Monthly COA Reporting


COA reports

If you have a 333 with a blanket COA, you have to report your monthly activity even if you did NOT fly. Yes, I know this stinks because I myself have a 333 and have to report each month. The FAA’s COA website says, “The Monthly Operational report is expected to be submitted within 5 business days after end of the reporting month.”

Thankfully, these requirements are not in Part 107 going forward. However, there are NTSB and FAA reporting requirements if your drone happens to crash. Better to read and know them BEFORE you crash so you are not fumbling around if the situation happens.

Do we have a continuing obligation to report once we all switch over to Part 107 and stop using our 333s? Strictly speaking, yes, because the 333 and COA are still valid and the COA requires you to report even when you do not fly. I would continue to do it until the FAA tells you to stop or until the exemption expires 2 years after the grant date. You can find your expiration date by looking at the last page of your exemption.

Filing reports shouldn’t be much trouble if you set up an alert in your schedule or digital calendar to remind you at the end of each month.

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Reporting Requirements from the Blanket COA

1. Documentation of all operations associated with UAS activities is required regardless of the airspace in which the UAS operates. NOTE: Negative (zero flights) reports are required.
2. The operator must submit the following information through mailto: 9-AJV-115-UASOrganization@faa.gov on a monthly basis:

a. Name of Operator, Exemption number and Aircraft registration number
b. UAS type and model.
c. All operating locations, to include location city/name and latitude/longitude
d. Number of flights (per location, per aircraft)
e. Total aircraft operational hours
f. Takeoff or Landing damage
g. Equipment malfunctions. Reportable malfunctions include, but are not limited to the following:

(1) On-board flight control system
(2) Navigation system
(3) Powerplant failure in flight
(4) Fuel system failure
(5) Electrical system failure
(6) Control station failure

3. The number and duration of lost link events (control, performance and health monitoring, or communications) per UA per flight.

 

Jonathan Rupprecht

Mr. Rupprecht is an aviation attorney who focuses on drones. Read more about his background as a commercial pilot, flight instructor, Embry-Riddle Aeronautical University grad, and legal author. He has had media appearances on Forbes, Newsweek, Politico, NPR, Marketwatch, The Independent, Motherboard, and other sources. Feel free to send Jonathan a message here.

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