VOLUME 16 Unmanned Aircraft Systems
CHAPTER 4 Operational Requirements and approval
Section 9 Public Certificate of Waiver or Authorization Safety Review
16-4-9-1 PURPOSE. This section provides guidance and policy to
Federal Aviation Administration (FAA) aviation safety inspectors (ASI) concerning
processes and requirements used within the General Aviation and Commercial Division
to facilitate and track the review of unmanned aircraft (UA) FAA Form 7711-1,
Certificate of Waiver or Authorization (CoW/A), requests from the FAA Air Traffic
Organization (ATO) regarding public UA operations above 400 feet above ground
level (AGL) and/or weighing over 55 pounds, or for any other nonstandard operations
in the National Airspace System (NAS).
16-4-9-3 AUDIENCE. The audience for this section is all Flight Standards divisions and
Flight Standards District Office (FSDO) ASIs, aviation safety technicians (AST),
and Flight Standards Service policy divisions responsible for implementation.
16-4-9-5 BACKGROUND. A CoW/A is an authorization issued by the ATO to a public
operator for a specific Unmanned Aircraft System (UAS) activity. Approval documents
are required since UAS may not be compliant with applicable sections of the
Code of Federal Regulations (CFR), and therefore require an alternative method
of compliance (AMOC). After a public operator/applicant submits a complete application,
the FAA conducts a comprehensive operational and technical review. If necessary,
provisions or limitations may be imposed as part
of the approval to ensure the UAS can operate safely with other airspace users.
In most cases, the typical CoW/A application approval process is completed within
60 business-days of receipt, provided there are no submittal errors, missing
information, or safety or airspace issues. Applicants submit a package requesting
UAS operations in the directly into the FAA UAS
Certificate of Authorization (COA) Application Processing System (CAPS)
(https://caps.faa.gov/). The package contains:
• Proponent information,
• Point of contact (POC) information,
• Operational description,
• Performance characteristics,
• Spectrum analysis approval,
• Air traffic control (ATC) communications,
• Electronic surveillance detection capability,
• Visual surveillance detection capability,
• Aircraft performance recording,
• Flight operations area/plan, and
• Special circumstances.
16-4-9-7 SAFETY REVIEW.
A. Administrative Review. ATO/the Emerging Technologies Team
review the submission for required documents to ensure it is complete. If deemed complete,
the package is classified as “committed.” If it is not complete, ATO returns
or “releases” the application back to the applicant for additional data. If
the applicant provides the additional data, the package is termed “recommitted”
back to ATO, which then undertakes a comprehensive review of the submission
to verify it is a complete package. During this phase, ATO does both an administrative
check and a feasibility check of the applicant’s request. ATO does the administrative
review from a policy perspective, checking to ensure the application is completed
correctly, and that all necessary documents and details are contained within
the submission. The appropriate ATO service area accomplishes the feasibility
check from a high-level air traffic perspective. “R” or renewal CoW/As differ
in that a renewal CoW/A is the same exact copy of a previous CoW/A for a different time period.
B. Safety Review. ATO will conduct the safety review unless the CoW/A application
is for a UAS operation weighing more than 55 pounds and/or operating above 400
feet AGL, or for any other nonstandard operation. If the request is for a UAS
weighing more than 55 pounds and/or above 400 feet AGL, or other nonstandard
operations, ATO will forward the package to the General Aviation and Commercial
Division to facilitate a safety review. The General Aviation and Commercial
Division will facilitate the safety review of CoW/A applications from a technical
analysis perspective and recommend risk mitigation provisions. The Flight Standards
safety review is intended to ensure that UAS, regardless of size, do not compromise
the high level of safety for aviation in the NAS, the public, and property on
the ground. The administrative and safety review process officially commences
upon receipt of the CoW/A application.
Figure 16-4-9A General Aviation and Commercial Division Safety Review Process
1.0 ATO (UAS OFFICE) REQUESTS FLIGHT STANDARDS SAFETY REVIEW.
1.1 ATO validates
a CoW/A application for UAS weighing more than 55 pounds and/or operating above
400 feet AGL, or for any other nonstandard operation, and sends an automatic
CAPS message to the General Aviation and Commercial Division Safety Manager,
notifying him or her that a safety review of the CoW/A is requested.
1.1.1 ATO does not require Flight Standards safety reviews for CoW/As for the following proponents:
18.104.22.168 Department of Defense (DOD) (refer to ATO/AJV-115 March 7, 2014, and May 5, 2014, memoranda).
22.214.171.124 Department of Homeland Security (DHS), including Customs and
Border Protection (CBP); Federal Bureau of Investigation (FBI); National Aeronautics
and Space Administration (NASA); National Oceanic and Atmospheric Administration
(NOAA); and Department of Interior (DOI) (refer to ATO/AJV-1 October 31, 2014, memorandum).
126.96.36.199 Public UAS operators requesting CoW/As for UAS weighing 55 pounds or less and/or
operating below 400 feet AGL, unless it is a nonstandard operation or when specifically requested by ATO.
1.1.2 Sensitive and/or emergency CoW/As, called Special Governmental Issue (SGI) CoW/As
(formerly eCOAs), will not be transmitted to the General Aviation and Commercial Division.
2.0 THE GENERAL AVIATION AND COMMERCIAL DIVISION PROCESSES THE
REQUEST. The responsible General Aviation and Commercial Division ASI will
conduct a safety review of the CoW/A application for requests for UAS operations
over 55 pounds and/or over 400 feet AGL, or for any other nonstandard operation.
2.1 The ASI assignment
should be made as soon as possible.
2.2 To meet its part
of the ATO policy of completing CoW/A actions within 60 days, the General Aviation
and Commercial Division normally assigns ASIs a due date of 15 business-days
from the date of the CoW/A Administrative Review. This allows for a 1- to 2-day
review and a 3-day processing time at the General Aviation and Commercial Division.
Flight Standards’ completion of this action occurs when the General Aviation
and Commercial Division forwards the safety review memorandum back to ATO through CAPS.
3.0 ASI ASSIGNED. The General Aviation and Commercial Division
CAPS Safety Manager assigns the CoW/A application package to the designated
ASI through the CAPS process. The package contains the validated application.
4.0 ASI TECHNICAL ANALYSIS. The assigned ASI will review the
application for safety of operational flight concerns, risk mitigation, etc.
4.1 The ASI completes
and forwards a draft memorandum detailing the result of the review to the General
Aviation and Commercial Division management.
4.2 The ASI will advise
if the CoW/A safety review cannot be completed within the assigned timeframe.
Under this circumstance, the ASI will coordinate with ATO.
4.3 The ASI will advise
the ATO POC through the “request release” CAPS workflow regarding any information
that is missing or needs to be revised in the proponent’s application and request
the CoW/A be “released” back to the proponent. The reviewing ASI will make appropriate
notes in the “Internal Comments” section in CAPS.
4.4 After the application
is released back to the proponent, proponent updates the application and resubmits
through CAPS. The ASI will be notified through CAPS to restart the safety review.
5.0 GENERAL AVIATION AND COMMERCIAL DIVISION MANAGEMENT REVIEW AND
COORDINATION. The General Aviation and Commercial Division ASI processes
the safety review memorandum and ensures it is compliant with correspondence guidelines.
5.1 When the CoW/A Safety
Review Memorandum is ready, the ASI will upload the memo in CAPS. CAPS automatically
advances the case back to ATO.
6.0 PROCESS MEASUREMENT. The target to complete processing
of a validated CoW/A application by the General Aviation and Commercial Division
is a maximum of 20 business-days from the time the CoW/A is validated as reported
in CAPS. The measured time excludes any time during which:
6.1 The package was in release
status. Note: Only ATO can release and revalidate a CoW/A. Flight Standards
should request ATO to release an application when the application needs clarification,
additional data, or for other reasons.
6.2 The package is put on
administrative ATO hold status for further research.
7.0 GENERAL AVIATION AND COMMERCIAL DIVISION TIMELINE.
The time in General Aviation and Commercial Division control can be measured
by calculating the number of days between the date the package received (i.e.,
validated in CAPS) and the date the package is sent back to ATO, subtracting
any days for administrative ATO hold or release status.
7.1 General timeline for a normal/new CoW/A: Goal 20 business-days.
7.2 ASI assignment: 2 days.
7.3 ASI assessment: 15 days.
7.4 General Aviation and Commercial Division coordination, signature, and closeout: 3 days.
16-4-9-9 through 16-4-9-29 RESERVED.