Part 107 and Public Safety agenCies

[boefinator]

There is certainly more flexibility in a COA for Public safety missions versus the line up and wait on the 107 process. We fly 107 right now, but if I had a mission requirement for BVLOS for instance, I would want an active COA that I could work hand in hand with the FAA versus the standard waiver process. 107 works until it doesn't and then you have to start a blanket COA as opposed to modifying a jurisdictional one. I stand by the advice to get both as do some key people in the FAA. But to each their own, the advice is with the price you pay for it. YMMV

 

[licensed pilot]

There is certainly more flexibility in a COA for Public safety missions versus the line up and wait on the 107 process. We fly 107 right now, but if I had a mission requirement for BVLOS for instance, I would want an active COA that I could work hand in hand with the FAA versus the standard waiver process. 107 works until it doesn't and then you have to start a blanket COA as opposed to modifying a jurisdictional one. I stand by the advice to get both as do some key people in the FAA. But to each their own, the advice is with the price you pay for it. YMMV

Not sure we would ever risk flying BVLOS, can't think of any practical scenario calling for that with our M600. But thanks for the advice.

 

[Southern Style]

I am currently flying in the state of Florida for a LE Agency.. We are currently flying under the Part 107. For some reason, the city attorney wanted NO NIGHT FLIGHTS written into our policy and procedures. We do have access to the Sheriff's Aviation Unit whenever needed. I am the only pilot for our agency as of now. We are definitely looking into a COA. BVLOS is usually taken care of utilizing other VO's on the scene (SWAT, etc). Will are working on flying at night. We just wanted to get our foot in the door and get the sUAS Unit operational and passed the City Council, City Attorneys, and more importantly.. CITIZENS. Now that we are up and running, we can slowly start tweaking our usages and policy as the laws relax..

 

[LevitatedMedia]

Currently in the process of setting up our departments sUAS program, working on a grant with a company and looking into getting the Inspire 1 FLIR package they offer. Was wondering if you had any reference material to obtaining the SGI's for LEO Agencies and such, right now the plan is to make it a regional asset which means I'd likely be called to fly in a few different types of airspaces but mainly Class D near KBDL.

The plan right now is I hold a Part 107 license and have the majority of the sUAS knowledge therefore I will be spearheading the program, doing all the in house training and so forth.

 

[licensed pilot]

I have an FAA email with info that may help you. send me a PM.

 

[Southern Style]

LevitatedMedia...BVLOS is something we have bsen discussing with administration.. specifically flying thru a window or door during a stand-off... was asked during a SWAT usage if I could fly into the residence.. just a thought

 

[Racer38]

Anyone aware of any PS agency currently operating under Part 107? If so please PM the agency name. Tried FAA, no response...Thanks.

We are not doing the Part 107 route. We are doing the Public COA. Not an easy task, but it allows us to self certify pilots. The FAA wouldn't track Agencies using the Part 107 Pilots they would only know who the licensed pilots are. You could tray and search for Public COA's, I know of a couple of Sheriff's Departments that went that route.

Craig

 

[Racer38]

Why would we need a COA? I'd like to know if we are missing the boat. We are in G airspace, have night waiver, no plans to ever operate in controlled airspace, nor agree to fly in any other agencies' controlled airspace, all flight crews are FAA 107 certified, with our own internal training and standards program. What will a COA bring to the party?

It takes the Liability off of the Licensed Pilot and places it on the Department. If you are flying as a Commercial Drone Pilot PIC, you own it not your department.

Craig

 

[Eric Gildersleeve]

Hello. I am a Public Safety COA Program Coordinator in the DFW airspace. I wrote three COAs and would be happy to share.

Our primary jurisdictional is Class B, D, G, and E. Up to 500 ft AGL and Night Authorized. I have an allowance up to 2000 ft AGL 1/4 mile around a tower outside our county as well.

My other primary is the Blanket Waiver which they amended to Night a while back.

The third is a jurisdictional and my first COA. When I amended to 500 ft the FAA decided to issue a new COA instead of amending.

I am studying for my 107, but (and there is a lot of confusion on this) we were specifically told by the FAA that publicly owned aircraft must have a COA for the bird. We can choose to fly 107 missions but the bird must be covered. I have been told by many this is not the case, but the FAA Fort Worth Regional Office has told me we must have a COA.

I would be happy to provide anyone with information. I have shared to many and it is all on a Dropbox link.

 

[licensed pilot]

It takes the Liability off of the Licensed Pilot and places it on the Department. If you are flying as a Commercial Drone Pilot PIC, you own it not your department.

Craig

Well, "liability" is a legal term, not a licensing term. Yes, any FAA enforcement action will be against your license. In reality, if a police department 107 pilot screws up, who do you think is getting sued? The deep pockets are with the municipality.

 

[Racer38]

Well, "liability" is a legal term, not a licensing term. Yes, any FAA enforcement action will be against your license. In reality, if a police department 107 pilot screws up, who do you think is getting sued? The deep pockets are with the municipality.

Yes I do agree with part of this, but there is still a lot of liability with the licensed PIC. We had our Union legal guys look at the part 107 way to do it and they said No Way. Public COA to protect the officer. It may be something you want to do or consider. Your already ahead of the game by having licensed pilots. That might make the training aspect in the COA a lot easier!

Craig

 

[licensed pilot]

Hello. I am a Public Safety COA Program Coordinator in the DFW airspace. I wrote three COAs and would be happy to share.

Our primary jurisdictional is Class B, D, G, and E. Up to 500 ft AGL and Night Authorized. I have an allowance up to 2000 ft AGL 1/4 mile around a tower outside our county as well.

My other primary is the Blanket Waiver which they amended to Night a while back.

The third is a jurisdictional and my first COA. When I amended to 500 ft the FAA decided to issue a new COA instead of amending.

I am studying for my 107, but (and there is a lot of confusion on this) we were specifically told by the FAA that publicly owned aircraft must have a COA for the bird. We can choose to fly 107 missions but the bird must be covered. I have been told by many this is not the case, but the FAA Fort Worth Regional Office has told me we must have a COA.

I would be happy to provide anyone with information. I have shared to many and it is all on a Dropbox link.

FAA Washinton told me a department can go either COA OR Part 107. There is no mix and match.

Here's a couple of FAA Washington folks who were very helpful:

John Meehan
UAS Integration Office, AUS-430
Safety & Operations Branch
Direct Tel: (202)-267-8825
Email: [email protected]

Steve Pansky/SAIC
Senior Aviation Analyst
Aviation Safety (AVS) Safety Technical Support Services (STSS)
Air Traffic and Law Enforcement/SAC-EC Liaison
Supporting Federal Aviation Administration
Unmanned Aircraft Systems Tactical Operations,
Emerging Technologies Team, AUS-430/AJV-115
[email protected]

202-904-9400

 

[licensed pilot]

Yes I do agree with part of this, but there is still a lot of liability with the licensed PIC. We had our Union legal guys look at the part 107 way to do it and they said No Way. Public COA to protect the officer. It may be something you want to do or consider. Your already ahead of the game by having licensed pilots. That might make the training aspect in the COA a lot easier!

Craig

I respect your opinion. Our legal eagles had no problem with 107, as they opined there are no better standards of training than holding an FAA Remote Pilot Certificate and, of course strict policies and procedures.

 

[Racer38]

I have had quite a bit of interaction with Steve Pansky in regards to our letter of declaration. He was a great help getting it through the FAA Lawyers. We now have access to the CAPS system to submit our COA.

Craig

 

[Racer38]

I respect your opinion. Our legal eagles had no problem with 107, as they opined there are no better standards of training than holding an FAA Remote Pilot Certificate and, of course strict policies and procedures.

Thanks, just looking at it from a different perspective. Your organization has no standing with the FAA as each pilot is a Licensed Part 107 Pilot as an individual. So if you have a reportable accident and have to file with the FAA it will be on that PIC in regards to the FAA. If the FAA were to find Pilot error, that is most likely who the lawyers are going to look at. I am sure they would also look at the Organization as that was who you were flying for. Also you had mentioned a Night Waiver, that waiver is most likely issued to the PIC that filed for it, where as under a COA its a blanket type waiver for the Department and all its Pilots.

I am just trying to point out the benefits of a COA vs Part 107 individuals.

Anyway, excellent exchange of ideas. Glad I found these forums and the professionalism shown by the members !

Craig

 

[licensed pilot]

The night waiver is issued to the organization, under my name.

We are talking about two different points of view. From a regulatory standpoint the FAA will come after the licensed pilot, you are right in that regard.. From a legal standpoint, in any lawsuit the city will be a co-defendant because the UAS unit is a part of the PD, on paper, that's where the money is. Just two different sides of the same coin.

Sort of the same scenario if a cop kills a pedestrian with his squad car; the state issues the driver's license (but the attorneys are not going after the state), the city will still get sued because that is where the big money is (the principles of negligent retention and vicarious liability).

I enjoy the discussion.

 

[boefinator]

You absolutely can operate under both 107 and a COA. Remember, just like manned aviation, it's a flight by flight determination of the rules that apply, made by the PIC at the time. You just can't operate a SINGLE FLIGHT under both sets of rules, it's as Licensed Pilot says, one or the other. As far as how you run your program it can be beneficial for both a COA and 107, but many agencies such as Licensed Pilot's, operate extraordinarily well with just a 107 and a night waiver. The complexity of your individual operation should be the determining factor for the statutory rules you operate under (107, COA or Both). As far as an agency needing a COA for the aircraft, that is not correct. You can register your UAS as Part 107 Aircraft and operate without a COA. We have and we do. If your FSDO is telling you that they are incorrect, you can contact John Meehan at the FAA who can verify. I will say 107 is easier to get going under and a night waiver is easy. But for my agency, it gets a little more complex because 80% of my 30 square mile jurisdiction is within the surface area of both a Class D and Class C airport. We have a waiver, with Tower support, pending with the 107 team and a blanket COA still pending. That being said we have conducted flights in the Class D with an Emergency Waiver on several occasions, usually airborne with waiver in hand in 30 minutes. As others have said, I would be more than willing to share our Flight Ops Manual, Policy, Training Materials and Waivers with those who are interested. Great Discussion here.

 

[licensed pilot]

Well said.

 

[boefinator]

You absolutely can operate under both 107 and a COA. Remember, just like manned aviation, it's a flight by flight determination of the rules that apply, made by the PIC at the time. You just can't operate a SINGLE FLIGHT under both sets of rules, it's as Licensed Pilot says, one or the other. As far as how you run your program it can be beneficial for both a COA and 107, but many agencies such as Licensed Pilot's, operate extraordinarily well with just a 107 and a night waiver. The complexity of your individual operation should be the determining factor for the statutory rules you operate under (107, COA or Both). As far as an agency needing a COA for the aircraft, that is not correct. You can register your UAS as Part 107 Aircraft and operate without a COA. We have and we do. If your FSDO is telling you that they are incorrect, you can contact John Meehan at the FAA who can verify. I will say 107 is easier to get going under and a night waiver is easy. But for my agency, it gets a little more complex because 80% of my 30 square mile jurisdiction is within the surface area of both a Class D and Class C airport. We have a waiver, with Tower support, pending with the 107 team and a blanket COA still pending. That being said we have conducted flights in the Class D with an Emergency Waiver on several occasions, usually airborne with waiver in hand in 30 minutes. As others have said, I would be more than willing to share our Flight Ops Manual, Policy, Training Materials and Waivers with those who are interested. Great Discussion here.

Class D Waiver received today with zero follow up, 45 days not bad!

 

[licensed pilot]

Class D Waiver received today with zero follow up, 45 days not bad!

Nice!