How to get FAA approval for your BVLOS (107.31) waiver application
These tips could get you the BVLOS ‘Holy Grail’ waiver you need for commercial drone operations in US
In the United States, commercial drone pilots do not need a waiver to fly a drone for work or business – if they have been certified by the Federal Aviation Administration (FAA) and are following Part 107 rules.
However, to fly a drone beyond the pilot's ability to clearly determine its orientation with unaided vision, aka Beyond Visual Line of Sight (BVLOS), Part 107.31 waiver is required.
In the drone industry, the BVLOS waiver is popularly known as the ‘Holy Grail’ – because of how eagerly it is pursued by commercial drone operators and how hard it is to get one. So, how do you ensure that your waiver application does not come back with a glaring ‘Not Approved’ stamp? Here are the top four tips you could follow:
Detail C2 Link and Emitters Performance Capabilities
According to the FAA, the waiver application must state and demonstrate the maximum range and envelope that the Command-and-Control (C2) can operate in. Keep the geographic area, environment, as well as the terrain in mind while doing so.
You must provide a thorough description of each emitter, including the Federal Communications Commission (FCC) grant of authorization and FCC ID number for each transmitter/emitter on the drone and ground control station.
In case the C2 operational capabilities are not evident in your application by way of data, you can wave your BVLOS waiver goodbye.
Describe Detect-and-Avoid (DAA) Methods
A common factor that has been observed among successful BVLOS waiver applications is that they provide detailed descriptions for the risk mitigation procedures adopted to avoid collisions with other aircraft (such as the role of visual observers and technology).
Your application is likely to get rejected if the methods to ‘see and avoid’ or ‘detect and avoid’ both participating and non-participating aircraft and persons are not described adequately. For example, the use of a video feed alone is not considered satisfactory because detection would be limited to the direction the camera is pointing in; it would have 360-degree coverage. Similarly, Automatic Dependent Surveillance-Broadcast (ADS-B) alone may not be enough because it provides data only for cooperative traffic and does not address the issue of avoidance.
Identify Weather Tracking and Operational Limitations
To get the coveted BVLOS waiver from the FAA, your application must provide details of when weather reports will be gathered, what will be gathered, and where they will be taken from. You also need to address the limitations related to weather, such as the drone manufacturer’s limitations or wind speed.
Vague statements like ‘We only fly on clear days’ or ‘Weather is to be of Visual Flight Rules in nature’ will not fly with the FAA.
Validate Training Requirements for Pilots
Not only should your application give the details of the employee training and testing programs, but it must also provide a means for validating their effectiveness. In other words, you must state who all had the training, what the training consisted of, and what method was followed to ensure all required persons have been successfully trained. As such, you should list out the courses/subjects covered and store the tests corrected to 100 percent for easy retrieval later.
If it is not evident to the FAA that all participating personnel have adequate knowledge in all aspects of BVLOS, your application is likely to get rejected.
For more clarity, we recommend that you go through this sample approved BVLOS waiver application.
Ishveena Singh is a versatile journalist and writer with a passion for drones and location technologies. In the last 12 years, she has worked with both mainstream media organizations (Miami Herald International, Times of India, Microsoft MSN) and dedicated geospatial technology media (Geospatial World, Geoawesomeness).
With a deep understanding of content marketing and social media, Ishveena also helps private companies (DJI, Terra Drone) to generate qualified leads through useful and timely content.
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