You're still limited to two hundred feet AGL if you're flying without a VO.

And then, you know, it would it would drop down from that. So if you're, like, in a hundred foot grid, then you're limited to a hundred fifty foot grid and so on. So just keep that in mind. Just because the grid is above two hundred does doesn't necessarily mean you can fly above two hundred.

And I think this actually I think this hits one of the questions. There's a a question that came in about just how do these waivers and authorizations, kind of work in relation to DOD military installations, in sensitive areas. So I think this probably answers that question is that you would still need some kind of additional authorization to, fly in those types of areas.

Okay. So now just kinda moving on to another, topic here, and that's operations over human beings. And so might be just kind of wondering, like, can I do it? Do I need a parachute? You know, what are the requirements and so on? So we'll kinda hit on this for a minute.

So the the waiver does allow flight over people, but you have to think about the flight purpose. And depending on your flight purpose, it dictates your requirements. So this is one of the key differences between a part ninety one waiver, this waiver, and, like, part one zero seven. Part one zero seven is just kind of explicit. There's a a way a regulation that specifically says you can't fly over people and you can't fly over moving vehicles unless you have an ops over people compliant drone, basically.

And there's waivers and stuff, so that's just kind of a general statement. But part ninety one doesn't have that kind of same, explicit restriction. Like, there's no part ninety one regulation that said you can't fly over people because they would cry over people all day.

So this is, again, just one of the kind of key differences. So, the the two kind of scenarios here. So if your flight is for the purpose of safeguarding human life, the key Okay. I think I'm back. Little Internet blip there.

But, yeah, the second part of the ops the twenty c, and this is provision twenty, the second part of that is that yours should minimize it to the extent possible.

Sorry for the technical issues there. I think I'm back. Just flipping Internet there. So, let me let me get back to the safeguarding human life. So when you are safeguarding human life for your the purpose of your flight is for safeguarding safeguarding human life and you do fly over somebody, the FAA, the the requirement in in the provision is that you minimize it to the extent possible.

Okay.

My, my friends in the background are are saying I'm good.

We will keep going. Sorry about that.

Alright. So I think I made that point.

But yeah. So let me give kind of a scenario of, like, where this would kind of come into play. So, let's say you're you get a you're doing DFR operations, you get a call for service, and you wanna get the drone as fast as possible to that location. So you might launch the drone and just point a to b as fast as possible. But let's say you incidentally and just for a brief moment, fly over somebody on the sidewalk on your way to the call.

So that is kind of effectively allowed under this provision. And then when you get to the call, your your pilots can make kind of small tactical decisions about where to place the drone kinda relative to what's on the ground to minimize this.

So the pilot can position the drone over the roof line of a building instead of, you know, a busy street or sidewalk right next to it.

And so just kind of thinking about, you know, minimizing it and just, doing it as little as possible is just kind of good practice to minimize this risk, sliding over people, but you are allowed to do it.

So then, in any other case, if you're if the flight purpose is not for safeguarding human life, then it's kinda one of two things. You either must have a drone that is ops over people compliant, and the FAA references back to part one zero seven, subpart d. So this is, like, the category one, two, three, four for ops server people.

You can check if the drone you're operating is is meets one of these categories. You can check on the FAA's website that I've put in small blue there on the right side.

And then the other option is if if your drone's not on that list, you can still equip a parachute recovery system that is compliant with the ASM standard and a mechanism to stop the propellers.

So for the x ten, we're gonna have a a parachute available very soon.

It's being designed to meet the the category requirements, but the parachute will also be ASTM compliant. So the the x ten parachute attachment will cover you in in these scenarios, or you can operate, in a minimal way over people without it when you're doing operations that are safeguarding human life.

Okay. So, hopefully, that kind of explains sort of your your two options that that you'd be thinking about.

And wanna kinda take a a a sidetrack here for a second. Like, airworthiness is related to to ops for people because, ultimately, the risk is, like, if your drone isn't airworthy and you have an issue, the drone could, injure somebody or or some in your property, damaged property on the ground, so on. So to really just to minimize the risk altogether, you should think about the the airworthiness of your drones. And so under part ninety one, your agency is responsible for self certifying airworthiness.

And so just kind of thinking about, like, how do how do I go about accomplishing that? Like, what kinds what kinds of things should I be thinking about?

The waiver doesn't speak to any of this, really. So there's no provision in the waiver that says you have to have airworthy drones or you have to do maintenance or inspections or anything like that. Like, this is just kind of best practice and good things to do to make sure that you're, safe.

So, what I would recommend and and there's this is a pretty minimal list, but what I would recommend is, have an error within a statement.

So this when you when you work through CAPS to get COEs before, there was actually a step that required you to upload an an error within a statement.

Since caps isn't part of this process anymore, that you don't necessarily get that prompt, but I would still recommend your agency have an airworthiness statement kind of on file for the drones you're operating.

We have examples of those if if you need one to, kinda know what to put together for that.

And then on a maintenance front, you know, definitely recommend following the OEM recommended procedures as, again, kind of a baseline. So things like scheduled maintenance, you know, following, like, the intervals for things like props and batteries and other consumables, doing your unscheduled maintenance.

And then after maintenance, one of the best practices out there is to do what's called a functional check flight. So, basically, this is a short kind of low risk flight, let's say, five minutes or less where you're kind of just exercising the drone and making sure it's all functional after you've done some maintenance. So let's say you've changed all the props on your drone. You wanna make sure that you did it correctly and the drone still flies safely and and and properly.

You can just do a short flight. Maybe just stay over the roof line or in a a dedicated, like, area and just kinda exercise that drone really quick to make sure it's good. So, and then just having a record of these things. This doesn't have to be too complicated, but just recording, you know, when maintenance is done, what was done in kinda simple terms. You know, I replaced all four props on June tenth, and then, like, a name and and, signature of who did it.

And then finally, before flight, you should also do preflight inspections.

And this is kind of a place where part ninety one regulations do come in. There's a a regulation ninety one dot one zero three preflight action, which basically says the pilot in command has to become familiar with all available information before flight. It's kinda one of those catchalls, but, doing your preflight inspection, helps that pilot in command, do that. So, the PIC, you wanna make sure they're verifying everything is ready for flight.

Again, it it should include the OEM kinda minimum recommendations, but you'll likely wanna expand on that a little bit.

And I'll give you examples. So what what we recommend at Skydio is actually kind of a two step or or two phased preflight inspection.

We recommend a kind of thorough full preflight that you do at the start of your shift.

This might take a little bit longer, but you're kinda going through everything. It's a full weather briefing, an airspace check, full check of the drone, the maintenance logs. You know, is everything ready to go? There's maybe notifications or, like, internal processes that you're running as part of that.

But and it might take a little bit of time, but you do it once at the start of your shift to kind of get settled in and and become available or become, familiar with all the available information.

But then after that, for every kind of subsequent flight the rest of your shift, you're doing more of an abbreviated checklist where you're just kinda quickly checking the things that might change throughout the day. So, you know, the winds change throughout the day. The thunderstorms come and go.

You're checking that the battery is charged every flight. So you're you're just checking more of kind of those quick things so that you can minimize the time between that call for service and and getting the drone in the air. So that's just a a strategy we recommend. But as an agency, you should be thinking about this and kind of putting procedures and processes in place, to ensure your fleet is there early.

Okay. And the next kind of big topic is qualifications and training. So this is another place where the waiver is pretty quiet.

It doesn't say a whole lot or kinda makes them just general statements.

So I've pulled those out here. There's there's a provision one that basically says the responsible person, has to make sure that the, flight crew is trained and has the necessary knowledge to safely operate, that they're informed of the waiver, and that they're informed and familiar with part ninety one regulations. So, it doesn't go into much detail, and it doesn't there's no provision otherwise that kinda says, like, training must have this or that.

So I I wanna kinda just pause here and and give again some, like, recommendations on, what your agency should be thinking about. So, and this is another kind of key difference between part one zero seven and part ninety one.

This really is kind of your agency's, like, self certification of flight cruise now strategy. So the previous part was self certification of the drone and the airworthiness.

Now we're talking self certification of the flight crews.

So firstly, it's it's a bit of a misunderstanding, but the remote pilot certificate is actually not an FAA requirement for part ninety one public aircraft operations.

It's definitely considered a best practice, and and we would continue recommending that, because if you if you have all of your pilots get their remote pod certificate, that gives you flexibility to do both part one zero seven operations.

You'd be fully qualified there and part ninety one operations under this waiver. So it is a best practice, but it's actually not an FAA requirement. And it it doesn't, it doesn't cover any of the skills and maybe only part of the knowledge that your pilots. So I'd say it's kind of a minimum qualification, but just simply getting your remote pass certificate and saying, like, that's our self certification strategy, I I think is kind of insufficient and maybe missing the mark a little bit.

So here's just kind of a an analogy I put together, that that might help to kind of get agencies thinking about this. And so, the analogy is, you have, like, a bucket. Let's say this is kinda represents your pilot, and you need to fill that bucket with knowledge and skills so that they become safe, proficient operators. So kind of the goal is to fill that bucket up, with, you know, different lesson and and knowledge and skills and so on.

And and once you hit the top of that bucket, you've got a a safe proficient operator.

And so there is a small part of that that is an FAA requirement. Like, under part one zero seven, the remote positive key is an FAA requirement. So that that, test and basically passing that will kinda fill that bucket up with a certain amount of knowledge on airspace and weather and, things like that. But it doesn't again, it kinda doesn't cover, like, skills or other knowledge that the pilot might need. Under part ninety one, there's actually no requirement. So, you know, you can use that remote pass certificate to fill that bucket up a little bit, but, again, it's not gonna be totally full.

So then, and a lot of agencies do this really well. Like, the next thing that we recommend is to have an in house kinda agency training.

And this nearly always includes the OEM, the vendor's training as part of that.

So you might, and this varies, but you might have some agencies doing a couple days where they're kinda working through some flights, adding in additional knowledge, and so on, where some agencies do, like, a full week or two even, which is awesome.

But you wanna have some kind of in house agency training to put more knowledge and skills in that bucket.

And then finally, yeah, let's imagine, like, the bucket has a tiny little pinhole leak in it. Right? So just over time, these skills might kind of degrade or, you forget things or, you know, the industry changes, quite fast. So there may just be new knowledge that wasn't part of that initial training. So you wanna have also some kind of recurrent training, and some strategy around that.

So I'll I'll just kinda give an example, one one level, more detailed than that. So here's what kind of a a training strategy might look like. So your agency might initially require all pilots to get their remote pilot certificate.

Again, this is considered a best practice, not necessarily an FAA requirement, though. Some agencies will actually use their remote pilot certificate as kind of a a barrier to entry, so to speak. So if they're posting, like, a job posting internally for drone pilots, this remote pilot certificate can kinda be a way to, force out, like, who's really serious about this or who who isn't.

So it's another way to use that.

Then the then the agency would do some kind of in house training on the knowledge topics that are kind of missing from that road pass ticket. So things like the part ninety one regulations, the the agency's waiver. So remember that the waiver requirement is that everybody's familiar with the waiver, so you'd cover that. You'd maybe go in-depth on the agency's airspace.

So the remote path certificate kind of broadly talks about airspace, but you might wanna deep dive on your specific airspace and things to look out for.

And then the, agency's policy. So, again, remote positive good doesn't talk about policy and SOP at your agency, so you may wanna, include that as part of the training.

Then it's pretty common to transition to kind of more skills based training. So that might include, like, our Skydio x ten and x ten doc training where you're gonna, meet with our trainers and basically learn all of the features and buttons and kind of functionality of the system.

But even then, you might wanna add a little bit to that. So you might wanna start introducing some scenario based training and and kinda put these these skills to the test in a simulated but kinda real type of scenario. And that really helps to build some of that aeronautical decision making and kind of applied skills.

So that might be kind of what the agency's training looks like initially, and then they'll do some kind of, like, monthly or quarterly training after that just to kinda keep those skills fresh, bring everybody together, talk about new things, new features, etcetera.

So, yeah, if if you're, on this webinar and and you're, like, command staff in your organization of leadership, I would certainly encourage you to I know dedicating time to training is hard. You know, everybody's kinda understaffed and and just working hard to kinda get the basic function done. But if you can find ways to just give your drone program a little bit of time to to do this training and do that that recurrent training, that'd be, I think, time well spent.

Or if you're, if you're not command staff on this webinar, but you're going, man, I I wish I could convince my command staff to give me more time for training, you're certainly welcome to point them to this webinar or, you know, I'm happy to kind of make the make the pitch again. But I think this is really important, for the overall success of your joint program.

Okay. Last topic, and then, I'm gonna get to some questions, and, hopefully, my my Internet's holding out here. So the last thing is just kind of on record keeping and reporting. So there are some requirements for record keeping in the waiver, things like tracking the evidence of your training, a current list of pilots, current list of drones, and your flight times. So, this information does not need to be kind of proactively provided to the FAA on any kind of, you know, monthly, quarterly basis, whatever. You should just be tracking it. And then if if the FAA requests the information from you, you'd produce it at that point.

It's also worth noting that the the caps reporting is not a requirement anymore, so you don't have to log in to CAPS and do any kind of monthly reporting. It's just, just these things that you're tracking and and producing upon request.

And then reporting, and this is more kinda accident incident reporting.

But there is a provision reminding agencies that the NTSB requirements still apply. It's worth noting that the NTSB requirements apply to any drone operation you do, whether it's part one zero seven, part ninety one, BVLOS, visualized site, it doesn't really matter. These requirements apply to any during operation, so you should become familiar with them.

There's a website here in blue. The NTSB put together a really good, kinda like a four page memo on what their requirements are and some examples and so on.

So I I would definitely bookmark this, memo and just review it and kinda become familiar with with the requirements there.

And then, the FAA has two additional re reporting things that they wanna know. So the first one and this is the very last provision in the waiver. The first one is they wanna know anytime the drone gets within five hundred feet of a crewed aircraft. So, basically, like, an encounter between your drone and and an aircraft.

They want that reported, basically, like, as it happens. So if this event happens to you, you would just, send the FAA note via email.

And the second one is they wanna know, anytime there's a loss of control event. And, again, if this were to happen to you, just send the FAA with an email and a brief description.

Okay. So left about ten minutes for questions.

I'm just gonna take a peek here and see.

Okay. So first question and there's some good ones here. So the first question is, you know, what if you don't use a VO, just a a pilot? So I think this is probably a question in reference to the visual line of sight.

So let me see if I can find it here. So, yeah, you you can do visual line of sight operations with just, like, the single pilot and command flight crew. I kind of gave, the exaggerated example here of, like, a full full crew of all positions, but you can definitely do visual on-site with just a pilot in command who can see the drone and see the airspace around it.

That's definitely allowed.

Alright.

There is a question about the executive orders, but I'm actually gonna pass on that one. So, we're still reading those, and and we'll definitely kind of put out some information, with Skye's perspective on that. But, yeah, still pretty fresh. Everybody's still kinda digesting those. I'm gonna pass on that one for now.

Question is, is it possible to get the waiver in advance of getting an aircraft?

So the answer is yes. You don't need to have, like, a an aircraft specifically picked out necessarily before getting the waiver.

These waivers are actually kind of aircraft agnostic now. When you submit the application, you don't even necessarily need to list, like, a specific make, model, or serial number, anything like that. You do need to make sure that the the drone you use meets the requirements.

So, you know, things like has the ADS B solution, has anti collision lights, has standard remote ID, etcetera.

Standard remote ID is a requirement in here. I didn't didn't kinda cover it, but it's one of the provisions. So you need to make sure your drone, meets those requirements, but you can certainly get the waiver in advance of kinda picking one, because you don't necessarily have to list a specific make and model.

And that's covered too. If you go to our guide and, you look through that and you you request the resources from us, some some of the resources that we provide is, like, how to fill out the seventy seven eleven to kind of be aircraft agnostic.

There's a question here about, like, does the fire service need a part one zero seven with the waiver? So I'm gonna kind of interpret this question as as, like, the qualifications thing. And if I get this wrong, just let me know. But, kinda back to to this this slide here. So when you're flying under part ninety one and under this waiver, just to kinda recap it, the remote pilot certificate or some people call it, like, the part one zero seven certificate, but it's really a remote pilot certificate as a name.

It's not an FAA requirement, but it's definitely considered a best practice. So, you know, we would still recommend that all your pilots get that certificate. And that way you're covered. You can fly on a par one o seven. You can fly on a par ninety one.

But do remember that the the remote pilot certificate is kind of just the beginning of your training, and you should do you you should do more on top of that to cover the the other knowledge topics, part ninety one and so on, and then the skills as well.

Okay. And then, question here about kind of again, I'm I'm sort of having to interpret the question a little bit. So if I get it wrong, just let me know. But it it's kind of a question of, like, how do we move forward, and expand operations under these waivers and not get, like, locked into a specific, aircraft or specific vendor and so on. So, and I think this ties back to the the the question I answered too about getting the waiver in advance of the aircraft. So, again, the waiver does not necessarily need to be locked specifically to kinda any one drone make or model or any vendor.

You can write the waiver in such a way that it covers kind of your future, or your current fleet and your future possibilities.

But, again, just like the the drone that you ultimately operate under the waiver has to meet, the requirements of it. So, so hopefully that that answers that one.

Another question here is, you know, kind of along the lines of my my department has, various Beyond Vision on-site waivers already.

So is this new waiver kind of like a a new thing, or or should is the old one, you know, good enough and so on?

So as kind of a broad statement, if you have some of the older types of waivers, like tactical, first responder, I I would recommend getting this new waiver. And once you do and, again, like, you can download the sample here so you can basically kind of see what the waiver you're you're, likely gonna get will look like.

You can likely let those previous COAs, expire, because you might find that the new waiver kinda covers, the types of operations that those waivers allowed or or maybe even gives you more capability, which is always good.

So you can potentially just let, like, your old waivers expire.

There was also this is probably a a small group of people out there, but there's also a group of agencies that got kinda the first versions of these Beyond Bitlyzed site waivers.

They still looked like a COA, and, you know, they did allow this Beyond Vision Eye site without a VO, but it it kinda looked more like the old style of COA instead of this new waiver.

And and I would say there's, I don't know, probably fifty or less agencies out there with this old one. But if you're one of those agencies and you're on the webinar and, and maybe the the the person who asked the question has one of those, you can just get this new waiver so you can go back through the process.

It's really straightforward and basically get yourself the new kind of version of it. And then, again, you can just kinda let that old, waiver expire.

And it's gonna be pretty similar, so there's not a a bunch of differences. Like, functionally, you can still do the same kinds of the envelope on-site operations, but the new waiver has some advantages of, like, less record keeping, and there's no caps requirement and so on. So there there are some advantages to just getting the newest version, if you're in that situation.

Right.

What additional question here, but just what additional requirements are there to get a four hundred foot damage on ISA waiver? So that's a that's a really good question. So, I I kinda briefly covered this in my April webinar. So, you can also go back and and just, rewatch that.

But kind of the the quick summary and recap of it is if you wanna do a four hundred foot approval, you need to deploy, some kind of noncooperative detect and avoid system. So the two hundred foot approval, you can do that with just ADSB, but But then the four hundred foot, you have to have ADS B and a noncooperative detection of white system. So this would be something like, Ddrone Beyond system with the radar panels, or there's CASA g systems out there and on other kinds of radars and so on. But it has to be a system that's capable of detecting aircraft without ADS B.

So that's kind of a basic, requirement. You know, there are options out there. We're partnering closely with D drone to basically have a direct integration between their system and ours, which will be coming soon. So, like, you'd see, the noncooperative targets from the D drone Beyond system, directly in Skydance GCS, which will be awesome. We're actually gonna do some, content about that, as well, so kinda stay tuned for that. But but, yeah, basic requirement.

And then the request itself, there's, like, two additional forms, that you need to fill out. You need to provide the FAA a bunch of information about that that system, to them to review it. So, hopefully, that answers that question.

Okay. A minute or two left here.

Question is, if if I if I'm if I'm an agency and I get this part ninety one beyond the line of sight approval, do I need, like, the traditional COA? Or the way I kind of interpret that is, like, do I need that, blanket COA or the jurisdictional COA? That was kind of the names for them, previously.

So I I would say, again, it's it's kind of a generic statement, to a group. But I would say you don't need that anymore because this new part ninety one beyond Visual I say waiver covers visual and a site operations, and you can write it in a way that actually covers nationwide, like, all uncontrolled airspace and then all controlled airspace below the grids.

So, yeah, if if I were an agency today, I would just get this part ninety one.

Beyond when I say waiver is, like, the first thing, and that's gonna cover visualized site beyond visualized site and and probably cover your needs for for quite a while until the next, best thing comes out at least. So Okay.

One file. This maybe is a good slide to leave up. There's a question here about ADS B, so let me just go back to that.

The ADS B standards, kinda what's allowed and what's not allowed. So, yeah, this is provision thirty four and thirty five. So if you if you downloaded that sample waiver or if you have the the waiver already, provision thirty four and thirty five are those requirements. And then here's just some examples again of systems that meet the requirements and then some examples of systems that don't.

Okay.

And I'll I'll do there's one final one here. How does this waiver interact with the new public safety shielded operations waiver? So, I think what what the, person asking this question is referring to is, like, the part one zero seven.

It's had some different names like, obstructed waiver, shield waiver, etcetera. But there is basically a part one zero seven waiver option out there.

And so kind of the quick quick differences, this part ninety one waiver, was really kind of designed for DFR, and it it actually allows, like, that full remote operation where the pilots kinda inside, you know, at a real time crime center, remote operation center, etcetera, and then flying a drone remotely to calls to get there before first responders. So this waiver allows that. The part one zero seven waiver, and, again, I'm I'm assuming they're talking about kind of this common shielded obstructive waiver, but that one was meant more as, like, a tactical beyond which line of sight, kind of part one zero seven option. So it actually requires the pilot to be still on-site and the drone to be flown within a mile of the pilot.

There's a requirement for, the parachute and kind of ops over ops over people compliant drones if it's over a certain weight.

So you're certainly welcome to pursue that. That could be, like, an additional capability, but I'd say the biggest difference is the part ninety one allows remote operations.

It's kinda fully designed for DFR, whereas the part one zero seven was more designed for kinda tactical use cases.

And and the second the the question wasn't specific to this, but I'll say it anyways. There are part one zero seven options for DFR as well.

So you can get a part one zero seven waiver to do remote operations that are effectively, like, the equivalent to this part ninety one, waiver.

So if you'd rather kinda do your operations on your part one zero seven, that's an option for you.

But just know that if you do, there's effectively a hard requirement for the, the parachute and the ops over people compliant drone. So you don't get this flexibility here to fly over people without it. It's it's basically a hard requirement under parlance seven.

Okay. A few minutes over, but thanks, for those of you that stuck with it. Thanks for, attending. And, yeah, hopefully, this information was all valuable for you.

We're gonna have another webinar probably in in August at some point. So, we've got some ideas for content around that. But if you wanna hear me kind of ramble on about some, regulatory topic, shoot me a note as well. So, yeah, thanks for joining, and we'll see you on the next one then. Stay safe.