Do I Need a Part 107 Certificate If My Public Agency Has a COA?

It is said that if you work for a federal, state or local government office and want to operate a UAV in your daily operations, you may not need a Part 107 certificate. Government drone pilots can be eligible to apply for a public Certificate of Waiver or Authorization, known as a COA. If your public agency does obtain a COA from the Federal Aviation Administration (FAA), do you still need a Part 107 certificate to fly your drone legally?

Part 107 vs COA

Part 107 – A set of Federal Aviation Regulations, or FARs. These are the FAA’s first official rules governing the commercial use of small Unmanned Aircraft Systems (sUAS). In addition to outlining the operational limitations of sUAS, Part 107 also provided requirements for the issuance of a Remote Pilot Certificate with an sUAS rating for commercial drone pilots. Part 107 is also intended to be the first step towards full integration for the use of commercial drones into the National Airspace System (NAS). The full set of regulations has been published in the Federal Aviation Regulations Aeronautical Information Manual (FAR AIM). A Part 107 Operator’s Certificate, or “drone license” allows a person to get paid for flying a drone. The purpose of the drone license is to ensure that a commercial drone pilot is familiar with and safely abides by the established drone rules of the sky.

COA – The Certificate of Waiver or Authorization (COA) for Public Aircraft Operations gives a good amount of flexibility to the organization who holds the COA. This certificate is a good option for qualifying governmental and nonprofit organizations, including the below:

• Local Municipalities
• Fire Departments
• Police Departments
• Public Schools

Although a COA can provide an organization with flexibility, the interested organization has to first request a COA from the FAA and then submit a series of information. So, while a COA does provide flexibility, it’s a longer and more difficult process than Part 107.

Do I Need a Part 107 Certificate With a COA?

The quick answer is that it’s not currently a requirement that sUAS pilots flying a drone for a public agency with a COA have to also possess a Part 107 Remote Pilot Certificate. However, it is absolutely becoming more common. Here are the 2 reasons why:

1. Every COA request requires that the requesting agency describe their planned UAS training protocols. This can be a very complex procedure to both develop and implement internally and it has been the reason that the FAA has denied many COA requests in the past if the information provided was insufficient. Because the release of Part 107 provided an FAA created and sanctioned method for “certifying” that an individual possessed the knowledge necessary to operate a sUAS for commercial or official purposes, it is now being used as a “boiler plate” method to fulfill that requirement on COA requests, provided the planned flight operations will utilize aircraft that the FAA designates as “small” unmanned aircraft systems.
2. The FAA has informally indicated that they do not intend to renew sUAS Exemptions and COAs indefinitely, and that ultimately Part 107 and other Federal Aviation Regulations will become the permanent rules for all types of official drone operations. As a result, they tend to look favorably on COA requests that indicate a knowledge of Part 107 regulations and intends to utilize sUAS pilots that possess the aeronautical knowledge necessary to safely operate their drones within the National Airspace System (NAS).

The Bottom Line

It is unclear if the FAA will one day require a Part 107 certification for public agencies that possess a COA. However, having Part 107 training and certification when applying for a COA will definitely help show the FAA that your agency is knowledgeable on sUAS rules and regulations. If you or your agency is interested in obtaining a Part 107 certificate, online drone classes, or flight training, visit secure.dartdrones.com or call us at 800-264-3907!