AVIATION SAFETY

UNMANNED AIRCRAFT PROGRAM OFFICE

AIR-160

Interim Operational Approval Guidance 08-01

Unmanned Aircraft Systems

Operations in the U. S. National Airspace System

March 13, 2008

Purpose
Aviation Safety Unmanned Aircraft Program Office (UAPO) Interim Operational Approval
Guidance, Unmanned Aircraft Systems Operations in the U. S. National Airspace System,
provides guidance to be used to determine if unmanned aircraft systems (UAS) may be allowed
to conduct flight operations in the U. S. national airspace system (NAS). UAPO and Air Traffic
Organization (ATO) personnel will use this policy guidance when evaluating each application
for a Certificate of Waiver or Authorization (COA) and special airworthiness certificates
(normally issued in an experimental category). UAPO Interim Operational Approval Guidance
provides additional information on a number of items in the COA processor application
developed by the Air Traffic Organization. Used in conjunction with the COA online
application system, this guidance will simplify the COA evaluation process.

1.0 Introduction
The proliferation of UAS into the NAS has resulted in an increased demand for the FAA to
process a large number of applications to review for operational approvals. These approvals are
required due to the fact that unmanned aircraft (UA) are not compliant with various sections of
Title 14 of the Code of Federal Regulations (14 CFR) and therefore, require an alternate means
of compliance. Most notably, the lack of an on-board pilot requires an alternate method of the
see-and-avoid provisions of 14 CFR 91.113, Right-of-Way Rules: Except Water Operations.

This document is intended to provide guidance and information to Aviation Safety (AVS) and
ATO personnel who are charged with the processing, reviewing, and approving of UAS
operations. The interim guidance presented in this document represents the culmination of best
practices and procedures used in prior UAS approvals, as well as input from other government
agencies, industry and user stakeholders. It should be noted that the material presented in this
document is a recommended approach to approving typical UAS operations, however, each
application needs to be assessed on its own technical merits and may require unique
authorizations which are based on the specific needs or capabilities of the UAS in question.

It should be further noted that due to the rapid evolution of UAS technology, this guidance
material will be subject to continuous review and may be updated when appropriate.

Note: In general, and as a minimum, applicants must observe all applicable regulations of 14
CFR parts 61 and 91. This document is intended to identify alternate methods of compliance
with the regulations when evaluating proposed UAS operations.

For a complete listing of regulations, refer to the following website:

http://www.faa.gov/regulations_policies/faa_regulations/

2.0 Background
UAS operations have increased dramatically during the past several years in both the public and
private sectors. In response to this increasing activity, it has become necessary to develop
guidance for Federal Aviation Administration to use when evaluating applications for
certificate(s) of waiver or authorization and special airworthiness certificates. This guidance is

UAS Interim Operational Approval Guidance 08-01 2

not meant as a substitute for any regulatory process. This guidance was jointly developed by,
and reflects the consensus opinion of:

The Unmanned Aircraft Program Office (UAPO), FAA Aircraft Certification Service
(AIR-160)
The Production and Airworthiness Division, FAA Aircraft Certification Service (AIR-200)
The Flight Technologies and Procedures Division, FAA Flight Standards Service (AFS-400)
The FAA Air Traffic Organizations Office of System Operations and Safety, (AJR-3).

3.0 Definitions
The following definitions apply to terms used in this document.

Airworthiness: For the UAS to be considered airworthy, both the aircraft and all of the
other associated support equipment of the UAS must be in a condition for safe operation. If
any element of the systems is not in condition for safe operation, then the UA would not be
considered airworthy.
Chase aircraft: A manned aircraft flying in close proximity to an unmanned aircraft that
carries, in addition to the pilot in command (PIC) of the aircraft, a qualified visual observer.
Cooperative aircraft: Aircraft that have an electronic means of identification (i.e., a
transponder) aboard and operating.
Inspection: The routine performance of inspection tasks at prescribed intervals. The
inspection must ensure the airworthiness of an aircraft up to and including its overhaul or life
limits.
Non-Cooperative aircraft: Aircraft that do not have an electronic means of identification
(i.e., a transponder) aboard or not operating such equipment due to malfunction or deliberate
action.
Off-Airport: Any location used to launch or recover an unmanned aircraft that is not
considered an airport (i.e., an open field).
Pilot in Command (PIC): The person who has final authority and responsibility for the
operation and safety of flight, has been designated as pilot in command before or during the
flight, and holds the appropriate category, class, and type rating, if appropriate, for the
conduct of the flight. The responsibility and authority of the pilot in command as described
by 14 CFR 91.3, Responsibility and Authority of the Pilot in Command, apply to the
unmanned aircraft PIC. The pilot in command position may rotate duties as necessary with
equally qualified pilots. The individual designated as PIC may change during flight.
Public aircraft: An aircraft operated by a public user which is intrinsically governmental in
nature (i.e. federal, state, and local agencies). Examples of public entities are Department of
Defense (DoD) and its military branches; other local, state, and federal government agencies;
and state universities. Refer to 14 CFR 1.1, General Definitions, for a complete definition of
a public aircraft.

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 Scheduled Maintenance (Routine): The performance of maintenance tasks at prescribed
intervals.
Supplemental Pilot: Supplemental pilots are those pilots assigned unmanned aircraft flight
duties to augment the pilot in command. It is common for applicants to have both an
internal and an external unmanned aircraft pilot. The supplemental pilot can assume
either of these positions. The supplemental pilot may also assume duties of the pilot in
command if they meet the qualifications.
Unmanned Aircraft: A device used or intended to be used for flight in the air that has no
onboard pilot. This includes all classes of airplanes, helicopters, airships, and translational
lift aircraft that have no onboard pilot. Unmanned aircraft are understood to include only
those aircraft controllable in three axes and therefore, exclude traditional balloons
Unscheduled Maintenance (Non-Routine): The performance of maintenance tasks when
mechanical irregularities occur. These irregularities are categorized as to whether or not they
occur during flight time.
Visual Line-of-Sight: A method of control and collision avoidance that refers to the pilot or
observer directly viewing the unmanned aircraft with human eyesight. Corrective lenses
(spectacles or contact lenses) may be used by the pilot or visual observer. Aids to vision,
such as binoculars, field glasses, or telephoto television may be employed as long as their
field of view does not adversely affect the surveillance task.
Visual Observer: A trained person who assists the unmanned aircraft pilot in the duties
associated with collision avoidance. This includes, but is not limited to, avoidance of other
traffic, clouds, obstructions and terrain.

4.0 Methods of Authorization and Applicability

Guidance in this document of an operational nature always applies to both civil and public
operators. In the areas of pilot certification, crew certification, pilot currency, medical
certificates, and airworthiness, it is assumed that all public aircraft comply with processes and
policies established by the public entity, in a manner similar to publicly operated manned
aircraft. If no established policies exist regarding pilot certification, crew certification, pilot
currency, medical certificates, and airworthiness, it is highly recommended that the public
agency/department apply the guidance outlined in this document.

The procedures contained in this document are applicable for operations in the contiguous
United States, Alaska, Hawaii, and the Flight Information Regions delegated to the United States
and areas where the FAA is the Air Traffic Service Provider.

In general, specific authorization to conduct unmanned aircraft operations in the NAS outside of
active Restricted, Prohibited, or Warning Area airspace must be requested by the applicant.
Airspace inside buildings or structures is not considered to be part of the NAS and is not
regulated. The two methods of approval are either a certificate of waiver or authorization (COA)
or the issuance of a special airworthiness certificate.

UAS Interim Operational Approval Guidance 08-01 4

The guidance information presented in this document applies to approvals for both COA and
special airworthiness certificates. Unless otherwise stated, recommended procedures and
guidance that appear in this document apply to both.

The applicability and process to be used in a UAS operational approval is dependent on whether
the applicant is a civil user or a public user. A public user is one that is intrinsically
governmental in nature (i.e., federal, state, and local agencies). Public applicants should utilize
the COA application process. Civil applicants must apply for an airworthiness certificate.

Regardless of authorization method, all UAS applications are ultimately processed through ATO,
UAPO, Flight Standards, and Aircraft Certification staff at the headquarters level for final
approval and disposition.

Notes:

This document and the processes prescribed do not apply to hobbyists and amateur model
aircraft users when operating systems for sport and recreation. Those individuals should
seek guidance under Advisory Circular (AC) 91-57, Model Aircraft Operating Standards,
which is currently under revision.
Civil UAS operations require a special airworthiness certificate and should follow the
process as specified in this document.
AC 91-57 shall not be used as a basis of approval for UAS operations and is applicable to
recreational and hobbyists use only.

4.1 Certificate of Waiver or Authorization (COA)

Applications for a COA are only accepted from public entities. An application may be referred
to the FAA Office of the Chief Counsel (AGC), for determination of the status of an applicant,
i.e., public or civil. COAs are typically issued for a period of up to one year, but may be issued
for a lesser duration if requested or deemed appropriate. COAs are not required for operations
conducted wholly within an active Restricted, Prohibited or Warning Area airspace when
operating with permission from the appropriate authority or using agency of that airspace.

4.1.1 General Process Air Traffic Operations (ATO) is responsible for the COA process.
Applications can be made on the internet or can be made on FAA Form 7711-2,
Application for Certificate of Waiver or Authorization. If the application is made on
FAA Form 7711-2 it will be sent to Headquarters ATO, through the local Air Traffic
Service Area. ATO has developed a guidance checklist covering the application and
approval process. This form and guidance material can be found on the internet at
www.faa.gov/uas via the Air Traffic Airspace (ATA), Unmanned Aircraft Systems
(UAS) Group link.

Prior to issuance of a COA, ATO normally requests a review of the COA application by
the UAPO. Specifically, the AFS-400 members of the UAPO evaluates each application
to determine if risks associated with the operation have been acceptably mitigated.
Formal recommendations are forwarded to ATO from the UAPO at the conclusion of the
review process.

UAS Interim Operational Approval Guidance 08-01 5

4.1.2 National Security Considerations When the Department of Defense or the Department
of Homeland Security declares a UAS operation is a matter of national security, the
FAA may approve an application for a COA which, under normal circumstances, might
not otherwise conform to the guidelines set forth in this guidance document. In this case,
national security itself may override risk mitigation requirements and the applicant must
declare in the COA application acceptance of all risks associated with the UAS
operations. In general, such requests should be directed to the Administrator, Federal
Aviation Administration, from an equivalent level individual of the applicants
organization.

4.2 Special Airworthiness Certificate

Civil applicants are required to apply for a special airworthiness certificate, typically, an
experimental certificate. The applicant is required to submit the requisite data to support a
determination that the aircraft and its systems, including the control station(s) is designed, built,
and maintained in a safe and airworthy condition. Experimental certificates are typically issued
for a period of up to one year. Experimental certificates are typically issued to industry and
manufacturers wishing to accomplish UAS research and development, testing, crew training, and
market survey in accordance with 14 CFR Part 21.191. In cases where an applicant has been
issued a special airworthiness certificate, and concurrently operates a corresponding UAS on a
COA in support of a public activity, the applicant must elect, prior to each flight, what authority
is to be used to conduct the flight. The use of both a special airworthiness certificate and a COA
authorization on a single flight is not permitted.

4.2.1 General Process For civil UAS operations, the Aircraft Certification Service,
Production and Airworthiness Division, AIR-200, at FAA headquarters is responsible for
the issuance of special airworthiness certificates. The issuance of an experimental
certificate is coordinated with the UAPO as well as AVS and ATO personnel at the
headquarters and regional levels. A thorough review is conducted by this team to
evaluate the systems airworthiness and operational specifics and to determine
mitigations required to meet acceptable standards of safety.

5.0 Alternate Methods of Compliance

All limitations and procedures presented in this guidance document are to be considered as
general guidelines only. Each application is evaluated on its own technical merit based on its
own set of operational parameters and proposed operational profiles, mitigations, and systems.
As such, deviations and alternate methods of compliance may be approved and may differ from
the information presented in this document. Therefore, if the applicant makes a safety case and
presents sufficient data for an alternate means of compliance, then this data should be taken into
consideration and evaluated for possible approval.

6.0 UAS Airworthiness

All UAS must be shown to be airworthy to conduct flight operations in the NAS. UAS should
be maintained and conform to the same airworthiness standards as defined for the 14 CFR parts

UAS Interim Operational Approval Guidance 08-01 6

under which UAS are intended to be operated. The FAA recognizes that some of the
requirements can differ from those for manned aircraft and appropriate changes can be defined.
In the future, UAS Maintenance Technician certification will parallel existing standards for
manned aviation. As with airworthiness standards, Maintenance Technicians Requirements will
be reviewed as part of the data collection process.

6.1 Public Applicants

The applicant must provide an airworthiness statement specifying compliance with the
proponents applicable airworthiness policy or criteria. Examples of acceptable policy/criteria
include, but are not limited to:

DoD: MIL-HDBK 516B, Airworthiness Certification

Air Force: AFPD 62-6, USAF Aircraft Airworthiness Certification
Army: AR 70-62, Airworthiness Qualification Of US Army Aircraft Systems (Level 1)
Navy and Marine Corps: NAVAIRINST 13034.1C, Flight Clearance Policy for Air Vehicles
and Aircraft Systems.

Note: As an example, an airworthiness statement could include words to this effect: This
COA application for (name of UAS) has been reviewed on behalf of the (name of applicant
or agency) in accordance with (MIL-HDBK-516 or specified alternative method) and has
been determined to be airworthy to operate as specified in this application subject to the
following restrictions (specify the conditions). The statement should be on letterhead
paper and both dated and signed by the responsible reviewing authority.

6.2 Civil Applicants

Approvals for civil applications using the special airworthiness process receive their
airworthiness certification as part of the review process with the FAA.

7.0 Continued Airworthiness

Applicants for UAS operational approvals must address continued airworthiness procedures as
part of their application. It is highly recommended that all applicants provide the following
information: a Continuing Airworthiness Program, a Maintenance Training Program, any unique
skill sets or maintenance practices relating to their aircraft and/or aircraft operations that may be
outside the current scope and practices of manned aviation and a process to report any applicable
data relating to the operation and maintenance of the UAS. All information that is received from
UAS operators will aid the FAA in tracking the various existing UAS types and operations. This
data will help expedite the regulatory process for UAS and allow the FAA to have a historical
data base from which to base current and future UAS regulatory guidance. Accurate
recordkeeping is essential in assuring positive operational and quality airworthiness control.

UAS Interim Operational Approval Guidance 08-01 7

8.0 Flight Operations

8.1 General

The guidance presented in this document applies only to those UAS operations affecting areas of
the NAS other than active Restricted, Prohibited, or Warning Areas. The FAA is particularly
concerned that UAS operate safely among all users of the NAS, including non-cooperative
aircraft and other airborne operations not reliably identifiable by radar (i.e., balloons, gliders,
parachutists, etc).

Unless specifically authorized, UAS operations in other than active Restricted, Prohibited, or
Warning Areas, or Class A airspace shall require visual observers, either airborne or ground-
based.

While considerable work is ongoing to develop a certifiable detect, sense, and avoid system,
no current solution exists. Compliance with the see and avoid aspect of 14 CFR 91.113, Right-
of-Way Rules: Except Water Operations, becomes one of the primary issues in UAS operational
approvals. As a result, alternate methods of compliance are required to accomplish the see and
avoid function. See and avoid risk mitigation strategies are normally based on the use of visual
observers or other methods of segregation. Risk mitigations may also include other methods or
systems that an applicant may propose for consideration. An applicant may propose any
reasonable type of mitigation or system, however, the FAA approves UAS flight activities that
can demonstrate that the proposed operations can be conducted at an acceptable level of safety.

Applicants proposing see and avoid strategies in lieu of visual observers, need to support
proposed mitigations with system safety studies which indicate the operations can be conducted
safely. Acceptable system safety studies must include a hazard analysis, risk assessment, and
other appropriate documentation that support an extremely improbable determination.

It is the applicants responsibility to demonstrate that injury to persons or property along the
flight path is extremely improbable. UA with performance characteristics that impede normal air
traffic operations may be restricted in their operations.

8.1.1 System Considerations

Onboard Cameras/Sensors: Although onboard cameras and sensors that are

positioned to observe targets on the ground have demonstrated some capability, their
use in detecting airborne operations for the purpose of deconfliction is still quite
limited. Therefore, these types of systems may not be considered as a sole mitigation
in the see and avoid risk assessment. In general, current designs are not mature and
have shown to be insufficient to provide the sole mitigation in the see and avoid risk
assessment. Although these systems are currently immature, applicants may be
allowed to propose any system solution that provides a mitigation strategy and should
be evaluated as a potential solution.
Radar and Other Sensors: If special types of radar or other sensors are utilized to
mitigate risk, the applicant must provide supporting data which demonstrates that:

UAS Interim Operational Approval Guidance 08-01 8

 o both cooperative and non-cooperative aircraft, including targets with low radar
reflectivity, such as gliders and balloons, can be consistently identified at all
operational altitudes and ranges, and,
o the proposed system can effectively deconflict a potential collision.
Lost Link Procedures: In all cases, the UAS must be provided with a means of
automatic recovery in the event of a lost link. There are many acceptable approaches
to satisfy the requirement. The intent is to ensure airborne operations are predictable
in the event of lost link.
Flight Termination System (FTS): It is highly desirable that all UAS have system
redundancies and independent functionality to ensure the overall safety and
predictability of the system. If a UAS is found to be lacking in system redundancies,
an independent flight termination system that can be activated manually by the UAS
PIC, may be required to safeguard the public.

8.2 Operational Requirements

Unless operating in an active Restricted, Prohibited, or Warning Area, UAS operations must
adhere to the following requirements.

8.2.1 Observer Requirement VFR UAS operations may be authorized utilizing either
ground-based or airborne visual observers onboard a dedicated chase aircraft. A visual
observer is required to perform the see and avoid function as alternative compliance to 14
CFR 91.113, Right-of-Way Rules: Except Water Operations.

The task of the observer is to provide the pilot of the UAS with instructions to steer the
UA clear of any potential collision with other traffic. Visual observer duties require the
ability to maintain visual contact with the UA at all times while scanning the immediate
environment for potential conflicting traffic. At no time will the visual observer permit
the UA to operate outside their line-of-sight. This ensures that any required maneuvering
information can be reliably provided to the PIC.

The visual limitation will specify both a lateral and vertical distance and shall be regarded
as a maximum distance from the observer where a determination of a conflict with
another aircraft can be made. When an application is approved by the FAA, the visual
limitation distance becomes a directive upon the observer.

Generally, observers are to be positioned no greater than one nautical mile laterally and
3000 feet vertically from the UA. The use of nautical miles is based on the fact that the
UA is being positioned by the pilot via control stations that typically use moving map
displays that are referenced in nautical miles.

This distance is predicated on the observers normal unaided vision. Corrective lenses,
spectacles, and contact lenses may be used.

When using other aids to vision, such as binoculars, field glasses, or telephoto television,
visual observers must use caution to ensure that the UA remains within the approved
visual limitation distance of the observer. Due to field of view and distortion issues, the

UAS Interim Operational Approval Guidance 08-01 9

 use of such aids can be used to augment the observers visual capability but cannot be
used as the primary means of visual contact.

Although this guidance specifies an observer distance, the small size of some UA may
not allow for adequate observation at the one mile limit. It should be understood that this
limit is the maximum range allowed and that a practical distance may be something less,
with the determination of such at the discretion of the applicant. Therefore, until an on
site validation of observer distance is conducted by the FAA, it will remain the
responsibility of the applicant to ensure the safety of flight and adequate visual range
coverage to mitigate any potential collisions. Conversely, larger UA may accommodate
an observer distance greater than the one mile limit. The applicant may establish a
distance greater than one mile based on a variety of factors. Increased observer distances
may be proposed by the applicant and will be subject to review by the FAA either by on
site demonstration or other means.

If UAS applications are approved for nighttime operations with flight operations that will
depart or arrive between sunset and sunrise, the ground observer(s) must be in place one
hour prior to that operation to ensure acclimation to the twilight/nighttime environment.

8.2.2 ATC Communications Requirements The UAS pilot must have immediate radio
communication with appropriate ATC facilities anytime:
the UA is being operated in Class A, D or sometimes E airspace (See 9.2.14 for
operations in Class B or C Airspace)
the UA is being operated under instrument flight rules (IFR)
it is stipulated under the provisions of any issued COA or a special airworthiness
certificate.
It is preferred that communications between the UAS pilot and ATC be established
through onboard radio equipment to provide a voice relay; this is required for IFR flight.

8.2.3 Inter-Communications Requirements Any visual observer, sensor operator, or other

person charged with providing collision avoidance for the UA must have immediate
communication with the UAS pilot. If a chase aircraft is being utilized, immediate
communication between the chase aircraft and the UAS pilot shall be required at all
times. If the UAS pilot is talking to air traffic control, monitoring of the air traffic
control frequency by all UAS crew members (UAS pilots, observers, and chase pilots) is
recommended for shared situational awareness. However, unless it is necessary, the UAS
PIC or the supplemental pilots are the only crewmembers that will talk to Air Traffic
Control.

8.2.4 Dropping Objects/Hazardous Materials If the UAs intended operation includes the
dropping or spraying of aircraft stores outside of active Restricted, Prohibited, or
Warning Areas, the application must specifically address the hazard and make a clear
case that injury to persons on the ground is extremely remote and operational risks have
been sufficiently mitigated. A similar case must be made for hazardous materials carried
aboard the UA.

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8.2.5 Flight Over Populated Areas Routine UAS operations shall not be conducted over
urban or populated areas. UAS operations may be approved in emergency or relief
situations if the proposed mitigation strategies are found to be acceptable.

8.2.6 Flight Over Heavily Trafficked Roads or Open-air Assembly of People UAS
operations shall avoid these areas. If flight in these areas is required, the applicant will be
required to support proposed mitigations with system safety studies that indicate the
operations can be conducted safely. Acceptable system safety studies must include a
hazard analysis, risk assessment, and other appropriate documentation that support an
extremely improbable determination. Additionally, it is the applicants responsibility
to demonstrate that injury to persons or property along the flight path is extremely
improbable. UAS with performance characteristics that impede normal air traffic
operations may be restricted in their operations.

8.2.7 Day/Nighttime Operations All UAS operations outside of Class A airspace must be
conducted during daylight hours. Nighttime operations may be considered in other
airspace if the applicant provides a safety case and sufficient mitigation to avoid collision
hazards at night. Examples of such may be transit operations in Class D airspace over a
non-joint use military airfield adjacent to restricted airspace.

8.2.8 Flights Below Class A Airspace All UAS operations (IFR or VFR) outside of active
Restricted, Prohibited or Warning Areas and below flight level (FL) 180 shall be
conducted in visual meteorological conditions (VMC) and in accordance with 14 CFR
91.155, Basic VFR Weather Minimums, however, a minimum flight visibility of not less
than three statue miles (SM) shall be maintained at all times. Cloud clearance
requirements shall remain as specified in 14 CFR 91.155, Basic VFR Weather Minimums.
Special VFR requirements per 14 CFR 91.157, Special VFR Weather Minimums, do not
apply to UAS operations and cannot be exercised.

8.2.9 Autonomous Operations It is generally understood that most UAS have some level of
autonomy associated with its operation. Although it is possible to have a completely
manual UAS, which requires a pilot-in-the-loop, the majority of UAS are autonomous to
a certain degree. Only those UAS that have the capability of pilot intervention, or pilot-
on-the-loop, shall be allowed in the NAS outside of Restricted, Prohibited, or Warning
areas. UAS that are designed to be completely autonomous, with no capability of pilot
intervention, are not authorized in the national airspace system. Although the pilot may
be technically considered out-of-the-loop in a lost link scenario, this restriction does not
apply to UAS operating under lost link.

8.2.10 Operations from Off-Airport Locations In most cases, an off-airport location should
be situated no closer than five nautical miles (NM) from any airport or heliport. The
operational areas, including the launch and recovery zones, should be free from
obstructions and reasonable efforts should be made to keep operations away from
structures and heavily trafficked roads. Due to the unique attributes of off-airport
locations, approval requests need to be evaluated on a case-by-case basis.

8.2.11 Other Mitigations in lieu of Observers See Alternate Methods of Compliance section.

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8.2.12 Operating Under Instrument Flight Rules (IFR) While operating on an instrument
flight plan, the following must exist, be completed, or be complied with:
The pilot in command must hold a current instrument rating in a manned aircraft.
The aircrafts airworthiness statement includes IFR flight and all equipment is
certified and working (including pitot static and transponder checks).
Aviation database and charts are current and available to the UAS pilot.
An IFR flight plan is filed.
An ATC clearance has been obtained and all clearances followed.
Direct two-way radio communication between the UAS pilot and ATC is available.
Communication relay through the UA is required.
Pre-coordination with ATC has been accomplished.
The UA is equipped with a certified operating mode C (mode S preferred)
transponder.
Visual observers are utilized in accordance with this guidance document.
ATC radar monitoring is available throughout the portion of the flight in Class A
airspace.
All operations outside of Class A airspace and active Restricted, Prohibited, or
Warning Areas shall be conducted in VMC conditions only.

8.2.13 Chase Aircraft Operations The chase aircraft must remain at a safe distance from the
UA to ensure collision avoidance should a UAS malfunction occur, but remain close
enough to provide visual detection of conflicting aircraft in the path of the UA in a timely
manner to advise the UAS PIC of the situation. Should the UAS pilot operate the UA
from the chase aircraft, the chase aircraft must remain within radio control range of the
UA to maintain appropriate signal coverage for flight control or activation of the flight
termination system. Chase aircraft may be required to have communication with
appropriate ATC facilities based on the applicants application or mission profile.
Chase aircraft are not required in Class A, active Restricted, Prohibited, or Warning
Area airspace.
Chase operations shall be conducted during daylight hours only.
Flight visibility for all UAS chase operations shall be three statute miles or greater.
Chase aircraft pilots must not concurrently perform either observer or UA pilot duties
along with chase pilot duties.
Chase aircraft operating as a formation flight will immediately notify ATC if they are
using a non-standard formation.

Note: A standard formation is one in which a proximity of no more than 1 mile

laterally or longitudinally and within 100 feet vertically from the flight leader is
maintained by each wingman.

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 Note: Nonstandard formations are those operating under any of the following
conditions:
When the flight leader has requested and ATC has approved other than standard
formation dimensions.
When operating within an authorized altitude reservation (ALTRV) or under the
provisions of a letter of agreement.
When the operations are conducted in airspace specifically designed for a special
activity.

8.2.14 Airspace Considerations by Airspace Designation:

Note: UA operating in airspace designated as reduced vertical separation minimum
(RVSM) airspace must comply with 14 CFR 91.180, Operations within Airspace
Designated as Reduced Vertical Separation Minimum Airspace.
Class A: Observers are not required in Class A. All UAS must be operating on an
instrument flight plan. UAS operations approved for Class A must comply with 14
CFR 91.135, Operations in Class A Airspace.
Class B: UAS operations are currently not authorized. Class B airspace contains
terminal areas highest density of manned aircraft in the National Airspace System.
As with all applications, the FAA will consider exceptional circumstances.
Class C and airspace within 30 nautical miles of an airport listed in 14 CFR
91.215: Requests for approval will be handled on a case-by-case basis and may be
approved if sufficiently mitigated and a safety case has been established. UAS
operations approved for Class C must comply with 14 CFR 91.130, Operations in
Class C Airspace, and 14 CFR 91.215, ATC Transponder and Altitude Reporting
Equipment and Use. The transponder requirement will not be waived.
Class D: Requests for approval will be handled on a case-by-case basis and may be
approved if sufficiently mitigated and a safety case has been established. UAS
operations approved for Class D must comply with 14 CFR 91.129, Operations in
Class D Airspace.
Class E: If there is an operating Air Traffic Control Tower Class D rules may apply.
UAS operations approved for Class E must comply with 14 CFR 91.127, Operating
on or in the Vicinity of an Airport in Class E Airspace.
Class G: UA operations approved for Class G must comply with 14 CFR 91.126,
Operating on or in the Vicinity of an Airport in Class G Airspace.

8.3 Oceanic Operations

8.3.1 UAS operations wholly contained within Warning areas are handled in the same manner
as those operations conducted in active Restricted and Prohibited areas, that is, no
specific approval is required and observers or chase aircraft are not required.

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8.3.2 Flight Information Region Operations. FAA rules and policies apply in the flight
information regions (FIRs) where the FAA is the air traffic service provider. As such, the
guidelines specified in this document apply to UAS operations conducted in these FIRs.

9.0 Personnel Qualifications

This section addresses the qualifications of UAS pilots, observers, maintainers, and other
personnel as appropriate. All references to a pilot certificate refer to an FAA issued private pilot
certificate or higher.

9.1 UAS Pilot Qualifications

The FAA is focused on insuring that UAS pilots have a common level of understanding of
federal aviation regulations applicable to the airspace where the UA will operate. Pilots are
responsible for a thorough preflight inspection of the UAS. They are accountable for controlling
their aircraft to the same responsible standards as the pilot of a manned aircraft. Pilot
qualifications for UAS operations conducted under IFR are addressed in this section.
The following items apply to the pilots of all UAS:
One pilot in command (PIC) must be designated at all times.
The PIC of an aircraft is directly responsible, and is the final authority of, the operation of
that aircraft.
Pilots must not perform crew duties for more than one UAS at a time.
Pilots are not allowed to perform concurrent duties both as pilot and observer.

9.1.1 Pilot in Command (PIC) The designated PIC is the pilot responsible for the UAS flight
operation. The PIC may be augmented by supplemental pilots; however, the PIC retains
complete and overall responsibility of the flight, regardless of who may be piloting the
UA. It is common for applicants to have both an internal and an external UAS pilot.
The PIC can assume any of these positions. The PIC duty may be rotated as necessary to
fulfill operational requirements.

9.1.1.1 Ratings Rating requirements for the UAS PIC depend on the type of operation
conducted and fall into two categories:
Operations that require a pilot certificate
Operations that do not require a pilot certificate.
The requirement for the PIC to hold a pilot certificate is based on various factors
including the location of the planned operations, mission profile, size of the UA, and
whether or not the operation is conducted within or beyond visual line of sight.
Operations without a pilot certificate may be allowed, permitting smaller UA to
operate below certain altitudes while controlled strictly by visual line of sight. The
cutoff point at which the smaller UA criteria will be utilized is yet to be defined;
therefore, each application will be carefully reviewed to assess the feasibility of
allowing that type of operation.

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 Operations requiring a pilot certificate: The PIC shall hold, at a minimum, an
FAA pilot certificate under the following circumstances:
All operations approved for conduct in Class A, C, D, and E airspace.
All operations conducted under IFR (FAA instrument rating required).
All operations approved for nighttime operations.
All operations conducted at joint use or public airfields.
All operations conducted beyond line of sight.
At any time the FAA has determined the need based on the UAS characteristics,
mission profile, or other operational parameters.

Note: The FAA may require specific aircraft category and class ratings in manned
aircraft depending on the UAS seeking approval and the characteristics of its flight
controls interface.

Operations not requiring a pilot certificate: The PIC may not be required to hold a
pilot certificate for operations approved and conducted solely within visual line of
sight in Class G airspace. For the PIC to be exempt from the pilot certificate
requirement the following conditions must exist and the alternate compliance method
described below must be followed:
The operation is conducted in a sparsely populated location, and,
The operation is conducted from a privately owned airfield, military installation,
or off-airport location.
Visual line of sight operations conducted no further than 1 NM laterally from the
UAS pilot and at an altitude of no more than 400 feet above ground level (AGL)
at all times.
Operations shall be conducted during daylight hours only.
Operations shall be conducted no closer than 5 NM from any airport or heliport.
Alternate Compliance Method: In lieu of a pilot certificate, the PIC must have
successfully completed, at a minimum, FAA private pilot ground instruction, and
have passed the written examination.
Note: The FAA may require an instrument rating in a specific aircraft category in
manned aircraft depending on the UAS seeking approval and the characteristics of
its flight controls interface.

9.1.1.2 Currency The applicant shall provide a process that ensures that the pilots receive an
appropriate level of currency in the UAS being operated. At a minimum, the PIC
must demonstrate three takeoffs (launch) and landings (recovery) in the specific UAS
in the previous 90 days.

For those operations approved for night operations, the PIC must demonstrate three
takeoffs (launch) and landings (recovery) in the specific UAS at night to a full stop in
the previous 90 days.

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 For those operations that require a certificated pilot per section 9.1.1.1 above, the
PIC, in order to exercise the privileges of his certificate, shall have flight reviews and
maintain currency in manned aircraft per 14 CFR 61.56, Flight Review and 61.57,
Recent Flight Experience: Pilot in Command.

For operations approved for night or IFR, the PIC shall maintain currency per 14 CFR
61.57, Recent Flight Experience: Pilot in Command, as applicable.

9.1.1.3 Medical The PIC shall maintain, at a minimum, a valid FAA Class 2 medical
certificate issued under 14 CFR part 67, and have it in their possession.

9.1.1.4 Training In addition to the aforementioned training required for a pilot certificate,
UAS pilots will have additional training in all specific details of the UAS being
operated including normal, abnormal, and emergency procedures. This must include
manufacturer specific training (or military equivalent), demonstrated proficiency, and
testing in the UAS being operated.

9.1.2 Supplemental Pilots Supplemental pilots are those pilots assigned UA flight duty to
augment the PIC. It is common for applicants to have both an internal and an
external UA pilot. The supplemental pilot can assume any of these positions.

9.1.2.1 Ratings No specific rating is required for supplemental pilots unless they are
assuming the role of pilot in command. However, at a minimum, they must have
successfully completed private pilot ground school and have passed the written test.

9.1.2.2 Currency The applicant shall provide a process that ensures that the pilots maintain
an appropriate level of currency in the UAS being operated.

9.1.2.3 Medical Supplemental pilots shall maintain, at a minimum, a valid FAA Class 2
medical certificate issued under 14 CFR part 67, and have it in their possession. Any
supplemental pilot acting as a dedicated visual observer or flying the UA on a visual
basis shall also maintain a valid FAA Class 2 medical certificate.

9.1.2.4 Training In addition to all training required for receiving and maintaining a pilot
certificate, the UAS pilot shall be additionally trained in all specific details of the
UAS being operated including normal, abnormal, and emergency procedures.

9.2 Observer Qualifications

All observers must have an understanding of federal aviation regulations applicable to the
airspace where the UA will operate. Observers are considered a crewmember of the UAS.
Observers must not perform crew duties for more than one UAS at a time. Observers are not
allowed to perform concurrent duties both as pilot and observer.

9.2.1 Medical All observers shall maintain, at a minimum, a valid FAA Class 2 medical
certificate issued under 14 CFR 67, and have it in their possession. 14 CFR 91.17,
Alcohol or Drugs, applies to all UAS crewmembers, including observers.

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9.2.2 Training Observers must have completed sufficient training to communicate to the pilot
any instructions required to remain clear of conflicting traffic. This training, at a
minimum, shall include knowledge of the rules and responsibilities described in 14 CFR
91.111, Operating Near Other Aircraft; 14 CFR 91.113, Right-of-Way Rules: Except
Water Operations; and 14 CFR 91.155, Basic VFR Weather Minimums; knowledge of air
traffic and radio communications, including the use of approved ATC/pilot phraseology;
and knowledge of appropriate sections of the Aeronautical Information Manual.

9.3 Other Personnel Qualifications

Ancillary personnel such as systems operators or mission specialists must be thoroughly familiar
with and possess operational experience of the equipment being utilized. If the subject systems
being utilized are for observation and detection of other aircraft for collision avoidance purposes,
they must be thoroughly trained on collision avoidance procedures and techniques and have
direct communication with the UAS pilot, observer, and other applicable personnel on an inter-
communication system.

9.4 Maintenance Personnel Qualifications

9.4.1 Ratings Will be established as more data is collected and a regulatory guideline is
developed.

9.4.2 Currency It is suggested that applicants follow applicable guidelines of 14 CFR 65.83
as appropriate until final UAS regulatory guidelines are available.

9.4.3 Medical No medical requirements have been defined at this time.

9.4.4 Training It is highly recommended that a Maintainer/Operator of a UAS submit a

training program. This requirement will be further defined as more data is collected and
the regulatory process better defines these guidelines.

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 Revision History

Date Action

Initial release as AFS-400 Policy Memo 05-01, Unmanned Aircraft Systems

6-01-2005 Operations in the U.S. National Airspace System Interim Operational
Approval Guidance.

Cancelled AFS-400 Policy Memo 05-01 and Reissued Updated Document as

3-13-2008 Interim Operational Approval Guidance 08-01, Unmanned Aircraft Systems
Operations in the U. S. National Airspace System.

Signed

March 13, 2008

K. Douglas Davis
Manager, Unmanned Aircraft Program Office, AIR-160

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