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 exposureRestrictions on leasing equipmentAdditional Documentation RequirementsYou 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 pilotLetter from Attorney GeneralDetailed 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!

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