Part 107 Q&As: Drone Requirements

Editor at Skyward

Part 107, the federal regulations governing commercial drone operations, took effect in the U.S. in August. Since then, we’ve received a steady stream of emails and webinar questions from people asking how Part 107 affects their specific situations. So our regulatory experts created a 60-page ebook to help business owners and managers navigate Part 1o7. It’s free, and you can download it here.

This article is about aircraft requirements, which is one of the most straightforward aspects of Part 107.

The most important requirement: UAVs must weigh less than 55 lbs (25 kg), including payload. This requirement is not waiverable under Part 107. If you must fly a heavier aircraft, you will need to apply for an exemption from the FAA or continue using your 333 Exemption if you have one.

Part 107 does allow for flights during civil twilight if your aircraft has appropriate anti-collision lights. Be aware that many of the most popular models of drones, such as the DJI Phantom, do not come equipped with standard anti-collision lights.

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This Phantom has been registered with the FAA and marked with its registration number.

Every UAV weighing between .55 lbs (250 grams) and 55 lbs (25 kg) must be registered with the FAA, regardless of whether it’s used recreationally or commercially. The online registration process is quick, straightforward, and only costs $5. Be sure to mark your aircraft with your registration number.

N-Numbers

We get this question all the time: Most commercial UAVs do not need N-numbers, which require a paper application. The only instances in which your aircraft will need an N-number are as follows:

  • Your UAV is 55 lbs or heavier
  • You want to qualify a UAV for operation outside the United States
  • You hold title to an aircraft in trust
  • The UAV owner uses a voting trust to meet U.S. citizenship requirements

Questions about the FAA’s UAV Requirements

These are all real questions from entrepreneurs, business managers, and drone pilots on aircraft requirements under Part 107.

Q: Are commercial drones still required to be registered?
Yes, any drone heavier than .55 lbs must be registered with the FAA.

Q: If my aircraft already has labeling required under the hobbyist registration (uses same number for all aircraft), will a separate N-number be required under Part 107?
It is unlikely that you will need an N-number. Select “Commercial Registration” when you go to the FAA website. The process is very straightforward. Aircraft used for commercial operations must each have their own registration number.

Q: If I add a new UAV to my commercial fleet, will I need an N-number to operate in controlled airspace?
An N-number is not required. Register as a commercial operator on the FAA’s UAV registration site.

Q: Can more than one operator use a single UAV? In other words can one operator use a UAV for Job #1 and then pass it off to a different operator for Job #2?
Yes, multiple pilots can use a single UAV. Just make sure everyone is qualified to fly and the UAV has been registered with the FAA. No need to register a UAV multiple times.

Q: Does a COA cover a single aircraft? If I have a fleet do I need a separate COA for each aircraft in the fleet?
If you operate under Part 107, you will no longer need a Blanket COA. In that case, you can use any UAV 55 lbs or lighter that you have registered with the FAA. If you continue to operate under a 333 Exemption, you can use any UAV on the FAA’s list of approved aircraft. Under Part 107, you will need a waiver to operate within certain airspace (Class B, C, D, E surface area). The waier application requires the registration number of the aircraft that will be used. The FAA has stated that a Certificate of Waiver process will be established for Part 107.

Q: Is Part 107 only for UAVs under 55 lbs or does it cover heavier UAVs as well?
Part 107 specifically applies to aircraft under 55 lbs. That is one of the provisions that is not waiverable.

Q: Which UAV was recently approved for night ops?
Industrial Skyworks received the first night exemption granted by the FAA. The exemption is for use with the Aeryon Labs Skyranger, but it should be noted that the conditions imposed are not aircraft-specific. There are specific visibility requirements, but they aren’t unique to that specific aircraft.

Q: Do lights on common drones, such as the Phantom and Solo, comply with the civil twilight lighting requirements?
No, the lights found on certain consumer-focused drones, including the Phantom or Solo, do not meet the requirements.

Q: My business uses custom-built UAVs, so we don’t have owner’s manuals or documented maintenance procedures. Should we create these?
The FAA has not specified a requirement for owner’s or maintenance manuals. That said, Part 107 gives the FAA the authority to inspect your procedures and records at any time. If an FAA inspection determines that you are not in compliance with Part 107 or that your operations are unsafe, this may have negative consequences for your business. Evidence of safe operating procedures will protect you. Even more importantly, owner’s manuals and standardized operating and maintenance procedures will ensure that your commercial drones jobs are completed professionally and safely. The aviation industry is unforgiving of lax flight discipline.

If your business needs maintenance procedures, operational checklists, and standard operating procedures, be sure to download a preview of Skyward’s Take Flight package, 130+ pages of operational and aviation expertise to ensure safe, efficient, consistently high quality drone operations.

Download a preview of Skyward's standard operating procedures and checklists for drones