Navigating the US Framework for Unmanned Aircraft Systems' Path to Compliance

Until this year came at us like a wave of turmoil and change, I was unaware of the full scope of “UAS”. I was familiar with drones, as they are more commonly known, their entertaining features with recreational piloting and next-level photography. As late as in March, we gave away a Mavic Mini as part of a draft at the last trade show Web Manuals visited in Charlotte, NC. Little did I know that drones would come to be my most significant focus as the airspace became increasingly vacant because of the global pandemic. 

As we expanded into the unmanned space to support some of the pioneers of drone deliveries streamlining their compliance, I started to reach out to other commercial drone operators to see if we could offer the same value to their operations. 

Almost without exceptions, I was met with the somewhat baffling response, “we have no need for documentation yet.”

Now, after months of deep-diving into the fascinating industry of drones, I feel confident enough to share a summary of my navigation through the complex framework of Unmanned Aircraft Systems’ path to compliance in the United States and its need for documentation.

I hope to guide those drone operators in my network who are uncertain how to take their business to the next scalable level without compromising the safety of our national airspace (and your relationship with the FAA!).

PART 107

The first step to operating a drone either recreationally or commercially in the US is to become compliant under the Federal Aviation Association’s Part 107 by completing the following:

1. Understand the rules under Part 107.
2. Pass the FAA Part 107 Certification Test.
3. Register your drone at FAADroneZone.
4. Download the B4UFLY Mobile App.

Under Part 107, you can operate one drone weighing less than 55lbs within the visual line of sight of the remote pilot in command as long as the altitude is no higher than 400 feet, during daylight hours and not above people. 

However, do not let these limitations stop entrepreneurial imagination. If your business model requires such operations, you can request waivers from the FAA. These include:

§ 107.25 - Operation from a Moving Vehicle or Aircraft

§ 107.29 - Daylight Operations

§ 107.31 - Visual Line of Sight Aircraft Operation

§ 107.33 - Visual Observer

§ 107.35 - Operations of Multiple Small UAS

§ 107.37 (a) - Yielding Right of Way

§ 107.39 - Operation Over People

§ 107.51 - Operating Limitations for Small Unmanned Aircraft

These waivers require more robust documentation and compliance expertise to obtain. For example, § 107.31 Beyond Visual Line of Sight waiver requires a General Operating Manual (GOM) outlining:

• Flight Operations
• Standard Operating Procedures
• Emergency Management Manual
• Safety Management Manual
• Maintenance Manual
• Training Manual

While these manuals are familiar to manned aviators, it can be challenging to understand the scope of documentation control and monitoring needed for someone in the unmanned space without proper support. 

PART 135

The next step, if you wish to develop an enterprise solution around UAS operations, is to become a certified Standard Part 135 holder with the Federal Aviation Administration (FAA). Currently, this regulatory path is exclusively used for package delivery. Yet, as the applications of drone usage diversify, I see Part 135 as an excellent path to compliance for companies interested in fast-scaling operations in many segments of advanced drone operations once challenges such as urban traffic management (UTM), radio-frequency identification (RFID) and other security measures are in place. 

As of now, there are currently two drone operators holding a Part 135 certification in the US, with many more to come. According to the FAA's website:

"Six additional part 135 air carrier certificate applications have been submitted by IPP operators and one 135 application was submitted by an FAA Partnership for Safety Plan (PSP) participant."

Under this certification, you have to exercise great control of your documentation. With 320 operators using the Web Manuals platform worldwide, we see how an agile document management system with aviation-specific authoring capabilities (such as automated LEPs, TOCs, Revision Bars and MEL formatting), up-to-date compliance monitoring and controlled distribution is imperative in order to stay profitable with scalable operations in a changing regulatory climate.

PART 91

Last but not least, Part 91 is an alternate path to compliance for public safety agencies interested in implementing extensive drone programs beyond Part 107 capabilities to their emergency management plan for safer and quicker missions. 

If you are interested in pursuing such operations, I would highly recommend reading “Drones, A report on the Use of Drones by Public Safety Agencies - and a Wake-Up Call about the Threat of Malicious Drone Attacks” published by Police Executive Research Forum earlier this year. They recommend public agencies to fly under Part 107, operate with a Certificate of Waiver or Authorization (COA), and Part 91 depending on the complexity of the operations.

It goes without saying that UAS operations in mission work need to be heavily documented with the highest priority possible to safety procedures and operational risk. The controlled documentation requires easy access and reportable distribution to ensure that all procedures are followed every step of the way.

Documentation for all!

Ultimately, the Unmanned Aerial Systems' path to compliance is moving more and more towards the same level of documentation as manned air carrier certifications.

Some explain this decision as an abrupt solution to previous ignorance of the growing industry. Others blame it on limited tech-expertise as a result of an overdue generational shift within the agency. 

I believe it is as simple as bringing the two worlds of manned and unmanned aviation together. There are endless teachings for the unmanned to gain from manned aviation with decades of experience in manual writing, compliance monitoring, and streamlined documentation.

It is not until we learn to work as one that we can improve the regulatory framework and the safety of our national airspace altogether. 

Web Manuals supports over 300 manned aviation companies and a growing number of safety-first drone operators. We provide a system for manual authoring, compliance monitoring, and pilot performance tracking. We are seeing an uptake in interest from the unmanned sector due to increased regulatory compliance and focus on risk management.

Visit our website www.webmanuals.aero to read more and book a demo!