navigating part 107...1. part 107 certification this is step #1—all of your uav pilots must be...

NAVIGATING PART 107What You Need to Know about Doing Business with Drones in the U.S.

233 SW Naito Pkwy, Suite 200 | Portland, OR 97204 | http://skyward.io

3 Part 107 Overview & Quick Guides5 Am I Allowed to…?

7 Comparing the 333 Exemption to Part 107

10 Pending Exemptions

12 FAQ

14 Pilot Qualifications16 How to Obtain UAV Certification

19 About the Remote Pilot Knowledge Test

21 Pilot Responsibilities

22 FAQ

25 Aircraft Requirements26 Registration

27 FAQ

29 Operation Planning & Execution30 Job Engagement

31 Operation Planning

34 On-site

35 Close Out

37 Delivery

37 FAQ

45 U.S. Airspace Under Part 10750 FAQ

54 Business Success, Finding Jobs & Marketing55 What You Need to Run Your Business

57 Marketing

62 FAQ

65 Notes

C O N T E N T S

3 | Navigating Part 107

Part 107 Overview & Quick GuidesFor the first time in U.S. history, businesses of all sizes are free to use drones to serve customers, improve worker safety, and innovate in ways that we can’t yet imagine.


On June 21, 2016 the Federal Aviation Administration announced that Part 107, the rule allowing any business to conduct commercial drone operations in the United States, had been finalized. Part 107 was added to the Federal Register shortly thereafter and became effective on August 29.

Before Part 107, the FAA required every business, from sole proprietors to major corporations, to apply for specific permission via the time-consuming and expensive 333 Exemption process. Many businesses waited months to receive approvals, and the FAA never resolved thousands of pending applications before the new rule took effect.

For many businesses, the barrier of applying for a 333 Exemption and complying with the terms of the Blanket COA was just too high. These businesses either made the decision to delay or forego innovating with drones—or they operated illegally.

Fortunately, this lengthy and burdensome bureaucratic process is a thing of the past for most U.S. businesses.

Part 107 lays out rules of the road for every business to follow, and standardizes the processes and minimum qualification requirements associated with commercial drone operations. By stripping away applications and waiting periods, Part 107 provides the framework to use drones as another tool for doing business, along the lines of computers, factories, semi-trucks, and retail stores.

Though U.S. businesses no longer confront a major regulatory barrier to entry when it comes to drones, there are still regulations to follow and requirements that have to be met.

This guide, validated by Skyward’s regulatory experts, will help you understand the rules and how to follow them.


Part 107 has streamlined the rules for doing business with drones. That said, there are still some basic requirements and tools you’ll need to ensure that you’re following the rules and operating safely. Consider the following to be must-haves:

1. �Part�107�certification This is step #1—all of your UAV pilots must be certified to fly under Part 107.

2. �Qualified�personnel The pilots you hire need to be certified, but they also need experience flying the aircraft in your fleet.

3. �Validated�airspace�map It’s impossible to know where it’s safe to fly and where you’ll need special permission without a validated airspace map, such as Skyward’s.

4. �Registered�aircraft Make sure your UAVs are registered with the FAA.1

5. �Insurance Though not required under Part 107, liability insurance is required by most corporations and business customers. It’s also a sign that you take your job seriously and are taking necessary steps to mitigate risks.

What You Need to Do Business Under Part 107

https://registermyuas.faa.gov/

Understanding Part 107This graphic answers the most frequently asked questions about Part 107, but the entire rule is 624 pages long. The FAA has published the entire text of Part 107,2 as well as a three-page summary.3

Part 107: Is It Allowed?

YES NO

Flights below 400ft or within 400ft of object of inspection (tower, building, etc)

Operate in Class B,C, D, and E airspace with ATC permission

Delivery (as long as attached cargo does not move total weight above 55lb)

Operations within civil twilight

Daisy chain pilots

Operations from a moving vehicle (in sparsely populated areas)

Flights over 100 mph (ground speed)

Flights with less than 3 miles visibility from control station

Acting as remote pilot in command for more than one aircraft at a time

Night time operations

Flights over non-participants without cover (concerts, live news events, sports, etc

Daisy chain observers

http://www.faa.gov/uas/media/RIN_2120-AJ60_Clean_Signed.pdf

http://www.faa.gov/uas/media/Part_107_Summary.pdf

The 333 Exemption and Part 107 Side-by-Side

TOPIC GENERAL 333 AND BLANKET COA4 PART 1075

Initial training At least a sport-pilot’s license and current flight review

Pass an initial aeronautical knowledge test at an FAA-approved knowledge testing center;orhold a Part 61 pilot certificate other than student pilot, complete a flight review within the previous 24 months, and complete a small UAV online training course provided by the FAA

Recurrent training Biennial flight review

Pass a recurrent aeronautical knowledge test every 24 months;orhold a Part 61 pilot certificate other than student pilot, satisfy the certificate flight review requirements, and complete an online training course every 24 months

Medical certificate FAA medical certificatePilots must ensure that they don’t have any condition that would interfere with safe drone operation.

Crew size At least 2: Pilot + visual observers

1 pilot with a remote pilot airman certificate with a small UAV rating;or2 or more crew members, with the operator under the direct supervision of a person who holds a remote pilot certificate (aka, remote pilot in command)


Flight restrictions

Must not operate in:1. Prohibited Areas2. Special Flight Rule Areas3. Temporary/Permanent

Flight Restricted Areas

Special permission for airports in controlled airspace and certain airports in uncontrolled airspace.

Must not operate in:1. Class A airspace (18,000 feet and above)2. Prohibited or restricted areas3. Temporary/Permanent Flight Restricted Areas

Prior authorization needed from air traffic control when in controlled airspace (Class B, C, D and airport Class E)

Time of day Daylight hours onlyOnly between official sunrise and sunset, with anti-collision lights used during civil twilight (dusk and dawn)

Weight limit 55 pounds 55 pounds

Speed limit 100 miles per hour 100 miles per hour

Weather3 mile visibility, 500 feet below clouds, 2000 feet horizontally away from clouds

3 mile visibility, 500 feet below clouds, 2000 feet horizontally away from clouds

Height limit 400 feet

400 feet above ground level; if you’re flying within a 400-foot radius of a structure, you can fly higher, but not more than 400 feet above the structure’s immediate uppermost limit

Visual line of sight Required Required


Operation from a moving vehicle Not allowed Not allowed

Operation above people

Not allowed if not participating or under covered structure providing protection

Not allowed if not participating or not under covered structure providing protection or if in a moving vehicle

Operation of multiple UAVs at the same time Not allowed Not allowed

Buffer Required Required

Aircraft allowed Specified by FAA Any aircraft under 55 lbs

NOTAM filing Yes No

Monthly COA report-ing Yes No

Incident reporting Yes

No later than after 10 days of a serious injury to any person or any loss of consciousness or property damage (other than to the UAV) greater than $500

If You’ve Applied—But Not Yet Received—Your 333 ExemptionThe FAA has said that they will continue to review all the 333 Exemption petitions in their queue. Based on the type of your operation, one of three things will happen:

1. If the FAA sees that you can conduct your flight ops entirely under Part 107, without a waiver or exemption, they will close your petition. You may begin operations as soon as your pilots have received their qualifications.

2. If the FAA sees that you can conduct your flight ops with a waiver under Part 107 (for example, your business needs to conduct night flights), the FAA will convert your 333 petition to a waiver application. The FAA has said that they will contact every company to which this applies; if you haven’t heard from them, email them at 9-AFS-800-Part107Waivers@faa.

Sections of Part 107 That You May Apply to Have Waived

• Operation from a moving vehicle or aircraft

• Daylight operation

• Visual line of sight aircraft operation

• Visual observer, if assigned

• Operation of multiple small unmanned aircraft systems

• Yielding the right of way to other aircraft

• Operation over people

• Operation in certain airspace

• Operating limitations for small unmanned aircraft

3. If the FAA decides that your requested operation may not be conducted under Part 107, even with waivers, they will continue working on your petition for exemption. If you believe your original request requires an exemption and you haven’t yet heard from the FAA, email them at [email protected].

TIER 1 TIER 2 TIER 3

• The entire operation can be conducted under Part 107• Review the Part 107 regulation, and may begin operations in compliance with the new rules on the effective date (August 29th, 2016)

• Requested operation able to be waived in Part 107. FAA will contact you within 60 days. Docket will be closed an FAA will consider your petition for exemption waiver to Part 107

• Requested operations outside of the Part 107 that are not able to be waived.

EXAM

PLES

Real-estate photography shoot w/no special permission requests.

Night Operations Flying a drone that weighs over 55lbs.

RESU

LT

Petition CLOSED Considered for107 Waiver

333 Exemption will continue to be reviewed and processed.

The FAA will evaluate waiver proposals based on operating restrictions, locations of the flight, and hazards unique to each individual request.


Questions about the 333 Exemption and Part 107

If�my�business�already�has�a�333�Exemption,�do�we�automatically� get�Part�107,�or�do�we�have�to�file� a�new�application?�Good news—there’s no need to apply for Part 107. As a piece of legislation, businesses simply need to familiarize themselves with the rule and then follow it.

My�company’s�333�Exemption�has�an�expiration�date—will�there�be�one�for� Part�107�too?Part 107 is a federal law that applies to all commercial UAV operations involving aircraft weighing less than 55 lbs, and it does not have an expiration date.

If�my�business�already�has�a�333�Exemption,�can�we�choose�to� continue�operating�under�it?� Is�there�an�advantage?Yes, you have the option to operate under your 333 Exemption until it expires. You must choose, though—you can’t alternate between the terms of your 333 Exemption and Part 107. Companies whose 333 Exemptions allow certain operations not allowed under Part 107 without an additional waiver (night flights, for example) may find it worthwhile to continue operating under their 333 Exemptions.

Under�my�333�Exemption,�my�company�was�responsible�and�held�accountable�for�safe�operations.�Under�Part�107,�is�it�now�the�pilot�and�not�the�company�that�is�responsible�and�held�accountable�for�safe�operations?Remember that a Section 333 Exemption is just that—an exemption from existing regulations. The petition for exemption was a statement of the restrictions and procedures that a business would use to ensure that the operation would be just as safe as fully complying with the regulations. Exemptions were granted to

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organizations to allow operations with certain aircraft under specified conditions and restrictions; but they still required the use of a certificated pilot. That person was immediately responsible for the safe operation of the aircraft. Under Part 107, the remote pilot in command is also immediately responsible for the safe operation of the aircraft. There is no change with regard to immediate responsibility. Without offering any type of legal opinion consider that immediate responsibility for safe operation of an aircraft is a separate issue from the FAA’s authority to issue orders assessing a civil penalty to businesses that violate certain aviation laws and regulations. Consult an aviation attorney for advice.

Are�the�waivers�for�Part�107�blanket�waivers,�or�will�every�flight�require�an�individual�waiver?�The FAA will be granting waivers to specific sections of Part 107 and not for specific flights. In order to obtain a waiver, show the FAA that you can maintain an equivalent level of safety for the proposed type of operation.

I�am�currently�a�contractor�for�a�business�that�has�a�333�Exemption.�After�I�pass�the�Part�107�exam,�will�I�be�flying� under�a�different�authorization�from� my�employer?�As an individual, you will no longer be bound to the terms of the 333 Exemption as long as you have a remote pilot certificate, the aircraft you are flying is under 55 lbs and is registered for commercial flight, and you fly according to the rules laid out under Part 107. However, your employer may choose to continue operating under their 333 Exemption until it expires. If that happens, when you fly for them, you must abide by the terms of their 333 Exemption.

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Pilot Qualifications Prior to Part 107, the FAA required all commercial UAV operators to hold, at minimum, a sports pilot’s license.


This presented a hiring challenge for many companies and excluded many highly experienced operators, including those who have years of experience flying UAVs in the military. Fortunately Part 107 gives businesses much more flexibility when it comes to hiring pilots.

Pilots now have two choices for obtaining and maintaining commercial certification, which is valid for two years. For those who don’t have a pilot’s license, the process is analogous to getting a driver’s license.

Pass an initial aeronautical knowledge test at an FAA-approved testing center; you can take the test as many times as you need, and it costs $150 each time.

Hold a Part 61 pilot certificate (excluding student pilot certificates), have a current flight review, and take a small UAV online training course provided by the FAA.

To maintain certification, pilots can either:

Pass a recurrent aeronautical knowledge test every 24 months.

Hold a Part 61 pilot certificate (excluding student pilot certificates), satisfy the certificate flight review requirements, and complete an online training course every 24 months.

When operating commercially, be sure to have your pilot certificate with you at all times, just as you would a driver’s license.

OPTION 2

OPTION 2OPTION 1

OPTION 1


How to Obtain UAV Certification YOU�DON’T�HAVE�A�PILOT’S�LICENSE

Make sure you meet the following criteria...• You’re at least 16 years old

• You can read, speak, write, and understand English (excepting a disability, such as hearing impairment)

• Your physical and mental condition allows you to safely operate a UAV

Then follow these steps:

1. First, schedule an appointment with an FAA-approved knowledge testing center.6

2. Then, show up and pass the test—the cost is $150. Remember to bring a government-issued photo ID! (More about the test following.)

3. Complete FAA Form 8710-13 for a remote pilot certificate (FAA Airman Certificate or Rating Application) using the electronic FAA Integrated Airman Certificate or Rating Application system (IACRA):

1. Register using the FAA IACRA system7

2. Log in with username and password

3. Click on “Start New Application” and 1) Application Type “Pilot”, 2) Certifications “Remote Pilot”, 3) Other Path Information, 4) Start Application

4. Follow the application prompts.

5. When prompted, enter the 17-digit knowledge test exam ID (NOTE: it may take up to 48 hours from the test date for the knowledge test to appear in IACRA).

OPTION 1

http://www.faa.gov/training_testing/testing/media/test_centers.pdf

https://iacra.faa.gov/IACRA/Default.aspx


6. Sign the application electronically and submit for processing.

4. You’ll receive an email when the TSA has completed your security background check. This email will provide instructions for printing a copy of the temporary remote pilot certificate from IACRA.

5. The FAA will send a permanent remote pilot certificate to you through the mail once processing is complete.

YOU�HAVE�A CURRENT PILOT’S LICENSE

Make sure you meet the following criteria...• You hold a pilot certificate issued

under 14 CFR Part 61.

• You’ve completed a flight review within the previous 24 months.

OPTION 2

Then follow these steps:

1. Complete the online training course “Part 107 small Unmanned Aircraft Systems (UAV) ALC-451” available on the FAA FAASTeam website.8 Initial training includes: • Applicable regulations relating to

UAV rating privileges, limitations, and flight operation

• Effects of weather on UAV performance

• UAV loading and performance

• Emergency procedures

• Crew resource management

• Determining the performance of UAVs

• Maintenance and preflight inspection procedures

http://www.faasafety.gov/


2. Complete FAA Form 8710-13 (FAA Airman Certificate or Rating Application for a remote pilot certificate):

1. Register using the FAA IACRA system9

2. Log in with username and password

3. Click on “Start New Application” and 1) Application Type “Pilot”, 2) Certifications “Remote Pilot”, 3) Other Path Information, 4) Start Application

4. Follow the application prompts.

5. When prompted, enter the 17-digit knowledge test exam ID (NOTE: it may take up to 48 hours from the test date for the knowledge test to appear in IACRA).

6. Upload the course completion document to the application if IACRA is used.

7. Sign the application electronically and submit for processing

3. Validate your identity:

1. Contact an FSDO, an FAA-designated pilot examiner, or an airman certification representative to make an appointment.

2. Present your photo ID, the completed FAA Form 8710-13 along with the online course completion certificate or knowledge test report and proof of your current flight review.

3. Sign the completed FAA Form 8710-13 application after the FSDO, pilot examiner, or airman certification representative examines your photo ID and verifies your identity. • Acceptable methods of

identification include U.S. driver’s licenses, government identification cards, passports, and military identification cards.

https://iacra.faa.gov/IACRA/Default.aspx


4. The FAA rep will sign your application and give you a temporary airman certificate (a CFI is not authorized to issue a temporary certificate; they can process applications for applicants who do not want a temporary certificate).

5. The FAA will send a permanent remote pilot certificate to you through the mail once processing is complete.

About the Remote Pilot Knowledge TestIf you’re going with Option 1, you’ll have to pass a knowledge test. The FAA has created a 17-page downloadable study guide,10 which will help you determine whether there are areas that you need to learn or brush up on. Currently, the FAA says that the test will include questions covering the following categories:

1. Applicable regulations relating to small unmanned aircraft system rating privileges, limitations, and flight operation

2. Airspace classification and operating requirements, and flight restrictions affecting small unmanned aircraft operation

3. Aviation weather sources and effects of weather on small unmanned aircraft performance

https://www.faa.gov/training_testing/testing/test_guides/media/remote_pilot_ktg.pdf

4. Small unmanned aircraft loading and performance

5. Emergency procedures

6. Crew resource management

7. Radio communication procedures

8. Determining the performance of small unmanned aircraft

9. Physiological effects of drugs and alcohol

10. Aeronautical decision-making and judgment

11. Airport operations

12. Maintenance and preflight inspection procedures

Unmanned�Aircraft�General�-�Small• 60 Questions

• 2 Hours to Complete

• 70% Correct to Pass

• 14 Day Waiting Period for Retesting

Test�TopicsRegulations 15-25%

Operations 13-18%

Airspace & Requirements 8-15%

Loading & Performance 7-11%

Weather 11-16%


Regulations 15-25%

Operations 13-18%

Pilot ResponsibilitiesOur National Airspace has an excellent safety record. This is largely due to the culture of safety that surrounds traditional pilots from their first day of ground school. It makes sense that UAV pilots wouldn’t have the same training and certification requirements as traditional pilots, but they are still just as responsible for maintaining the integrity and safety of the national airspace.

Piloting a UAV, whether commercially or recreationally, should never be taken lightly. According to Part 107, the minimum responsibilities of a pilot-in-command include:

• Make available to the FAA, upon request, the small UAS for inspection or testing, and any associated documents/records required to be kept under the rule.

• Report to the FAA within 10 days any operation that results in at least serious injury, loss of consciousness, or property damage (other than to the UAV) of at least $500.

• Conduct a preflight inspection, to include specific aircraft and control station systems checks, to ensure the small UAS is in a condition for safe operation.

• Ensure that the small unmanned aircraft complies with the existing registration requirements specified in § 91.203(a)(2).

• A remote pilot in command may deviate from these requirements in response to an in-flight emergency.


Questions About Pilot CredentialsTESTING

How�much�does�the�test�cost?The test costs $150 each time you take it.

Will�every�FAA�testing�center�offer� the�exam?�We can’t confirm that every testing center will offer the exam. Look up your local testing centers here,11

and then call CATS or PSI to schedule your test. (Test centers with a Site ID beginning with ABS are CATS, those beginning with LAS are PSI.)

Since�this�is�a�new�process,�how�can�we�prepare�for�the�test�and�how�can�companies�claim�to�know�what�knowledge�is�required�without�even�seeing�the�test?The FAA has published Airman Certification Standards that detail the material any remote pilot taking the test will need to know. The FAA creates the exam to test on these standards. Any good study material will follow these.

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When�can�we�expect�the�Part�107�test�to�be�available�and�do�we�need�to�schedule�a�testing�time?�The test will be available to take on August 29, 2016. You do need to schedule tests in advance. At Skyward, we were able to schedule our tests well before August 29.

How�should�I�study�for�the�test?�At Skyward, we’ve been using a combination of the Airman Certification Standards12 to know what topics are covered, the Pilot Handbook, and the sample Remote Pilot Knowledge Test published by the FAA.13

I’ve�been�reviewing�the�Airman�Certification�Standards14�for�study�materials�and�it�seems�to�just�be�a�list�of�references�to�other�publications.�I’m�confused.�Is�this�how�we’re�expected�to�study�for�the�test?�It�would�be�nice�if�there�was�a�single�study�guide�or�manual.�We agree! Because the test is new, there isn’t yet a comprehensive study guide, but we feel certain that one will be created soon. In the meantime, companies such as Dart Drones, Drone Pilot School, Drone U, and Aerodrome might be able to provide study materials.

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http://www.faa.gov/training_testing/testing/media/test_centers.pdf

https://www.faa.gov/training_testing/testing/acs/media/uas_acs.pdf

https://www.faa.gov/training_testing/testing/test_questions/media/uag_sample_exam.pdf




What�happens�if�I�fail�the�test?� Can�I�take�it�again?Yes, you can retake the test after 14 days. $150 is required each time you take the test.

Did�I�hear�that�it�will�take�six�to�eight�weeks�to�get�our�certificate�after�we�pass�the�part�107�test?�Yes, that is the current time estimate. Once the TSA has completed your background check, you will be able to download and print a temporary certificate to use until the FAA sends the permanent one through the mail.

LICENSED PILOTSIf�I�hold�a�Part�61�pilot�certificate�and�have�taken�the�online�test�through�the�FAA�website,�should�I�then�apply�for�an�actual�certificate�via�the�FAA�IACRA�site?�This website15 can walk you through the process.

Can�I�fly�under�my�333�Exemption�with�a�UAV�remote�licence�or�do�I�still�need�my�pilot’s�licence?

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If you fly under a 333 Exemption, you must have a pilot’s license; if you fly under Part 107, you don’t.

Will�licensed�pilot�holders�have�any�advantage�in�acquiring�COAs�and�permission�to�fly�in�controlled�airspace?�We’ve seen that licensed pilots may have a slight advantage because they are familiar with communicating about airspace regulations and speaking the FAA’s language. But the FAA won’t prioritize COA applications from licensed pilots.

Does�a�Transportation�Worker�Identification�Credential�(TWIC)�count?�Part 107.12 only speaks to the FAA remote pilot certification as a requirement for commercial UAV operations.

What�are�medical�requirements� for�drone�pilots?The only medical requirements for Part 107, as stated in 107.61: (c), are: “Not know or have reason to know that he or she has a physical or mental condition that would interfere with the safe operation of a small unmanned aircraft system.”

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http://www.faa.gov/UAV/getting_started/fly_for_work_business/becoming_a_pilot/


FLYING�FOR�FUNWill�there�eventually�be�license�requirements�for�hobbyist� drone�operators?��14 CFR 101.41 (being published with this new set of regulations along with Part 107) just codifies section 336 of Public Law 112-95 as passed by Congress. There are no licensing requirements for hobbyists in that legislation, and the FAA has not stated that there will be a future licensing requirement for hobbyists.

As�a�recreational�pilot,�do�I�really�need�to�“operate�a�UAV�under�the�direct�supervision�of�someone�who�holds�an�RPAC”?�Is�there�a�required�ratio�of�RPAC�holders�to�amateur�recreational�drone�users?�Is�there�a�required�“supervision”�distance�between�the�RPAC�holder�and�amateur�user?No, you don’t need to be supervised to fly recreationally. Part 107 only applies to commercial UAV flights. Recreational flights are governed by different rules..16

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CITIZENS�OF�OTHER�COUNTRIESI�am�Canadian�but�many�of�my�customers�are�in�the�U.S.;�am�I�able�to�be�certified�as�a�UAV�pilot�under�Part�107?Maybe. U.S. Airmen Certificates are generally issued only to U.S. citizens or resident aliens. For non-U.S. citizens or resident aliens, a reciprocal certificate may be issued on the basis of a certificate held by a pilot in another country, but this process is still in development for remote pilots. A possible approach may be to apply for permission to operate as a foreign entity with the Office of the Secretary of Transportation Foreign Air Carrier Licensing Division under 14 CFR Part 375. However, if your business received a 333 Exemption from the FAA, you can continue to operate under those rules.

I�live�and�work�in�the�U.S.�on�a�work�visa.�As�a�non-citizen,�am�I�eligible�to�be�certified�as�a�UAV�pilot�under�Part�107?The FAQs on the FAA’s site suggest that you are eligible to take the test. When you go, be sure to bring a passport and a U.S. issued driver’s license or an ID card issued by a government entity.

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https://www.faa.gov/uas/getting_started/fly_for_fun/

https://www.faa.gov/uas/getting_started/fly_for_fun/


Aircraft Requirements


N-NumbersMost commercial UAVs do not need N-numbers, which require a paper application. The only instances in which your aircraft will need an N-number are as follows:

• Your UAV is 55 lbs or heavier

• You want to qualify a UAV for operation outside the United States

• You hold title to an aircraft in trust

• The UAV owner uses a voting trust to meet U.S. citizenship requirements

The requirement for UAVs is one of the most straightforward aspects of Part 107: UAVs must weigh less than 55 lbs (25 kg). This requirement is not waiverable under Part 107. If you must fly a heavier aircraft, you will need to apply for an exemption from the FAA or continue using your 333 Exemption if you have one.

Part 107 allows flying during civil twilight if your aircraft has appropriate anti-collision lights.

RegistrationEvery UAV weighing between .55 lbs (250 grams) and 55 lbs (25 kg) must be registered with the FAA, regardless of whether it’s used recreationally or commercially. The online registration process17 is quick, straightforward, and only costs $5.




Questions about Aircraft Requirements

Are�commercial�drones�still�required� to�be�registered?Yes, any drone heavier than .55 lbs must be registered with the FAA.18

If�my�aircraft�already�has�labeling�required�under�the�hobbyist�registration�(uses�same�number�for�all�aircraft),�will�a�separate�N-number�be�required�under�Part�107?�It is unlikely that you will need an N-number. Select “Commercial Registration” when you go to the FAA website. The process is very straightforward.19 Aircraft used for commercial operations must each have their own registration number.

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If�I�add�a�new�UAV�to�my�commercial�fleet,�will�I�need�an�N-number�to�operate�in�controlled�airspace?An N-number is not required. Register as a commercial operator on the FAA’s UAV registration site.

Can�more�than�one�operator�use�a�single�UAV?�In�other�words�can�one�operator�use�a�UAV�for�Job�#1�and�then�pass�it�off�to�a�different�operator�for�Job�#2?�Yes, multiple pilots can use a single UAV. Just make sure everyone is qualified to fly and the UAV has been registered with the FAA. No need to register a UAV multiple times.

Does�a�COA�cover�a�single�aircraft?�If�I�have�a�fleet�do�I�need�a�separate�COA�for�each�aircraft�in�the�fleet?If you operate under Part 107, you will no longer need a Blanket COA. In that case, you can use any UAV 55 lbs or lighter that you have registered with the FAA. If you continue to operate under a 333 Exemption, you can use any UAV on the FAA’s list of approved aircraft.20 Under Part 107, you will need

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https://www.regulations.gov/document?D=FAA-2007-3330-0007

https://www.regulations.gov/document?D=FAA-2007-3330-0007


a waiver to operate within certain airspace (Class B, C, D, E surface area). The current civil COA application requires the registration number of the aircraft that will be used. The FAA has stated that a Certificate of Waiver process will be established for Part 107. At press time, it remains to be seen whether that application will apply to only one aircraft.

Is�Part�107�only�for�UAVs�under�55�lbs� or�does�it�cover�heavier�UAVs�as�well?�Part 107 specifically applies to aircraft under 55 lbs. That is one of the provisions that is not waiverable.

Which�UAV�was�recently�approved� for�night�ops?�Industrial Skyworks received the first night exemption granted by the FAA.21 The exemption is for use with the Aeryon Labs Skyranger, but it should be noted that the conditions imposed are not aircraft-specific. There are specific visibility requirements, but they aren’t unique to that specific aircraft.

Do�lights�on�common�drones,�such�as�the�Phantom�and�Solo,�comply�with�the�civil�twilight�lighting�requirements?

No, the lights found on certain consumer-focused drones, including the Phantom or Solo, do not meet the requirements.

My�business�uses�custom-built�UAVs,�so�we�don’t�have�owner’s�manuals�or�documented�maintenance�procedures.�Should�we�create�these?��The FAA has not specified a requirement for owner’s or maintenance manuals. That said, Part 107 gives the FAA the authority to inspect your procedures and records at any time. If an FAA inspection determines that you are not in compliance with Part 107 or that your operations are unsafe, this may have negative consequences for your business. Evidence of safe operating procedures will protect you. Even more importantly, owner’s manuals and standardized operating and maintenance procedures will ensure that your commercial drones jobs are completed professionally and safely. The aviation industry is unforgiving of lax flight discipline.

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https://www.irs.gov/businesses/small-businesses-self-employed/deducting-business-expenses

https://www.irs.gov/businesses/small-businesses-self-employed/deducting-business-expenses


Operation Planning & Execution


and it will help you to provide the best service—even if it means declining the job. Your customer is anyone requesting your UAV services, including a colleague within your company.

• What is the final product that your customer expects?

• When does your customer expect it?

• What is your customer’s budget for the job?

Then, analyze the customer’s requirements. Are you able to meet them?

• Can you undertake the job without violating airspace regulations?

• Using a validated drone airspace map, check to see whether the job is within controlled or restricted airspace where you may need special permission to fly.

• Do you have the aircraft and qualified personnel needed to perform the job?

• Do you have the permits, licenses, and insurance needed to perform the job?

The importance of having an efficient, scalable process can’t be overstated: It will save you time and money, enable excellent customer service, empower your crew to do their best work, and allow you to scale up as your business grows.

Remember: The best ops planning processes prioritize safety, compliance, and efficiency.

When we conduct commercial flights at Skyward, we follow a five-phase process.

Job engagementUnderstand the project requirements. This is all about asking the right questions and communicating well. Taking the time to understand your customer’s expectations at the outset will save you time and money,

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• Do you and your crew have the time? Are your schedules full?

• Is the budget reasonable? Or would you lose money if you were to undertake it?

• Is there a more cost-effective way of achieving the same result?

If you have the time, availability, crew, aircraft, insurance, permission, and expertise to undertake the job, you’re ready to start planning.

Operations planningMore than any other, this step will ensure that your crew operates as efficiently as possible.

Evaluate airspace Using a validated drone airspace map, take a look at the location of the job. During the job engagement phase, you determined the type of airspace in which you’ll need to fly to complete the job.

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Why the Skyward Airspace Map Is DifferentAt Skyward, we believe that safety is #1 for all aircraft, including UAVs. That’s why our team of airspace analysts inspects every piece of airspace data we receive from airspace regulators. This allows us to correct errors and alert the regulator so that they can be corrected for everyone.

Then, we simplify the airspace to make it relevant and easy to understand for commercial drone operators.

Safe�airspace�benefits�all�of�us.


For example, if the job is in the United States within controlled airspace, you’ll need to apply for a Civil COA from the Federal Aviation Administration’s website.

If the job requires that you fly over your crew, you’ll need to plan for and conduct a safety briefing beforehand and arrange for security to keep non-participants out of the area. If you need to fly directly over non-participants, you’ll need to apply for a waiver, which will affect your scheduling.

Create a flight area Depending on the scope of the flight job, your flight area may be very large (eg, a wildlife survey) or highly constrained (eg, inspecting a cellular tower). Regardless, the area should encompass your crew’s rally point and takeoff and landing areas.

In this example, a business has been hired to film a section of freeway in the Washington, DC metro area. The interactive Skyward

Airspace Map shows that the section of freeway is between both controlled (yellow) and restricted (red) airspace. The flight area (blue) has been drawn on the Skyward Airspace Map. The sidebar at the left shows the different classes of airspace.


Mark points of interest Your crew needs to know exactly what’s expected of them, including rally points, potential takeoff areas, where they need to fly, when, and the type of data they need to recover. Mark points of interest and record these details so they can see everything in advance and avoid guesswork once they’re in the field.

Mark hazards Show your crew potential hazard areas, such as power lines, roads, and high-traffic pedestrian areas that may need to be blocked off, or obstructions which may block the line of sight or be collision hazards.


Coordinate with your field crew and schedule the job Share the flight plan with your crew and make sure that everything makes sense to them. Check your crew’s availability, and remember to factor in extra time if you need to obtain special permission from a regulator or landowner.

Other scheduling considerations:

• Make sure your UAVs and batteries are available.

• Make sure that your available pilot-in-command has been trained to fly the UAV scheduled for the job.

• Do you have enough batteries for the planned flight duration?

• Do you need to coordinate traffic control?

• Does your client require that you have an escort or supervision?

• Depending on the time of year and weather in your area, you may need to add a buffer to your schedule to account for weather-related delays.

Confirm with your customer Send your customer screenshots of your flight plan and confirm that all the details have been accounted for.

On-siteOn the day of the flight, check your validated drone airspace map again. Temporary flight restrictions can happen at any time—for example, if there is a forest fire or public safety emergency, or if the president comes to town.

There may be a way to work with regulators even in the event of a temporary flight restriction, but don’t settle for verbal approval—insist on getting it in writing.

Also, take a look at the weather. If it’s raining, snowing, foggy, or very cold, you may have to reschedule for another day.

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Once on-site:

• Check the weather, including temperature and windspeed.

• Are there non-participants in the area?

• Are there structures that are higher than you are allowed to fly?

• Begin your preflight checklist.

Close Out As soon as the crew finishes the job, they should log the operation. In general, flight logging involves two types of data, which should be reflected in your system of record:

1. what the human beings did and

2. what the aircraft did.

Here is the logged operation within Skyward:

All aviators log flights in order to maintain pilot credentials, track training requirements, and be prepared for regulatory audits—airspace authorities routinely review pilot logbooks.

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Crew training programs and maintenance requirements need the support of logged flight data. You’ll also need to know how long an aircraft has been flown in order to schedule routine maintenance.

For all pilots, flight hours are the major benchmark of professionalism and credibility and they can only be tracked by logging flights.

In terms of your business, UAVs represent a major investment. But they only provide return value if they’re being used. Logging flights will show you whether you’re maximizing your investment.

Flight logging is essential for:

• Understanding the totality of your operations

• Keeping a record of adverse incidents, such as collisions

• Tracking pilot hours

• Maintaining training schedules

• Promoting a pilot to pilot-in-command

Aviation Runs on ChecklistsFor more than a century, aviation has run on checklists, including preflight, in-flight, postflight, and emergency checklists. Checklists remove variables and lower risks by ensuring that complex processes and procedures are carried out the same way every time.

At Skyward, we’ve developed our own General�Operating�Manual�and�Operational�Checklists�in collaboration with aviators, UAV experts, regulators, and insurance providers.22

https://skyward.io/proservices/

https://skyward.io/proservices/


• Tracking how many craft were used

• Billing and invoicing

• Recording the time and resources required for the job (which will help you determine your ROI)

Delivery For your customers, this is the most important part.

UAVs have an enormous capacity to quickly and efficiently capture data, but raw data is rarely enough to meet the customer’s requirement. Raw data must be turned into knowledge to help the customer meet a business need.

This may involve mapping or video editing software. Depending on the type of service you provide, you may also be expected to interpret raw data so your customer can easily make use of it.

If you’re a major corporation, you probably already have the systems in place to handle that type of logistical challenge. If you’re a small business, you may need to invest in image processing or data analysis systems in order to use the information you gather.

Questions about Operations PlanningAPPROVALS�&�PERMISSIONS� UNDER�PART�107

333�Exemptions�have�required�a�monthly�flight�report,�even�if�you�haven’t�logged�any�flights.�Does�Part�107�have� reporting�requirements?�Part 107 does not require monthly reports unless you have a separate waiver that requires it. The FAA only requires incident reports if there are injuries or property damage exceeding $500 (other than to the UAV involved).

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How�does�Part�107�affect�flight�operations�over�people?�As�a�law�enforcement�agency,�a�60-90�day� lead�time�could�prohibit�us�from�accident/crime�scene�investigation.�Part 107 does make it difficult to fly over non-participants, even with a waiver. Options include: 1) Operate under Part 107 but make sure not to directly fly over unprotected non-participants. Part 107 does not specify a minimum distance. 2) Apply for an Exemption that allows you to fly over non-participants. For safety reasons, we recommend option 1.

The�waiver�takes�60-90�days�to�process�it�seems.�Is�this�project-based�or�can�you�obtain�a�blanket�waiver?We have seen waivers take as little as 30 days and as many as 90. Remember, there is not a “blanket waiver” under Part 107. The FAA is developing a Certificate of Waiver (CoW) that we hope will be much faster than the Civil COA process. The waiver may be generalized to a type of operation or specific to a location and time depending on the complexity of the operation and the impact it has on airspace safety.

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Q Does�anything�in�Part�107�affect�how�a�local�government�agency�would�obtain�approval�for�drone�use?�Local governments can choose to operate under Part 107 or request a Public Certificate of Waiver or Authorization for certain operations.

Does�Part�107�have�the�same�property�owner�permission�requirements�as�the�333�Exemption?�What�are�the�“borders”�of�private�airspace?�When�are�you�over�someone’s�airspace�instead�of�in�it.�For�example,�regular�manned�aircraft�do�not�ask�for�permission�to�fly�over�properties.Part 107 does not require permission to overfly private property but it may still be an excellent practice, depending on the situation—use good judgment. The FAA refers to the National Telecommunications and Information Administration Voluntary Best Practices for UAS Privacy,23 as well as local trespassing ordinances. Part 107 does specify that you cannot directly overfly any person not participating in your operation, or endanger people or property on the ground, but it doesn’t specify a minimum distance.

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https://www.ntia.doc.gov/files/ntia/publications/voluntary_best_practices_for_uas_privacy_transparency_and_accountability_0.pdf




For�aerial�photography�what�is�required�to�fly�over�a�property�in�order�to�photograph�a�different�property.�For�example�to�photograph�my�house,�I�fly�over�my�neighbor’s�yard.�Is�there�any�ruling�on�who�owns�the�airspace�over�a�person’s�land?�What�permission�is�needed�from�landowners?Part 107 does not require operators to receive permission from landowners before flying over their property. Landowners don’t own the airspace over their property. However, in certain cases, it’s a great idea to ask for permission anyway. Following the law is one thing, being a professional is another. If you’re flying over a large vacant lot, there’s probably no need to contact the landowner. But if you’re flying over your neighbor’s house, we recommend asking permission.

Will�UAV�operators�be�required�to�maintain�communication�with�air�traffic�control�during�flight�operations?�Not unless you are operating under a certificate of waiver or authorization (COA) that requires air traffic control communication. This may happen if you wanted to operate inside controlled airspace.

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Q Is�there�any�regulatory�process� underway�to�allow�commercial�drone�flights�within�the�Washington,�DC�Flight�Restricted�Zone?�We have not seen any indications of this. Technically, the NOTAM implementing the FRZ states that flight is not allowed without permission. But it does not specify how permission is to be obtained.

CERTIFICATES�OF�WAIVER� OR�AUTHORIZATION�(COAs)

Is�it�true�that�under�Part�107,�we�won’t�be�operating�under�a�COA�any�longer?�If you choose to operate under Part 107 rather than your 333 Exemption, you will no longer be subject to a the Blanket COA (which means no more monthly reports!). However, COA/CoWs will still be required to operate in certain types of airspace.

Do�COAs�expire�and�what�do�they�cost?�COAs are generally granted for a maximum of two years but the exact period can be specified in your application. The FAA does not charge for COA/CoW

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requests. At Skyward, we assist our business and enterprise customers with their initial request for a COA/CoW. Usually once you are familiar with the process it is fairly straightforward.

COA�delays�are�costing�my�business�a�lot�of�money.�Any�relief�in�the�horizon?��Across the industry, we all hope the Certificate of Waiver (CoW) will be a faster process. The FAA recognizes that there is an issue, and this seems to be intended to address it.

Can�you�clarify�under�what�circumstance�you�need�to�apply�for�a�COA?�Is�that�for�any�flight�or�only�in�limited�airspace?�You will need to apply for CoWs to conduct operations in Class B, C, D and some Class E airspace, as defined in 107.41.§ 107.41:

Operation in certain airspace. No person may operate a small unmanned aircraft in Class B, Class C, or Class D airspace or within the lateral boundaries of the surface area of Class E airspace designated for an airport unless that person has prior authorization from Air Traffic Control (ATC).)

Will�my�COA�be�denied�if�I�request� that�it�lasts�for�longer�than�two�years?� I�would�like�to�request�one�that�lasts� for�four�years.We have by no means reviewed every COA/CoW or COA/CoW application. However, our research indicates that they are granted for no longer than two years.

I�was�under�the�impression�that�the�FAA�viewed�COAs�as�indirect�for�Part�107�and�wanted�the�UAV�operator�to�contact�ATC�directly�since�they�are�the�actual�controllers�of�the�airspace.�The method of contacting ATC under Part 107 is still being finalized.

If�you�have�additional�COAs�under�your�333�but�now�want�to�hire�a�pilot�that�has�the�new�Part�107�certificate�can�you�combine�the�two?�You can choose to fly under the COA or Part 107 but not both at the same time. A Part 107 pilot who doesn’t meet Section 333 cannot fly under Section 333.

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OPERATIONS�PLANNING,�OVERFLYING�PEOPLE

What�is�the�107�current�regulation�regarding�first-person�viewing�(FPV),�and�will�that�change?Part 107 does not prohibit first-person viewing, but FPV doesn’t meet the requirements for maintaining visual line-of-sight with the aircraft. Part 107 requires the remote pilot-in-command to be able to see the aircraft at all times without aids other than glasses or contact lenses. This would seem to not allow the remote-PIC to use any FPV devices which block normal vision. The FAA has stated that they don’t have enough data to validate the use of FPV as an acceptable method of meeting the requirement to detect-and-avoid other traffic. It’s possible that in the future enough data may become available to allow the FAA to validate the use of FPV. The visual line-of-sight requirement is waiverable, but Part 107 seems to not allow the use FPV as a method of providing equivalent level of safety (ELOS) during a beyond visual line-of-sight operation (BVLOS).

Has�there�been�any�legal�definition�of�“people�directly�involved�in�the�operation”�as�stated�in�Part�107?Part 107 does not contain the phrase “people directly involved in the operation.” 14 CFR 107.39 prohibits operation over a human being unless that person is “directly participating in the operation of the small unmanned aircraft.” This means crew, not subjects, bystanders, or any other people. Without offering a legal opinion, a crew may be as small as one person (remote-PIC) or have many members (remote-PIC, remote-operator under remote-PIC supervision, visual observer, sensor operator, aircraft handler, operator of ground equipment necessary for the operation, etc). The intent is that anyone who may be directly overflown is aware of the risks and is under the control or coordinating authority of the remote-PIC.

Flights�directly�over�non-participants�are�not�allowed,�but�flying�over�participants�is�allowed.�I�have�seen�FAA�communications�that�speak�about�a�minimum�safe�distance�of�25�feet;�however,�the�online�training�for�Part�107�makes�it�sound�like�you�need�to�get�everyone�completely�out�of�the�way.�

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For�example,�would�a�group�photo� be�allowed�as�long�as�it�doesn’t�fly� directly�overhead?Under Part 107, flying over human beings not directly involved in the operation of the UAV (that is, the crew) requires a waiver. A condition of the waiver may be that the flight is conducted at a closed-set or controlled-access area (a film shoot or a construction site, for example) and that the people being overflown have all received safety briefings, are aware that the flight is happening, and are aware of the risks. It’s important to note that these are provisions of the waiver, not Part 107 itself, which does not allow flying over human beings not directly involved in the operation of the UAV. This is a little different from a section 333 Exemption which grants permission to operate over people on a closed set or controlled access area.

I�regularly�fly�over�privately�owned�agriculture�fields.�Will�crews�working�in�the�fields�need�to�be�removed�before�flights?�Will�I�need�to�get�special�approval�to�be�conducting�flights�over�people?�

Unless you can either ensure that the people working in the field will not be overflown by the UAV or those people are under safe cover during the flight, they should be removed from the field prior to the flight. Careful preflight planning and coordination may make it possible to ensure that you don’t overfly anyone.

In�the�construction�industry,�we�sometimes�need�to�be�able�to�fly�over�a�job�site�or�quarry�during�working�hours�when�many�different�types�of�workers�are�onsite.�We�will�obviously�need�to�waive�the�rule�that�prohibits�flight�over�unsheltered�persons.�Does�the�fact�that�construction�or�quarry�workers�are�required�to�wear�personal�protective�equipment�such�as�safety�glasses�and�hard�hats�mean�that�they�are�protected?Part 107 does not seem to consider personal protective equipment (PPE) such as hardhats or safety glasses as being equivalent to “safe cover.” That said, you should include that information along with the fact that the operation will be conducted at a controlled-access site, and that you will notify all the workers before the flight in your request for a waiver. This will demonstrate to the FAA that you can operate with an equivalent level of safety and not endanger anyone on the ground.

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FLIGHT�LOGGINGI�use�the�DJI�app�to�log�flights.�Should�I�get�a�paper�logbook�as�well?�

If you’re running a business, we don’t recommend using paper logbooks. They require too much legwork, they’re unsearchable, and they don’t provide reports or business insights. Of course, we recommend logging flight ops in Skyward in order to understand the totality of your flight ops.

Does�the�flight�log�need�to�be�more�like�my�log�in�a�Cessna�162�or�can�I�use�the�DJI�app�as�my�flight�log?�

The FAA does not specify the form of the flight log required. If you have even two aircraft or pilots, we highly recommend having one, external flight log as your business’s system of record. That is one of the core features of the Skyward platform.

MOTION�PICTURE�&�TELEVISIONDoes�closed-set�filming�under�Part�107�require�a�waiver�and�motion�picture�manual�just�as�Section�333�did?�

Yes, you will need a waiver to fly directly over people. The reference to a specific MPTOM is not in Part 107 but you will need to submit as part of your waiver request your operations and safety procedures. This may be a motion picture and television operating manual (MPTOM) or a controlled access ops manual.

How�does�Part�107�affect�MPTOMs?

If you have a section 333 exemption allowing closed-set operations there is no effect if you operate under that exemption. Under Part 107, a waiver is required for flying over people. Your MPTOM can be used to support your waiver request. You will most likely still need to submit a Plan of Activities to the FSDO with your procedures included in an MPTOM.

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I�understand�the�idea�of�not�flying�over�stadiums�full�of�people�without�permission�but�for�a�television�commercial�or�similar�industrial�product,�can�we�fly�over�paid�actors�or�others�that�are�part�of�the�production?�What�are�those�limits?

Under Part 107, flying over any human being not directly involved in the operation of the UAV (the crew) requires a waiver. Subjects such as actors are not directly involved in the operation of the UAV. A condition of the waiver may be that the flight is conducted on a closed-set, the people being overflown have all received safety briefings, are aware that the flight is happening, and are aware of the risks. It’s important to note that these are provisions of the waiver, not Part 107 itself which does not allow flying over human beings not directly involved in the operation of the UAV. A waiver is granted for a specific rule and is not necessarily required for a specific operation.

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U.S. Airspace Under Part 107

Part 107 marks an important step toward the full integration of UAVs into U.S. airspace. You no longer face the administrative burden of filing monthly COA reports or applying for

NOTAMs before each flight. Part 107 also opens many areas to commercial UAVs that previously required Civil COA applications. This is great news all around, but it also

U.S. Airspace Prior to Part 107The Skyward Drone Airspace Map shows airspace that had been restricted (in red) or that required a Civil COA (in yellow) prior to Part 107. (The Skyward Airspace Map depicts airspace for the entire world, not just the U.S.)

U.S. Airspace After Part 107And here is U.S. airspace after Part 107. The red areas still indicate restricted airspace including temporary flight restrictions and prohibited and restricted areas, and the yellow areas indicate controlled airspace that requires either coordination with air traffic control or a Certificate of Waiver.

means that the FAA is giving individual operators more responsibility for maintaining airspace safety. And that requires an expertly validated, up-to-date airspace map.

If your business chooses to operate under a 333 Exemption rather than Part 107, keep in mind that you will continue following the pre-107 airspace regulations, including pre-flight NOTAM filing and monthly COA reporting.


Commercial operators can now fly in many more places without seeking prior authorization. And in certain cases, you’ll also be able to fly higher.

This graphic shows just how much airspace has opened up under Part 107.

According to Part 107, UAVs must fly no higher than 400 feet above ground level (AGL). But the FAA understands that, in certain cases, a commercial UAV pilot needs to fly higher—for

example, to inspect certain towers, masts, smokestacks, buildings, bridges, and roadways. In that case, a UAV must fly

Within 400FT

No higher than 400FT above

400FT SAFE ZONE

VERTICAL STRUCTURES

within a 400 foot radius of and no higher than 400 feet above the immediate uppermost point of the structure being inspected.


FLYING�IN�CONTROLLED�AIRSPACEIf�I�already�have�a�333�Exemption,�can� I�do�some�flights�under�Part�107�and� some�under�the�333?�Or�do�I�have�to�make�a�decision�to�go�one�way�or�the�other�from�now�on?Part 107 does not apply to any operation that a remote pilot in command elects to conduct under a Section 333 unless otherwise specified in the exemption. For each operation you must determine whether to operate under your 333 Exemption or Part 107. You cannot operate under both at the same time.

Are�we�required�under�Part�107�to�contact�every�heliport�or�airport�with�towers�within�five�miles?�Part 107 does not require you to contact heliports or airports within five miles. You must have permission to operate within controlled airspace (Class B,C, D, E surface area). Otherwise Part 107 directs operators to be aware of traffic patterns and to not interfere with them.

Questions about AirspaceTHE�SKYWARD�AIRSPACE�MAP

How�are�your�mapping�services�kept�up-to-date?�How�do�you�ensure�that�the�integrity�of�these�are�usable�in�real-time?�Our map data is sourced from official airspace regulators and validated by our geospatial experts. If we identify an error, we contact the regulator. Our map updates about every five minutes.

How�quickly�is�your�airspace�chart�updated�when�the�FAA�makes�any�changes,�like�setting�a�restricted�area?The Skyward Airspace Map reflects most airspace updates, such as temporary flight restrictions, within five minutes of posting.

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My�local�airport�has�a�published�IFR�approach,�so�I�haven’t�been�able�to�fly�within�three�NM�of�the�airport.�Does�that�change�with�107?�Part 107 doesn’t contain the Blanket COA’s standoff requirements. Instead, Part 107 requires you to be aware of traffic patterns at airports and to not interfere; so you will be able to fly within three NM, assuming that the airport is not within controlled airspace. It is your responsibility to be aware of the traffic patterns and to not interfere with them. This includes any aircraft which may be using the IFR approach.

Has�the�process�for�requesting�permission�to�fly�in�Class�C�and�D�airspace�been�fleshed�out�yet?�Many�commercial�opportunities�are�within�controlled�airspace.�Also,�who�will� dictate�flights�in�the�Class�D�controlled� by�military?�We specifically asked the FAA’s UAS Integration Office about this. The reply was that the specific method was still being finalized and would be published on the www.faa.gov/UAV website. We suspect that, at

least initially, the process will involve a waiver. The FAA works closely with military aviation facilities in all matters relating to airspace use.

Are�there�any�restrictions�when�flying�in�uncontrolled�airspace�adjacent�to�an�airport�with�an�ILS�procedure?�With Part 107, the three NM standoff is removed. Part 107 requires you to be aware of and not interfere with the traffic patterns of nearby airports. This includes IFR traffic. No minimum distance is specified.

I�understood�that�the�FAA�has�“final�authority”�when�it�comes�to�regulating�the�airspace,�but�local�governments�and�states�seem�to�be�adding�many�additional�regulations.�Does�Skyward�follow�and�track�local�and�state�regulations�just�as�you�do�FAA�regulations?�Skyward follows the development of local and state regulations in order to gauge their relationship to national regulations. However, the Skyward Airspace Map typically doesn’t reflect local or state ordinances regarding drones.

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http://www.faa.gov/UAV


What�if�local�airspace�use�(let�us�say� Class�D)�can�be�approved�by�FAA�local�tower.�Does�that�really�require�a�COA/CoW�application?�Part 107 says that operators must have prior authorization from air traffic control and does not specify the method of obtaining authorization. Future Advisory Circulars are expected to specify and require you to use a standardized process.

Since�much�of�metropolitan�areas�are�covered�by�airspace�other�than�Class�G�airspace�how�are�the�new�full�COA�requirements�even�practical�in�a�news-gathering�context?Depending on the complexity of the operation or the airspace, a waiver may be granted that applies to all operations conducted by the applicant under the same conditions. For example, waivers have been granted that allow an operator to fly at any location within the controlled airspace surrounding a specific airport subject to minimum distances from any runway, altitude limitations, and communication and notification requirements. The applicant must provide evidence that the operation can be conducted with an equivalent level of safety. The busier the airspace, the

greater the requirement for evidence. For example, short notice news-gathering operations in Class B airspace would likely require major operational restrictions and may never be permitted. It’s also possible that you can make the case that certain operational limitations or procedures can make such operations acceptable to the FAA.

Please�expand�on�getting�permission�from�air�traffic�control�to�fly�in�controlled�airspace.�Will�the�local�ATC�grant�or�deny�permission?�Who�has�the�authority�to�override�a�“no”?�Is�ASO�in�line�with�ATO?�We asked the FAA’s UAS Integration Office whether this process will involve a waiver or some other method. Here is the reply: “We are still developing the policy for authorizing operations in Class B, C, D, or E airspace under the Part 107 rule. The information and notification process regarding those classes of airspace will be released on the www.faa.gov/UAV website as soon as they are finalized.”

How�should�UAV�pilots�contact�ATC?�Do�I�need�to�purchase�a�radio?�From the UAS Integration Office’s reply to our direct question, the FAA has not yet finalized the method

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of coordination with ATC. It has been suggested to us that, at least initially, operators should apply for a Certificate of Waiver. We do not recommend attempting to contact air traffic control via radio, which could be distracting for the workers. Some Skyward customers have received COAs allowing operation near airports, and they use radios to monitor airport traffic.

ALTITUDE�LIMITSWhen�Part�107�specifies�that�you�can�fly�up�to�400�feet�over�the�highest�point�of�a�structure,�does�“structure”�always�refer�to�something�manmade?�Can�in�be�a�natural�occurrence?Because Part 107 specifies 400 feet above ground level (AGL), land features such as hills, mountains, and cliffs elevate the ground level so the top of that feature would be the baseline. However, the implication is that non-land features such as trees and rock spires are not included. Remember: This rule is in place because manned aircraft are supposed to stay 500 feet away from structures.

Does�this�relate�only�to�structures�directly�being�inspected?�If�I�am�surveying�a�nearby�field�or�building,�can�I�use�the�additional�air�space�altitude�surrounding�the�vertical�structure�even�if�it’s�not�what�I’m�inspecting?The rule does not require you to be actually inspecting that structure; it just states that you must fly within a 400 foot radius of and not more than 400 feet higher than the immediate uppermost part of it.

How�can�I�fly�an�area�for�topography�that�has�500�ft�of�relief�(from�the�bottom�of�a�valley�to�the�top�of�adjacent�hills)�over�a�distance�of�2500�ft?�Should�I�fly�less�than�400�above�the�top�of�the�hill�or�400�ft�above�the�ground?�400�ft�above�the�top�of�the�hill�is�easier. Section 107.51, which includes the altitude limitation, is waiverable. To operate using the first method proposed, you would need to request a waiver that would allow you to exceed 400 ft AGL and that includes your procedures for how you will avoid interfering with manned aircraft. The second method you proposed (following the terrain at 400 ft AGL) is certainly in compliance with Part 107—but it does seem operationally challenging.

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BONUS SECTION

Business Success, Finding Jobs & Marketing

At the beginning of this guide, we listed several must-haves for running a safe operation in full compliance with Part 107:

1. Part 107 certification This is step #1—all of your UAV pilots must be certified to fly under Part 107.

2. Qualified personnel The pilots you hire need to be certified, but they also need experience flying the aircraft in your fleet.

3. Validated airspace map It’s impossible to know where it’s safe to fly and where you’ll need special permission without a validated airspace map, such as Skyward’s.

4. Registered aircraft Make sure your UAVs are registered with the FAA.24

5. Insurance Though not required under Part 107, liability insurance is required by most corporations and business customers. It’s also a sign that you take your job seriously and are taking necessary steps to mitigate risks.

But to run a successful, thriving operation, you’ll need more than the bare minimum.




Operations Management Software

Right now, commercial drone operators are faced with the complexity of evolving regulations and the uncertainty of any new, quickly growing industry. Operations management software enables operators to manage the specific information and airspace data they need to meet business, insurance, and regulatory requirements.

If you’re using UAVs for your business look for these features:

• a validated airspace map sourced from official regulatory bodies so you know where you can and can’t fly

• ops planning and flight logging capabilities to efficiently collaborate with your crew and understand the totality of your operation

• a digital system of record to manage pilots, training, maintenance, battery performance, flight hours, and organize key documents like pilot licenses, regulatory approvals, proof of insurance, and operating checklists, associated with specific flight records

Best-in-class software, such as Skyward, ensures safe commercial drone operations while providing the foundation for an emerging global drone network. It gives business leaders the intelligence and processes to do business across the world, and it gives regulators and insurers the quality assurance and metrics they require.

Operations management software will allow you to

1. Meet regulatory requirements For every pilot, safety is number one. The first part of flying drones safely is knowing where it’s safe to fly, right now—not last week, not two months ago. Skyward’s interactive airspace map updates to reflect up-to-the-minute airspace regulations.


2. Scale your business Whether you’re starting a business from scratch, or using drones to expand your current operation, you want to build your business efficiently. If you’re adding drone ops to a corporate ecosystem, you want to prove to your executive and legal teams that the program complies with the law and isn’t exposing the company to undue risk. While many drones come with flight recording systems, if you have multiple drones and pilots operating on different systems, your information will be fragmented at best—and there are no ops planning capabilities. And, because the drone industry is so new, keeping up with evolving regulations will be a continuous undertaking for companies that try to operate without software that provides automated compliance as a function of workflow, even as the rules change.

Skyward puts all of your operational data in one place and creates a system of record that scales with you as you grow. It ensures that you’ll stay up to date with changing regulations. And it enables you to prove your flight hours and operational experience to potential customers.

3. Operate intelligently and efficiently Not every UAV operation is run by an aviation expert. Software is all about bridging the knowledge gap between aviators and executives and empowering everyone to make well-informed decisions. If you’re a pilot, software gives you trustworthy, validated information to plan your flights and an efficient system to log them. If you’re a manager or business leader, software should give you the tools to organize your operations and manage and store records on maintenance, flight hours, regulatory approvals, and proof of insurance.


At Skyward, we’ve focused on creating a user experience that makes sense to aviators and non-aviators alike. Drone pilots may understand all the rules, but it’s essential that executives, investors, and legal teams are able to verify processes.

4. Lower your risks Every business that uses UAVs should have an insurance policy. Insurers want to know that you have safety procedures in place, and they also want proof of maintenance. Software that captures this data makes obtaining insurance efficient, straightforward, and, in some cases, less expensive. Getting insurance may seem like a hassle, but for most companies, insurance is simply a part of doing business. In Canada and the U.S., most businesses carry insurance of some kind. It’s reasonable for customers and clients to expect a service provider to have insurance. And it’s reasonable for customers to require it before they hire you

MarketingThe most frequently asked questions we receive from drone operators are about marketing and finding new customers. Even if your business is just getting started, there are steps you can take to market your services to potential clients.

Step 1: Identify your customer If you specialize in aerial surveying or wind turbine inspection, this will be relatively easy. However, if you’re a pilot-for-hire, the answer may seem wide open. But trying to be everything to everyone is a recipe for failure.

Consider your strengths, your weaknesses, your interests, and the area where you live: If your business is located in Beverly Hills or Westchester County, you may find a ready market for luxury real estate photography. In that case, your customers will likely be high-end realtors. If you live in the


heartland and most people you know work in agriculture, you might think about going into infrared crop imaging or volumetrics. The applications for commercial drone operations are numerous and expanding all the time— which means your opportunities are as well.

Step 2: What problems are you solving for your customer? Too many businesses focus all their marketing energy on “educating the customer.” But your customers don’t want to be educated; they want their problems solved. The difference? Getting educated feels like a lot of work. But if you’re solving your customer’s problem, you’re alleviating their work.

Find out what problems your customers know they have, and be clear about how you’re solving them.

Are you doing something entirely new? Or are you doing something faster and cheaper than it’s been done until now? Make your value clear, whether it’s on your website, your LinkedIn page, Twitter, Facebook, a flier, or in person.

Step 3: Meet your customers and ask a lot of questions While focusing on educating your customer isn’t a great use of your time, you should spend some time educating—yourself.

Networking events, online forums, meet-ups, conferences, the local diner—learning about your customers is key. Depending on your industry, these are all great ways to find out if your customer base knows they have the problem you identified in Step 2. How are they solving it now? What solutions are they using? What are their goals? They may surprise you.


And in the process of having these conversations, there’s a chance you’ll build rapport and gain a customer.

Step 4: Talk to your customers in their own language Every industry has its own jargon. This can work against you (if you use your own), or it can work for you (if you talk like your customers).

If your business’s website is your main form of marketing, use terms that are meaningful to your customers on your homepage. For example, if you’ve identified that your customers are mostly real estate agents, you might choose a website header that says “Drone Real Estate Photography in Miami” rather than “Miami Drones.”

If you have the resources to maintain a blog, you can use it to showcase your work, but be sure to focus on addressing problems that you know your customers have.

The same concept applies if you meet your potential customers at networking events, trade shows, or the local diner.

Step 5: Don’t discount the channels used by other businesses LinkedIn, Craigslist, Twitter, Facebook, and Angie’s List are some of the main ways that customers find solutions to their business problems.

Step 6: Be a pro Word of mouth can make or break a business. If you’re a pro at every step of the way, your clients will recommend you to others, without any time or expense on your part.

So what does it mean to be a pro in the drone industry? It means operating safely (and showing your customers that you do). It means having insurance, just like professionals in other industries. It means meeting regulatory requirements.


Little things can make a huge impact—filling out a scope of work in advance, for example, will show your customers that you take them seriously.

Step 7: Showcase your expertise As the UAV industry matures and competition increases, companies will look for ways to differentiate themselves. Showcasing your experience and flight hours on your website and social media is a great way to set yourself apart. Your flight hours, whether as an organization or an individual, tell prospective clients whether you have in-depth experience or if you’re still in the early stages of becoming a professional.

Logged flight hours not only show that you’re experienced, they also show prospective clients that you pay attention to detail and that you take regulatory requirements seriously. For most companies in most industries, these are a big deal. Drone service

providers who aren’t detail oriented or who don’t care about regulations present too much of a risk for most of the companies and organizations hiring drone pilots today.

We realized that it should be easy for our customers to share their expertise with the wider world. So we created two badges that Skyward users can embed on their websites and share with the world


The personal badge aggregates all of the flight hours an individual pilot logs in Skyward across every organization they fly for, including historical flight hours. This is great for freelancers or contractors who may be a member of several different organizations. This badge is available to everyone with a Skyward Basic subscription (it’s free).

The organizational badge aggregates the flight hours logged by every pilot within a particular organization, including historical flight hours. If a pilot is a member of multiple organizations, the organizational badge only shows hours logged for that specific organization. This badge is available to any business with a paid Skyward subscription.


Are�we�required�under�Part�107�to�contact�every�heliport�or�airport�with�towers�within�five�miles?�Part 107 does not require you to contact heliports or airports within five miles. You must have permission to operate within controlled airspace (Class B,C, D, E surface area). Otherwise Part 107 directs operators to be aware of traffic patterns and to not interfere with them.

I�have�a�sport�pilot’s�license.�Can�I�pursue�and�attract�clients,�and�get�paid,�say�in�real�estate,�at�this�moment?�Or�do�I�need�to�wait�until�I�get�the�Remote�Pilot�Certificate?If you already have a 333 Exemption, you can go ahead with your business. If you don’t, you’ll be operating under Part 107, which means you’ll need to wait until you have been certified.

Questions on Business Processes and MarketingGETTING�STARTED

What�options�do�drone�operators�have�for�liability�insurance?�Are�there�respected�providers�in�this�space�as�of�yet?��There are definitely respected providers. Skyward does not broker, sell, or underwrite insurance, but we do have some useful information at skyward.io/getting-drone-insurance

I’d�like�to�leverage�the�skyward�platform�as�a�selling�point.�Absolutely! Check out this support page to learn more: https://skyward.io/support/user-guide/badges/overview/

Is�there�a�way�to�integrate�the�“flight�hours”�badge�from�my�Skyward�account�into�my�own�website?Yes, see this user guide for instructions: https://skyward.io/support/user-guide/badges/overview/

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https://skyward.io/getting-drone-insurance/

https://skyward.io/getting-drone-insurance/


Do�I�need�a�degree�in�any�specific�field�in�order�to�obtain�a�job�in�the�UAV�field?�After�getting�certified,�it�would�benefit�me�to�get�a�job�with�an�established�company�before�going�off�on�my�own.�Hiring requirements vary by company. A remote pilot certification is the first step, practice and recorded hours at the controls is another, and then there are any number of ways to deepen your knowledge and skills that will make you an attractive candidate for a job. A specific degree may not be a requirement for real estate photography but it might at a company that has corporate hiring standards or more complex operations.

I’m�new�to�flying�drones.�I�just�started�flying�a�few�weeks�ago�for�fun,�now�I�want�to�start�my�own�drone�business.�What�do�you�recommend�as�a�starting�point?�We always recommend identifying an industry (real estate photography, precision agriculture) and developing an expertise and customer base there. It can take time to build trust and a really great portfolio. So start small, build up flight hours, get insurance, and provide excellent customer service.

I�started�for�the�real�estate�industry,�but�I�want�to�plan�a�long-term�career�in�UAVs.�What�industry�is�most�profitable?�The most profitable industry for you is the one that you have the most expertise and best portfolio in. For example, there is a huge demand in construction, which would be a great industry to specialize in—but only if you are also an expert on the construction industry’s needs, which probably includes 3-D modeling and various other data processing.

What�are�the�best�ways�of�obtaining�a�pilot�job�after�getting�certified?Pilot requirements will vary by employer. Logging your flight hours is the best way to demonstrate time at the controls. A good safety record is also important for employers.

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TAXES�&�ACCOUNTING

Can�you�speak�to�the�financial�information�I’ll�need�for�taxes�and�financial�record�keeping?Generally speaking, every business should keep track of the following financial information (this is the bare minimum):

• Receipts for all business expenses—you’ll need these to deduct your business expenses

• Your cash flow—this shows each of your company’s incoming and outgoing financial transactions (operations, investing, and financing)

• Balance sheet—this shows how what you own (your assets) compares to what you owe (liabilities and equity)

• Profit & loss statement—this shows your revenue, costs, and expenses over a given time period

From�an�IRS�stance,�what�I�should�write�off�and�not�write�off�on�my�expenses?The IRS allows you to write off just about every expense you incur in the course of doing business.25 These include, but are certainly not limited to:

• A home office that’s used regularly and exclusively for business (this counts only if you don’t have another office)

• The first $5,000 of expenses you incur from launching your business in its first year

• Travel expenses directly related to your business

• Office supplies & furniture

• Retirement & social security contributions

• Health insurance premiums

• Fees & payments, such as bank fees, interest payments, & accounting fees

• Bad debt (if a customer doesn’t pay you)

• UAVs & batteries

• Website design, maintenance, & hosting

PRO TIP: Avoid a common first-time business owner mistake and always keep your business and personal expenses separate! Get a dedicated bank account and credit card for your business and never use them for your personal expenses or vice versa. This one step will make your tax filing and accounting exponentially easier.

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N O T E S1 FAA’s UAV registration site: https://registermyuas.faa.gov/

2 Entire text of Part 107: http://www.faa.gov/uas/media/RIN_2120-AJ60_Clean_Signed.pdf

3 Summary of Part 107: http://www.faa.gov/uas/media/Part_107_Summary.pdf

4 Based on April 2016 Blanket COA and Exemption No. 15857 retrieved from FAA.gov on April 27, 2016.

5 Based on the FAA’s Summary of Part 107, which took effect in late August.

6 FAA’s list of approved testing centers: http://www.faa.gov/training_testing/testing/media/test_centers.pdf

7 FAA IACRA system: https://iacra.faa.gov/IACRA/Default.aspx

8 FAA’s FAASTeam website: http://www.faasafety.gov/

9 FAA IACRA system: https://iacra.faa.gov/IACRA/Default.aspx

10 FAA’s Remote Pilot Knowledge Test Guide: https://www.faa.gov/training_testing/testing/test_guides/media/remote_pilot_ktg.pdf

11 FAA-approved local testing centers: http://www.faa.gov/training_testing/testing/media/test_centers.pdf

12 Airman Certification Standards: https://www.faa.gov/training_testing/testing/acs/media/uas_acs.pdf

13 FAA’s sample Remote Pilot Knowledge Test: https://www.faa.gov/training_testing/testing/test_questions/media/uag_sample_exam.pdf

14 Airman Certification Standards: https://www.faa.gov/training_testing/testing/acs/media/uas_acs.pdf

15 FAA’s instructions for becoming a commercial UAV pilot: http://www.faa.gov/UAV/getting_started/fly_for_work_business/becoming_a_pilot/

16 FAA’s rules for recreational pilots: https://www.faa.gov/uas/getting_started/fly_for_fun/

17 FAA’s UAV registration site: https://registermyuas.faa.gov/



20 FAA’s list of approved aircraft for 333 Exemption holders: https://www.regulations.gov/document?D=FAA-2007-3330-0007

21 Read the terms of Industrial Skyworks’ exemption at: https://www.faa.gov/UAV/getting_started/fly_for_work_business/beyond_the_basics/section_333/333_authorizations/media/Industrial-Skyworks-16341.pdf

22 Learn more about Skyward’s General Operating Manual and checklists at: https://skyward.io/proservices/

23 NTIA’s Voluntary Best Practices for UAS Privacy, Transparency, and Accountability: https://www.ntia.doc.gov/files/ntia/publications/voluntary_best_practices_for_uas_pri-vacy_transparency_and_accountability_0.pdf


25 Consult this IRS article to learn more about deducting business expenses: https://www.irs.gov/businesses/small-businesses-self-employed/deducting-business-expenses

Skyward does not provide legal advice. This guide is based on our

regulatory analysts’ best understanding of the FAA’s Part 107 rule at the

time of publication, and it will be revised regularly to reflect changes or

corrections. For legal and regulatory advice on drones or using drones

for business, contact an aviation attorney.

Manage and Scale with Skyward’s Drone Operations Management Platform

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Drone Flight LoggingMeet regulatory requirements; track flight hours & maintenance

Digital System of RecordStore & organize licenses, insurance policies, & regulatory paperwork

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