We always get questions regarding Part 107 vs COA and if a Blanket COA is the right move for a public safety sUAS program. Overall, many people that work for a federal, state, or local government office and want to implement a sUAS into their daily operations, think that a COA is the way to go. However, with a Part 107 certification now in the mix, that is not always the case anymore. Let us explain why.
What is a Blanket COA?
A Certificate of Waiver or Authorization (COA) is an authorization issued by the Air Traffic Organization to a public operator for a specific UAS activity. A Blanket COA is a granted authorization that includes the following:
- The drone must operate within the visual line of sight of the pilot
- Visual observers must be used at all times
- Operations must occur during the day
- The drone must remain below 200 feet above ground level (AGL)
- The drone must stay 2-5 nautical miles away from all public-use airports or heliports
- The drone must be registered and display its aircraft registration number
- A Notice to Airmen must typically be issued for each operation
If a government entity wants to fly outside of their granted Blanket COA, they must apply for a separate COA for that specific operational change.
A Blanket COA sounds like a great option, right? Here’s the catch:
Now that a Part 107 certification is an option; your organization would actually be more restricted under a Blanket COA than the standard Part 107 regulations in the majority of cases. Part 107 is a better option in uncontrolled airspace since the majority of airports in the country are located in regions of uncontrolled airspace and the standard Blanket COA requires a minimum distance of 2 miles be maintained from all of these facilities. Also, the Federal Aviation Administration (FAA) has indicated that since the Part 107 regulations created a new Airman Certificate type in the form of the Remote Pilot Certificate with sUAS Rating, they now prefer that public safety departments adopt the Remote Pilot Certification standard if the scope of their proposed operations falls within the parameters of most Part 107 rules.
As we mentioned above, the term “COA” simply stands for Certificate of Waiver or Authorization. These documents are issued for a variety of “special situations” for which standard Federal Aviation Regulations (FARs) do not apply in many different areas of aviation. In virtually all cases, the COA is meant to be a temporary solution until suitable FARs are developed. Once they are, the FAA will begin to phase out the applicable COA. We have already seen this happen to the Section 333 Exemption and its COA (the Commercial sUAS equivalent of the Public Use Blanket COA) in cases where the scope of the proposed operations would now largely fall under Part 107 regulations. It is also now happening with Public Use Blanket COAs since the implementation of Part 107 covers all of the same operational areas; again, provided the Unmanned Aircraft System (UAS) intended to be used falls under the classification of “small unmanned aircraft” or sUA. If your sole reason for pursuing a Blanket COA and utilizing an internally developed “self-certification” plan for your operators is to avoid having to take an exam, and is not based on a definitive operational requirement that cannot be met using Part 107, the FAA will most likely challenge your request and your proposed sUAS training and certification plan very strongly.
Let’s discuss the bottom line:
Ultimately, we predict that in the not-so-distant future, Blanket COAs will no longer be given at all for true sUAS operations and everyone will be pushed to either Part 107 and/or a Jurisdictional COA if necessary. Also, contrary to former practices that were in common prior to the adoption of Part 107, it is not necessary for a Public entity to initially receive a Blanket COA and then request a Jurisdictional COA in order to enhance operational effectiveness associated with airspace and other “waiverable” items. It is currently an option to petition directly for a Jurisdictional COA for sUAS use by a Public/Government entity if appropriate.
Why does this matter:
For public safety departments or any other government entity pursuing a sUAS program, it’s crucial to take the correct steps to certifying and training your team. It’s important to know that although COAs are usually know as being the flexible option, a Part 107 certificate is what the FAA is pushing, and all sUAS operations falling under the FARs is the ultimate goal.
Interested in sUAS Training?
DARTdrones is the national leader in drone training and consulting. Our expert flight instructors will use their real-world experience to get you trained and launched in the drone industry. If you or your organization are interested in public safety UAS training, Part 107 test prep, online UAS courses, UAS consulting, or any other information and resources, visit www.dartdrones.com or call us at 800-264-3907!