As my favorite saying goes, “The only problem with doing something right the first time is, no one appreciates how difficult it was.” This certainly applies to Part 107 waivers.
Here are some tips from Skyward for submitting a successful Part 107 waiver.
It may take several months for your application to be approved or denied, so it’s worth it to take your time and be thorough. When it comes to your waiver application, the details matter
Be specific. Select only the Part 107 regulations that need to be waived in order to perform your operation. Don’t attempt to have every regulation waived. The more complicated the waiver request, the more likely it is that there will be a point of conflict that will result in denial of the entire request.
Do your homework and be detailed. The FAA wants to know the steps you’ll be taking to ensure that your proposed operation is just as safe as a standard operation under Part 107. Briefly state what you’ll be doing to mitigate risks. For example, when describing the remote pilot’s methods for seeing ground-based structures and obstacles, one of several may include: “The Remote Pilot will ensure that the takeoff and landing area is sufficiently illuminated so that the aircraft can be safely controlled during takeoff and landing and that any obstructions within 50 feet (15 meters) laterally of the takeoff and landing area are visible.”
Don’t overspecify. Your waiver, if granted, becomes binding. Don’t propose methods or procedures that will be burdensome or impossible to follow on a routine basis.
Be responsive. The FAA may ask you for additional information. If they don’t hear back from you within 30 days, your request will be withdrawn.
Night Flights
As an example, the FAA gives guidelines for the performance based standards that must be met to obtain a waiver for night flights, which I’ve summarized below.
Explain in detail how the pilot will maintain visual line of sight with the UAS during darkness.
Explain how the pilot will see and avoid other aircraft, people on the ground, and structures and other obstacles during darkness.
Explain how the pilot will continuously know the position, altitude, attitude, and movement of the UAS.
Explain how you will ensure that the entire flight crew understands how to recognize and overcome visual illusions caused by darkness, as well as the physiological conditions that can degrade a person’s night vision.
Explain how you will make sure that the aircraft is visible from 3 statute miles or otherwise how you will detect and avoid all non-participating aircraft.
Be sure to consult the complete instructions.
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