This article covers the FAA drone regulations and compliance documentation needed for recreational, commercial, and governmental drone operations. The three paths to compliance under FAA drone regulations include Part 107, Part 91, and Part 135.
At the time being, the latter two certifications are similar to those of manned aviation. Therefore, Web Manuals support documentation processes for both manned and unmanned aviation. We are a strong advocate of the collaboration and integration between the two.
With an ever-evolving and ever-growing drone industry, compliance is inevitably subject to change. Regardless of the level of complexity, controlled documentation and compliance monitoring are imperative to successful and scalable drone operations in such changing regulatory climates. Web Manuals are here to help!
Author’s Note
As Web Manuals expanded into the unmanned space to support some of the pioneers of drone deliveries streamlining their Part 135 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 FAA drone regulations and reply – “you do have a need for documentation and here is why”!
DRONE REGULATION – 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:
- Understand the rules under Part 107.
- Pass the FAA Part 107 Certification Test.
- Register your drone at FAADroneZone.
- 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 compliance monitoring needed for someone in the unmanned space without proper support.
Web Manuals are actively working with our partner community to offer template manuals and managed manual services through our Web Manuals Store. In Europe, we have partnered with AirHub to support EASA drone regulations with LUC Manuals and SORA Risk Assessments.
DRONE REGULATION – 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, Part 135 could be 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 United States, with many more to come. According to 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 340 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.
Read Matternet’s case study here.
DRONE REGULATION – PART 91
Last but not least, Part 91 is an alternate yet fairly unsought path to compliance with FAA drone regulations for public safety. It is for those 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, read “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 from 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 with FAA drone regulations is moving more and more towards the same level of regulation and documentation as manned air carrier certifications.
There is a clear intent of bringing the two worlds of manned and unmanned aviation together. Compliance and documentation might be new for the growing unmanned industry. Favorably, there are endless teachings to gain from manned aviation with decades of experience in manual writing, compliance monitoring, and streamlined documentation.
Hence, Web Manuals is the tool to use. We are the world standard in digitizing manuals with a growing aviation community and integrated third party services. We are here to help.
Web Manuals supports over 300 manned aviation companies and a growing number of safety-first drone operators worldwide. 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 safety management.
