FAA Part 108 New Operational Requirements
With the FAA’s proposed Part 108, BVLOS flights won’t just be allowed, they’ll come with clear boundaries and expectations. These new operational requirements are designed to ensure safety, accountability, and consistency as drones take on larger, more complex roles in surveying and beyond. Read below for a complete synopsis and link to the regulation(s).
1. Altitude and Flight Areas
- BVLOS operations are limited to at or below 400 feet above ground level, and must originate from pre‑designated, access‑controlled locations with FAA-approved operational boundaries. Operators must also ensure communication reliability and have contingency plans for communication loss.
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2. Authorization Structure
- A two-tier authorization system:
- Permits for lower-risk BVLOS operations.
- Certificates for higher-risk, more complex operations, requiring a Safety Management System (SMS) and formal training programs.
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- Population-density limits: Permits are restricted to lower-density areas (up to Category 3). Higher-density operations (Categories 4–5) require a certificate.
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3. Separation & Traffic Management
- Use of FAA-approved Automated Data Service Providers (ADSPs) for traffic monitoring, strategic deconfliction, and conformance monitoring. Operators can also act as their own ADSP if compliant.
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- UAVs must have onboard detect-and-avoid systems and yield to manned aircraft using ADS‑B. Operations must not interfere with airports or other critical airspace zones.
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4. Aircraft & Equipment Standards
- Permissible UAS weight up to 1,320 pounds (including payload).
- No traditional FAA airworthiness certificates; instead, adherence to industry consensus standards, lighting, and Remote ID are required.
- DroneXL.co+5Federal Aviation Administration+5Drone Law and Drone Attorney Assistance+5
5. Organizational Roles & Training
- Shift from individual pilot certification to a corporate responsibility model:
- Operations Supervisor: ensures overall safety, training, and compliance.
- Flight Coordinator: oversees actual operations and intervenes if risks arise (without direct manual control).
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6. Security & Recordkeeping
- Stricter physical and cybersecurity measures, including:
- TSA security checks (background, watchlists, fingerprints) for key personnel.
- Policies to prevent unauthorized access and respond to cyber threats.
- Federal Aviation Administration
- Detailed reporting and recordkeeping required for:
- Flight logs, incident reports, mechanical issues, maintenance, training, operations manual.
- Manufacturers must maintain records of compliance testing and configuration changes; ADSPs must log compliance and software revisions.
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7. Operations Over People & Hazardous Materials
- Allowed, but with population-density-based restrictions and escalating mitigations for denser areas. Large gatherings remain off-limits.
- Federal Aviation Administration
- Framework contemplates transport of hazardous materials under strict control, contingent on risk assessments and packaging requirements.
- DARTdrones
8. Performance-Based Standards
- Emphasis on performance-based requirements rather than prescriptive equipment mandates. Technologies like detect-and-avoid must meet performance benchmarks.
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9. Workforce Rest & Oversight
- Rest limits: Operators are subject to restrictions such as max 14-hour shifts or 50 hours per week, with mandatory 10-hour rest periods—mirroring manned aviation safety standards.
- DRONELIFE
Summary Table
| Category | Key New Restrictions/Requirements |
| Flight Altitude & Zones | ≤400 ft AGL; defined operational areas with contingencies |
| Authorization | Permit vs. Certificate system; population-density limits |
| Separation & UTM | ADSP requirement; detect-and-avoid; yield to ADS-B aircrafts |
| Aircraft Standards | Up to 1,320 lbs; consensus-based airworthiness; lighting + Remote ID |
| Organizational Structure | Roles: Operations Supervisor & Flight Coordinator; organizational accountability |
| Security & Documentation | TSA checks; cyber and physical security; extensive recordkeeping |
| Operations Over People | Allowed with density-based restrictions; large crowds prohibited |
| Technology Standards | Performance-based approach, not prescribing equipment |
| Workforce Safety | Shift limits; mandatory rest periods |
Why These Matter
These new requirements introduce a more structured, safer, and scalable environment for BVLOS operations. For companies like H&M Surveying, this means:
- Expanded capability: Conduct large-scale BVLOS surveys with clear regulatory backing.
- Role clarity: Dedicated operations supervisors and flight coordinators enable streamlined organizational workflows.
- Tech-enabled savings: With mandates like detect-and-avoid and ADSP integration, operations become more autonomous, efficient, and safe.
- Preparedness: H&M’s existing Part 107 certifications, UAV fleet, and tech infrastructure position it well to adapt swiftly once Part 108 becomes final.
