Certificate of Waiver, Airworthiness Certificates, and Certificate of Authorization (COA)

As you may have noticed from the materials you reviewed in the previous section, no one is allowed to fly a UAS without prior approval from the FAA. Any UAS operation in the United States has to occur in one of two ways. Either the UAS belongs to a public agency (i.e., governmental) and then requires a COA or operates under Part 107 rules, or it belongs to to a civilian entity and therefore requires adherence to Part 107 rules and perhaps a special airworthiness certificate or a waiver. For manned aircraft, the FAA requires several basic steps to obtain an airworthiness certificate in either the Standard or Special class. The FAA may issue an applicant an airworthiness certificate when:

the registered owner or operator/agent registers the aircraft,
the applicant submits an application through the dedicated portal, and
the FAA determines the aircraft is eligible and in a condition for safe operation.

The process for a UAS is different for the time being, as it is approached through either a COA or a special airworthiness certificate, as was discussed above. For UAS, the FAA may consider an airwortiness letter like the following:

"To Whom It May Concern:

The eBee small Unmanned Aircraft System has been inspected and reviewed on behalf of XY organization by qualified individuals and a determination has been made based on testing data and evaluation data provided by the manufacturer that the aircraft is serviceable and airworthy for the intended use as advertised by the manufacturer, subject to the warrantees and representations offered by said manufacturer.

Sincerely,

John Doe, System Engineer, XY organization"

Just to reiterate, the process of requesting a UAS operation within the territorial airspace of the United States (the airspace above the contiguous United States, Alaska, Hawaii, U.S. territories, and U.S. territorial waters) differentiates depending whether the applicant is a public agency or a civilian entity. The methods of operational approval are the issuance of either a COA for public aircraft operations or for civilian operators is either to operate under PART 107 for UAS that weighs less than 55 lbs or operators need to apply for an exemption under the Special Authority for Certain Unmanned Systems (49 U.S.C. §44807) [1]. Special Airworthiness Certificate [2] is needed for civil operations under certain conditions. The FAA on its website allowed civil users to apply for a COA, it is not needed anymore, through a dedicated portal. This Form shows the web application interface [3]. The form is provided to show the actual interface for the COA application and the required materials and all applicants have to provide the required submissions through the portal. To apply for a COA, go to the FAA UAS Civil COA Portal [4]. You will need to create an account on the FAA website before you proceed with your application. Anyhow, if you are planning to apply for a COA, be prepared to provide the following materials and information through the portal and/or when the FAA ask you later if needed:

Sample Certificate of Authorization Application

This link provides a sample of COA application provided by the FAA on their website Sample COA application form from the FAA website [5].

Certificate of Authorization Application Components

Make sure that your COA application provide the FAA with the following components:

- Applicant Contact Information:

333 Exemption number if any
name, address, phone, and email

- Purpose of the operation and the requested exemption, if any

- Aircraft System

description
- picture
- airframe
  - dimensions
- power source
  - electric, internal combustion, etc.
- weight (gross takeoff weight)
- avionics
- performance
  - endurance
  - range
  - speed
  - operating altitude
  - turing radius
  - climb/decent rates
Airworthiness statement and documentation
Communications
pilot/operator to aircraft
pilot/operator to observers
communication within the airspace
- air traffic control procedures and frequencies
- local airspace frequencies
video/data
- FCC approved frequencies
- ranges
operational communications range
backup communication
- radios
- cell phones/landlines

- Ground Control Station

description
- picture
- capabilities
- setup and operations
frequency management
FCC approved equipment
range

- ConOps, Emergency Procedures, and Risk Mitigation

identify, control, and document potential hazards (examples)
- human factors
- machine
- media
- management
- mission
assess the risks (examples)
- weather induced flight cancelation or termination
- lost communication
- loss of payload
- aircraft fire
analyze risk control measures (examples)
- mishap notification
- access and contact procedures to fire and rescue
- programmed procedure for lost links
make control decisions
implementation of risk controls
review and improvement process

- Flight Operations Area and Time

COA Location
- boundary points (or center point if circular) recorded in coordinates
Time of Day
Launch and Recovery Points
- launch and recovery points recorded in coordinates
Lost Link/Rally Points
- lost link/rally points recorded in coordinates
Description of airspace class(es) (A, C, D, E, or G) for proposed operations and surrounding area

Map and/or aeronautical chart depicting the flight operations in relation to ground references and airspace
- VFR Chart
- Aerial image (i.e. Google Earth/Maps)
  - Show COA area with boundaries clearly marked.
  - Show planned launch, recovery, and rally points.
FAA coordination and concept of operations plan (Flight Standards District Office, Air Traffic Control Tower, etc.)
Planned nominal flight operations in proposed airspace
Altitude (minimum and maximum)
Security for crew

- Launch and Recovery Procedures

Primary/planned launch and recovery location(s)
Launch and recovery checklists and procedures
Takeoff and Landing or Fixed Wing launch and recovery methods
- Launch (examples)
  - Hand-held
  - Rail
  - Catapult
  - Support vehicles/equipment
  - Weather limits
- Recovery (examples)
  - Net
  - Grass
  - Weather limits
  - Landing speed

- Lost Communications Procedure

Return to Base (RTB) procedures
Lost communication between pilot and Air Traffic Controllers
Lost communication between pilot and observers

- Operator (Pilot) and Visual Observers

Crew qualifications
- Pilot certifications
- Aircraft currency
- Required currency of medicals
- Platform training and currency
Crew resource management (CRM) approach
Communications and coordination for operations
Provision for UAS operations (single platform at a time)

Part 107 Certificate of Waiver

Public agencies or private individual or business who wants to be exempted to fly UAS under certain conditions can apply for Certificate of Authorization (COA) [6]. The introduction of Part 107 removed many hurdles from the face of operating civilian UAS under many conditions. However, for conditions that are not listed or described directly under Part 107 regulations, a civilian operator can apply for a waiver. The FAA states "A waiver is an official document issued by the FAA which approves certain operations of aircraft outside the limitations of a regulation. You may request to fly specific drone operations not allowed under part 107 by requesting an operational waiver. These waivers allow drone pilots to deviate from certain rules under part 107 by demonstrating they can still fly safely using alternative methods." . The following table illustrate the conditions under which one needs to apply for a waiver to operate under Part 107.

List of operations that require a waiver under Part 107 (source FAA [7])

How To Apply For a Waiver?

One can apply for a waiver through the FAA website [7]. The FAA details the guidelines for the waiver application and the required information. Pay close attention to the "Waiver Safety Explanation Guidelines for Part 107 Waiver Applications" that you may encounter in the DroneZone operational waiver application. For the waiver application, the FAA required extensive details on:

Describing the proposed operation
Describing possible operational risks and methods to mitigate those risks

The following items are required for the "Waiver Safety" part of the application as adopted from the FAA website [8]:

Describe Your Proposed Operation(s)

Operational Details

Where do you plan to operate?
1. Consider providing latitude/longitude and a detailed map of your planned flight area.
How high will you fly your aircraft (maximum altitude above ground level)?
Do you want to fly in controlled airspace (Class B, C, D, surface E)?
1. If yes, please see 14 CFR §107.41 [9] and our Flying Drones Near Airports (Controlled Airspace) – Part 107 page [7]
Are there any other kinds of airspace within 5 miles of any planned flight area?
What kind of area(s) will you fly over?
1. For example: rural, sparsely populated, congested, populated, a neighborhood, within city limits, large outdoor gathering of people, a restricted access site, etc.

Small UAS Details

What kind of UAS will you use to fly the operations requested in this application?
1. For example: multi-rotor, fixed wing, hybrid (both multi-rotor and fixed wing), single rotor, lighter than air, etc.
What is your UAS's power or energy source in flight?
What is your UAS's maximum flight time (in minutes), range (in feet), and speed (in miles per hour)?
How big is the aircraft (length/width/height in inches)?
How do you ensure the aircraft only flies where it is directed (i.e. ensure containment)?
1. For example: geo-fencing, tether, etc.
What kind of termination system, if any, does the UAS have?
1. For example immediate flight termination switch
How much will the aircraft and its payload weigh when flying?
If the aircraft carries any external or internal load (or object), how is the load secured?
What, if any, external or internal load (or object) could be dropped from the aircraft when flying, and how will you assure the safety of people, or other people's property, if it is dropped or detached when flying?

Pilot/Personnel Details

What minimum level of experience will the Remote Pilot in Command (Remote PIC) have to fly under this waiver?
How many personnel (including the Remote PIC) will you use for operations under this waiver (minimum needed)?
What kind of training, if any, will personnel (e.g. visual observer(s)) have prior to flying under the waiver?
1. How will the personnel be trained?
2. How will the Responsible Person know the other personnel are competent and have operational knowledge to safely fly the UAS under the waiver conditions?
3. If personnel will be tested, what kind of testing will be performed, and how will evaluations be conducted and documented?
4. How will personnel maintain the knowledge/skill to fly under this waiver? Will recurrent training or testing be required?

Describe Operational Risks and Mitigation

Provide, to the greatest extent possible, how you propose to address or lessen the possible risks of your proposed operation. This could include using operating limitations, technology, additional training, equipment, personnel, restricted access areas, etc. When reviewing the questions for each section below, the FAA's primary concerns are:

How you will ensure your operation(s) remains safe at all times, even in unusual circumstances.
What kinds of circumstances could arise, and how you plan to handle each.

The following questions [10] are associated with each waivable section of part 107. Only answer the questions for the regulatory section applicable to the application you will submit:

107.25 Operations from a moving vehicle or aircraft
107.29 Daylight operation
107.31 Visual line of sight aircraft operation
107.33 Visual observer
107.35 Operation of multiple small unmanned aircraft
107.37 Operation near aircraft
107.39 Operation over people
107.51(a) Operating limitations: ground speed
107.51(b) Operating limitations: altitude
107.51(c) Operating limitations: minimum visibility
107.51(d) Operating limitations: minimum distance from clouds

NOTE: The list of questions may not be all-inclusive. You may need to provide additional information based on your specific operation.

To Do:

Read chapter 4 of the textbook "Introduction to Unmanned Aircraft Systems."
Review the FAA national policy on the Unmanned Aircraft Systems (UAS) operational approval. [11]
Review the samples COA applications [12] that you may benefit from for your COA application.
Review the samples of valid operational Part 107 Waivers [13].