U.S. DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION
Effective Date: 7/30/13
Cancellation Date: 7/30/14
Unmanned Aircraft Systems (UAS) Operational Approval
1. Purpose of this Notice. This notice provides policies necessary for reviewing and evaluating the safety and interoperability of
proposed Unmanned Aircraft Systems (UAS) flight operations conducted within the United States (U.S.) National Airspace System (NAS) for the Aviation Safety (AVS) Flight
Standards Service (AFS), UAS Integration Office (AFS-80), when assessing applications for a Certificate of Waiver or Authorization (COA) or Special
2. Audience. This notice applies to AFS divisions at the Federal Aviation Administration (FAA)
Washington headquarters (HQ) and regional field offices.
4. Where You Can Find This Notice. You can find this notice on the MyFAA Web site at
can access this notice through the Flight Standards Information Management System
(FSIMS) at http://fsims.avs.faa.gov. Air
carriers and operators can find this notice on the FAA’s Web site at:
notice is available to proponents and the public at
a. UAS Operations. UAS operations have increased dramatically in both the public and private sectors. This proliferation has introduced
greater exposure and elevated risk to the safety of operations within the NAS. This growth in UAS operations has increased the number of applications for operational
approvals and increased demand on the FAA to process them. For these activities, the development of a notice is required for the FAA to use when evaluating applications
for COAs and Special Airworthiness Certificates.
b. Policy. Policy identifies Unmanned Aircraft (UA) as “aircraft” flown by a “pilot” regardless of where the pilot is located. Aircraft
and pilots must demonstrate compliance with applicable sections of Title 14 of the Code of Federal Regulations (14 CFR) to operate in the NAS. However, UA are not
compliant with certain sections of 14 CFR. For instance, the absence of an onboard pilot
means that the “see-and-avoid” provisions of 14 CFR part
be satisfied. Without an onboard pilot, there is a significant reliance on the command and control link, and a greater emphasis on the loss
of functionality associated with lost link. Furthermore, for air traffic control (ATC) operations requiring visual means of maintaining in-flight separation,
the lack of an onboard pilot does not permit ATC to issue all of the standard clearances or instructions available under the current edition of FAA Order
Traffic Control. Consequently, to ensure an equivalent level of safety, UAS flight operations require an alternative method of
compliance (AMOC) or risk control to address their “see-and-avoid” impediments to safety of flight, and any problems they may generate for ATC. In the future, permanent
and consistent methods of compliance will be needed for UAS operations in the NAS without the need for waivers or exemptions.
6. Consensus Opinion. This notice is subject to continuous review, will be updated when appropriate, is not meant as a substitute for
any regulatory process, and was jointly developed by and reflects the consensus opinion of:
· Flight Technologies and Procedures Division (AFS-400);
· UAS Integration Office (AFS-80) and the ATO component of AFS-80; and
· Aircraft Certification Service (AIR), Production & Airworthiness
Note: In general, and as a minimum, proponents must observe all applicable regulations of 14 CFR parts
notice identifies acceptable AMOC with the regulations when evaluating requests for approval of proposed UAS operations. Refer to the following Web
site for a listing of regulations:
7. Discussion. This notice represents the culmination of input from government agencies, industry, and user stakeholders along with
best practices and procedures that have been used by FAA in prior approvals for UAS applications for COAs or Special Airworthiness Certificates. The material presented
in this notice represents the process and procedures necessary for approving applications for UAS flight operations. However, because of the uniqueness of various UAS
flight operations, each application must be evaluated on its own technical merits, including operational risk management (ORM) planning. Each application may require
unique authorizations or limitations directly related to the specific needs or capabilities of the UAS and/or the proposed specific mission and operating location.
8. Applicability and Approval Process Criteria. The applicability and process to be used in UAS operational approval are dependent on
whether the proposed UAS operation within the territorial airspace of the United States (the airspace above the contiguous United States, Alaska, Hawaii, U.S.
territories, and U.S. territorial waters) is defined as public or civil (refer to 14 CFR part
Public Law 110-181, “The National Defense Authorization Act of 2008”). UAS operations outside the territorial airspace of the U.S. will be classified as either state or
civil operations in accordance with international law. A public operation is one that is intrinsically governmental in nature (i.e., Federal, State, and local agencies).
Proponents requesting approval of public aircraft operations by UAS will use the COA application process. Proponents requesting approval for civil operations will use
the Special Airworthiness Certificate process, provided the aircraft has been issued a type certificate from AIR in accordance with 14 CFR part
prohibits operation of an aircraft that has an experimental certificate from “carrying persons or property for compensation or hire.”
a. Coordination and Approval. Regardless of the process for the authorization approval, COA applications for UAS flight operation
approvals will be coordinated through the ATO component of AFS-80 and AVS. Special Airworthiness Certificates will be coordinated through the AIR-240 staff as well as
the ATO and AFS component of AFS-80 for final approval and disposition.
b. Applicability and Methods of Authorization. Operational policy in this notice applies to both public and civil operations
and certain state aircraft operations.
(1) Applicability. These procedures are applicable for all operations in the contiguous United States, Alaska, Hawaii, U.S. territories, and
international airspace in the Flight Information Regions (FIR) delegated to the United States where the FAA is the Air Traffic Service (ATS) provider. These procedures do
not apply to the territorial airspace of another sovereign country that lies within FIRs delegated to the United States where the FAA is the ATS provider, except by
agreement with that country, or airspace in FIRs delegated to other countries. All UAS proponents, operators, and pilots must observe all applicable regulations of
(a) In general, specific authorization to conduct UAS operations in the NAS outside of active Restricted and Warning Areas designated for
aviation use, or approved Prohibited Areas, must be requested by the proponent. Airspace inside buildings or structures is not considered to be part of the NAS and is
not regulated. (Refer to the current edition of Order JO
Traffic Organization Policy.)
(b) This notice and the processes prescribed do not apply to hobbyists and amateur model aircraft users when operating unmanned systems for
sport and recreation. Those individuals should seek policy under the current edition of advisory circular (AC)
Aircraft Operating Standards. AC
not to be used as a basis of approval for operation of any other aircraft, including by Federal, State, and local governments, commercial entities,
or law enforcement.
(c) This notice and the processes prescribed also do not apply to UAS operations in FAA-controlled international airspace by an agency of, or
a contractor to, the Federal government when those operations are appropriately designated as State aircraft operations and are operated under “due regard” rules and
procedures established by the Federal agency responsible for the operation. The designation of flight operations as State aircraft operations normally are made in
coordination with the U.S. Department of State (DOS). This notice and the processes prescribed do, however, apply where the responsible Federal agency either has not
established a formal set of rules and procedures for “due regard” operations, or is not operating the UAS under “due regard” rules and procedures in FAA‑controlled
international airspace. This notice and the processes prescribed also apply to all UAS operations by an agency of, or a contractor to, the Federal government
that transit through U.S. territorial airspace en route to or from international airspace. See Appendix F, UAS COA Requirement. The “due regard” option is not
available for state aircraft operations transiting through U.S. territorial airspace en route to or from international airspace.
(d) Oceanic Operations Within Warning Areas. UAS operations contained within Warning Areas are handled in the same manner as those operations
conducted in active Restricted and approved Prohibited areas; that is, neither specific
FAA approval nor observers or chase aircraft are required by the FAA.
(e) The only public aircraft that can fly under “due regard” are U.S. government aircraft designated as State aircraft.
(2) Methods. The methods of operational approval are the issuance of either a COA for public aircraft operations or a Special Airworthiness
Certificate for civil operations, provided the aircraft has been issued a type certificate from AIR in accordance with part
the case of public aircraft operations, the operating entity applying to conduct the UAS operation must comply with its own processes, policies, and
standards in the following areas, in addition to complying with all applicable safety provisions in all other parts of 14 CFR:
· Pilot certification,
· Crew certification,
· Recent pilot experience (or, currency),
· Medical certificates, and
· Airworthiness of public UAS.
Note: If no established public entity processes, policies, or standards exist, it is highly recommended that the public
agency/department apply the specifics outlined in this notice and comply with the provisions of 14 CFR applicable to civil UAS operations.
9. COA for UAS Operations.
a. Applications. Applications for a COA are accepted from entities that intend to conduct public aircraft, civil, or commercial
operations. An application may be referred to the FAA Office of the Chief Counsel (AGC-200) for determination of the status of a proponent as a government entity under
the public aircraft statute Title 49 of the United States Code (49 U.S.C.), § 40102(a)(41). Applications for COAs for civil and commercial operations will
only be accepted for aircraft that have received a type certificate from AIR for those operations specified within part
duration of COAs complies with the time limitations specified under the current edition of FAA Order
Operation and Administration. COAs may be issued for a lesser duration if requested or deemed appropriate. COAs are not required for public operations conducted within
active restricted or warning area airspace designated for aviation use, or approved prohibited Areas with permission from the appropriate authority or using agency of
that airspace. (Refer to the current edition of Order JO
7400.8, Special Use Airspace.)
b. Approving and Reviewing Authority. AFS-80 is responsible for determining whether the proponents’ proposed UAS operations can be
conducted safely and responsibly in the NAS, and that they comply with all COA limitations and provisions.
(1) In accordance with FAA Order
a general rule, a waiver or authorization should be canceled when it is no longer required or there is an abuse of its provisions or unforeseen safety factors develop.
Failure to comply with the waiver or authorization is cause for cancellation.”
(2) The FAA has the authority to suspend or cancel the COA, or to delay any activities if there is a violation of the terms in the COA, or if
the safety of persons or property on the ground or in the air is determined to be in jeopardy. That may include, but is not limited to:
· Incidents or accidents occurring during UAS operations in the NAS;
· Habitual noncompliance with administrative requirements, such as failure to
provide the FAA with monthly reports on the number of flights, pilot duty time, or unusual equipment malfunctions (e.g., a malfunction or failure
of ground control station (GCS) flight control hardware or software (other than loss of control link); a power plant failure or malfunction; a deviation from
any provision contained in the COA);
· Deviations from ATC instructions, operational, or coordination issues; and
· Events of intermittent or persistent lost-link as described in
the COA or events determined to pose as a risk to the safety of the NAS.
(3) COA suspensions and cancellations are not automatic. Whenever possible, a documented conversation, between the FAA and the proponent, will
happen before the suspension/cancellation is issued. Timely and transparent responses to accidents,
deviations, and similar safety-related events are expected.
c. Accident and Incident Notification and Investigation. The current edition of FAA Order
Accident and Incident Notification, Investigation, and Reporting, and Title 49 of the Code of Federal Regulations (49 CFR) part 830, outlines reporting procedures for
accidents and incidents involving civil aircraft and certain public aircraft. All accidents and incidents involving fatalities, injuries, property damage,
and fly-away by civil aircraft and those public aircraft subject to part 830 require FAA notification within 24 hours. No additional flights by those aircraft
under this COA are allowed before notification. An immediate investigation is required, and when requested to do so, UAS proponents are expected to provide
copies of written aircraft accident/incident reports to AFS-80 for review. In accordance with 49 CFR part 1520, § 1520.5, reports will not be released outside of
government channels without originator permission.
d. General COA Process. The ATO component of AFS-80 is responsible for the administration of the COA process. Applications can be made
(1) On the Internet using the UAS COA Online System at
UAS COA Online System requires a user name and password; a support desk phone number and e-mail address is provided to assist with obtaining an account.
(2) Using FAA Form
for Certificate of Waiver or Authorization, available online at
completed form can be mailed to: FAA Headquarters, Unmanned Aircraft Systems Integration Office, 490 L’Enfant Plaza SW, Suite 3200, Washington, DC 20024.
Mail submittal may encounter significant delay due to current U.S. Postal Service security screening procedures in place.
e. Operational Review. Prior to issuance of a COA, air traffic specialist components of AFS-80 conduct an operational validation that
addresses ATC processes. Next, an aviation safety inspector (ASI) evaluates each application to determine if risks to the NAS associated with the operation have been
acceptably mitigated. Both the ASI and ATC requirements are merged into the final COA.
f. Safety Risk Management (SRM) Process. ASIs and other FAA personnel
use SRM principles outlined in the current edition of AC
Management Systems for Aviation Service Providers, to maintain or improve the safety of the NAS by identifying safety risks, hazards, and mitigations associated with
proposed UAS operations. When deemed appropriate, Safety Risk Management Documents (SRMD) are created through SRM reviews of specific operations or of risks associated
with UAS operations in various classes of airspace. SRM reviews may result in the incorporation of additional mitigations or controls into all or some COAs.
g. National Security Considerations. When appropriate levels of Department of Defense (DOD) or Department of Homeland Security (DHS)
declare a UAS operation to be a matter of national security, the FAA may approve an application for a COA which, under normal circumstances, might not otherwise
conform to the guidelines set forth in this notice. In this case, national security may override risk mitigation requirements. Such requests to the FAA Administrator
will originate from an equivalent level of authority from the proponent’s parent organization.
h. Special COA.
(1) National Disaster COA. Due to the unpredictability of national disasters, a National Disaster COA is issued in two parts. In part 1 of the
COA, AFS-80 completes an evaluation, excluding the location of the disaster. All known information is inserted into a template and signed by appropriate FAA authority.
Once the specific location is identified, this information, along with the specific operation, is inserted into part 2 of the COA in the form of an attachment. Part 2 of
the COA must then be signed by appropriate FAA authority, which completes and establishes a valid COA.
(2) Emergency COA. An emergency UAS COA may be considered when all of the following conditions apply:
(a) A situation exists that is defined as a condition of distress or urgency,
where there is, or that has, the extreme possibility of loss of life, and
(b) The proponent has determined that manned flight operations cannot be conducted efficiently, and
(c) The proposed UAS is operating under a current approved COA for a different purpose or location.
Note: Requests for UAS COAs that fall outside of these parameters will be processed
through the normal online COA application process. Emergency UAS COAs will not be considered for:
· Demonstration flights,
· Flights to test capabilities,
· Flights in Class B Airspace, or
· Flights over populated areas, unless a suitable mitigation strategy
is proposed and found to be acceptable.
10. Special Airworthiness Certificate for Civil UAS Applicants.
a. Airworthiness Determination. Civil applicants may apply for a Special Airworthiness Certificate from the FAA. The proponent is
required to submit the requisite data to support a determination that the aircraft and its systems, including the control station (CS), are designed, built, and
maintained in a safe and airworthy condition.
b. Special Airworthiness Certificate Issuance. Special Airworthiness Certificates are typically issued to proponents wishing to
conduct UAS research and development (R&D), crew training, and market surveys under
part 21, §
FAA also issues special flight permits for production flight testing of UAS under §
Special Airworthiness Certificates for restricted category aircraft may be issued for special purpose operations, including agricultural
spraying, aerial surveying, pipeline patrolling, and other operations specified by the FAA under §
Airworthiness Certificates are issued in accordance with FAA Order
Certification of Unmanned Aircraft Systems and Optionally Piloted Aircraft, current edition. Refer to Order
in-depth information on Special Airworthiness Certificates.
c. Proponents with Special Airworthiness Certification. In cases where a proponent has been issued a Special Airworthiness Certificate,
they will still require a COA to conduct UAS operations. For public aircraft operations that have aircraft with type certificates issued by AIR, the COA remains the
means of authorization for flight operations.
d. General Process for Civil UAS Operations. For civil UAS operations, the Aircraft Certification Service, Production and Airworthiness
Division (AIR-200) at FAA HQ, is responsible for the issuance of Special Airworthiness Certificates according to FAA Order
issuance of a Special Airworthiness Certificate is coordinated with AIR-200, AFS-80 and the ATO component of AFS-80, and AFS at the HQ and
regional levels. A thorough review is conducted by the FAA to evaluate the system’s airworthiness and operational specifications. In addition, the FAA reviews and
accepts mitigations developed by the proponent to meet acceptable standards of safety.
11. UAS Airworthiness. All UAS must be in an airworthy condition to conduct flight operations in the NAS. An “airworthy condition for
UAS subject to a COA” means that the UAS has been issued the appropriate type certificate from AIR and/or meets the applicable
standards and requirements of its operating agency and is capable of operating in compliance with the applicable requirements in part
FAA recognizes that some of the requirements can differ from those for manned aircraft and appropriate changes can be defined. As with airworthiness
standards, maintenance technician requirements will be addressed as part of the review process.
a. Public Aircraft Proponents. The proponent must provide an airworthiness statement specifying compliance with the proponent’s
applicable airworthiness criteria. Airworthiness statements must be provided on agency letterhead and include:
· The date the statement is effective,
· A signature of the responsible certifying authority within the
· A point of contact (POC), and
· Any warnings/limitations.
(1) Airworthiness statements are generally written for one UAS. If more than one UAS model is included on a single airworthiness statement,
each UAS will be listed and specific information for each UAS will be included in the statement. Airworthiness statements with an expiration date must remain current
for the duration of the COA including extensions. If a new airworthiness statement is issued during the period the COA is active, a copy of the airworthiness certificate
must be provided to AFS-80.
(2) Examples of acceptable policy/criteria include, but are not limited to:
· Department of Defense (DOD) Handbook, MIL-HDBK 516B, Airworthiness
· Air Force Policy Directive (AFPD) 62-6, USAF Aircraft Airworthiness
· Army Regulations (AR) 70-62, Airworthiness Qualification of Aircraft
· Naval Air Systems Command Instruction, NAVAIRINST 13034.1 series,
Flight Clearance Policy for Air Vehicles and Aircraft Systems.
b. Civil Aircraft Proponents. Approvals for civil applications using the Special Airworthiness Certificate process receive their
airworthiness certification from the FAA.
c. Continued Airworthiness.
(1) Public Aircraft. Proponents for UAS used in public aircraft operations should follow their own agency’s procedures and guidelines to
maintain continued airworthiness at a level which ensures they continue to operate the aircraft safely.
(2) Civil Aircraft. Proponents for civil UAS operational approvals must address continued airworthiness procedures as part of their
application. Civil UAS should be maintained and must conform to the same airworthiness standards defined in 14 CFR parts under which UAS are intended to be operated. It
is highly recommended that all proponents provide the following information:
· A Continuing Airworthiness Program,
· A maintenance training program,
· Any unique skill sets or maintenance practices relating to their
aircraft and/or aircraft operations that may be outside the current scope and practices of manned aviation, and
· A process to report any applicable data relating to the operation
and maintenance of the UAS.
d. Database and Recordkeeping. All information received from UAS proponents aids the FAA in establishing a database for the existing
UAS types and operations. This data is critical to our development of future certification criteria for both systems and pilots. It expedites the regulatory process for
UAS and allows the FAA to have historical data from which to base current and future UAS policy. Accurate recordkeeping is essential in assuring positive operational and
quality airworthiness control. In accordance with 49 CFR § 1520.5, reports will not be released outside of government channels without originator permission.
12. Flight Operations of a UAS.
a. Applicability and Requirements. This notice applies to UAS operations conducted in the NAS other than in active Restricted and
Warning Areas designated for aviation use or approved Prohibited Areas. The FAA requires aircraft to operate safely among all users of the NAS, including non-cooperative
aircraft (e.g., aircraft operated without a transponder), and other airborne operations not reliably identifiable by ATC radar (e.g., balloons, gliders,
parachutists). Unless otherwise specifically authorized, UAS operators must use observers, either airborne or ground-based, to comply with part
b. Risk Mitigation. While considerable work is ongoing to develop
a certifiable detect, sense, and avoid system as an AMOC with the see-and-avoid aspect of §§
current solution exists. As a result, compliance with the see-and-avoid requirement and navigational awareness are primary concerns in UAS operational
approvals leading to imposition of AMOC. Risk mitigation for these two issues is normally based on the use of observers or other methods of maintaining flight
separation and collision avoidance or ‘segregation’; however, they may also include other concepts or systems that a proponent may propose for FAA review.
The FAA only approves UAS flight operations that can be conducted at an acceptable level of safety. Refer to the current editions of AC
120-92 and FAA Order
8000.369, Safety Management System Guidance.
Note: Risk mitigations that depend on the establishment of new types and categories of airspace are extremely difficult and
time-consuming. The NAS is established and configured through a rigorous regulatory process. Risk mitigations that result in the prohibition of the public’s right to
transit airspace will require a very long lead time with no guarantee that they will be approved.
(1) Proponents proposing see-and-avoid strategies in lieu of visual observers (VOs) are required to support proposed mitigations with system
safety cases which indicate the operations can be conducted safely. Acceptable system safety cases must include a hazard analysis, risk assessment, and other appropriate
documentation that identifies the level of risk.
(2) It is the proponent’s responsibility to demonstrate that the risk of injury to persons or property along the flightpath is appropriately
mitigated. Aircraft with performance characteristics that impede, delay, or divert other normal air traffic operations may be restricted in their operations.
13. System Considerations for UAS.
a. Traffic Alert and Collision Avoidance Systems (TCAS). The use of TCAS by UAS has not been validated as an acceptable alternative for
see-and-avoid requirements, and is not an approved means of mitigation for UAS see-and-avoid requirements or strategies.
b. Onboard Cameras/Sensors. Although onboard cameras and sensors positioned to observe targets on the ground have demonstrated some
capability, their use in detecting airborne operations for the purpose of segregation is still quite limited. To date, these types of systems have not been approved
as a sole mitigation in the see-and-avoid risk assessment.
c. Use of Equipment in Lieu of VOs.
(1) Any equipment proposed for use on UAS to accomplish the function of see-and-avoid in lieu of VOs must:
· Be certified as an aircraft system and equipment using standards,
requirements, and processes commensurate with installation of equipment in aircraft by a recognized airworthiness authority, and
· Meet the requirements of 14 CFR part
equivalent process, for any UAS installation, regardless of its size, performance, or maximum takeoff weight.
Note: For other equipment that is not proposed for use in meeting see-and-avoid requirements,
§ 23.1309, or equivalent process, should be used.
(2) It is the responsibility of the proponent to show that the contemplated
standards, requirements, and processes meet an equivalent level of safety.
d. Radar and Other Sensors. If special types of radar systems or other sensors are utilized to mitigate risk, the proponent must
provide supporting data which demonstrates the following can be accomplished safely:
· Both cooperative and non-cooperative traffic can be detected and
tracked to ensure appropriate separation and collision avoidance,
· The proposed system can effectively mitigate a potential collision,
· Operators are suitably trained and equipped to use them effectively, and
· Procedures are in place for the pilot in command (PIC) to effectively
use the data.
e. Lost Link Procedures. There are many acceptable approaches to satisfy lost link requirements. The intent of any lost link procedure
is to ensure airborne operations remain predictable. Proponents will comply with the UAS lost link procedures as specified in the COA.
Note: Lost link is not considered fly-away. Refer to definitions in Appendix A.
(1) Unless otherwise authorized, lost link solutions must comply with the last ATC clearance (if ATC clearance is required), for a period of
time sufficient for ATC to ensure conflict resolution without loss of required separation.
(2) Lost link procedures are pre-coordinated by AFS-80 with the appropriate ATC facility and included in the COA. They include, at a minimum,
lost link route of flight, transponder use, lost link orbit points, communications procedures, and pre-planned flight termination points (FTP) or other contingency
planning measures in the event recovery of the UAS is not feasible.
(3) If lost link occurs within a Restricted Area, Warning Area, or Class A airspace, or lost link procedure takes aircraft into one of these
areas, the aircraft will not exit that airspace, unless otherwise authorized, until link is re-established. All exceptions will be submitted as part of the COA
application to AFS-80 for review.
(4) Unless otherwise authorized, lost link procedures will conform to the
Contingency Planning Limitations in Appendix E and in general, include the following:
· Limiting of UAS operations to operations over water or sparsely
populated areas over the ground to transit to another Restricted Area, Warning Area, or to a pre-planned lost link orbit point within visual line-of-sight
to re-establish link. (The UAS lost link procedure will not transit over fixed structures on the water.)
· Lost link programmed procedures will avoid unexpected turn-around
and/or altitude changes and will provide sufficient time to communicate and coordinate with ATC.
· Lost link orbit points will not be contained within any published
holding area, airway, Jet route, T route, or other area navigation (RNAV) published route.
(5) If the link is not re-established within a pre-determined time as defined by the FAA-approved COA, the aircraft may:
· Autoland; however, the aircraft will not exit the Restricted Area
or Warning Area in accordance with subparagraph 12.e.(3) above,
· Proceed to another lost link point (LLP) in an attempt to regain
communication link, or
· Proceed to an FTP or the location specified in other contingency
planning measures for flight termination.
Note: LLPs may be used as FTPs. In this case, the aircraft may loiter at the LLP/FTP
until link is re-established or fuel exhaustion occurs.
· UAS without auto-land capability will proceed to a pre-planned
FTP or other acceptable contingency planning option prior to fuel exhaustion.
(6) Refer to Appendix E for more Contingency Planning Limitations.
f. Flight Termination System (FTS). It is highly desirable that all UAS have system redundancies and independent functionality to
ensure the overall safety and predictability of the system. UAS that lack system redundancies may be required to have an independent FTS that can be activated manually
by the UAS PIC to safeguard the public.
g. Spectrum Authorization.
(1) Every UAS proponent must have the appropriate National Telecommunications and Information Administration (NTIA) or Federal Communications
Commission (FCC) authorization/approval to transmit on the radio frequencies (RF) used for UAS uplink and downlink of control, telemetry, and payload information.
(2) Non-Federal public agencies, such as universities and State/local law enforcement, and all civil UAS proponents generally require a
license from the FCC as authorization to transmit on frequencies other than those in the unlicensed bands (900 megahertz (MHz), 2.4 gigahertz (GHz), and 5.8 GHz). This
generally will be in the form of an Experimental Radio License or a Special Temporary Authority (STA) issued by the FCC. Non-Federal public agencies and civil UAS
proponents that operate systems using frequencies assigned to the Federal government (e.g., the DOD) must demonstrate they have the proper authorization through
(3) DOD agencies will typically demonstrate UAS spectrum authorization through an STA issued by NTIA or a frequency assignment in the
NTIA-administered Government Master File (GMF). Authorizations issued under Title 47 of the Code of Federal Regulations (47 CFR) part 300, in the NTIA Manual, Chapter 7,
paragraph 7.11, Use of Frequencies by Certain Experimental Stations, are not appropriate for UAS operations.
(4) Federal public agencies other than DOD, such as National Aeronautics and Space Administration (NASA), U.S. Coast Guard (USCG), and U.S.
Customs and Border Protection (USCBP), also need an STA issued by NTIA or a frequency assignment in the NTIA-administered GMF. This is especially important for systems
designed to operate on frequencies assigned to DOD.
14. Operational Requirements for UAS. Unless operating in an active Restricted or Warning Area designated for aviation use, or approved
Prohibited Areas, UAS operations must adhere to the following requirements.
a. Observer Requirement. Visual flight rules (VFR) UAS operations may be authorized utilizing either ground‑based or airborne VOs
onboard a dedicated chase aircraft. A VO must be positioned to assist the PIC, to exercise the see-and-avoid responsibilities required by §§
scanning the area around the aircraft for potentially conflicting traffic and assisting the PIC with navigational awareness.
(a) Must assist the PIC in not allowing the aircraft to operate beyond the visual line-of-sight limit, and
(b) Must be able to see the aircraft and the surrounding airspace sufficiently to assist the PIC with:
· Determining the UA’s proximity to all aviation activities and
other hazards (e.g., terrain, weather, structures), and
· Exercising effective control of the UA, and
· Complying with §§
· Preventing the UA from creating a collision hazard, and
(c) Must inform the PIC before losing sufficient visual contact with the UA or previously sighted collision hazard. This distance is
predicated on the observer’s normal vision. Corrective lenses, spectacles, and contact lenses are permitted.
(2) Because of field of view and distortion issues with aids to vision such as binoculars, field glasses, night vision devices, or telephoto
lenses, these are allowed only for augmentation of the observer’s visual capability; they cannot be used as the primary means of visual contact. When using other aids
to vision, VOs must use caution to ensure the aircraft remains within normal visual line-of-sight of the observer. These aids to vision are not to be confused
with corrective lenses or contact lenses, which do not alter the field of view or distort vision.
(3) The responsibility of ensuring the safety of flight and adequate visual range coverage to avoid any potential collisions remains with the
PIC. The PIC for each UAS operation must identify a location from which the observer will perform his/her duties. This location will be selected to afford the best
available view of the entire area within which the operation is to be conducted.
(4) Daisy-chaining of observers to increase operational distance is not normally approved; however, a proponent may provide a safety case for
daisy-chaining in accordance with paragraph 16 by demonstrating an acceptable level of risk to the NAS.
(5) Observer(s) must be in place 30 minutes prior to night operations to ensure dark adaptation. Refer to subparagraph 13.i.(2)(b) for night
b. ATC Communications Requirements.
(1) The UAS pilot must establish and maintain direct two-way radio communication with appropriate ATC facilities anytime:
· The aircraft is being operated in Class A or D airspace (under §
91.135 or §
when required, in Class E and G airspace (under §
91.127 or §
subparagraph 13.q.(2) and (3) for operations in Class B or C airspace; or
· The aircraft is being operated under instrument flight rules (IFR); or
· It is stipulated under the provisions of any issued COA or Special
(2) It is preferred that communications between the UAS pilot and ATC be established through onboard radio equipment to provide a voice relay,
however, for IFR flight this method of transmission is required.
c. Inter Communications Requirements. Any VO, sensor operator, or other person charged with providing see-and-avoid assistance must
have immediate communication with the UAS pilot. If a chase aircraft is being utilized, immediate communication between the chase aircraft and the UAS pilot is required
at all times. If the UAS pilot is in communication with ATC, monitoring of the ATC frequency by all UAS crew members (pilots, observers, and chase pilots) is recommended
for shared situational and navigational awareness. However, unless it is approved for others to do so, the UAS PIC or the supplemental pilots are the only crewmembers
that will communicate with ATC.
d. Electronic Devices. The use of electronic devices (including cell phones) other than for UAS flight- and mission-required usage is
governed by §
ensures these devices do not interfere with the UAS systems. The use of electronic devices (including cell phones) is not authorized for
primary communication with ATC unless authorized under the Special Provisions of the COA.
e. Dropping Objects/Expendable Stores or Hazardous Materials. If the intended UAS operation includes the carriage, dropping, or
spraying of aircraft stores outside of active Restricted or Warning Area airspace designated for aviation use, or approved Prohibited Areas, the proponent must ensure
that specific approval is listed in the special provisions, the operational risks have been sufficiently mitigated as required by §
that the hazardous material requirements in 49 CFR have been met. Acceptable procedures for hung stores and loss of control link while carrying stores must be provided
to the FAA. A similar case must be made for hazardous materials carried aboard the aircraft and, if approved, will be listed in the special provision section of the COA.
f. Flight Over Populated Areas. Routine UAS operations are prohibited over urban or populated areas, except where the level of
airworthiness allows. UAS operations may be approved in emergency or national disaster relief situations if the proposed mitigation strategies are found to be acceptable.
See Appendix A for definition of populated or urban area.
g. Air Shows. A proponent is required to provide a safety case in accordance with paragraph 16 that demonstrates an acceptable
level of risk and must receive a separate Air Show Waiver in accordance with FAA Order 8900.1, Flight Standards Information Management System (FSIMS).
h. Flight Over Heavily Trafficked Roads or Open-Air Assembly of People. UAS operations must avoid these areas,
except where level of airworthiness allows. If flight in these areas is required, the proponent is required to support proposed mitigations with system safety
cases that indicate the operations can be conducted safely. Acceptable system safety cases must include information located in paragraph 16. Additionally,
it is the proponent’s responsibility to demonstrate that risk of injury to persons or property along the flightpath has been mitigated. UAS with performance characteristics
that impede, delay, or divert other air traffic operations may be restricted in their operations. Refer to
AC 120-92 and FAA Order
8000.369, current editions.
i. Day/Night Operations.
(1) Day Operations. UAS operations outside of Class A airspace, active Restricted or Warning Areas designated for aviation use, or approved
Prohibited Areas will be conducted during daylight hours unless otherwise authorized.
(2) Night Operations.
(a) Night operations may be considered if the proponent provides a safety
case and sufficient mitigation to avoid collision hazards at night.
(b) UAS night operations are those operations that occur between the end of evening civil twilight and the beginning of morning civil twilight,
as published in the American Air Almanac, converted to local time. (Note: this is equal to approximately 30 minutes after sunset until 30 minutes before sunrise, except
in Alaska.) External pilots and observers must be in place 30 minutes prior to night operations to ensure dark adaptation.
j. Flights Below Class A Airspace. All UAS operations outside of active Restricted/ Warning/Sensitive Security Information (SSI)
airspace designated for aviation use, or approved Prohibited Areas must be conducted in visual meteorological
conditions (VMC) if using ground or airborne VOs. In addition, the following weather requirements apply:
· If on IFR flight, remain clear of clouds. This requirement does
not relieve the PIC from following the ATC clearance. According to §
PIC retains responsibility for, and is the final authority as to the operation of that aircraft.
· If on VFR flight, maintain §
cloud clearances, except in Class G airspace, where Class E airspace visibility requirements must be applied, but not less than 3 statute miles (SM)
· Special VFR is not permitted.
· For chase aircraft, 5 SM in-flight visibility.
k. Autonomous Operations. Although it is possible to have a completely manual (direct pilot intervention) UAS, the majority of UAS are
autonomous to a certain degree. Only those UAS which have the capability of direct pilot intervention will be allowed in the NAS outside of active Restricted or Warning
Areas designated for aviation use, or approved Prohibited Areas. Because the pilot may be technically considered out-of-the-loop in a lost link scenario, this
restriction does not apply to UAS operating under lost link.
l. Operations from Off Airport Locations. In most cases, an off-airport location should be situated no closer than 5 nautical miles
(NM) from any airport or heliport. The operational areas, including the launch and recovery zones, should be free from obstructions; reasonable efforts should be made to
keep operations away from structures.
m. Crew Resource Management (CRM). Proponents must train all UAS crewmembers in CRM. The current edition of FAA AC
Resource Management Training, or an FAA-recognized equivalent applies to UAS operations. Proponents must implement the recommended training
and procedures included in AC
in an FAA-recognized equivalent. The PIC of a UAS must ensure no activities other than those duties required for safe flight operation are performed. No UAS crewmember
may engage in any activities unrelated to those required for safe operation of the UAS during critical phases of flight such as launch/takeoff and landing/recovery.
n. Sterile Cockpit. Proponents must comply with the current edition of AC
Operating Procedures for Flight Deck Crewmembers, or the FAA-recognized equivalent, for ensuring the PIC implements sterile cockpit procedures. During critical phases of
flight, including all ground operations involving taxi (movement of an airplane under its own power on the surface of an airport), takeoff and landing, and all other
flight operations in which safety or mission accomplishment might be compromised by distractions, no crewmember may perform any duties not required for the safe
operation of the aircraft. No crewmember may engage in, nor may any PIC permit, any activity during a critical phase of flight which could distract any crewmember from
the performance of his/her duties or interfere in any way with the proper conduct of those duties.
o. Operating Under IFR. While operating on an instrument flight
plan, the following must exist, be completed, or be complied with:
(1) The PIC must hold a current instrument rating or an FAA-recognized equivalent.
(2) The aircraft’s airworthiness signature statement for flight release (not airworthiness document) must include IFR flight and indicate that
all equipment required for IFR operations is certified and working (including pilot-static and transponder checks).
(3) Applicable navigation database and charts are current and available to the UAS pilot.
(4) An IFR flight plan is filed.
(5) An ATC clearance has been obtained and all clearances must be followed.
(6) Direct two-way radio communication between the UAS pilot and ATC is established
and maintained. (A communication relay through the aircraft may be required.)
(7) Alternate communication capabilities with ATC for the purpose of lost
link and/or lost communication are designated and operational during all phases of flight.
(8) The UAS is equipped with a certified operating mode C (mode S preferred) transponder.
(9) ATC radar services are obtained throughout the portion of the flight
in Class A airspace whenever possible (overwater non-radar operations may be allowed in the special provisions section).
(10) All operations outside of Class A airspace and active Restricted, Prohibited, Warning Areas, or SSI airspace designated for aviation use,
must remain clear of clouds. If operating under IFR, to comply with this provision, the PIC must have an ATC clearance to deviate. According to §
PIC retains responsibility for, and is the final authority as to, the operation of that aircraft.
(11) VOs are not required in Class A airspace unless stipulated in the COA.
p. Chase Aircraft Operations. The chase aircraft:
(1) Must remain at a safe distance from UA to ensure collision avoidance if a malfunction occurs, and
(2) Must remain close enough to the UA to provide visual detection of any
conflicting aircraft and advise the PIC of the situation.
(3) Must remain within radio control range of the UA, in the case of pilot
operation from the chase aircraft, to maintain appropriate signal coverage for flight control or activation of the FTS.
(4) May be required to have communication with appropriate ATC facilities based on the proponent’s application or mission profile.
(5) Is not required by FAA in active Restricted or Warning Area airspace designated for aviation use, or approved Prohibited airspace.
(6) Is not required for Optionally Piloted Aircraft (OPA) if a qualified VO is on board.
(7) Is not required in Class A airspace unless stipulated in the COA.
(8) Operations must be conducted in accordance with the Special Provisions listed in the approved COA.
(9) Must maintain 5 SM in-flight visibility restrictions.
· Will not concurrently perform either observer or UAS pilot duties
along with chase pilot duties unless otherwise authorized.
· Must maintain direct voice communication with the UAS pilot.
(11) Pilots operating as a formation flight will immediately notify ATC if they are using a non-standard formation. Non-standard formations
must be pre-approved by ATC. Proponents adhere to the current edition of Order JO 7610.4, Special Operations, as applicable. Refer to Appendix A for definitions of
standard and non‑standard formations.
(12) Operations will not be conducted in IMC.
(13) Operations will be thoroughly planned and briefed.
(14) Pilot, during a lost link situation, must be notified immediately along
with ATC. The chase pilot will report to ATC that the UA is performing lost link procedures as planned or if deviations are occurring.
(15) Pilot will ensure safe separation with the UA, and immediately notify ATC and the UA PIC during loss of visual contact with the UA by
both the chase pilot and observer, when such contact cannot be promptly re-established. The UA PIC will either execute lost link procedures to facilitate a rejoin,
recover the UA, or terminate the flight as appropriate.
q. Airspace Considerations by Airspace Designation.
Note: UAS operating in airspace designated as reduced vertical separation minimum (RVSM) airspace must comply with §
(1) Class A. Observers are not normally required in Class A. All UAS must be operating under IFR and on an instrument flight plan. UAS
operations approved for Class A must comply with §
(2) Class B. UAS operations are currently not authorized. Class B airspace contains terminal areas with the highest density of manned aircraft
in the NAS. On a case-by-case basis, the FAA may consider exceptional circumstances. For public aircraft, a Letter of Agreement (LOA) between the affected ATC facility
and the proponent describing UAS segregation procedures is required. For civil aircraft, segregation procedures should be incorporated into the operating limitations.
UAS operations must not impede, delay, or divert other Class B operations.
(3) UAS operations approved for Class C must comply with §§
for operations without this equipment will be handled on a case-by-case basis and may be approved if sufficiently mitigated and a safety case has been established. For
public aircraft, an LOA between the affected ATC facility and the proponent describing UAS segregation procedures may be required. For civil aircraft, segregation
procedures should be incorporated into the operating limitations. UAS operations must not impede, delay, or divert other Class C operations.
(4) Class D. Requests for approval will be handled on a case-by-case basis and may be approved if sufficiently mitigated and a safety case has
been established. UAS operations approved for Class D must comply with
§ 91.129. For
public aircraft, an LOA between the affected ATC facility and the proponent describing UAS segregation procedures may be required. For civil aircraft, segregation
procedures should be incorporated into the operating limitations. UAS operations must not impede, delay, or divert other Class D operations.
(5) Class E. If there is an operating ATC tower, Class D rules may apply. UAS operations approved for Class E must comply with §
public aircraft, an LOA between the affected ATC facility and the proponent describing UAS segregation procedures may be required. For civil aircraft, segregation
procedures should be incorporated into the operating limitations. UAS operations must not impede, delay, or divert other Class E operations.
(6) Class G. UAS operations approved for Class G must comply with §
r. ATC Visual Approach Clearances. The UAS PIC must not accept visual approach clearance, an instruction to follow another aircraft by
visual means, or a clearance to maintain visual separation from another aircraft.
s. In-Flight Emergencies.
· The PIC will notify ATC of any in-flight emergency or aircraft
accident as soon as practical.
· The PIC will notify ATC of any loss of control link as soon as
practical. Loss of control link scenarios may be handled by ATC as an emergency.
15. Contingency Planning Limitations. See Appendix E.
16. Personnel Qualifications. This paragraph addresses the qualifications of all UAS flightcrew members, observers, maintainers, and other
personnel as appropriate. All references to a pilot certificate or FAA written examination refer to an FAA-issued private pilot certificate, higher certification,
or an FAA-recognized equivalent.
a. UAS Pilot Qualifications. The FAA is focused on ensuring that UAS pilots have an appropriate level of understanding of 14 CFR
applicable to the airspace where UAS operate. UAS pilots are responsible for controlling their aircraft to the same standards as the pilot of a manned aircraft. Civil
UAS pilots may be required to have instruction by an FAA-certificated flight instructor.
b. UAS General Operational Requirements. The following operational restrictions apply to all UAS pilots:
· One PIC must be designated at all times.
· The PIC of an aircraft is directly responsible for, and is the
final authority of the operation of that aircraft.
· Pilots must not perform crew duties for more than one UAS at a time.
· Pilots are not allowed to perform concurrent duties both as the
pilot and the VO. In the case of OPA, the airborne pilot may assume the role of PIC at all times, but will only be the observer when the OPA is operated by the CS pilot.
· Unless undergoing initial qualification training, pilots must
be qualified on the aircraft being flown.
· Only one PIC per aircraft is authorized, and the PIC must be in
a position to assume control of the aircraft.
(1) The designated PIC:
· Has been designated as PIC before or during the flight.
· Is responsible for the UAS flight operation as described under §
91.3, or FAA-recognized equivalent.
· Is responsible for determining whether the UAS is in condition
for safe flight.
· Must land as soon as safely practical when any condition occurs
that causes operations to be unsafe.
· May be augmented by supplemental pilots; however, the PIC retains
complete and overall responsibility of the flight, regardless of who may be piloting the aircraft.
· Has the ability to assume the duties of an internal or an external
UAS pilot at any point during the flight.
· May rotate duties as necessary to fulfill operational requirements.
· Operating under a public agency, must have a thorough knowledge
of the COA issued to the organization and must retain a copy to reference during flight.
· Must be trained and qualified on the specific UAS for the conduct
of the flight.
· May assume the duties of VO or PIC, if piloting an OPA when the
OPA is being utilized as a UAS and being flown by the CS pilot.
(2) PIC Rating Requirements. Rating requirements for the UAS PIC depend on the type of operation conducted; they fall into two categories:
· Operations that require at least a private pilot certificate or
FAA-recognized equivalent, or
· Operations that do not require at least a private pilot certificate
or FAA-recognized equivalent.
(a) The requirement for the PIC to hold a pilot certificate or FAA-recognized equivalent is based on various factors including:
· The location of the planned operations,
· The mission profile,
· The size of the aircraft, and
· Whether or not the operation is conducted within or beyond visual
(b) The PIC must hold, at a minimum, an FAA private pilot certificate or FAA-recognized equivalent for all operations listed below:
· Flight in Class A, B, C, D, E, and G (400 feet above ground level
· IFR (must have instrument rating) operations.
· Night operations.
· At joint use or public airfields.
· Requiring a chase aircraft.
· At any time the FAA has determined the need, based on the UAS
characteristics, mission profile, or other operational parameters.
(c) Operations without a pilot certificate may be allowed when all of the following conditions are met:
· The PIC has successfully completed, at a minimum, FAA private
pilot ground instruction and passed the FAA Private Pilot written examination or FAA-recognized equivalents. (Airman Test Reports are valid for the 24 calendar-month
period preceding the month the exam was completed, at which time the instruction and written examination must be repeated.)
· Operations are during daylight hours.
· The operation is conducted in a sparsely populated location.
· Operations are approved and conducted solely within visual line-of-sight
in Class G airspace.
· Visual line-of-sight operations are conducted no further than
½ NM laterally from the UAS pilot and at an altitude of no more than 400 feet AGL at all times. Refer to Appendix A for the visual line-of-sight definition.
· Operations are conducted no closer than 5 NM from any FAA-designated
airport or heliport other than the airport from which the aircraft is operating.
· The operation is conducted from a privately owned airfield, military
installation, or off-airport location.
(3) PIC Recent Flight Experience (Currency). The proponent must provide documentation showing the pilots maintain an appropriate level of
recent pilot experience in the UAS being operated, or in an FAA-certified simulator. At a minimum, the PIC must conduct three takeoffs (launch) and three landings
(recovery) in the specific UAS within the previous 90 days (excluding pilots who do not conduct launch/recovery during normal/emergency operations); or as prescribed by
the proponent’s accepted recurrent training and currency program.
(a) For those operations that require a certificated pilot, the PIC, to exercise
the privileges of his certificate, must have flight reviews and maintain recent pilot experience in manned aircraft per 14 CFR part
appropriate; or FAA-accepted equivalent.
(b) For flights approved for night operations, the PIC must conduct three takeoffs (launch) and three landings (recovery) each, in the
specific UAS at night, to a full stop in the previous 90 days (excluding pilots who do not conduct launch/recovery during normal/emergency operations).
(c) For operations approved for night or IFR, the PIC must maintain recent pilot experience per §
FAA-accepted equivalent as applicable.
(4) PIC Medical. The PIC must maintain, at a minimum, a valid FAA second-class medical certificate issued under 14 CFR part
the FAA-recognized equivalent. The second-class medical certificate expires at the end of the last day of the 12th month after the month
of the date of the examination shown on the medical certificate listed in
FAA-recognized equivalent applies to all UAS crewmembers.
(6) PIC Training.
(a) In addition to the training required for a pilot certificate, UAS PICs
must have the following additional training (or FAA-recognized equivalent):
· Including normal, abnormal, and emergency procedures in all specific
details of the UAS being operated,
· Manufacturer-specific training,
· Demonstrated proficiency, and
· Testing in the UAS being operated.
(b) Proponents must maintain individual training records of all UAS personnel. All training and testing will be documented in the individual’s
training record by the instructor and initialed by the trainee.
d. Supplemental Pilots. Supplemental pilots are those pilots assigned UAS flight duty to augment the PIC. It is common for proponents
to have both an internal and an external UAS pilot. The supplemental pilot can assume either of these positions.
(1) Ratings. Supplemental pilots must have, at a minimum, successfully completed private pilot ground school and passed the written test or
FAA-recognized equivalents. The ground school written test results are valid for two years from the date of completion, at which time the instruction and written
examination must be repeated. If a supplemental pilot assumes the role of PIC, he/she must comply
with the PIC rating, currency, medical, and training requirements listed above in subparagraph 15c.
(2) Recent Pilot Experience. The proponent must provide a process that ensures
that pilots maintain an appropriate level of recent pilot experience for the position they are assigned in the UAS being operated.
(3) Medical. Supplemental pilots must maintain, at a minimum, a valid FAA second-class medical certificate issued under part
the FAA-recognized equivalent. The second-class medical certificate expires at the end of the last day of the 12th month after the month of the
date of the examination shown on the medical certificate, according to §
FAA-recognized equivalent applies to all UAS crewmembers.
(a) UAS supplemental pilots must have:
· Training in all specific details of the UAS being operated, including
normal, abnormal, and emergency procedures;
· Manufacturer-specific training (or FAA-recognized equivalent);
· Demonstrated proficiency and successful testing in the UAS being operated.
(b) Proponents must maintain individual training records for all UAS personnel.
All training must be documented by the instructor and initialed by the trainee.
e. UAS Observer Qualifications. All observers must have an understanding of Federal aviation regulations applicable to the airspace
where the UAS will operate. Observers are considered crewmembers. Observers must not perform crew duties for more than one UAS at a time. Observers are not allowed to
perform concurrent duties both as UAS pilot and observer.
(1) Medical. All observers must have a valid FAA second-class medical certificate issued under part
FAA-recognized equivalent is an acceptable means of demonstrating compliance with this requirement. The second-class medical certificate expires
at the end of the last day of the 12th month after the month of the date of the examination shown on the medical certificate. Section
FAA-recognized equivalent applies to all UAS crewmembers.
(2) Training. Observers must complete sufficient training to communicate to the pilot any information required to remain clear of conflicting
traffic, terrain, and obstructions, maintain proper cloud clearances, and provide navigational awareness. This training, at a minimum, must include knowledge of:
(a) Their responsibility to assist pilots in complying with the requirements of 14 CFR:
91.111, Operating Near Other Aircraft;
91.113, Right-of-Way Rules: Except Water Operations;
91.115, Right-of-Way Rules: Water Operations; and
91.155, Basic VFR Weather Minimums;
(b) Air traffic and radio communications, including the use of approved ATC/pilot phraseology; and
(c) Appropriate sections of the Aeronautical Information Manual (AIM).
f. UAS Maintenance Personnel Qualifications.
(1) Maintenance Ratings. Will be established as more data is collected and a regulatory guideline is developed.
(2) Recent Maintenance Experience. It is suggested that proponents follow applicable guidelines of 14 CFR part
appropriate, until final UAS regulatory guidelines are available.
(3) Maintenance Medical Requirements. At a minimum, the requirements of §
FAA-recognized equivalent must be met. No additional medical requirements have been defined at this time.
(4) Maintenance Training. It is highly recommended that a proponent of a UAS submit a training program. This requirement will be further
defined as more data is collected and the regulatory process affects these guidelines.
g. Other UAS Personnel Qualifications. Ancillary personnel such as systems operators or mission specialists must be thoroughly familiar
with and possess operational experience of the equipment being utilized. If the systems being utilized are for observation and detection of other aircraft for collision
avoidance purposes, personnel must be thoroughly trained on collision avoidance procedures and techniques and have direct communication with the UAS pilot, observer,
and other applicable personnel.
17. AMOC. This notice defines certain limitations and procedures to conduct UAS operations, but each application is evaluated on its
own technical merit based on its own set of operational parameters and proposed operational profiles, mitigations, and systems. When a proponent desires to deviate from
these limitations and procedures, an AMOC that includes a safety case (recommended format provided in Appendix D), must be submitted for approval. For a proponent
to make an acceptable safety case, information must be provided that outlines all hazards and risks associated with the requested AMOC. In addition, the proponent
must provide a description of the methods and procedures or equipment for mitigating each hazard and risk. As such, deviations and AMOC may differ from the information
presented in this notice. Therefore, if the proponent provides an acceptable safety case with sufficient data that supports the proposal, the AMOC will be
considered and evaluated for approval.
a. Safety Case Information. The proponent should include at a minimum:
(1) A thorough description of the environment in which the aircraft will operate;
(2) Criteria for categorizing hazards (e.g., severity and likelihood);
(3) A detailed airworthiness description of the affected items associated with the proposed AMOC, which includes, as a minimum:
· Certification status of components and systems, or statement of
airworthiness for public aircraft,
· Reliability data,
· Redundant systems,
· Failure modes and effects, including system response to loss of
control link, and
· An airworthiness determination (for COA proponents only);
(4) Capabilities of the aircraft;
(5) Flight data;
(6) Accident data;
(7) Emergency procedures; and
(8) Pilot/crew roles and responsibilities.
b. Sample Safety Case. Appendix D represents the FAA’s approach to documenting the process used for hazard identification and risk
mitigation. It is provided as an example for proponents to use when developing and documenting a safety case. In addition to these guidelines, other government and
industry methods similar to the FAA’s approach to developing a safety case also provide acceptable hazard analysis tools. These include Preliminary Hazard Analysis,
Operational Safety Assessment, Comparative Safety Assessment, and Fault Hazard Analysis. See Appendix D for a complete list.
18. Disposition. We will incorporate the information in this notice into FAA Order 8900.1 before this notice expires. Direct questions
concerning the information in this notice to the Unmanned Aircraft Systems Integration Office (AFS‑80) at 202-385-4835.
ORIGINAL SIGNED by
/s/ Michael Zenkovich, for
John M. Allen
Director, Flight Standards Service
APPENDIX C. RELATED REGULATIONS AND PUBLICATIONS
1. Title 14 of the Code of Federal Regulations (CFR).
Procedures for Products and Parts.
of Type Certificate: Restricted Category Aircraft
of Airworthiness Certificates for Restricted Category Aircraft.
21.191, Experimental Certificates.
21.193, Experimental Certificates: General.
Certificates: Aircraft to be Used for Market Surveys, Sales Demonstrations, and Customer Crew Training.
21.197, Special Flight Permits.
21.199, Issue of Special Flight Permits.
23.1309, Equipment, Systems, and Installations.
25.1309, Equipment, Systems, and Installations.
Pilots, Flight Instructors, and Ground Instructors.
61.23, Medical Certificates: Requirement and Duration.
61.56, Flight Review.
61.57, Recent Flight Experience: Pilot in Command.
Proficiency Check: Operation of an Aircraft That Requires More Than One Pilot Flight Crewmember or is Turbojet-Powered.
65.83, Recent Experience Requirements.
Standards and Certification.
Operating and Flight Rules.
91.3, Responsibility and Authority of the Pilot in Command.
91.13, Careless or Reckless Operation.
91.15, Dropping Objects.
91.17, Alcohol or Drugs.
91.21, Portable Electronic Devices.
91.111, Operating Near Other Aircraft.
91.113, Right-of-Way Rules: Except Water Operations.
91.115, Right-of-Way Rules: Water Operations.
91.126, Operating on or in the Vicinity of an Airport in Class G Airspace.
91.127, Operating on or in the Vicinity of an Airport in Class E Airspace.
91.129, Operations in Class D Airspace.
91.130, Operations in Class C Airspace.
91.135, Operations in Class A Airspace.
91.155, Basic VFR Weather Minimums.
91.157, Special VFR Weather Minimums.
within Airspace Designated as Reduced Vertical Separation Minimum Airspace.
91.203, Civil Aircraft: Certifications Required.
Transponder and Altitude Reporting Equipment and Use.
having Experimental Certificates: Operating Limitations.
2. Title 49 of the Code of Federal Regulations (CFR).
a. Chapter I, Subchapter C, Hazardous Materials Regulations.
b. Chapter VIII, Part 830, Notification and Reporting of Aircraft
Accidents or Incidents and Overdue Aircraft, and Preservation of Aircraft Wreckage, Mail, Cargo, and Records.
c. Chapter XII, Part 1520, § 1520.5, Sensitive Security Information.
3. Related Publications (current editions).
4. Advisory Circulars (AC).
00-1.1, Government Aircraft Operations.
91-57, Model Aircraft Operating Standards.
120-51, Crew Resource Management Training.
Operating Procedures for Flight Deck Crewmembers.
to Safety Management Systems for Air Operators.
5. FAA Notices. N JO
Aircraft Operations in the National Airspace System (NAS).
6. FAA Orders.
1000.37, Air Traffic Organization Safety Management System.
7110.65, Air Traffic Control.
7210.3, Facility Operation and Administration.
7400.8, Special Use Airspace.
· JO 7610.4, Special Operations.
· 8000.369, Safety Management System Guidance.
· 8020.11C, Aircraft
Accident and Incident Notification, Investigation, and Reporting.
· 8130.34, Airworthiness
Certification of Unmanned Aircraft Systems and Optionally Piloted Aircraft.
· 8900.1, Flight Standards Information Management System.
7. Other Documents.
· Title 47 CFR Part 300, National Telecommunications and Information
Administration (NTIA) Manual, Chapter 7.11, Use of Frequencies by Certain Experimental Stations.
· Title 49 United States Code (49 U.S.C.) §§ 40102(a)(41), Definitions.
· FAA Air Traffic Organization (ATO) Safety Management System Manual.
· Memorandum of Agreement Concerning the Operation of Department
of Defense Unmanned Aircraft Systems in the National Airspace System (DOD-FAA MoA, September 24, 2007).
· Convention on International Civil Aviation (“Chicago Convention”).
7 December 1944, 61 Stat. 1180, 15 U.N.T.S. 295.