Episode 7: What’s New in Part 91 BVLOS for Public Safety in 2026

Everyone, good afternoon or good morning, depending where you are. Welcome to another, regulatory updates for public safety webinar. I'm Jakee Stoltz with Skydio regulatory team again.

And, yeah, this is episode seven, of just kind of a ongoing series that we're doing to to give regulatory updates for public safety, across the US, as as things evolve and change.

For this year, we're kinda starting off a year fresh.

What I wanted to do is recap a little bit of twenty twenty five and and just kind of talk about the breakout year, really, that Beyond Visualize Site Operations and Public Safety had.

So we'll give a little bit of update there.

And then I thought it would be a good opportunity to to just kind of level set. And and there's been a lot of changes in this process, just kind of continual tweaks by the FAA and changes things that aren't needed anymore, things that are.

And so the the process has just changed enough since I did this webinar or, a topic back in, like, April, May, June kind of as this process initially rolled out. There's been enough changes that I thought it'd be worth just kind of starting fresh and talking about what the process is today.

And so there might be a little bit in this webinar for agencies that are in different stages of the process here. So if you're if you're still, like, just thinking about getting into this, this will be a kind of a clean, fresh guide on how to get these waivers, what they allow you to do. If you've already been through the process, you might still learn a little bit and get some tidbits along the way. So so without further ado, let's let's get into it.

So, again, last year and and really, actually, it kind of all started at the tail end of twenty twenty four, but last year was just a a breakout year. It's super exciting. I've been doing this for a long time, like thirteen, fourteen years, and there's really never been a year that that I'll talk about here in a second. But I've never seen a year like this where just kind of the pace and scale of the on vision ISA operations happen. So so to rewind back to end of twenty twenty four a little bit, all starts with New York City Police Department receiving this revolutionary FAA approval.

It's kind of the first approval of its kind that allowed Jonas first responder operations beyond Visualize site across the entire city. And this could be done without visual observers, without kind of complex detect and avoid equipment, just this kind of instantaneously scalable approval across the city.

A couple months later, right at the tail end of the of twenty twenty four, Las Vegas Metro gets a similar approval as well as Oklahoma City Police Department.

And what was really key, the Oklahoma City Police Department approval was really key because it removed the requirement to have kind of a special type of airspace called Moet C Veils.

Earlier approvals, New York, Las Vegas, were kind of based on this.

This is airspace around the busiest airports in America where ADS-B equipage is high.

But Oklahoma City's approval kind of flipped this, removed the airspace requirement, and really created, like, a blueprint that was scalable then across the entire US. So, like, any agency at this point was kind of eligible for this for this type of approval.

And out of Oklahoma City, we we kinda got to this this blueprint right here. So conceptually, as long as you could fly at lower altitudes, two hundred foot and below, and use ADS-BN technology, which is built into our Skydio drones as men well, as many others, you could get a beyond visual line of sight approval, kind of remove the need for those visual observers to be standing outside, standing on rooftops, looking at the airspace, and really remove, like, one of the key kind of hurdles to scaling Dronez first responder.

And so that that really kinda kinda set us off to the races. Right? So this graph here shows really, like, how quickly the processing times for these waivers dropped. So those first couple approvals and this is just true kind of generally speaking with the FAA. The first time they approve something new, it just takes a little bit of while takes a little while to talk through the safety case, think through the mitigations, get these things signed.

But by early twenty twenty five, they were starting to get these approvals out in kind of the the standard sort of FAA timelines, two months, three months, give or take.

But in really, like, the April, May time frame, that really got accelerated, and the FAA created this new streamlined process to get these waivers. So, again, like, this is pretty remarkable. Like, basically, from April on, the entire year, like, the average approval times were just under a week, which, again, has, like, never happened in the at least as long as I've been doing this type of work to see, like, an FAA turnaround and beyond visual line of sight approval in that amount of time. So huge kudos to the team that, you know, both got, like, the initial approvals done in New York City and Las Vegas and Oklahoma, and then the team that took the ball and just created this super streamlined process to really accelerate this. And, I mean, even during, you know, government shutdown, the FAA was still signing these things in under a week. So just tremendous credit to them, and, it was it's been amazing.

And then, that, you know, those timelines and just kind of the streamline of process really took, us from, like, you know, quote, one approval to a thousand, in about a year. So we ended twenty twenty four with three.

End of twenty twenty five, it was about nine hundred. And already just this month for twenty twenty six, they've issued over seventy approvals already. So I would say by now, we're we're probably at a thousand or, close or maybe more. But, yeah, again, it's just been this tremendous gross growth of approvals, and scale for Beyond Visual Onesite.

And then, you know, beyond just this streamlining of kind of the standard Beyond Visual Line of Sight waivers now, we did have some additional breakthroughs last year in Las Vegas. So, you know, had to pull one of the pictures from Las Vegas Metro's event a couple weeks ago. The the photography and the event was just, like, amazing. Had more than one person ask me, you know, tell me nice AI, but, these are real pictures. This is a real event. You can go watch watch it. So Las Vegas Metro, they secured in September of last year, they secured one of the first Beyond Bridgeline site in zero grid approvals.

That was kind of a new process that got stood up at the end of the year. And then they also received a Part one zero seven multidrone approval, which is kind of a first of its kind. So, and we'll we'll talk more about these as the webinar goes on. But but, yeah, some kind of breakthroughs at the end of last year that we're really hoping to see some scale around this year.

So, again, just like an incredible year of both kind of streamlining and accelerating just sort of standard, you know, kind of two hundred foot beyond the line of sight operations, and then we're continuing to to push the boundary with our with our partners like Las Vegas Metro.

Alright.

So, yeah, now I just kind of want to, again, like, get back to the basics a little bit.

Again, just things have changed.

The process is a little bit different than it was, you know, April of last year. I'd say everything is kind of improving and getting more streamlined.

So these are all kind of positive changes that are happening.

And so, yeah, good chance to just go back, kind of get back to what do you need to do to request one of these waivers if you don't yet have one, what is in these waivers.

And I think this will be valuable for both those that already have the waiver and those that are looking to get it. It's like, what can I do? What are the requirements, restrictions around this this thing?

And then as I mentioned with Las Vegas Metro, there is a new process now to request a part ninety one airspace authorization, and this is what would enable you to fly in areas closer to airports like zero grids, fifty foot grids, hundred foot grids, kind of areas that might otherwise sort of limit your your altitudes.

And so we'll talk a little bit about how to get that airspace authorization as well.

Alright. And just a reminder, we do have a website guide that covers all of this. So you can grab the QR code with your phone if you have it handy.

The link is also right there. They go to the same place.

In a couple places throughout our website guide, there's mentions of, like, request the form or request the example or something like that from Skydio.

You can click those buttons in the website. It's just gonna basically take you to an email address where you'll send us an email for that form or document or whatever it is.

So the the email address shown on the screen here is the same email address. So, like, if you need kind of our concept of operation example, you can just email that.

I monitor that inbox as well as the the rest of the regulatory team here, so we'll we'll get back to you.

And, yeah, the website covers, really, the whole process. So it does cover how to get the, the basic part ninety one public safety waiver, the steps you need to go through, the forms, where to send them, and then it does have some information as well now about the airspace authorization process. So, so, yeah, feel free to refer back to that after the webinar or really at any point. We're gonna continue to keep that up to date. Alright.

So, yeah, let's let's first talk about how to get one of these waivers.

So if you don't have one yet, this is basically how to do it.

And so there's kind of two steps that I've sort of grouped together here. So firstly, you wanna make sure that you are actually eligible for this waiver.

Not everybody is. There are some requirements around this, and we'll talk about that. And then if you are eligible, you're going to complete a couple documents and email those to the FAA. And that's basically a request.

I am gonna kind of focus today's webinar on the two hundred foot waivers because those are by far still the majority of the requests both that we get and agencies across the country are requesting.

If you're doing a four hundred foot request, that's still an option. I've kind of talked about these two options before, two hundred, four hundred. The four hundred foot requests, they do require you to have additional detect and avoid technology that can detect non cooperative aircraft.

So we're talking like a radar system, something like Dedrone Beyond.

The process is similar. There's there's basically just, one extra form that you need to fill out for that. So so, again, I'm gonna kind focus on the two hundred foot waivers today, but the four hundred foots are very similar, just a bit of extra information you need to provide.

All right. So eligibility.

So these are the two requirements here. So your your agency must be eligible to operate as a public aircraft operator. It's kind of requirement number one.

And, at a high level, this is basically means that you're a government entity. So a part of city government, state government, county government, federal government as well.

So, you know, your kind of typical city police department, county sheriffs, state highway patrols, you know, National Guard or equivalent type of organizations, federal agencies.

These are kind of typically examples of of agencies that are eligible for public aircraft operations.

Not every agency will fit this, though. So, you know, examples of maybe, like, nonprofits, volunteer search and rescue, private universities, things like that. So, I I do recommend, you know, really for all of this, that you go, read more about this. The website also has a a little more detail.

There's some US code. There's FAA guidance on that will help you determine if you are a public aircraft operator or not. I'm just kinda giving some high level generalities on this. So you need to be a public aircraft operator, and then you also need to be a public safety organization.

This definition's a little simpler. It's just an entity that primarily engages in the safety and well-being of the general public, also just out of, like, US code.

But, yeah, you your agency needs to meet both of these requirements to be eligible for this waiver. If you don't meet these requirements, there's other options for you under, like, part one zero seven. So there's some part one zero seven waivers that are kind of equivalent, different process. But but, yeah, there's options out there if you don't meet these requirements to get this this streamline waiver.

Alright. And then, assuming you're eligible, to actually request the waiver from the FAA, you need to complete a set of documents and just email them to the FAA.

So, I'm actually just gonna kind of show those really quick here.

Again, there's there's kind of further guidance, both from the FA and from us on, how to fill these out, things to look for. But I just wanna kinda show these at at a pretty high level to see if kinda have, like, this mental image of of what you're looking for when you're preparing these documents to submit. So one of the documents that you'll need is called a form seventy seven eleven.

You know, it's government form. It has a a number kinda just like your tax forms, seven seven eleven. But at any rate, the act the FAA actually has a guide on basically exactly how to fill this out. And what what is shown here is essentially what is how you'd fill it out if you followed their guide. So the first page, you you type in some information.

The second page basically stays blank with the exception of your date and signature at the bottom.

And there's kind of a common question of, like, who should sign these documents? Like, kinda ultimately, who who takes responsibility for this or who is responsible. So the the person that signs these documents from kind of the FAA's perspective is is what's called the responsible person.

And it's kind of in the name, so it it it probably wouldn't surprise you to hear that this person would be responsible for the drone program, flight operations under this waiver.

They're gonna be responsible for making sure they know the waiver themselves and that all the the rest of the flight crew is familiar with the waiver, making sure pilots are trained and qualified.

There is some kind of minimal reporting requirements. This person will be responsible for that and so on. So so you are when you sign these, you are, you know, taking responsibility for this program and and kind of all the pieces of it.

What I typically recommend for agencies is that it's somebody that does have some knowledge of the drone program kind of day to day and could actually answer some of those questions. Like, you know, if the FAA were to ask, how did you train all your pilots, and, you know, what is the evidence of that? Like, you you I think you'd want somebody that has kind of some understanding of, yes, I trained them. Here's our records, and just is, like, familiar kind of day to day.

I think it also, though, should be somebody that is in more of, like, a leadership position and is kind of in good standing at the agency that can take responsibility for this.

So it's up to you to to kind of find the right person in your agency who sort of has that authority but also kind of understands, like, day to day what what is happening with the DRIP program.

It doesn't have to be a person that has a remote pod certificate, so that's kind of one key thing. They don't have to be a pilot in the seat, so to speak, themselves, but I just recommend that they do have some working knowledge of the program.

K. So that that's one form that you're gonna fill out and sign and send in.

Let's go to the next one here.

There's gonna be a checklist, it's called. And this is a document the FAA put together that basically tells you the requirements of the waiver, like, ahead of time. So there's a two hundred foot checklist and a four hundred foot checklist. Just make sure that you're grabbing the right one for the waiver that you're requesting.

And you'll see here as as you start to kinda go through this checklist, there's basically rows of requirements.

And these are requirements that kinda range from, like, drone requirements. The drone has to have anti collision lighting. It has to have standard remote ID. It has to be under fifty five pounds and so on.

There's requirements about the altitudes that you can fly at, you know, visual line of sight four hundred, beyond visual line of sight two hundred. There's weather requirements.

There's the reporting requirements and so on. So there there ends up being, twenty things in this checklist today at least that could always change.

And then I'll just kinda click through the pages here.

And what you need to do at and this is the responsible person that is signing this document as well. You need to initial every row, and there's a space for that on the far right side.

And then at the very bottom, there's a table where you just kind of fill out your your information again. So your agency's information would go on the left side, name of the agency address, and so on. And then the responsible person fills out their information on the right side, signature, name, etcetera.

K. So seventy seven eleven checklist. The third document is that the concept of operation. So one of the checklist requirements, I'll just point it out here while I got it, number three here. It says you have to you have to submit a complete description of the proposed operation kinda with your request. So, so the way we recommend agencies do this is is this CONOP document, this concept of operation.

And so the purpose of this document is a little bit different, I would say, than the checklist in the form seven thousand seven hundred eleven. The checklist is really like the the hard FA requirements. You know, that's what they want to see, and you're initialing it, saying you're going to comply with those things.

The CONOP, I think, serves a little different purpose in in, you know, number one, it it tells the FAA a little bit about what you're doing. But I think more importantly, it's for you, it's for your agency to, like, think through some of these drone program elements. So it's one thing to, you know, initial check a few boxes, submit something, and get a waiver back, but it's another thing to actually understand your waiver, understand your airspace, understand how the system works, understand how you're going to meet all those requirements and operate under them. So I think this ConnoHUB is actually pretty useful for kind of going through those items and, like, thinking about those, you know, with your with your pilots, with your leadership, etcetera, and just kind of think through these items. So let me give an example.

And actually, when you if you request the the Conop example from us, like, this is exactly what you'll get, is basically what I'm showing here. So so an example is airspace. So the waiver is just going to say us kind of a generic thing about you can fly in uncontrolled airspace. You can fly in controlled airspace below facility maps.

You gotta give way to aircraft and stay out of their way. But it doesn't actually go through, like, what your airspace is, and that's your responsibility. So I recommend, you know, doing a little research. Like, what airspace am I in? Am I near airports? Are there hospitals with helipads that are within my city that I should be thinking about?

Are there areas that are zero grids that I'm gonna have to stay out of entirely and so on? So kinda think through those things.

When you're flying beyond visualized sight, you're gonna need an ADS B solution. You know, think about how that system works. The drone you're using, does it have one? How does it work? Skydio X10s, it's just built in, and we actually kind of show you screenshots of how the system works, when it's gonna alert you of traffic that's coming in and so on.

And there's other things in here. So basic information about the drone. We have, like, all of our operator manuals linked in here.

Training. You know, think about how you're gonna do training. I'm gonna touch up more on these in a minute, so I'm gonna just kind of skim through this quickly at this point. But but, yeah, use this Conop as as, number one, it's gonna check the FAA's box.

But number two, just use it as as kind of this internal document to to think through these things. Right?

All right. Okay. So you're gonna basically take those three documents. The responsible person is gonna sign two of them, initial all the requirements, add in a little bit of information about the agency, and then you're just going to email them to the FAA.

And as shown before, the kind of average processing time is under a week still, so you should have a waiver back, pretty shortly.

And, honestly, I'm sure the FAA would echo this.

A lot of times, the biggest issue is just, like, the agency forgets an initial on one of the rows or they don't sign something, they, like, forget the signature on the bottom of the checklist. So, honestly, a lot of the issues are just kind of, like, basic, didn't check the box or didn't sign something type of thing. The FAA will let you know if that happens, but as long as you're thorough and you just go through it, it should go through pretty quickly.

All right.

So let me take a look actually at the questions for a minute. We're gonna get into the waiver, like, requirements. This actually kind of dovetails nicely with the checklist in a second, but just gonna take a quick peek at the questions here.

And I think we're gonna answer some of them.

But, yeah, operations, let's see. So do do you do you have to complete a new Beyond Virgin Islands state waiver for four hundred foot if you already have one for two hundred foot, was the question that came in. So the answer would be yes.

And this is actually a really good question because the four hundred foot waivers, if you get a four hundred foot waiver, you're gonna have to provide information about the detect and avoid technology with a document called a CMD document. That's an extra document that I I don't have listed right here.

So that's that extra document for the four hundred foot approvals.

But assuming you successfully get through the process and you're issued a four hundred foot waiver, it will actually include the ability to do two hundred foot operations as well.

And essentially, what what happens is the FAA will say you can fly a four hundred foot within kind of the detect and avoid, operational volume that you you you're gonna provide this in the application, and you're gonna say, like, our sensor covers x, y, z area. So that's where you're gonna be able to fly four hundred foot. And then outside of that area and really, like, nationwide then, you'll be able to fly to two hundred foot. But it doesn't go the opposite direction. So if you get a two hundred foot waiver, it doesn't allow you to kind of automatically do four hundred foot operations. You'd have to request that separately.

So one contains both, and the four hundred foot contains both. The two hundred foot is just two hundred foot.

There's a question about the the drone operator license, the remote pod certificate.

I'm I will hit that one as I go through what this waiver requires. So so keep an eye out for that. We'll get to that in a second here.

And, yeah, you know, copies of the CONOP, copies of this document.

Basically, if you send let me go back a slide. This is noted on the website, but if you send this aviation underscore regulatory at skydeo dot com an email, I'll see it. We'll get you the con op.

That's an easy one.

Okay. I'm gonna there there are some good questions coming in. I think I'm gonna answer quite a few of them in this next section. So let me continue on, and then we'll kind of I'll try and kind of bounce back and forth between questions and, section at a time here.

So okay. So what does this waiver, like, actually allow you to do? You you get one. You submit the documents.

You've got a two hundred foot waiver now. But like I said, it's it's kinda one thing to ask for the waiver and get it. Pretty streamlined process these days. And then it's another thing to, operate safely and understand it and kinda fully comply with it.

So whose job is this to, like, know the waiver and make sure all your flight crews know the waiver? It's the responsible person's responsibility.

So, again, it's kinda in the name. But one of the first things that this waiver will say is the operator listed on the waiver is responsible to the FAA for the safe conduct of the operations. So they're responsible for making sure pods are trained, pods are informed of the waiver, they're informed of part ninety one regulations, amongst other things. So, so what I cover here, I I, you know, I wanna help you understand these things, and I'll kind of speak to them in, like, plain language. This is what this provision means, what you can do, but it's also your responsibility to to know these things.

Alright. So with these waivers, you actually can do visual line of sight. And this is effectively like an equivalent part one zero seven type of line of sight. So you're gonna do Visualize site operations under part ninety one still, but they more or less match part one zero seven is kind of one way to think about it.

There still is a little bit of misunderstanding out there about what visual line of sight is. So to kind of be clear, visual line of sight is when the entire flight crew can, at a minute's notice, basically look up and see the drone and see the airspace around the drone. So I'm gonna just go to the next one here. Visual line of sight is not where, like, the pilot is inside flying and somebody outside can see the drone.

And this used to be approved. It's kind of the first responder beyond visualized sight. Some of you may remember this from from a couple years ago. This used to be kind of how DFR was done.

The pilot would be inside. There'd be a visual observer outside scanning airspace.

But the FAA is essentially not issuing those waivers anymore and has kind of moved past that as a as a way of doing this. So so, yeah, pilot pilot has to be outside kind of flying with a controller, so to speak, and a good view of the sky and the drone. But when you are flying visualized sight, you can fly up to four hundred feet, or you can fly up to the facility map altitudes in controlled airspace.

There is a couple questions in here about, like, class d airspace and stuff like that. So that's I'm gonna hit that here in just a second.

Beyond visualized site.

So if you're flying where the pilot cannot see the drone, you're flying beyond visualized sight. So you just have to keep with these two hundred foot waivers that is, you just have to keep the drone below two hundred feet AGL.

And I I didn't mention it, but this graphic kind of illustrates a point here. You there is a a limited exception to go above two hundred feet AGL as long as you're within a hundred foot of, like, a structure, an object, some kind of obstruction.

This used to be fifty foot. For those, you know, that may recall back, or you may even have a waiver that still says within fifty foot, the FAA kind of doubled that last year or so.

This is kind of the standard now.

And then if you're flying in controlled airspace, again, that facility map becomes the the hard ceiling for your operations unless you go get an authorization.

When you're flying beyond Visualize site, you do have to have an ADS B solution, as mentioned.

So this is built into x tens, and it it just works. It you don't have to, like, turn it on or do anything. It's just active.

It's functional on the controllers, in DFAR command when you're flying remotely, just kind of across the board for X10s.

Of note, like, the ADS B solution does have to be the the waiver will will have clear requirements on this, but it does have to be a a sensor or some kind of solution that's, like, local and owned by the entity, the agency, or an FA approved third party data source.

So just note, I know, like, a lot of agencies have used these systems in the past, these, like, FlightRadar24s, FlightAware, etcetera.

They're they're great great solutions for kind of, like, just general airspace awareness, but they're not really intended for collision avoidance purposes. So those systems don't kind of qualify for this requirement.

But with Skydio, it doesn't matter. You've got a built in solution that that will cover you.

Okay. So if you're if you're an agency that is, you know, your your whole jurisdiction is in class D airspace, like one of the questions here, or just any control airspace for that matter, you are allowed to fly in control airspace without any extra coordination approvals, etcetera, as long as you stay below the facility map altitudes. So you don't need to go get Lance.

LAANC is not applicable to part ninety one anyways, but you don't need to go use that system. You don't need to make radio calls. You don't need to get tower approval or anything like that. So and just as an example, I grabbed an airport Salinas in California just as an example here. So and and these are FA data sources. There's a website called UIS Visualize It. There's a bunch of different apps out there that have this data displayed.

We've also started displaying this data in Skydio Cloud. So when you're doing, like, remote operations, you'll see this as a map layer. But, basically, these these controlled air spaces are gridded up, and then every grid's gonna have a number in it.

And that number is the maximum AGL altitude that you can fly with this kind of just standard two hundred foot approval, that is.

So that's kind of how you'd know if you're in Class D airspace, sort of, can you fly, and how high would that maximum altitude be.

Okay.

And then, related but kind of separate, there are heliports and airports that are in uncontrolled airspace. And there won't be, like, a facility map grid in these cases to kind of guide you on, like, where you can and can't fly.

But the waiver does have some kind of catch all provisions that would still apply to operating near these areas, and you do want to be mindful and and kind of cautious when you're operating around these. So there's provisions twenty one and twenty two that talk about having situational awareness awareness of air traffic, making sure you're safe operating distance from other aircraft and not interfering with operations at airports.

So to kind of look at an example of that, just another airport. But San Martin here, this is a example of an airport that is in uncontrolled airspace. So there's no grids. There's no zero grids or a hundred foot grids or anything like that to kind of put hard restrictions on you.

But you you really don't wanna necessarily just go flying at b b loss, you know, two hundred foot over the airport either because there could be aircraft taking off and landing and just operating in that area. So so there's no hard restrictions, but just be mindful of these and and be cautious when you're operating around them.

You know, it it and heliports too. That's the second part here. Like, lot of hospitals will have a helipad. Similar story. So some agencies will use, like, geofences to kind of mark these areas off and keep their operators aware and kind of away from them. That's not necessarily an FAA requirement, but there's tools you can use to keep an eye on these, operate safely around them, and and comply with your your waivers.

Yeah. And is there a waiver for flying into zero grid? A question came in, yes. And and that'll be actually the last part of kind of the webinar today is I I will get into that, what that process is.

Yep.

K. Let's move on here. So another requirement, the drone has to have anti collision lighting for all operations.

The reason I call this one out, like, this is pretty common even under apartment one zero seven for night operations, but the difference here is it has to be on for day and night. So, basically, just turn the strobe lights on. These are the the white flashing lights at the end of, like, the x ten arms, for example.

Just turn them on, basically. Easy one.

Okay. Operations over human beings.

This one, I'm sure, will will draw some questions. So kind of breaking news. Last week, our Parachute for x ten system did meet kind of full FAA part one zero seven subpart d compliance, which is really exciting. So if you go on the FAA's declaration of compliance website now and type in Skydio, you'll see just what's on the screen here, X10 with Skydio parachute approved for category two and three part one zero seven operations. So so, yeah, we're really excited about that.

That really opens up the door for ops over people for part one zero seven operators, but it does have implications for part ninety one as well that we're talking about today.

Of note, this is a little bit less relevant now that we've met part one zero seven compliance, but the parachute does have ASTM f thirty three twenty two compliance as well, which is noted in these waivers. So, essentially, if you put the X10 parachute on, you're you're kind of safe to fly over people no matter what the purpose of the flight is, really, under these waivers.

I do recommend as well, we put out a blog post last week about the parachute. There's a link to our parachute operator manual in that blog post.

And the the parachute manual, there's a nice table in that manual that tells you what conditions the parachute would meet category two or three. So so, yeah, there sometimes there's questions like category two, category three, what's the difference?

The key kind of difference between them is really, like, environmental conditions and, like, the number of attachments you have.

And it's a bit counterintuitive, but essentially the windier it is, the more energy the parachute will have, as it comes down. And so it's it's, like, kind of counterintuitive. The parachute will if it deploys, if the winds are high enough, the parachute's basically a sail, and it will, like, accelerate the drone to an unsafe speed again. So the lower the winds are, the safer. And that's where you'd have, like, category two compliance. But, anyways, please just refer to the manual. There's a nice kind of graph that will show you when the parachute meets those requirements.

Okay. So under Part ninety one then, do I need a parachute on every flight? This is like a question I I commonly get. And the answer is no, but there's some nuance here.

Okay? So the parachute, generally speaking, is a requirement to fly over people in most cases, but it's not like a blanket requirement. It's not just like a if you fly a drone period under this part ninety one waiver, you gotta have a parachute. So the agency and and really the the pilot as well need to think about, like, the factors and kind of the the flight that you're about to do.

So a a simple initial question is, during this flight, will I fly over somebody, or is it likely that I'll fly over somebody?

And if the answer is yes to one of those, then you should consider putting the parachute on, or you might be required to put it on.

You know, is it a visualized sight flight, or is it beyond visualized sight? Is it from a dock or not? So, you know, an example, like, if you're doing patrol led, kind of pull the drone out of your trunk and fly it on a short range tactical mission under this waiver, you might not need the parachute. Like, you might be able to fly in a way that's just not over people.

Maybe the the scene is cordoned off. Maybe you can put the drone over a rooftop and just not kind of fly over people in general. Maybe you don't need to parachute for that flight. But if you're doing a dock based flight where the drone is gonna fly two miles across town and, you know, these are just towns.

There's people walking around. There's cars driving around. So it almost becomes kind of hard to say that you're not flying over people or, like, inevitable that you will.

Maybe the parachute is required. So just consider consider kind of the circumstances.

But, you know, it's not a blanket you must have it for every flight requirement. It's just the requirement to fly over people in most cases.

There is an exception that if you're flying for the purpose of safeguarding human life, this is the very bottom provision here, The parachute is kind of optional in that scenario, and the FAA is kind of giving a little bit of flexibility to kind of accomplish a mission. And they sort of recognize that, in some cases, the mission is more important, and the benefits of that mission kinda outweigh the risks of flying over somebody. But but yeah. The so it's it's not a hard yes or no.

Just kind of please think about the factors and consider the flight and what it's going to fly over. And, you know, I'd say, just generally speaking, like, dock based flights, we definitely encourage the parachute use. We include them now orders. So maybe to make it a little bit simple, like dock based flight, probably recommend putting parachute on handheld flights.

You can probably get by without it.

But please consider the factors. So and, yeah, is there a is there a plan to release the parachute for non docked X10s is a question. It's a good one. So so, yes, the the the short answer is yes. We we're basically just in kind of a ramp up period now. So we're prioritizing docs, parachutes for doc based systems because those, as I just explained, like, inherently will kind of do more flight over people and have a higher usage.

But as we just get our our stock and kind of catch up to the orders, they'll be available for for all drones. X TENS, that is.

And our another good question. Are law enforcement officers, first responders, etcetera, included as people? So when I say kind of flight over people, what is the people part? So, yeah, essentially, like, anybody that's not the flight crew, which for, like, a DFR flight is essentially the pilot sitting inside.

So kind of everybody outside really is considered a person that's not participating in the flight. So, yeah, even if you're flying over your own people, that would still still fall under kind of the explanation I gave. Because you, I mean, you really the parachute's there to protect people. You don't really want the drone coming down and hitting one of your own officers and causing a serious injury as well. So the parachute would also protect them in the event something goes wrong.

And another good question is is it, you know, is it one person or a group of people?

The FAA would say that kind of like technically speaking, flying over even just one person is technically fly over people. So and and it actually goes a step further. If you it doesn't really matter if you're transiting or sustaining flight over them. If you fly over literally over a person from an FAA definition standpoint that is ops over people.

Okay.

Self certification. So this is a unique thing for Part ninety one and kind of one of the key things that distinguishes part one zero seven from part ninety one.

Under part ninety one, you are self certifying your aircraft airworthiness and your flight crew.

So let's get into a little bit of that.

Grab a drink. Okay. So aircraft airworthiness. So so you're responsible for making sure your aircraft are airworthy, and how do you do this?

So the waiver doesn't say much around this. I I just kinda wanted to take the chance to give you some some information on things the waiver isn't really explicit about but are still important. So how do you accomplish aircraft airworthiness? I would recommend having an airworthiness statement on file because you know, so essentially, typically, aircraft that fly under part ninety one, they would have an airworthiness certificate from the FAA, your Cessnas, your Boeings, etcetera.

Drones don't have these, but you're still flying under partner ninety one. So your airworthiness statement kind of serves as that, like, written official, like, we are making sure these aircraft are airworthiness kind of statement.

I would say it's just kind of a CYA thing, honestly.

And it's not hard to create one and just sign it and have it on file. If you do actually do go through the next step, this airspace authorization, you actually do need to submit it. So it's worth having it on file for that as well.

But then what are the actually the actions that you do? So you should follow OEM recommendations for maintenance. This includes scheduled, unscheduled maintenance, doing a functional check flight after you do maintenance, recording these things.

We have a like, for X ten doc, for example, we have a maintenance manual that will tell you all the scheduled maintenance and and things like that.

So for example, for us, it's like make sure the props are changed at their kind of life limits or or if they are damaged.

Make sure the batteries are changed, if they hit their life limits, make sure the software is updated, etcetera. So make sure you're following that. And then that's kind of one part of the awareness strategy. The other part is just checking through your drones before you fly, so doing a good preflight inspection.

So, yeah, have a strategy in place around this because, again, it's kind of your responsibility as an agency to be operating airworthy equipment.

And then the flight crew. So what the waiver says on kind of flight qual flight crew qualifications and training isn't much. But this actually kind of goes back to that very first provision I mentioned that the responsible person is responsible for. Right? So the responsible person, they have to make sure the flight crew is trained and certified. They're informed of the waiver. They're informed of the part ninety one regulations.

And this is essentially your self certification. Like, this is all the FAA really says in terms of requirements.

So how do you do this, though? Like, this is pretty vague. It's like, what does it mean to be trained on Part ninety one regulations?

A really common question I get, and I think it actually was an earlier question in the chat about I'll never find it now. But, essentially, do I have to have, like, kind of the FAA remote pod certificate? And the answer is is no. So the remote pod certificate is not an FAA requirement under part anyone.

I would say, speaking, it's a best practice. A lot of agencies do do this. They require their pilots to get their remote pilot certificate.

And this there's different reasons for this, but one potential reason is if you fly under both sets regulations. If you fly under Part one hundred seven sometimes and then fly under Part ninety one other times, then you'd have to have it because you have to be fully qualified to fly under Part one hundred seven. But if you're an agency that's just flying under Part ninety one, this is kind of an optional choice for you.

And, again, it's not a bad choice. It's pretty common.

But let me give you some thoughts on kind of what I think is more important. So here's just kind of part you know, again, a little bit of part one hundred seven, part ninety one, sort of the the training philosophy behind these. So under one hundred seven, the remote pod certificate is required. That's an FA requirement. Part ninety one is optional. But the kind of the key thing that ties these two together, and I think agencies should spend more of their time thinking about, is their in house training.

So how are you going to train pilots on all the knowledge that the remote pod certificate doesn't cover? So the remote pod certificate doesn't cover ninety one regulations. It doesn't cover your ninety one waiver. It doesn't talk about your policies, your procedures, how you manage data, how you your tactics, how you fly DFR, how you do other things, crime scene photography, whatever it is. It doesn't really dig into, like, the specific airspace you're gonna be flying into. It talks a lot about charts, sectional charts, everybody's favorite.

But it doesn't really talk about facility map grids and the airspace that you're gonna be flying in, like, day to day.

So I I really the agencies create good training to cover these things, and then the remote pod certificate can kind of be an add on to that.

If you don't require the remote pod certificate, then you should also just make sure you're kinda covering at least, like, the topics out of that remote pod certificate that are applicable to your day to day ops. So this training should include, like, OEM and vendor training, and, you know, of course, we offer that. So you you know, bring us out. We'll teach you how to fly the drone, how all the features, capabilities, and stuff like that.

But your training may go a little bit above and beyond that still. Right? And then have a have an idea on how you wanna do kind of that recurring training. So are you gonna bring your pilots together monthly, quarterly?

Like, how are you gonna kinda keep your your skills fresh?

And this is just an example of that. So, if you're gonna do a part anyone kind of like in house training, go through in house ground school. You could have an exam even so you could kind of replicate that FA test, go through your in house flight training, and then think about some way again to kind of keep those skills fresh and bring piles together monthly or quarterly.

Alright.

Okay. Recordkeeping and reporting. This will be the last thing. So there is a little bit of recordkeeping requirements in here. The FAA has done a lot to streamline this. This is kind of one of the key things that has kind of been reduced over time.

So the responsible person, they do need to just track evidence of training, current list of pilots, current list of drones, and then the flight times under the waiver. And the again, the pink numbers I I probably didn't explain this very well to start, but the pink numbers on the left side of all these slides, that's reference to the actual provision in your waiver. So you can kind of reference this back to what the FAA text actually is.

All this information, you're just going to keep it on hand. If the FAA ever asks for it, you'll provide it then, but there's no, like, kind of proactive monthly reporting or anything.

Alright. And then reporting. So this really refers to the accident and incident reporting that you're required to do. So there's actually two agencies here that you need to report things, and they have different requirements. So NTSB is one of them.

And it's worth noting here that the NTSB, these reporting requirements actually apply to all drone flights, like, period. If you fly under one zero seven, if you fly under ninety one, and you have an incident that meets one of the requirements for the NTSB, you have to report that.

The link here in the middle, the the NTSB actually put together a really good memo on, like, what their requirements are, and there's some examples and, like, a flowchart. And it's it's, like, four pages. So it's actually it's very good. It's, like, one of the better kind of government entity memos I've I've seen out there. So I would I would just refer you to that and have that bookmarked. So if something goes wrong, you know, knock on wood, you kinda know what your reporting responsibilities are.

And then the FAA. So and this is separate. Right? So if if one of these two events happens, a close call with an aircraft or a loss control, you'd report that to the FAA separately.

Alright. Okay. So that's a overview of the waiver, And we got about eight minutes left, so I'm gonna, I'll have to kinda speed it up here a little bit. I apologize.

But, now let's get into this is back to kind of the facility map altitude. So if you have a situation and let me see if I can find the slide really quick where you want to fly back to this example here. If you wanna fly in this no fly zone, this zero grid, for example, there is a process to request the an authorization to fly in there. And so here's just a little bit of information about that process and and what you do.

I'll get back to here. Okay. So this is in your part ninety one waivers. So if you look on provision twelve, there's a provision that says an airspace authorization must be obtained through CAPS, unfortunately. CAPS to fly above the facility map grids, the UAS of MS.

And, you know, I hear a lot, like, agencies are are just kind of working this with their airports at the moment. You know, if I just call the tower and they say, I'm good, can't I fly?

And I I covered this actually in in the last episode, episode six as well. But, you know, bottom line is you're probably operating safely. So I don't necessarily agree with the the strategy there. Call the tower, coordinate with them.

You're probably all good from sort of a safe, just kind of common sense operating standpoint. But you're not really covered kind of technically speaking, and it's not sort of the right way to go about it now that there is this process. So really what this airspace authorization does is it it almost kind of just memorializes and makes that that verbal thing you might be doing, like, official, and it kind of puts it down on paper. So if anything were to happen, you're kind of fully covered.

Okay. So three steps. This process is more involved, and there's more variance to this. So it's a little hard to kind of give really clear instructions on, like, this is exactly what kind of how close you can fly to the airport, because every airport's a little bit different, but I I at least want to give you the the high level kind of process here.

So the first step is that you'd actually have to get access to the CAP system, the co application processing system.

This is a website. It's a it's a FAA kind of web portal where you request these these authorizations or these COAs.

So to get access to CAHPS, you need two things. You need a public declaration letter, and you need to fill out the CAHPS access form.

The public declaration letter, this is kind of the the tricky part of this. This is a letter that has to be created and signed by outside counsel, so you cannot, like, self certify this.

And for those of you that are that are kind of in tune here, you might have noticed that you can self certify this for the two hundred foot waiver for the the initial waiver that we just talked about.

And the FAA did a good job of streamlining that and kinda removing some of those barriers. But, unfortunately, this aerospace authorization process is kinda the old process.

And, hopefully, it gets streamlined.

But at least today, it's it is what it is. So you have to go get this letter. You have to work with your, like, your city attorney, your county attorney, your state AG, to get this letter. There's guidance on this, so, like, please reach out if you're having issues.

The FAA has a whole, like, two pager on what this letter needs to contain. We can share that with you. The FAA would, of course, share it upon request as well. So so, yeah, get this letter, fill out this CAPS access form.

You're gonna send these to the FAA, and then they're gonna review them, and they'll help you get an account stood up, essentially.

K. Next thing. And and this this part here is really kind of the art of it. So, you know, you have to kind of understand, again, that the zero grids are there for good reasons in some some cases. They are there to kind of protect aircraft taking off and landing from airports, of course, and as sometimes, like, the helipads, the hospitals that are within these controlled air spaces are also protected.

And sometimes they're there for, like, other reasons. So, you know, there there's typically some good reason for why the zero grid is there. And kind of the key to your success is figuring out, like, what are what are the risks? Why is this zero grid here?

Is it protecting aircraft take off and landing? And if so, how how can I operate safely around that? And and there may be some kind of wiggle room. So sometimes these zero grids are just bigger than they need to be, and you can kind of shrink those in a little bit.

But there's every airport's, again, gonna be a little bit different, and and there's kind of different circumstances. So the things on the left are just kind of good things to consider as you're kind of putting together your request.

And just as an example, this image on the right side, this is in New Orleans.

It's basically ADS B traffic below five hundred feet AGL is kind of all the lines you're seeing. So in the upper right, that's an airport. And so, of course, out of that airport, you're seeing a lot of tracks kind of coming off in in sort of the runway directions.

So you may not wanna you may wanna that area from your ask. Right? Because there there really is, like, aircraft at low altitudes, in that area that you'd encounter.

And then kind of more in the center of the image, there ends up being, like, three hospitals in in the ruins in this area, where there's just kind of medevac traffic coming in and out of. So it's good to know where those are, and those may be kinda areas again that you you wanna be mindful of and limit your operations.

But then you can you could use information like this to say, well, there's areas over here where it's zero grid, but I know I can operate safely. It's, like, away from airports. It's not aligned with the runway and so on.

Here's an example of one I just helped with. So Salt Lake City Police Department.

So they they put together a proposal kinda with my support. We we actually met with the airport, and I I highly recommend this if you can. Most airports are are willing to take a meeting and discuss drone operations.

Some of them are are just super busy, they don't have time for it, and that's okay. But if you can, it's great to meet with your airport. Because when we met with them, we we proposed something, but they said, you know, like, this is close, but we would actually prefer if you stayed, you know, east of this road. And if you could fly it below one hundred and fifty feet, like, we'd be okay with that instead of two hundred. And we ended up basically coming to this map that you see on on the screen here.

And and it's a little bit different than kind of what we had proposed initially, but we came to an agreement, and it still gets Salt Lake City Police Department a bunch more access. So a lot of the areas in orange were, like, fifty foot, hundred hundred foot grids, and then there were some kind of restrictions even in the blue. So so they they they definitely got, you know, some of what they wanted. The airport's happy. It keeps their their traffic safe, and it doesn't interfere with them, and and everybody's good.

Okay. So assuming you you kinda work out that that area, you get some graphics together, you've met with your airport if possible and and talk to them about it, ultimately, need to submit the application in CAHPS. And this is a complicated enough website that I would honestly just recommend sending us an email, and I'll give you a guide on almost, like, exactly step by step how to fill out the boxes and click no here, click yes here, and so on.

So, yeah, we we have a guide for this. You'll just submit the application in the CAPS, and then the FA will process it.

Processing times for these are can vary quite a bit. One of the big reasons for that is the airport is part of the approval chain. So the the service centers will get the initial request. They'll review it.

They send it to the airport for basically sign off. And sometimes the airports can be slow. Sometimes the person that signs them isn't there or they're out, whatever. So I, you know, I I would just bank on maybe a month, but it it's highly variable on how long these take.

And I say that, and one just came in, like, this week for an agency in less than a week. So, so, yeah, just plan ahead a little bit on this one. This is not a guaranteed, like, under a week approval.

Okay.

So the the outcome here, the the result, if you go through both of these processes, is you'll have a Bjornbergine site waiver, and that'll allow you to fly in uncontrolled airspace and then controlled airspace below the grids.

And then you'd get a separate but related airspace authorization that will say you can fly BVLOS in that area, in, like, a specific area that you you put together like this according to your waiver. So you'll end up with actually two documents, two kind of approvals, but they're connected essentially, and they kind of work together.

Okay. I know I'm a minute over already. I'm gonna just maybe take, like, five more minutes here for questions. So for those of you that are sticking with it, I appreciate it.

And if we don't get to your question, I apologize. Just had a lot of content to cover today. So on on the CAHPS thing, there's a question of, like, is there kind of a way to to bypass that public declaration letter for CAHPS?

Unfortunately, today, no.

You know, I know there's some FA folks that that listen in on these these webinars, and that that'd be great if we could get rid of that requirement. But, yeah, the answer today at least is you do need this public declaration letter to get CAHPS access and to to request these kind of zero grid approvals, so to speak.

Yeah. I didn't I I did see a couple multidrone questions, and and I I didn't wanna make multidrone a kind of a main topic for discussion today. But as a quick update, at least, we are engaged in in many others. Like, this is this is becoming a a kind of known topic to the FAA.

They're having kind of some internal pro internal meetings this month.

Basically, the we're we're kind of in the phase of just trying to figure out, like, what would a part ninety one approval look like for multidrone. And my hope is that we we kind of go right into this kind of streamlined approvals for multidrone.

Again, you know, if the FAA's listening, that'd be awesome.

But we we also just kinda don't know yet, and we need to give them a little bit of time to to just kind of work through their their safety review process and kind of these draft provisions that they might issue in these waivers and so on. But I I do feel like twenty twenty six this year will be kind of the year we see multidrone scale up.

We were definitely excited for that. We've been working with, like, Vegas already on just kind of testing some of our early sort of alpha software as we get ready to get that software available to to everybody as well. So more to come on multidrone. I I'm sure I will be back in a webinar to talk about that again soon.

Let's see.

If I have an existing Kawa, I love this. As a as a side note, the the acronyms can be really confusing now because there's COAs, there's COAs, there's COAs.

And to make it worse, there's part one zero seven COAs. There's part ninety one COAs. There there's a there's a COA for both Part ninety one and one zero seven. So, like, kind of yeah. It's complicated. So I try to use the words like waiver and airspace authorization. You may have kind of caught that throughout the webinar here today to try and be a little more specific on what we're talking about.

But to answer the question, if I have an existing Part ninety one waiver, can I add BVLAS, or do I need to, like, submit for a new one? So if you have, like, one of the blanket COAs, jurisdiction COAs, first responder, PV loss COAs, if you have, like, any of those kind of old Part ninety one approvals, I would recommend just just go through the process as I talked about today from from start to finish.

So just treat treat this as, like, an entirely new waiver.

And then you'll end up with a new approval. And these new approvals really kind of roll up all of the old approvals.

So likely what you can do is just retire all of your old waivers, your old COAs, etcetera, and just kind of fly, do everything under this new waiver.

So, yeah, just treat it as a as a new waiver and a new process and kind of a new day, so to speak.

Alright. Is I'll come back to kind of an early one. There's a couple questions related to, like, four hundred foot waivers and detect and avoid and whether the meets those requirements. So the X10 by itself is ready to go for two hundred foot operations. There's nothing extra needed to do that. If you want to go up to four hundred foot, if you want to request that four hundred foot waiver, that the X10 is not kind of sufficient by itself. So you would need to look at some third party detect and avoid solution.

We're partnered really close with Axon and d Drone, so like their d Drone Beyond system. That has garnered a number of approvals for our customers already, so that's kind of a proven system that will help you get that four hundred foot waiver.

But, yeah, essentially, you do need to go look at some extra kind of third party detect and avoid technology to request those four hundred foot approvals within XDIN.

Okay. And the last one I'm going take, because I had a feeling there'd be a question on this.

So any any part one zero eight updates? We'll we'll end on this one. So, yeah, I mean, twenty twenty six, this could be one of the the curveballs of this year and not necessarily, like, in a bad way. It's just we we are kind of keeping a very close eye on part one zero eight and if it'll come out this year.

The the White House had had basically directed the FAA to get this rule out this year. So in some ways, we are expecting it to be published, the final rule that is. But, you know, it's a little bit of wait and see, and nobody knows for sure.

So I I would say there's kind of two things to it. Number number one is keep keep a close eye on it and, you know, just kind of follow follow the news on it and so on. It's not it's not something you want to ignore. But the second thing I would say is don't let it, like, kind of, deter you from, like, getting started today.

So you can get this Part ninety one waiver today. It has you know, it will allow you to do beyond visual assay operations and do DFR, and you can get started. And then if Part one hundred eight gets published, we do expect there to be some kind of grace period or implementation period where the rule is out, but then it goes into effect at, like, a later date. So, there will be time to kind of transition from let's say you have your part ninety one waiver today to part one zero eight.

And so, yeah, it's it's worth kind of keeping track of, and we will definitely tell you and and communicate anything we know that's, like, kind of public as it comes out and help you guys do that transition. But don't, like, just don't kind of just sit and wait for part one zero eight to come, and don't let it stop you from from getting started today is is the other main thing.

So, yeah, more to come on that as well.

Okay. So I know I didn't have all the questions, but we're kinda well over time. I just appreciate everybody joining in today for those that stuck around a little bit later.

And we will be doing these just kind of on a recurring basis now. So look out for the next webinar.

All the previous webinars are are also just available on our website. You can go watch those at any point.

And so, yeah, we'll be back for the next one. And until then, fly safe and take care.