Pros and Cons of Flying Under a Certificate of Authorization
Today’s show is about COA vs. Part 107. Is flying under a Certificate of Authorization the most practical option for fire-fighters and law enforcement officers?
What is a UAS COA?
First things first. What exactly is a UAS COA? The FAA defines a COA or a Certificate of Authorization as a document issued by the Air Traffic Organization to a public operator for a specific UA activity.
How Do You Get a COA?
You can apply for a COA on the UAS COA Online System. Federal employees can log in to the system using their federal email address. Whereas, external users will have to go through an extra hoop by getting their identity validated here.
External users will have to share their phone number and SSN to get their identity validated. You can check out a sample COA application here.
COA vs. Part 107 – What are the Biggest Disadvantages of Flying Under a COA?
There is a common misconception within the drone industry that a Certificate of Authorization (COA), and not a Part 107 certificate is the best option for public safety agencies. However, in today’s show, you will learn why this is not true.
Specifically, these are the main DISADVANTAGES of flying under a COA:
- Liability exposure
- Restrictions on leasing equipment
- Additional Documentation Requirements
- You CANNOT train pilots
So, let’s take it from the top:
Liability Exposure
Using a COA, while you may get the necessary permission to fly almost instantaneously, you also risk exposing yourself to additional liabilities. How so? Well, if you read the fine print, most drone insurance policies state that in order to claim damages, a drone pilot must be flying in accordance with “FAA guidelines”. Now, when you are flying under a Certificate of Authorization, you are operating under your guidelines. So, you have a very high chance of running into this legal hurdle if you have to invoke
your insurance.
Additionally, when you are operating under a federal COA, all your flight logs and documents can be audited if any citizen of the United States requests this information by filing an FOIA request (Freedom of Information Act).
Restrictions on Owning Equipment
49 USC §40102(a)(41) states that “An aircraft exclusively leased for at least 90 continuous days by the government of a State, the District of Columbia, or a territory or possession of the United States or a political subdivision of one of these governments, except as provided in section 40125(b)”.
So, when you are flying under a COA, as per the rules, you cannot go for longer than 90 days without owning equipment. So, let’s presume that you are leasing a drone and your drone gets damaged. If you do not get your drone back within 90 days, you are violating the law and possibly exposing yourself to liabilities.
Additional Documentation Requirements
Lastly, flying under a Certificate of Authorization means that you will have to put in additional up-front work. This includes:
- Self-certify airworthiness
- Self-certify the pilot
- Letter from Attorney General
- Detailed concept of operations
You CANNOT Train Pilots when Flying Under a Certificate of Authorization (COA)
Moreover, as per the rules, while you can self-certify drone pilots, training them is not permissible!
Is Mavic 2 Enterprise Dual the Best Drone for Public Safety? What About the Yet-To-Be-Released Autel Evo 2 Dual?
We wrap up this show by discussing some of the best drones for public safety. In and earlier podcast, John had revealed why compact equipment like the Mavic 2 Enterprise Dual can prove to be excellent firefighting drones. Today, John shares his experience of test-flying the yet-to-be-released, Autel Evo 2 Dual. Can a geo-fencing free, Autel Evo 2 prove to be a far better option compared to popular DJI drones?
We managed to get our hands on the Autel Evo 2 at CES 2020. You can check out our review here:
So, which is the right option for you – COA or Part 107? Tune in to find out. We hope you enjoy this special show. Fly Safe!
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Timestamps
- [01:44] Paul welcomes ex-firefighter John Wakie to the show
- [04:00] What are the different ways public safety agencies are using drones?
- [04:32] "]COA vs Part 107 – which is the best option for public safety agencies to fly drones?
- [06:00] Are you better off going for a Certificate of Authorization when flying in a large city?
- [06:54] What do you think about the ability to self-certify once you get a COA?
- [09:45] Is flying under Part 107 a better option if you plan on obtaining a daytime waiver to fly at night?
- [11:20] Can flying under a COA hurt your ability to claim insurance?
- [12:06] "] Can public safety agencies fly in emergency situations under a SGI (Special Government Interest)?
- [14:42] What is a SGI (Special Government Interest)? Can you procure one instantly?
- [17:13] As per the rules, are you required to document your flights when flying under a COA?
- [21:53] Can flying your drone under a COA expose you to additional liabilities?
- [29:31] Why public safety agencies in large cities prefer to fly under COA’s
- [31:34] Can drone footage be used as evidence in courts?
- [33:43] Major Pros and Cons of operating under a Certificate of Authorization
- [37:18] Is Part 107 the most practical option for public safety agencies?
- [37:55] Is flying your drone under a NOTAM a big hassle?
- [40:13] Is it difficult for a 501 c volunteer organization to obtain a Certificate of Authorization?
- [41:13] How not holding equipment for more than 90 days could open you up to additional liabilities when flying under a COA
- [44:33] Do standard operating procedures for COA’s differ by state?
- [46:11] John shares why it would be prudent for public safety agencies to start with a Part 107 and add a Certificate of Authorization later
- [47:41] Why drone safety is paramount when using drones for firefighting and law enforcement
- [49:17] John shares how “perching” can prove to be an efficient way of utilizing drones for public safety
- [51:38] Which is the best drone for public safety? Can the Autel Evo 2 Dual prove to be a good option to DJI drones?