Commercial Drone Rules (Part 107)


Ultimate Guide to Drone Anti-Collision Lights-[2019]

drone-anti-collision-lights

Are you searching for a drone anti-collision light?

There are some great benefits to using a drone anti-collision light for recreational, public safety, and commercial operations.  It increases safety and gives you greater flexibility in your operations. Remember to go over the list of tips and considerations before you buy anything because each drone anti-collision light has its own strengths and weaknesses.

Table of Contents:

Why Drone Anti-Collision Lights?

So you might be saying to yourself, “Hey, why would I need some anti-collision lights for my drone? I already have lights on my drone!”

1. Helps you, and others, see the drone better. Yes, you might have some built-in drone lights but typically they are almost invisible during the day and not that bright during the night. This is where drone anti-collision lights come in help you and others see the drone during the day and night.

Remember that lights don’t solve all your night operational problems. What good are these lights if you don’t have training on how to fly at night? If you are looking at training for night operations, there is a Night Operations Video Course over at Rupprecht Drones that covers the night visual illusions and their remedies, physiological conditions which may degrade night vision, proper nighttime scanning techniques, and discusses more on aircraft lighting and considerations on how to mount the lights.

2. Required under Part 107 for civil twilight flying. Section 107.29 allows remote pilots to fly during civil twilight (twice daily: starting 30 minutes before sunrise to sunrise & sunset to 30 minutes after sunset). The big point is that the drone anti-collision lights must be visible for 3 statute miles or greater. There is a good chance your wimpy built-in drone anti-collision lights won’t cut it.

3. Some of the Part 107 waivers require them. The night waiver, reduced visibility, and beyond line of sight waivers typically use drone anti-collision lights as a method of helping other aircraft to see your drone flying. If you are planning on operating under one of these waivers, you should think about obtaining some good anti-collision lights visible for 3 statute miles or more. If you are wanting to learn more about Part 107 night waivers for your public safety or commercial operation, I have an entire article on this topic. If you are interested in obtaining a night waiver, contact me. I have over 90 night waiver approvals.

What are Drone Anti-Collision Lights?

Not everything is an anti-collision light. This is where everyone gets confused.

Anti-collision lights are (1) red or white and (2) blinking/strobing.

Navigation lights are: (1) red, green, and white and (2) solid. Here is a picture from the Rupprecht Drones Night Operations Video Course that visually explains navigation lights on manned aircraft.

drone-navigation-lights

This is extremely important because you need to make sure your lights communicate accurate information to other aircraft so they can see and avoid your drone. There are lights being sold out there in blue, yellow, etc. but these colors do not mean anything to other aircraft. 

One great example of a light communications failure is your DJI Phantom which totally fails at having navigation lights. (e.g. the green lights should not be on the back but the front right and back right.)

In addition to the colors, the drone anti-collision light needs to be blinking/strobing.

So am I stuck putting only one light on my drone?

No, you could put on multiple drone anti-collision lights!  You could have a blinking red one and a blinking white one to increase the visibility of your aircraft!

Additionally, you could also equip your aircraft with navigation lights which can be used for orientation.   Section 107.31 says the remote pilot in command: “must be able to see the unmanned aircraft throughout the entire flight in order to: (1) Know the unmanned aircraft’s location;  (2) Determine the unmanned aircraft’s attitude, altitude, and direction of flight[.]” Some of these drone lights can be purchased in different colors such as green and red and used as navigation lights. Some of the drone anti-collision lights on the market have the ability to change their patterns (blinking, strobe, or solid). This means if you have a red anti-collision light and can change the pattern to solid, you now have a red navigation light for the left hand side of your aircraft.

What Types of Drone Anti-Collision Lights Are There?

They are either portable or built in. Most modern day drones have built in drone anti-collision lights. There are some after market lights that can mounted through different methods (3M tape, straps, special mount, etc.) and they are powered with either LIPO batteries or some type of disposable battery (alkaline or lead/acid).

Drone Anti-Collision Light Tips/Considerations:

1. How many lights do you need? Some aircraft shapes don’t work so well. You might need to have 2 or more lights to ensure that light is being spread out.

2. How omni-directional is the light? You want a light that spreads the light and not just some directional light like the Lume Cube.

3. Are you planning on also outfitting your drone with navigation lights? Maybe consider purchasing a drone anti-collision light that is capable of being solid or a strobe in case you have a light failure. This way if your red drone anti-collision light fails or runs out of battery power, you could change the red solid light to a red strobe to act as the drone anti-collision light. It’s a backup.

4. Are you flying in the rain, snow, fog, etc.?  Your DJI Matrice might be waterproof but are your drone anti-collision lights? Some of these drone anti-collision lights are NOT water resistant. Some are waterproof and some water resistant. You might need a few drone anti-collision lights in your tool box to complete the mission.

5. Red or white?  A red LED does not mess up your night vision like a white light does but a white light is wayyyy more visible. One cool trick is if you can make your red strobe go a solid red, you can then use it like a flash light. Might come in handy if ya dropped something and need to find it. :)

6. How long are you planning on operating these things for? Some options have options to draw from the power of the drone while some of the portable ones are LIPO batteries that have to be recharged. Yes, they are LEDs so their run time can be for a long time and they are low cost enough so you could always keep a second one in your bag. One anti-collision light uses 2 alkaline acid AA batteries.

7. Consider the lifting capability of the aircraft. Some drone anti-collision lights are low weight while others weigh more. Keep this in mind as weight will always affect your flight times.

8. Are the lights visible for 3 statute miles or more? While recreational flyers do not have a 3 statute mile requirement, Part 107 flyers do. Make sure the manufacturer does say that the light is visible for 3 statute miles or more. If you want to take things one step further, maybe print the web page out that says the light is visible for 3 statute miles or more in case an FAA inspector or police officer asks.

9. Do you have to do anything else to make it operational? Some of the portable type of drone anti-collision lights are all self-contained while others you might have to wire in or buy a kit/mount to put them on the aircraft. Just compare below the Firehouse Technologies ARC with the North American Survival Systems DS-30.

Drone Anti-Collision Lights for Sale

Before we dive in, I want to say that I’m not being paid to write this. Aveo Engineering, ACR, and Firehouse Technologies were all kind enough to send me units to test out.

ACR Firefly Pro SOLAS

drone-anti-collision-light-ACR-fireflyThis light was not originally designed for drones. This is really an emergency distress strobe that is waterproof. I was looking for an all-weather drone anti-collision light to mount to a Matrice. This is important for fire departments (they do spray water everywhere), mountain rescue in the snow, search and rescue in the rain, etc. The light has been “Factory tested to 33 feet.” So I guess if you accidentally crash the drone in the lake, you might be able to find it blinking at the bottom and at least get your strobe light back.

The Firefly PRO Solas emergency strobe light boasts an all-new light output power management system that produces over 41 candelas of light per strobe for up to 56 hours of use (with AA lithium batteries). Using wide-light emission LEDs, it cuts through even the toughest conditions, creating a super-bright flash visible for over 3 miles.

As I said, it was not designed for drones so it is heavy compared to all other drone anti-collision lights because it uses two AA alkaline batteries. It weighs around 2.39 ounces.

It has solid, strobe, and S-O-S morse code flashing. It is only white.

 

Aveo Engineering’s PicoMax Drone Anti-collision Light

drone-anti-collision-light-picomaxThis is a very elegant drone anti-collision light. This strobe comes in either red or white. There is a cover for the USB port which makes it somewhat water resistant. Additionally, there are two tunnels right through the middle of the light which allow you greater flexibility to mount it to the aircraft with some type of bungee cord or string.  If you don’t like that, you can always do the 3M tape underneath.

Aveo’s website says:

Battery operated with DC adapter recharging, the PicoMax™ will strobe for longer than your drone flies on its charge. Exceeding the 2 nautical mile standard, the PicoMax™ actually surpasses 3 nm, and due to its proprietary Aveo firmware and circuitry it offers the brightest and fully airworthy tested features for the serious drone operator.

One thing to keep in mind when storing this is to make sure the button can’t be pressed or you’ll find out your light is dead when you go to operate it. There isn’t like a cover or cap to protect the button from being pushed.

 

Survival Systems DS-30 Strobe

This is a popular strobe. This strobe using a 9 volt battery is weaker than the Picomax or Firehouse Technologies ARC lights. I don’t know the brightness if a 11 volt 3S battery is used. The reason I bring this up is I know some of the small add on kits/mounts for the DS-30 use the a lead/acid 9 volt.

 

Firehouse Technologies ARC

These strobes are becoming very popular because they are low cost, you can mount them almost anywhere with the 3M tape, and they are very bright. Everything you need to charge and mount comes in the kit.

It now features 4 cree lights in one unit and a new improved interface with 3 lighting modes, Strobe, Flash, and a fixed (solid) mode. We also have a charge indicator. Its available in White, Red, Green Or Blue or Tri Color please scroll down to see color drop down menu when ordering.

Keep in mind that these are not waterproof or really resistant. (Maybe you could spray some of that water repellent sealer on it?) The plastic wrapping on the edges is open so dirt and water can get in through the sides. Additionally, with wear and tear, the plastic will tear and you might have to fix things with clear tape.

 

Further Reading:

How to Fly Your Drone at Night-(Part 107 Night Waiver)

Rupprecht Drones Night Operations Video Course (Designed for the Part 107 Night Waiver).

 

Conclusion:

There are some great benefits to using a drone anti-collision light for recreational, public safety, and commercial operations.  It increases safety and gives you greater flexibility in your operations. Remember to go over the list of tips and considerations before you buy anything because each drone anti-collision light has its own strengths and weaknesses.

What good are these lights if you don’t have training on how to fly at night? If you are looking at training for night operations, there is a Night Operations Video Course over at Rupprecht Drones that covers the night visual illusions and their remedies, physiological conditions which may degrade night vision, proper nighttime scanning techniques, and discusses more on aircraft lighting and considerations on how to mount the lights.

If you are wanting to learn more about Part 107 night waivers for your public safety or commercial operation, I have an entire article on this topic. If you are interested in obtaining a night waiver, contact me. I have over 90 night waiver approvals.


Section 107.79 Voluntary surrender of certificate.

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Section 107.79 Voluntary surrender of certificate.

(a) The holder of a certificate issued under this subpart may voluntarily surrender it for cancellation.

(b) Any request made under paragraph (a) of this section must include the following signed statement or its equivalent: “I voluntarily surrender my remote pilot certificate with a small UAS rating for cancellation. This request is made for my own reasons, with full knowledge that my certificate will not be reissued to me unless I again complete the requirements specified in §§107.61 and 107.63.”

My Commentary on Section 107.79 Voluntary surrender of certificate.

This comes in handy for a defense attorney who wants to negotiate with a prosecutor for a better deal.

Advisory Circular 107-2 on Section 107.79 Voluntary surrender of certificate.

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FAA’s Discussion on Section 107.79 Voluntary surrender of certificate.from the Final Small Unmanned Aircraft Rule

Section 107.79 will allow the holder of a remote pilot certificate with a small UASrating to voluntarily surrender it to the FAA for cancellation. However, the FAA emphasizes that cancelling the certificate pursuant to § 107.79 will mean that the certificate no longer exists, and the individual who surrendered the certificate will need to again go through the entire certification process if he or she subsequently changes his or her mind. For individuals who are not part 61 pilot certificate holders, this includes passing the initial aeronautical knowledge test. Accordingly, § 107.79(b) will require the individual surrendering the certificate to include the following signed statement (or an equivalent) in his or her cancellation request:

I voluntarily surrender my remote pilot certificate with a small UAS rating for cancellation. This request is made for my own reasons with full knowledge that my certificate will not be reissued to me unless I again complete the requirements specified in § 107.61 and § 107.63.

The FAA did not receive any adverse comments on this provision when it was proposed in the NPRM.

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Section 107.77 Change of name or address.

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Section 107.77 Change of name or address.

(a) Change of name. An application to change the name on a certificate issued under this subpart must be accompanied by the applicant’s:

(1) Remote pilot certificate with small UAS rating; and

(2) A copy of the marriage license, court order, or other document verifying the name change.

(b) The documents in paragraph (a) of this section will be returned to the applicant after inspection.

(c) Change of address. The holder of a remote pilot certificate with small UAS rating issued under this subpart who has made a change in permanent mailing address may not, after 30 days from that date, exercise the privileges of the certificate unless the holder has notified the FAA of the change in address using one of the following methods:

(1) By letter to the FAA Airman Certification Branch, P.O. Box 25082, Oklahoma City, OK 73125 providing the new permanent mailing address, or if the permanent mailing address includes a post office box number, then the holder’s current residential address; or

(2) By using the FAA Web site portal at www.faa.gov providing the new permanent mailing address, or if the permanent mailing address includes a post office box number, then the holder’s current residential address.

My Commentary on Section 107.77 Change of name or address.

It’s important that you give the FAA your correct address because if they need to mail you something, like a certificate revocation, they fine you if you don’t turn over your certificate timely.

Advisory Circular 107-2 on Section 107.77 Change of name or address.

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FAA’s Discussion on Section 107.77 Change of name or address from the Final Small Unmanned Aircraft Rule

This rule will extend the existing change-of-mailing-address requirement of part 61 to holders of a remote pilot certificate with a small UAS rating. Specifically § 107.77(c) will require a certificate holder who has made a change in permanent mailing address to notify the FAA within 30 days of making the address change. Failure to do so will prohibit the certificate holder from exercising the privileges of the airman certificate until he or she has notified the FAA of the changed address. This regulatory provision will help ensure that the FAA is able to contact airman certificate holders. The FAA did not receive any adverse comments on this provision when it was proposed in the NPRM.

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Section 107.74 Initial and recurrent training courses.

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Section 107.74 Initial and recurrent training courses.

(a) An initial training course covers the following areas of knowledge:

(1) Applicable regulations relating to small unmanned aircraft system rating privileges, limitations, and flight operation;

(2) Effects of weather on small unmanned aircraft performance;

(3) Small unmanned aircraft loading;

(4) Emergency procedures;

(5) Crew resource management;

(6) Determining the performance of small unmanned aircraft; and

(7) Maintenance and preflight inspection procedures.

(b) A recurrent training course covers the following areas of knowledge:

(1) Applicable regulations relating to small unmanned aircraft system rating privileges, limitations, and flight operation;

(2) Emergency procedures;

(3) Crew resource management; and

(4) Maintenance and preflight inspection procedures.

My Commentary on Section 107.74 Initial and recurrent training courses.

Aeronautical Knowledge Tests (Initial and Recurrent). It is important to have and retain the knowledge necessary to operate a small UA in the NAS. This aeronautical knowledge can be obtained through self-study, taking an online training course, taking an in-person training course, or any combination thereof. The FAA has published the Small Unmanned Aircraft Systems Airman Certification Standard (https://www.faa.gov/training_testing/testing/acs/) that provides the necessary reference material. Note: The below information regarding initial and recurrent knowledge tests apply to persons who do not hold a current part 61 airman certificate. 6.6.1 Initial Test. As described in paragraph 6.4, a person applying for remote pilot certificate with an sUAS rating must pass an initial aeronautical knowledge test given by an FAA-approved KTC. The initial knowledge test will cover the aeronautical knowledge areas listed below: 1. Applicable regulations relating to sUAS rating privileges, limitations, and flight operation; 2. Airspace classification and operating requirements, and flight restrictions affecting small UA operation; 3. Aviation weather sources and effects of weather on small UA performance; 4. Small UA loading and performance; 5. Emergency procedures; 6. Crew Resource Management (CRM); 7. Radio communication procedures; 8. Determining the performance of small UA; 9. Physiological effects of drugs and alcohol; 10. Aeronautical decision-making (ADM) and judgment; 11. Airport operations; and 12. Maintenance and preflight inspection procedures. 6.6.1.1 A part 61 certificate holder who has completed a flight review within the previous 24 calendar-months may complete an initial online training course instead of taking the knowledge test (see paragraph 6.7). 6/21/16 AC 107-2 6-5 6.6.1.2 Additional information on some of the knowledge areas listed above can be found in Appendix B. 6.6.2 Recurrent Test. After a person receives a remote pilot certificate with an sUAS rating, that person must retain and periodically update the required aeronautical knowledge to continue to operate a small UA in the NAS. To continue exercising the privileges of a remote pilot certificate, the certificate holder must pass a recurrent aeronautical knowledge test within 24 calendar-months of passing either an initial or recurrent aeronautical knowledge test. A part 61 pilot certificate holder who has completed a flight review within the previous 24 calendar-months may complete a recurrent online training course instead of taking the knowledge test.

Advisory Circular 107-2 on Section 107.74 Initial and recurrent training courses.

Aeronautical Knowledge Training Course (Initial and Recurrent). This section is applicable only to persons who hold a part 61 airman certificate, other than a student pilot certificate, and have a current flight review.

6.7.1 Initial Training Course. As described in paragraph 6.4, a pilot applying for a remote pilot certificate may complete an initial training course instead of the knowledge test. The training course can be taken online at www.faasafety.gov. The initial training course will cover the aeronautical knowledge areas listed below:

1. Applicable regulations relating to sUAS rating privileges, limitations, and flight operation;
2. Effects of weather on small UA performance;
3. Small UA loading and performance;
4. Emergency procedures;
5. CRM;
6. Determining the performance of small UA; and
7. Maintenance and preflight inspection procedures.

Note: Additional information on some of the knowledge areas listed above can be found in Appendix B.

6.7.2 Recurrent Training Course. After a pilot receives a remote pilot certificate with an sUAS rating, that person must retain and periodically update the required aeronautical knowledge to continue to operate a small UA in the NAS. As a renewal process, the remote pilot must complete either a recurrent training course or a recurrent knowledge test within 24 calendar-months of passing either an initial or recurrent aeronautical knowledge test. Figure 6-2, Recurrent Training Course Cycle Examples, illustrates an individual’s possible renewal cycles.

6.7.2.1 The recurrent training course areas are as follows:
1. Applicable regulations relating to sUAS rating privileges, limitations, and flight operation;
2. Emergency procedures;
3. CRM; and
4. Maintenance and preflight inspection procedures.

FAA’s Discussion on Section 107.74 Initial and recurrent training courses from the Final Small Unmanned Aircraft Rule

For the reasons discussed below, this rule will allow part 61 pilot certificate holders (other than the holders of a student pilot certificate) with current flight reviews139 to substitute an online training course for the aeronautical knowledge testing required by this rule.

Airborne Law Enforcement Association and Texas A&M University-Corpus Christi, suggested requiring only the recurrent knowledge test for part-61-certificated pilots. Numerous commenters also suggested that holders of part 61 airman certificates should be required to take only the recurrent knowledge test, not the initial knowledge test, or should be exempted entirely from knowledge-testing requirements. One commenter suggested that the holders of private, commercial, and ATP certificates who have operated UAS under exemptions be exempted from the initial knowledge test requirement. Another commented that non-military COA pilots should be permitted to take just the recurrent test, since the applicants will usually hold at least a private pilot certificate. One commenter stated that those applicants who hold part 61 pilot certificates should be required only to complete UAS-specific modules as part of the existing FAA Wings program. Another commenter stated that there should be a provision to enable existing small UAS pilots with a certain amount of logged PIC time to fly a small UAS without having to take a knowledge test.

The FAA agrees with commenters who suggested that requiring part-61-certificated pilots who satisfy the flight-review requirements of § 61.56 to take an initial or recurrent knowledge test is unduly burdensome. Through initial certification and subsequent flight reviews, a part-61-certificated airman is required to demonstrate knowledge of many of the topic areas tested on the UAS knowledge test. These areas include: airspace classification and operating requirements, aviation weather sources, radio communication procedures, physiological effects of drugs and alcohol, aeronautical decision-making and judgment, and airport operations. Because a part 61 pilot certificate holder is evaluated on these areas of knowledge in the course of the part 61 certification and flight review process, reevaluating these areas of knowledge on the initial and recurrent knowledge tests conducted under part 107 would be needlessly duplicative.

However, there are UAS-specific areas of knowledge (discussed in section III.F.2.j of this preamble) that a part-61-certificated pilot may not be familiar with. Accordingly, instead of requiring part-61-certificated pilots who are current on their flight reviews to take the initial and recurrent knowledge tests, this rule will provide those pilots with the option to take an online training course focusing on UAS-specific areas of knowledge. Just as there is an initial and recurrent knowledge test, there will also be an initial and recurrent training course available to part 61 pilot certificate holders. Those certificate holders will be able to substitute the initial training course for the initial knowledge test and the recurrent training course for the recurrent knowledge test. To ensure that a certificate holder’s UAS-specific knowledge does not become stale, this rule will include the requirement that a part 61 pilot certificate holder must pass either the recurrent training course or the recurrent knowledge test every 24 months.

The FAA emphasizes that the online training course option in lieu of taking the knowledge test will be available only to those part 61 pilot certificate holders who satisfy the flight review required by § 61.56. This is to ensure that the certificate holder’s knowledge of general aeronautical concepts that are not included on the training course does not become stale. Part 61 pilot certificate holders who do not meet the flight review requirements of § 61.56 will be unable to substitute the online training course for the required aeronautical knowledge test. Thus, under § 107.63(a)(2), a part 61 pilot certificate holder seeking to substitute completion of the initial training course for the initial aeronautical knowledge test will have to present his or her logbook upon application for a remote pilot certificate with a small UAS rating to demonstrate that he or she has satisfied this requirement. The applicant will also have to present a certificate of completion showing that he or she has completed the initial online training course.

The FAA also notes that the above discussion does not apply to holders of a part 61 student pilot certificate. A person is not required to pass an aeronautical knowledge test, pass a practical (skills) test, or otherwise demonstrate aeronautical knowledge in order to obtain a student pilot certificate. Further, student pilot certificate holders who have received an endorsement for solo flight under § 61.87(b) are only required to demonstrate limited knowledge associated with conducting a specific solo flight. For these reasons, the option to take an online training course instead of an aeronautical knowledge test will not extend to student pilot certificate holders.

j. Areas of Knowledge on the Aeronautical Knowledge Tests and Training Courses for Part  61 Pilot Certificate Holders
The NPRM proposed that the initial aeronautical knowledge test would test the following areas of knowledge: (1) regulations applicable to small UAS operations; (2) airspace classification and operating requirements, obstacle clearance requirements, and flight restrictions affecting small unmanned aircraft operation; (3) official sources of weather and effects of weather on small unmanned aircraft performance; (4) small UAS loading and performance; (5) emergency procedures; (6) crew resource management; (7) radio communication procedures; (8) determining the performance of small unmanned aircraft; (9) physiological effects of drugs and alcohol; (10) aeronautical decision-making and judgment; and (11) airport operations. The NPRM also proposed the following areas of knowledge for the recurrent knowledge test: (1) regulations applicable to small UAS operations; (2) airspace classification and operating requirements, obstacle clearance requirements, and flight restrictions affecting small unmanned aircraft operation; (3) official sources of weather; (4) emergency procedures; (5) crew resource management; (6) aeronautical decision-making and judgment; and (7) airport operations.

For the reasons discussed below, this rule will remove obstacle clearance requirements and add maintenance and inspection procedures as areas of knowledge that will be tested on both the initial and recurrent aeronautical knowledge tests. Further, aviation weather sources will be removed from the recurrent aeronautical knowledge tests. Except for these changes, this rule will finalize all other areas of knowledge as proposed in the NPRM.

With regard to the initial and recurrent training courses for part 61 pilot certificate holders, those courses will only cover UAS-specific areas of knowledge that are not included in the training and testing required for a part 61 pilot certificate. Thus, the initial training course will cover: (1) regulations applicable to small UAS operations; (2) small UAS loading and performance; (3) emergency procedures; (4) crew resource management; (5) determining the performance of the small unmanned aircraft; and (6) maintenance and inspection procedures. The recurrent training course will cover: (1) regulations applicable to small UAS operations; (2) emergency procedures; (3) crew resource management; and (4) maintenance and inspection procedures.

i. Regulations Applicable to Small UAS
The NPRM proposed to include an area of knowledge on both the initial and recurrent knowledge tests that determines whether the test taker knows the regulations applicable to small UAS. By testing the applicant for an airman certificate on knowledge of applicable regulations, the initial and recurrent knowledge tests would ensure that the applicant understands what those regulations require and does not violate them due to ignorance.

The FAA did not receive any adverse comments on this aspect of its proposal, and as such, this rule will include regulations applicable to small UAS as an area of knowledge that is tested on both initial and recurrent aeronautical knowledge tests. This area of knowledge will also be included on the initial and recurrent training courses that can be taken by part 61 pilot certificate holders instead of a knowledge test because regulations applicable to a small UAS are a UAS-specific area of knowledge that is not included in the training and testing required for a part 61 pilot certificate.

ii. Airspace Classifications and Operating Requirements, and Flight
Restrictions Affecting Small Unmanned Aircraft Operation The NPRM also proposed testing (on both the initial and recurrent knowledge tests) knowledge of airspace classification and operating requirements, as well as knowledge of flight restrictions affecting small unmanned aircraft operation. The NPRM explained that part 107 would include airspace operating requirements, such as the requirement to obtain ATC permission prior to operating in controlled airspace, and in order to comply with those requirements, an airman would need to know how to determine the classification of the airspace in which he or she would like to operate. The NPRM also proposed to test knowledge of how to determine which areas of airspace are prohibited, restricted, or subject to a TFR.

Under the NPRM, this area of knowledge would also be included in the recurrent knowledge test because: (1) airspace that the airman is familiar with could become reclassified over time; (2) the location of existing flight restrictions could change over time; and (3) some airmen may not regularly encounter these issues in their operations. For the reasons discussed below, this rule will include knowledge of airspace classification and operating requirements and knowledge of flight restrictions affecting small unmanned aircraft operation as an area of knowledge tested on both the initial and recurrent knowledge tests.

The California Agricultural Aircraft Association supported testing on how the airspace is managed, what the rules and regulations are, and how manned aircraft operate in the airspace. Aerius suggested that the knowledge test should include special use airspace, right-of-way rules, visual scanning, aeromedical factors (e.g., the limitations of the human eye), and accident reporting. On the other hand, the Electronic Frontier Foundation asserted that airspace classification is not relevant for low altitude micro UAS flights far away from airports and should not be tested for airmen seeking to operate micro UAS. The FAA declines to eliminate airspace classification as an area of knowledge tested for small UAS operations. As an initial matter, the FAA notes that this rule will not prohibit any small UAS (including micro UAS) from operating near airports. For UAS not operating near an airport, the FAA notes that controlled airspace can extend a significant distance away from an airport. For example, the surface area of Class B airspace can extend up to 8 nautical miles away from an airport. Additionally, airspace classification may change over time; uncontrolled (Class G) airspace may be changed to controlled airspace and vice versa. A remote pilot of any small UAS will need to have the ability to determine what class of airspace his or her small UAS operation will take place in to ensure that the operation complies with the airspace rules of part 107.

In response to Aerius, the FAA notes that special-use airspace will be covered under knowledge of flight restrictions, which will determine the test taker’s knowledge of regulatory restrictions on small UAS flight imposed through means such as prohibited airspace or a TFR. Right-of-way rules, visual scanning, and accident reporting will be covered by the knowledge area of regulations applicable to small UAS operations because all of these concepts are codified in the operational regulations of part 107. Aeromedical factors will not specifically be included on the knowledge test, but the FAA may publish further guidance to remote pilots on topics such as aeromedical factors and visual scanning techniques.

AUVSI recommended that the FAA require more extensive knowledge testing than what was proposed for an operator desiring to fly in Class B, C, D, or E airspace, operate small UAS for commercial purposes, or operate small UAS beyond visual line of sight with risk-based approval. The commenter did not, however, specify what should be included in this more extensive testing, and as such, the FAA is unable to evaluate AUVSI’s suggestion.

iii. Obstacle Clearance Requirements
The NPRM proposed to include obstacle clearance requirements as an area of knowledge to be tested on the initial knowledge test to ensure that an applicant for a remote pilot certificate knows how to avoid creating a collision hazard with a ground structure. One commenter suggested removing this area of knowledge from the knowledge test because, according to the commenter, there are no obstacle clearance requirements in part 107, and therefore, there should be nothing to test. The FAA agrees with this comment and has removed obstacle clearance requirements as an area of knowledge to be tested on the initial knowledge test.

The FAA notes that although the test taker will not be tested on knowledge of obstacle clearance requirements, they will be tested for knowledge of regulations applicable to small UAS, including the requirements of §§ 107.19(c) and 107.23(a), which: (1) prohibit operating a small unmanned aircraft in a careless or reckless manner so as to endanger the life or property of another; and (2) require the remote pilot in command to ensure that the small unmanned aircraft will pose no undue hazard to other aircraft, people, or property in the event of loss of control of the aircraft. A small unmanned aircraft flown in a manner that creates a collision hazard with a ground structure may violate one or both of these regulations, especially if there are people near the ground structure who may be hurt as a result of the collision.

iv. Aviation Weather Sources and Effects of Weather on Small Unmanned

Aircraft Performance The NPRM proposed to test, on the initial and recurrent knowledge test, knowledge of official sources of weather. The NPRM also proposed to test on the initial knowledge test whether the applicant understands the effects of weather and micrometeorology (weather on a localized and small scale) on a small unmanned aircraft operation. The NPRM explained that knowledge of weather is necessary for the safe operation of a small unmanned aircraft because, due to the light weight of the small unmanned aircraft, weather could have a significant impact on the flight of the aircraft.

One commenter recommended the removal of “official” from “official weather sources,” saying that operation of a UAS calls for assessment of “local” weather conditions, and, furthermore, that there are no clearly identified “official sources of weather.” Aviation Management suggested that official sources of weather be excluded from the recurrent knowledge test.

The FAA agrees with the commenter that there are no specific “official sources of weather,” and has removed that terminology from this rule. However, the FAA emphasizes that there are several sources of aviation weather useful to remote pilots. Accordingly, remote pilots will be required to be familiar with aviation weather products such as the ones provided by the National Weather Service through Flight Service Stations, Direct User Access Terminal Systems (DUATS), and/or Flight Information Services-Broadcast (FIS-B).140 While this rule does not require the use of those sources of weather for planning flights, aviation weather sources could be a valuable resource for remote pilots that choose to use them. For example, a remote pilot conducting an operation in an area with quickly changing weather may wish to access weather information from an aviation weather source for the most up-to-date weather data to ensure that the small UAS operation will comply with the minimum visibility and cloud clearance requirements of § 107.51. The FAA notes that aviation weather sources include weather data that can be used to evaluate local weather conditions.141 Because there is no requirement for remote pilots to use aviation weather products on an ongoing basis, the FAA has removed this area of knowledge from the recurrent aeronautical knowledge test.

Accordingly, this rule will include knowledge of aviation weather sources and the effects of weather on small unmanned aircraft performance on the initial knowledge test. Additionally, this rule will include knowledge of the effects of weather on small unmanned aircraft performance as an area of knowledge on the initial training course available to part 61 pilot certificate holders because this is a UAS-specific area of knowledge that is not included in the training and testing required for a part 61 pilot certificate. The training course will not include knowledge of aviation weather sources because that is not a UASspecific area of knowledge.

v. Small UAS Loading and Performance
The NPRM proposed to include weight and balance as an area of knowledge to be tested on the initial knowledge test to ensure that an applicant for a remote pilot certificate knows how to calculate the weight and balance of a small unmanned aircraft to determine impacts on performance. The NPRM noted that in order to operate safely, operators need an understanding of some fundamental aircraft performance issues, including load balancing and weight distribution as well as available power for the operation. University of Arkansas Division of Agriculture suggested that the FAA’s proposal suggests a lack of understanding by the FAA of these lightweight aircraft. The commenter added that when they place a battery or camera on their aircraft, it is immediately obvious if something is not balanced.

While the FAA agrees that in some circumstances the effect certain loads may have on the weight, balance, and performance of the aircraft may be obvious—such as adding a five pound weight to one side of a 0.5 pound small unmanned aircraft—other weight distributions and how they affect the balance of the aircraft may be more difficult to surmise. For example, it may not be intuitive for a remote pilot to determine the effect a half-pound battery will have when added to a forty-pound aircraft. Additionally, a remote pilot needs to understand the effect that the added weight will have on the aircraft’s operation over time. For example, while a small unmanned aircraft may be balanced for the first few flights after a weight is added, that weight may influence the aircraft over time
such that during later flights the aircraft is no longer balanced and no longer flying safely. For these reasons, the FAA will include a section on the initial knowledge test ensuring that a remote pilot applicant understands how to calculate the weight and balance of a small unmanned aircraft and the resulting impacts on performance. Because small unmanned aircraft loading is a UAS-specific area of knowledge, the FAA will also include it on the initial training course that part 61 pilot certificate holders can take in place of the knowledge test.

vi. Emergency Procedures
The NPRM noted that a small UAS airman may have to deal with an emergency situation during a small UAS operation. As such, the NPRM proposed to include an area of knowledge on the initial knowledge test that would determine whether the applicant knows how to properly respond to an emergency. The NPRM also proposed to include knowledge of emergency procedures on the recurrent knowledge test because emergency situations will likely be infrequent and as such, a certificate holder’s knowledge of emergency procedures may become stale over time. The FAA did not receive adverse comments on including emergency procedures on the initial knowledge test, and as such, this area of knowledge will be included on the initial knowledge test.

Turning to the recurrent knowledge test, Aviation Management recommended that the FAA remove emergency procedures as an area of knowledge covered on that test. The FAA declines to remove emergency procedures from the recurrent knowledge test. As discussed in the NPRM, emergency situations will likely arise infrequently, and as such, a remote pilot’s knowledge of emergency procedures may become stale over time. Accordingly, including this area of knowledge on the recurrent knowledge test will ensure that the remote pilot retains the knowledge of how to properly respond to an emergency. Because this area of knowledge is UAS-specific, it will also be included on the initial and recurrent training courses that can be taken by part 61 pilot certificate holders instead of an initial or recurrent knowledge test.

vii. Crew Resource Management
The NPRM proposed to include crew resource management as an area of knowledge to be tested on the initial and recurrent knowledge tests to ensure that an applicant for a remote pilot certificate knows how to function in a team environment, such as when visual observers are used to assist a remote pilot. In those circumstances, the remote pilot would be in charge of those observers and therefore need an understanding of crew resource management.

Several commenters, including the Small UAV Coalition, Princeton University, and the Electronic Frontier Foundation, argued that crew resource management may not be relevant for all small UAS operations and, as such, should be removed from the knowledge test. Princeton University added that crew resource management would be an irrelevant area of knowledge for student operators who will be operating the aircraft at a low altitude, for a limited distance, on university property, and under the direct supervision of a faculty member. Electronic Frontier Foundation stated that this area of knowledge is irrelevant for micro UAS operations.

One commenter suggested removal of crew resource management stating it is “overkill” and is really just referring to possible communications between the pilot and the visual observer. If kept, the commenter suggested modifying it to “Crew resource management as it may pertain to operation of a small unmanned aircraft system.” The FAA acknowledges that not all small UAS operations will utilize a visual observer or more than one manipulator of the controls of the small unmanned aircraft. However, the FAA anticipates that many remote pilots operating under part 107 will likely use a visual observer or oversee other individuals that may manipulate the controls of the small unmanned aircraft. In order to allow flexibility for certificated remote pilots to determine whether or not to use a visual observer or oversee other individuals manipulating the controls of the small unmanned aircraft, the FAA must ensure that an applicant for a remote pilot certificate is able to function in a team environment and maximize team performance. This includes situational awareness, proper allocation of tasks to individuals, avoidance of work overloads in self and in others, and effectively communicating with other members of the crew such as visual observers and individuals manipulating the controls of a small UAS.

The scenario Princeton University provided in its comment is precisely the type of scenario that would require a certificated remote pilot in command to have an understanding of crew resource management. The remote pilot in command in Princeton University’s scenario would be supervising a student who is manipulating the controls of the small unmanned aircraft. Therefore, the remote pilot in command in that scenario would need to know how to effectively communicate and guide his or her crew (the student). In response to Electronic Frontier Foundation, the FAA notes that even remote pilots operating smaller UAS may choose to use a visual observer or supervise other manipulators of the controls.

It is not necessary to change the title of this area of knowledge because crew resource management correctly captures what this area of knowledge will cover. The FAA also notes that this rule will include crew resource management as an area of knowledge on the initial and recurrent training courses available to part 61 pilot certificate holders because this is a UAS-specific area of knowledge.

viii. Determining the Performance of the Small Unmanned Aircraft
The NPRM proposed to include an area of knowledge on the initial aeronautical knowledge test to ensure that an applicant knows how to determine the performance of the small unmanned aircraft. Aviation Management suggested that this area of knowledge be excluded from the initial knowledge test because, the commenter argued, this knowledge is unnecessary for all small UAS operations.

The FAA will retain determining the performance of the small unmanned aircraft as an area of knowledge on the initial knowledge test. As discussed in section III.E.6.a.i of this preamble, the remote pilot in command will be required to conduct a preflight assessment of the area of operation and ensure that the small unmanned aircraft will pose no undue hazard to other aircraft, people, or property if there is a loss of positive control. In order to be able to do that, the remote pilot in command will need to be able to assess how a small unmanned aircraft will perform in a given operating environment. This area of knowledge will determine whether an applicant for a remote pilot certificate has acquired the knowledge necessary to conduct this assessment.

This rule will also include this area of knowledge on the initial training course that can be taken by part 61 pilot certificate holders instead of an initial knowledge test because it is a UAS-specific area of knowledge.

ix. Physiological Effects Of Drugs and Alcohol
The NPRM proposed to include the physiological effects of drugs and alcohol as an area of knowledge covered by the initial knowledge test. The Electronic Frontier Foundation argued that knowledge of the effects of drugs and alcohol is irrelevant for micro UAS operations and should not be tested for pilots of a micro UAS. The FAA disagrees. As explained in the NPRM, there are many prescription and over-the-counter medications that can significantly reduce an individual’s cognitive ability to process and react to events that are happening around him or her. This can lead to impaired decision-making, which could adversely affect the safety of any small UAS operation. Accordingly, the initial aeronautical knowledge test will include an area of knowledge to determine whether the applicant understands how drugs and alcohol can impact his or her ability to safely operate a small UAS.

x. Aeronautical Decision-Making and Judgment
The NPRM proposed to include aeronautical decision-making and judgment as an area of knowledge tested on the initial and recurrent knowledge tests. Aviation Management suggested that this area of knowledge be excluded from the knowledge tests because this knowledge is unnecessary for all small UAS operations.

The FAA disagrees. As discussed in the NPRM, even though small unmanned aircraft will be limited to a relatively low altitude by the provisions of this rule, they will still share the airspace with some manned-aircraft operations. To safely share the airspace, a remote pilot in command will need to understand the aeronautical decision-making and judgment that manned aircraft pilots engage in so that he or she can anticipate how a manned aircraft will react to the small unmanned aircraft. Accordingly, this rule will retain aeronautical decision-making and judgment as an area of knowledge covered on the initial and recurrent knowledge tests.

xi. Airport Operations
Noting that some small UAS operations could be conducted near an airport, the NPRM proposed to include airport operations as an area of knowledge tested on the initial and recurrent knowledge tests.

Several commenters, including the Small UAV Coalition, Princeton University, and Predessa, argued that airport operations may not be relevant to all small UAS operations, and as such, should be removed from the knowledge tests. The Electronic Frontier Foundation argued that this area of knowledge is “clearly irrelevant” for micro UAS flights conducted far away from airports.

There are over 5,000 public use airports in the United States. As such, the FAA expects that a number of small UAS operations may take place near an airport. The FAA also expects that there could be instances where a small unmanned aircraft unexpectedly ends up flying near an airport due to adverse conditions, such as unexpectedly strong winds that carry the aircraft toward the airport. In those instances, the remote pilot in command will need to have an understanding of airport operations so that he or she knows what actions to take to ensure that the small unmanned aircraft does not interfere with airport operations or traffic patterns. Accordingly, this rule will retain airport operations as an area of knowledge tested on the initial and recurrent knowledge tests.

xii. Radio Communication Procedures
Finally, the NPRM proposed to include radio communication procedures as an area of knowledge covered on the initial aeronautical knowledge test.

Several commenters, including Princeton University, Predesa, and Aviation Management, argued that radio communications may not be relevant for all small UAS operations and as such, should be removed from the knowledge test. Predesa suggested that the FAA design a new “Class G-only unmanned aircraft operator certificate with a small UAS rating” that, among other things, does not include radio communication procedures as an area of knowledge that is tested on the knowledge test. One commenter recommended removal of “radio communication procedures” because there is no requirement for radio communications of any sort with small UAS operations.

As discussed earlier, the FAA expects that a number of small UAS operations will take place near an airport. That is why § 107.43 prohibits a small unmanned aircraft from interfering with airport operations or traffic patterns. Understanding radio communication procedures will assist a remote pilot in command operating near a Class G airport in complying with this requirement. Understanding radio communication procedures will assist a remote pilot in command operating near a Class G airport in complying with this requirement if that pilot chooses to use a radio to aid in his or her situational awareness of manned aircraft operating nearby. As described in section 4-1-9 of the Aeronautical Information Manual, manned-aircraft pilots may broadcast their position or intended flight activity or ground operation on the designated Common Traffic Advisory Frequency (CTAF). This procedure is used primarily at airports that do not have an airport traffic control tower, or have a control tower that is not in operation. Pilots of radio-equipped aircraft use standard phraseology to announce their identification, location, altitude, and intended course of action. Self-announcing for arriving aircraft generally begins within 10 nautical miles of the airport and continues until the aircraft is clear of runways and taxiways. Aircraft on the ground intending to depart will begin to make position reports prior to entry of the runway or taxiway and continue until departing the traffic pattern. Aircraft remaining in the pattern make position reports on each leg of the traffic pattern. Thus, knowledge of radio communication procedures will provide a remote pilot in command with the ability to utilize a valuable resource, CTAF, to help determine the position of nearby manned aircraft. As such, this rule will retain this area of knowledge on the initial aeronautical knowledge test.

xiii. Other Areas of Knowledge Suggested by The Commenters
The NPRM invited comment on whether additional areas of knowledge should be tested on the initial and recurrent knowledge tests. In response, the FAA received comments listing additional areas of knowledge that commenters would like to see on the knowledge tests. For the reasons discussed below, the FAA will add a section on maintenance and inspection to the initial and recurrent knowledge tests and the online training courses. The FAA will not add any other areas of knowledge to the knowledge tests or training courses.

The National Transportation Safety Board (NTSB) suggested that the test content should include awareness of lost-link failsafe procedures, operator development, use of maintenance and inspection steps and guides, and the characteristics and proper handling of lithium batteries. The NTSB referred to an April 2006 accident involving a U.S. Customs and Border Protection unmanned aircraft and encouraged the FAA to review its recommendations and supporting information stemming from that accident for potential lessons learned when developing guidance material and specific content for the written knowledge tests outlined in proposed part 107.

The FAA notes that topics associated with lost-link failsafe procedures will be covered by the area of knowledge testing an applicant’s understanding of the applicable small UAS regulations. With regard to maintenance and inspection, the FAA has taken action by adding maintenance and inspection knowledge test topic area requirements to the initial and recurrent knowledge tests. The addition of maintenance and inspection knowledge test topics will consist of small UAS basic maintenance and inspection knowledge that is common to all small UAS regardless of complexity. An understanding of maintenance and inspection issues will ensure that remote pilots are familiar with how to identify when a small unmanned aircraft is not safe to operate, and how to maintain a small
unmanned aircraft to mitigate the possibility of aircraft failure during flight. Although this area of knowledge will not cover every possible inspection and maintenance method, it will
provide a baseline of knowledge that will be useful to all small UAS remote pilots. The FAA disagrees with NTSB’s recommendation that the knowledge test include a topic on the characteristics and proper handling of lithium batteries. Under § 107.36, small  UAS are prohibited from carriage of hazardous materials. When installed in the aircraft for use as a power source (as opposed to carriage of spares or cargo), lithium batteries are not considered hazardous material.

NOAA suggested that the knowledge test include questions relating to protecting and operating in the context of wildlife. The Ventura Audubon Society also suggested that the FAA test an applicant’s understanding of Federal and State wildlife protection laws. The FAA is required by statute to issue an airman certificate to an individual when the Administrator finds that the individual is qualified and physically able to safely perform the duties authorized by the certificate. See 49 U.S.C. 44703(a) (stating that the Administrator “shall issue” an airman certificate to an individual who is qualified and physically capable). Therefore, the FAA cannot deny or delay the issuance of an airman certificate if an applicant has demonstrated that he or she is qualified and physically able to safely perform the duties authorized by the certificate. In this case, a remote pilot certificate with small UAS rating authorizes the holder to operate a small UAS safely in the NAS. Thus, under § 44703(a), the FAA is required to issue an airman certificate to an individual who has demonstrated an ability to safely operate a small UAS, and may not require that individual to also demonstrate an understanding of Federal and State wildlife protection laws.

The FAA emphasizes, however, that a small UAS operation may be subject to other legal requirements independently of this rule. A remote pilot in command is responsible for complying with all of his or her legal obligations and should thus have a proper understanding of wildlife protection laws in order to comply with the pertinent statutes and regulations.

Drone User Group Network suggested the following topics for the knowledge test: the concepts of lift, weight, thrust and drag, Bernoulli’s principle, weight and balance, weather, situational awareness, safety in preflight, in flight and post flight, battery theory, radio frequency theory, electrical theory, understanding flight modes, fail-safes, and aircraft types and limitations

The FAA notes that weight and balance, weather, and preflight requirements will be tested under § 107.73. The FAA agrees with the commenter that technical topics such as principles of flight, aerodynamics, and electrical theory may enhance the knowledge and technical understanding of the remote pilot. However, these topics are not critical subject areas for safe operation of small UAS. The FAA includes many of these topics in the curriculum of part 61 knowledge testing because they are critical knowledge areas for persons operating an aircraft with passengers over populated areas that may need to respond to an emergency resulting from engine failure, unexpected weather, or onboard fire. Conversely, small UAS operations take place in a contained area in a light-weight aircraft that has no people onboard, so these topics are not applicable to the same extent as they are to a manned-aircraft operation. However, the remote pilot in command should familiarize him or herself with all of the necessary information to be able to fly the unmanned aircraft without causing damage to the aircraft.

Southwest Airlines Pilots’ Association encouraged the FAA to require that operators be knowledgeable about Safety Management Systems (SMS) and the Aviation Safety Reporting System (ASRS), which could be used to collect data to support a risk managed growth of the industry and the integration into the NAS. The FAA disagrees that SMS and ASRS systems should be covered on the knowledge tests. Participation in a formal SMS program is currently required only for part 121 operations, which are the largest and most complex manned-aircraft operations regulated by the FAA. Requiring small UAS to participate in this program would not be justified considering the fact that the FAA does not require non-part-121 manned-aircraft operations to have an SMS. Similarly, the FAA will not require testing on ASRS knowledge because ASRS is not currently required knowledge for part 61 pilot certificate holders.

k. Administration of the Knowledge Tests and Training Courses
This section discusses how the initial and recurrent knowledge tests and online training courses will be administered under this rule. Specifically, this section addresses: (1) the location at which a knowledge test can be taken; (2) the prohibition on cheating and engaging in unauthorized conduct during a knowledge test; (3) the identification of the test taker; and (4) retesting after failing a knowledge test.

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Section 107.71 Retesting after failure.

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Section 107.71 Retesting after failure.

An applicant for a knowledge test who fails that test may not reapply for the test for 14 calendar days after failing the test.

My Commentary on Section 107.71 Retesting after failure.

So on top of this regulation forcing you to wait 14 days, you have to pay another $150 to take the test again.

Advisory Circular 107-2 on Section 107.71 Retesting after failure.

None

FAA’s Discussion on Section 107.71 Retesting after failure from the Final Small Unmanned Aircraft Rule

The NPRM noted that some applicants may fail the initial aeronautical knowledge test the first time that they take it. To ensure that those applicants take the time to do additional studying and/or training (rather than simply take the test over and over again), the NPRM proposed to require that a person who fails the aeronautical knowledge test must wait 14 calendar days before retaking it. For the reasons discussed below, this rule will finalize this provision as proposed in the NPRM. 14 CFR 107.71.

One commenter suggested that an applicant who fails the knowledge test should be required to receive additional training in the area(s) of deficiency and receive an endorsement from a flight instructor in order to retake the test. The commenter rationalized that this would be consistent with current policy for pilot applicants with regards to failure and retesting, and will enhance safety by ensuring some level of oversight in the training process.

A person who fails the aeronautical knowledge test will receive a knowledge test report pointing out the areas of knowledge on which he or she did not test well. That person will then have 14 days to conduct additional study or training in those areas of knowledge prior to retaking the knowledge test. Specifying a prescriptive method of study is not necessary in this rule. Instead, the applicant will be incentivized to select the method of study that works best for him or her.

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Section 107.69 Knowledge tests: Cheating or other unauthorized conduct.

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Section 107.69 Knowledge tests: Cheating or other unauthorized conduct.

(a) An applicant for a knowledge test may not:

(1) Copy or intentionally remove any knowledge test;

(2) Give to another applicant or receive from another applicant any part or copy of a knowledge test;

(3) Give or receive assistance on a knowledge test during the period that test is being given;

(4) Take any part of a knowledge test on behalf of another person;

(5) Be represented by, or represent, another person for a knowledge test;

(6) Use any material or aid during the period that the test is being given, unless specifically authorized to do so by the Administrator; and

(7) Intentionally cause, assist, or participate in any act prohibited by this paragraph.

(b) An applicant who the Administrator finds has committed an act prohibited by paragraph (a) of this section is prohibited, for 1 year after the date of committing that act, from:

(1) Applying for any certificate, rating, or authorization issued under this chapter; and

(2) Applying for and taking any test under this chapter.

(c) Any certificate or rating held by an applicant may be suspended or revoked if the Administrator finds that person has committed an act prohibited by paragraph (a) of this section.

My Commentary on Section 107.69 Knowledge tests: Cheating or other unauthorized conduct.

Seriously, don’t mess around with cheating. This is really bad because it spills over onto all certificates, ratings, or authorizations issued under the chapter. This means manned, and unmanned, certificates, Airspace authorizations, etc. On top of that, if you are manned aircraft pilot, you could have your certificate revoked.

Advisory Circular 107-2 on Section 107.69 Knowledge tests: Cheating or other unauthorized conduct.

None

FAA’s Discussion on Section 107.69 Knowledge tests: Cheating or other unauthorized conduct from the Final Small Unmanned Aircraft Rule

To ensure that the aeronautical knowledge test is properly administered, the NPRM proposed to prohibit an applicant from cheating or engaging in other unauthorized conduct during the knowledge test. This would include: (1) copying or intentionally removing a knowledge test; (2) giving a copy of a knowledge test to another applicant or receiving a copy of the knowledge test from another applicant; (3) giving or receiving unauthorized assistance while the knowledge test is being administered; (4) taking any part of a knowledge test on behalf of another person; (5) being represented by or representing another person for a knowledge test; and (6) using any material not specifically authorized by the FAA while taking a knowledge test. Cheating or engaging in unauthorized conduct during a knowledge test would be grounds for suspending or revoking the certificate or denying an application for a certificate. In addition, a person who engages in unauthorized conduct would be prohibited from applying for a certificate or taking a knowledge test for a period of one year after the date of the unauthorized conduct.

The FAA did not receive any adverse comments on this component of the proposed rule. Accordingly, this rule will finalize the cheating or engaging-in-unauthorized-conduct provisions of the NPRM as proposed. 14 CFR 107.69

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Section 107.67 Knowledge tests: General procedures and passing grades.

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Section 107.67 Knowledge tests: General procedures and passing grades.

(a) Knowledge tests prescribed by or under this part are given by persons and in the manner designated by the Administrator.

(b) An applicant for a knowledge test must have proper identification at the time of application that contains the applicant’s:

(1) Photograph;

(2) Signature;

(3) Date of birth, which shows the applicant meets or will meet the age requirements of this part for the certificate and rating sought before the expiration date of the airman knowledge test report; and

(4) Permanent mailing address. If the applicant’s permanent mailing address is a post office box number, then the applicant must also provide a current residential address.

(c) The minimum passing grade for the knowledge test will be specified by the Administrator.

My Commentary on Section 107.67 Knowledge tests: General procedures and passing grades.

Pay attention that you have to be 16 to have a remote pilot certificate but a minimum of 14 to TAKE the remote pilot knowledge exam.

Advisory Circular 107-2 on Section 107.67 Knowledge tests: General procedures and passing grades.

KTCs will administer initial and recurrent examinations provided by the FAA. In order to take an aeronautical knowledge test, an applicant will be required to schedule an appointment with the KTC providing proper government-issued photo identification to the KTC on the day of scheduled testing. The location of the closest KTC can be found at http://www.faa.gov/training_testing/testing/media/test_centers.pdf.

FAA’s Discussion on Section 107.67 Knowledge tests: General procedures and passing grades from the Final Small Unmanned Aircraft Rule

The NPRM proposed to ensure that an applicant who is about to take the knowledge test is properly identified by requiring the applicant to present identification to the knowledge testing center prior to taking the knowledge test. This identification would have to include the applicant’s: (1) photograph; (2) signature; (3) date of birth, which shows the applicant meets or will meet the age requirement for a remote pilot certificate; and (4) the applicant’s current residential address. For the reasons discussed below, this rule will finalize this aspect of the NPRM as proposed.

An individual commenter questioned an apparent contradiction in the NPRM, which would allow knowledge testing centers to verify an applicant’s identification for the purposes of administering a knowledge test but would prohibit knowledge testing centers from verifying identification for the purposes of submitting an airman application. The commenter added that if the goal of this rule is to achieve the least burdensome process, then knowledge testing centers should be permitted to verify a person’s identification for both testing and application submission to the FAA.

The FAA acknowledges the positive identification conducted by the knowledge testing centers, and has determined that there is no need to repeatedly identify a person who has already been positively identified for the purposes of taking the knowledge test. Accordingly, as discussed later in section III.F.l, this rule will allow an applicant to submit his or her remote pilot application without having to be positively identified a second time.

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Section 107.64 Temporary certificate.

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Section 107.64 Temporary certificate.

(a) A temporary remote pilot certificate with a small UAS rating is issued for up to 120 calendar days, at which time a permanent certificate will be issued to a person whom the Administrator finds qualified under this part.

(b) A temporary remote pilot certificate with a small UAS rating expires:

(1) On the expiration date shown on the certificate;

(2) Upon receipt of the permanent certificate; or

(3) Upon receipt of a notice that the certificate sought is denied or revoked.

My Commentary on Section 107.64 Temporary certificate.

If you want to obtain a temporary certificate immediately, the Part 61 certificated pilot with a flight review should go to an FAA aviation safety inspector, a designated pilot examiner, or an airmen certification representative who has the ability to receiving the 8710-13 form and ALSO issue a temporary certificate right there.

Advisory Circular 107-2 on Section 107.64 Temporary certificate.

When the applicant uses this online option, the application will be transmitted electronically from the applicant to the Airman Registry. The only electronic signature that will be reflected on the IACRA application will be the applicant’s. The applicant will then receive a confirmation email once his or her application has completed the Transportation Security Administration (TSA) vetting process. The email will provide information that will allow the applicant to log into the IACRA system and print a copy of the temporary certificate.

………………

A CFI is not authorized to issue a temporary certificate. They can process applications for applicants who do not need a temporary certificate. If using IACRA and the applicant is utilizing a CFI as the FAA representative, the applicant can print their own temporary airman certificate after receiving an email from the FAA notifying them that it is available. If using the paper method and the applicant is utilizing a CFI as the FAA representative, the applicant will not be issued a temporary airman certificate. Once the FSDO has signed and approved the application, it will be mailed to the Registry for the issuance of the permanent certificate.

FAA’s Discussion on Section 107.64 Temporary certificate from the Final Small Unmanned Aircraft Rule

Several commenters, including the Electronic Frontier Foundation, Washington Aviation Group, and Event 38 Unmanned Systems, opposed the requirement for small UAS operator applicants to undergo a TSA background check prior to receiving their operator certificate. Many of these commenters pointed out that it is highly unlikely that an individual who poses a threat to national security would seek to obtain an airman certificate and go through the TSA vetting process.

Several commenters argued that pre-screening applicants is extremely burdensome for entrepreneurs and small businesses, and creates a barrier to market entry. Some commenters argued that 49 U.S.C. 46111 does not require the FAA to wait until hearing back from TSA prior to granting the certificate, or that it does not confer the authority to pre-screen applicants for an airmen certificate. One commenter suggested that the knowledge testing centers be able to issue temporary certificates upon passing the knowledge test, which could be revoked if the TSA vetting process indicated that the individual should not be issued a remote pilot certificate.

As discussed previously, 49 U.S.C. 44903(j)(2)(D)(i) is unambiguous and states that the vetting must be completed before the FAA may issue an airman certificate. Given the relatively short time the vetting takes for the overwhelming majority of applicants, it is difficult to identify a burden that is not outweighed by the clear benefit of ensuring that certificate holders do not pose a threat to national or transportation security. Section 44903(j)(2)(D)(i) explicitly states that TSA screening of an individual must take place “before” that individual is certificated by the FAA.

In addition, 49 U.S.C. 44903(j)(2)(D) and 46111 vest the authority for vetting with TSA. Specifically, section 46111(a) states that “[t]he Administrator of Federal Aviation Administration shall issue an order amending, modifying, suspending, or revoking any part of a certificate issued under this title if the Administrator is notified by the Under Secretary for Border and Transportation Security of the Department of Homeland Security that the holder of the certificate poses, or is suspected of posing, a risk of air piracy or terrorism or a threat to airline or passenger safety.” (Emphasis added). Thus, under § 46111, the FAA’s role in the vetting process is ministerial; the FAA acts on findings that have been made by the TSA, but it is TSA that makes the actual security determinations. Because the authority for making the pertinent security determination is vested with TSA, the Department does not have jurisdiction to alter the criteria and requirements of that determination in the manner suggested by the commenters.

The FAA acknowledges, however, the commenters’ concern regarding the estimated 6-to-8-week timeframe associated with processing the certificate application. In response, this rule will allow an applicant who already holds a part 61 pilot certificate to obtain a temporary remote pilot certificate immediately upon FAA receipt of his or her application. The FAA is able to issue a temporary remote pilot certificate to part 61 pilot certificate holders prior to completion of new security vetting because these individuals have already been successfully completed the TSA vetting when they obtained their part 61 pilot certificates.

The FAA will also issue a temporary electronic remote pilot certificate to all other applicants who apply through IACRA upon successful completion of TSA security vetting. The FAA anticipates that, while it may take the FAA 6 to 8 weeks to issue a permanent remote pilot certificate, a temporary remote pilot certificate can be issued in about 10 business days. The temporary remote pilot certificate will allow the certificate holder to exercise all the privileges of the certificate, thus significantly reducing the waiting period prior to being able to operate as a remote pilot in command under part 107.

Just like a temporary pilot certificate issued under part 61, a temporary remote pilot certificate with a small UAS rating will be valid for 120 days after issuance. This will provide sufficient time for the FAA to complete its processing of the certificate application and issue the applicant a permanent remote pilot certificate. The temporary certificate will automatically expire once the applicant receives a permanent remote pilot certificate with a small UAS rating. The temporary certificate will also expire if the FAA discovers an issue with the certificate application and issues the applicant a notice that his or her certificate application is denied or the certificate (if one has already been issued) is revoked.

The FAA defers to TSA on whether current part 61 pilot certificate holders will have to continue to undergo the vetting process in order to receive a non-temporary remote pilot certificate with a small UAS rating. The FAA also notes that applicants who have passed STAs for other federal programs, received background checks, or hold U.S. passports will still need to satisfy TSA’s STA specific to the statute that requires security vetting prior to issuance of an airmen’s certificate (49 USC 44903). The FAA does not have jurisdiction to accept alternative documentation instead of a TSA security finding because, as discussed earlier, 49 U.S.C. 44903(j)(2)(D) and 46111 vest the pertinent jurisdiction in the TSA. In response to DJI, the FAA notes that a complete TSA vetting process is an integral part of the requirements of this rule because it reduces the risk of a person who poses a security threat obtaining an airman certificate under part 107.

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Section 107.63 Issuance of a remote pilot certificate with a small UAS rating.

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Section 107.63 Issuance of a remote pilot certificate with a small UAS rating.

An applicant for a remote pilot certificate with a small UAS rating under this subpart must make the application in a form and manner acceptable to the Administrator.

(a) The application must include either:

(1) Evidence showing that the applicant passed an initial aeronautical knowledge test. If applying using a paper application, this evidence must be an airman knowledge test report showing passage of the knowledge test; or

(2) If a person holds a pilot certificate (other than a student pilot certificate) issued under part 61 of this chapter and meets the flight review requirements specified in §61.56, a certificate of completion of a part 107 initial training course.

(b) If the application is being made pursuant to paragraph (a)(2) of this section:

(1) The application must be submitted to the responsible Flight Standards office, a designated pilot examiner, an airman certification representative for a pilot school, a certificated flight instructor, or other person authorized by the Administrator;

(2) The person accepting the application submission must verify the identity of the applicant in a manner acceptable to the Administrator; and

(3) The person making the application must, by logbook endorsement or other manner acceptable to the Administrator, show the applicant meets the flight review requirements specified in §61.56 of this chapter.

My Commentary on Section 107.63 Issuance of a remote pilot certificate with a small UAS rating.

If you want to obtain a temporary certificate immediately, the Part 61 certificated pilot with a flight review should go to an FAA aviation safety inspector, a designated pilot examiner, or an airmen certification representative who has the ability to receiving the 8710 form and ALSO issue a temporary certificate right there.

On an interesting side note, the FAA updated this regulation on March 5, 2018 by a direct rule making which is AFTER it went into effect on August 29, 2016. The FAA has the ability to do updates to regulations when they are slight editorial changes no one will care about.

The FAA’s update said:

64.The authority citation for part 107 continues to read as follows:

Authority: 49 U.S.C. 106(f), 40101 note, 40103(b), 44701(a)(5); Sec. 333 of Pub. L. 112-95, 126 Stat. 75.

[Amended]

65.In § 107.63(b)(1), remove the words “a Flight Standards District Office” and add, in their place, the words “the responsible Flight Standards office”.

See what I mean when it is slight editorial changes no one cares about? The FAA occasionally does this.

Advisory Circular 107-2 on Section 107.63 Issuance of a remote pilot certificate with a small UAS rating.

Applicants with Part 61 Certificates. Instead of the process described above, a person who holds a part 61 pilot certificate, except a student pilot certificate, and has completed a flight review within the previous 24 calendar-months may elect to apply using the following process:

1. Complete the online course (Part 107 small Unmanned Aircraft Systems (sUAS), ALC-451) located within the FAA Safety Team (FAASTeam) Web site (www.faasafety.gov) and receive a completion certificate.
2. Complete the Remote Pilot Certificate and/or Rating Application for a remote pilot certificate (FAA Form 8710-13).

• Option 1 (Online Application): In almost all cases, the application should be completed online using the electronic FAA IACRA system (https://iacra.faa.gov/iacra/). The applicant must include verification that he or she completed the online course or passed an initial aeronautical knowledge test. The applicable official document(s) must be uploaded into IACRA either by the applicant or the certifying officer.
• Option 2 (Paper): The application may be completed on paper. Using this method, the certificate of completion for the online course or original initial aeronautical knowledge test report must be included with the application. Please note that the processing time will be increased if a paper application is used.

3. Contact a FSDO, an FAA DPE, an ACR, or an FAA CFI to make an appointment to validate the applicant’s identification. The applicant must present the completed FAA Form 8710-13 along with the online course completion certificate or knowledge test report (as applicable) and proof of a current flight review. The FAA Form 8710-13 application will be signed by the applicant after the FSDO, DPE, ACR, or CFI examines the applicant’s photo identification and verifies the applicant’s identity. The FAA representative will then sign the application. The identification presented must include a photograph of the applicant, the applicant’s signature, and the applicant’s actual residential address (if different from the mailing address). This information may be presented in more than one form of identification. Acceptable methods of identification include, but are not limited to U.S. drivers’ licenses, government identification cards, passports, and military identification cards (refer to AC 61-65). If using paper or IACRA method, an appropriate FSDO representative, a DPE, or an ACR will issue the applicant a temporary airman certificate.

Note: A CFI is not authorized to issue a temporary certificate. They can process applications for applicants who do not need a temporary certificate. If using IACRA and the applicant is utilizing a CFI as the FAA representative, the applicant can print their own temporary airman certificate after receiving an email from the FAA notifying them that it is available. If using the paper method and the applicant is utilizing a CFI as the FAA representative, the applicant will not be issued a temporary airman certificate. Once the FSDO has signed and approved the application, it will be mailed to the Registry for the issuance of the permanent certificate.

4. Receive permanent remote pilot certificate once all other FAA internal processing is complete.

FAA’s Discussion on Section 107.63 Issuance of a remote pilot certificate with a small UAS rating from the Final Small Unmanned Aircraft Rule

The NPRM proposed establishing eligibility requirements for a part 107 airman certificate and specifying when a certificate would be issued. The NPRM proposed that an applicant must be: (1) at least 17 years of age; (2) able to read, speak, write and understand the English language; and (3) vetted by the Transportation Security Administration. Additionally, the NPRM proposed that the applicant must pass an initial aeronautical knowledge test and self-certify, at the time of application, that he or she does not have a medical condition that could interfere with the safe operation of a small UAS. As discussed in more detail below, the process for issuance of a remote pilot certificate will be as follows. First, an applicant will have to take and pass an initial aeronautical knowledge test. After taking the knowledge test, the applicant will be provided with an airman knowledge test report showing his or her test results. If the applicant passed the test, the applicant will then fill out an application for a remote pilot certificate using either the FAA’s electronic application process (referred to as the Integrated Airman Certification and Rating Application (IACRA) system) or a paper application. The FAA will then forward the applicant’s information to the TSA for security vetting to determine whether the applicant poses a security risk. Once TSA notifies the FAA that the applicant does not pose a security risk the FAA will issue an electronic temporary remote pilot certificate to an applicant who applied through the IACRA system.128 This temporary certificate (valid for 120 days after receipt) will be issued within 10 business days after receipt of an electronic application, and it will allow the applicant to exercise all the privileges of a remote pilot certificate with a small UAS rating. Once all other FAA internal processing is complete, the FAA will issue the applicant a permanent remote pilot certificate.

Holders of a part 61 pilot certificate other than student pilot who have completed a flight review within the previous 24 months will have the option of a different certification process. These pilot certificate holders will be allowed to substitute completion of an online training course for the small UAS aeronautical knowledge test. Upon completion of the training course, the part 61 pilot certificate holder will then go to one of the following authorized portals: an FAA Flight Standards District Office (FSDO), a designated pilot examiner (DPE), an airman certification representative (ACR) for a pilot school, or a certificated flight instructor (CFI). The certificate holder will provide his or her remote pilot certificate application and supporting documentation to that portal to verify the applicant’s identity, fill out the pertinent portion of the application, and then forward the completed application to the FAA Airman Certification Registry. Because a part 61 pilot certificate holder has already been vetted by TSA, he or she will be issued a temporary remote pilot certificate with a small UAS rating, valid for 120 days, immediately upon the FAA’s receipt of the completed application via IACRA. Once all other processing is complete, the FAA will issue a permanent remote pilot certificate.

The FAA emphasizes that part 61 pilot certificate holders are not required to use the process discussed in the previous paragraph and can instead apply for a remote pilot certificate by taking the small UAS initial aeronautical knowledge test. Part 61 pilot certificate holders who pass the knowledge test will not be required to submit their application to a FSDO, DPE, ACR, or CFI. Instead these certificate holders may submit their applications via IACRA. Because these certificate holders have already been vetted by TSA, they will be issued a temporary remote pilot certificate, valid for 120 days, upon FAA’s receipt of their application via IACRA regardless of the method they use to qualify for the certificate (i.e. knowledge test or online training course).

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Section 107.61 Eligibility

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Section 107.61 Eligibility.

Subject to the provisions of §§107.57 and 107.59, in order to be eligible for a remote pilot certificate with a small UAS rating under this subpart, a person must:

(a) Be at least 16 years of age;

(b) Be able to read, speak, write, and understand the English language. If the applicant is unable to meet one of these requirements due to medical reasons, the FAA may place such operating limitations on that applicant’s certificate as are necessary for the safe operation of the small unmanned aircraft;

(c) Not know or have reason to know that he or she has a physical or mental condition that would interfere with the safe operation of a small unmanned aircraft system; and

(d) Demonstrate aeronautical knowledge by satisfying one of the following conditions:

(1) Pass an initial aeronautical knowledge test covering the areas of knowledge specified in §107.73(a); or

(2) If a person holds a pilot certificate (other than a student pilot certificate) issued under part 61 of this chapter and meets the flight review requirements specified in §61.56, complete an initial training course covering the areas of knowledge specified in §107.74(a) in a manner acceptable to the Administrator.

Advisory Circular 107-2 on Section 107.61 Eligibility.

Eligibility. A person applying for a remote pilot certificate with an sUAS rating must meet and maintain the following eligibility requirements, as applicable:

• Be at least 16 years of age.
• Be able to read, speak, write, and understand the English language. However, the FAA may make an exception if the person is unable to meet one of these requirements due to medical reasons, such as a hearing impairment.
• Be in a physical and mental condition that would not interfere with the safe operation of an sUAS.
• Pass the initial aeronautical knowledge test at an FAA-approved knowledge testing center (KTC). However, a person who already holds a pilot certificate issued under 14 CFR part 61, except a student pilot certificate, and has successfully completed a flight review in accordance with part 61 within the previous 24 calendar-months is only required to successfully complete a part 107 online training course, found at www.faasafety.gov. For more information concerning aeronautical knowledge tests and training, see paragraph 6.6.

Application Process. This paragraph provides guidance on how a person can apply for a remote pilot certificate.

6.4.1 Applicants Without Part 61 Certificates. A person who does not have a part 61 pilot certificate or a part 61 certificate holder who has not completed a part 61 flight review in the previous 24 calendar-months must use the following process. A part 61 pilot who has completed a flight review within the previous 24 calendar-months may elect to use this process.
1. Pass an initial aeronautical knowledge test administered at a KTC (see paragraph 6.6).
2. Complete the Remote Pilot Certificate and/or Rating Application for a remote pilot certificate (FAA Form 8710-13).

• Option 1 (Online Form): This is the fastest and simplest method. The FAA Form 8710-13 application should be completed online using the electronic FAA Integrated Airmen Certificate and/or Rating Application (IACRA) system (https://iacra.faa.gov/iacra/). The applicant must have already passed an initial aeronautical knowledge test. Once registered with IACRA, he or she will login with their username and password. Click on “Start New Application” and,

1) Application Type “Pilot”, 2) Certifications “Remote Pilot,” 3) “Other Path Information,” and 4) “Start Application.” Continue through the application process and, when prompted, the applicant will enter the 17-digit Knowledge Test Exam ID from the knowledge test in IACRA. It may take up to 48 hours from the test date for the knowledge test to appear in IACRA. The KTC test proctor will be the one that verified the identity of the applicant. Once the applicant completes the online application in IACRA, he or she will sign the application electronically and submit it to the Airman Registry for processing. No FAA representative will be required to sign the application if the applicant was able to self-certify.

Note: When the applicant uses this online option, the application will be transmitted electronically from the applicant to the Airman Registry. The only electronic signature that will be reflected on the IACRA application will be the applicant’s. The applicant will then receive a confirmation email once his or her application has completed the Transportation Security Administration (TSA) vetting process. The email will provide information that will allow the applicant to log into the IACRA system and print a copy of the temporary certificate.

• Option 2 (Paper Application): An applicant could also submit a paper application. If the applicant chooses the paper method, the original initial aeronautical knowledge test report must be mailed with the application to the following address:

DOT/FAA
Airmen Certification Branch (AFS-760)
P.O. Box 25082
Oklahoma City, OK 73125

Note: A temporary airman certificate will not be provided to the remote pilot applicant if they do not hold a part 61 certificate. For this reason, it would be of the applicant’s best interest to utilize Option 1 (IACRA system) instead of the paper method, in order to receive a temporary airman certificate once the application has completed the TSA vetting process.

3. Receive permanent remote pilot certificate once all other FAA internal processing is complete.

6.4.2 Applicants with Part 61 Certificates. Instead of the process described above, a person who holds a part 61 pilot certificate, except a student pilot certificate, and has completed a flight review within the previous 24 calendar-months may elect to apply using the following process:

1. Complete the online course (Part 107 small Unmanned Aircraft Systems (sUAS), ALC-451) located within the FAA Safety Team (FAASTeam) Web site (www.faasafety.gov) and receive a completion certificate.
2. Complete the Remote Pilot Certificate and/or Rating Application for a remote pilot certificate (FAA Form 8710-13).
• Option 1 (Online Application): In almost all cases, the application should be completed online using the electronic FAA IACRA system (https://iacra.faa.gov/iacra/). The applicant must include verification that he or she completed the online course or passed an initial aeronautical knowledge test. The applicable official document(s) must be uploaded into IACRA either by the applicant or the certifying officer.
• Option 2 (Paper): The application may be completed on paper. Using this method, the certificate of completion for the online course or original initial aeronautical knowledge test report must be included with the application. Please note that the processing time will be increased if a paper application is used.

3. Contact a FSDO, an FAA DPE, an ACR, or an FAA CFI to make an appointment to validate the applicant’s identification. The applicant must present the completed FAA Form 8710-13 along with the online course completion certificate or knowledge test report (as applicable) and proof of a current flight review. The FAA Form 8710-13 application will be signed by the applicant after the FSDO, DPE, ACR, or CFI examines the applicant’s photo identification and verifies the applicant’s identity. The FAA representative will then sign the application. The identification presented must include a photograph of the applicant, the applicant’s signature, and the applicant’s actual residential address (if different from the mailing address). This information may be presented in more than one form of identification. Acceptable methods of identification include, but are not limited to U.S. drivers’ licenses, government identification cards, passports, and military identification cards (refer to AC 61-65). If using paper or IACRA method, an appropriate FSDO representative, a DPE, or an ACR will issue the applicant a temporary airman certificate.

Note: A CFI is not authorized to issue a temporary certificate. They can process applications for applicants who do not need a temporary certificate. If using IACRA and the applicant is utilizing a CFI as the FAA representative, the applicant can print their own temporary airman certificate after receiving an email from the FAA notifying them that it is available. If using the paper method and the applicant is utilizing a CFI as the FAA representative, the applicant will not be issued a temporary airman certificate. Once the FSDO has signed and approved the application, it will be mailed to the Registry for the issuance of the permanent certificate.

4. Receive permanent remote pilot certificate once all other FAA internal processing is complete.

6.5 Security Disqualification. After the FAA receives the application, the TSA will automatically conduct a background security screening of the applicant prior to issuance of a remote pilot certificate. If the security screening is successful, the FAA will issue a permanent remote pilot certificate. If the security screening is not successful, the applicant will be disqualified and a temporary pilot certificate will not be issued. Individuals who believe that they improperly failed a security threat assessment may appeal the decision to the TSA.

6.6 Aeronautical Knowledge Tests (Initial and Recurrent). It is important to have and retain the knowledge necessary to operate a small UA in the NAS. This aeronautical knowledge can be obtained through self-study, taking an online training course, taking an in-person training course, or any combination thereof. The FAA has published the Small Unmanned Aircraft Systems Airman Certification Standard (https://www.faa.gov/training_testing/testing/acs/) that provides the necessary reference material.

Note: The below information regarding initial and recurrent knowledge tests apply to persons who do not hold a current part 61 airman certificate.

6.6.1 Initial Test. As described in paragraph 6.4, a person applying for remote pilot certificate with an sUAS rating must pass an initial aeronautical knowledge test given by an FAA-approved KTC. The initial knowledge test will cover the aeronautical knowledge areas listed below:
1. Applicable regulations relating to sUAS rating privileges, limitations, and flight operation;
2. Airspace classification and operating requirements, and flight restrictions affecting small UA operation;
3. Aviation weather sources and effects of weather on small UA performance;
4. Small UA loading and performance;
5. Emergency procedures;
6. Crew Resource Management (CRM);
7. Radio communication procedures;
8. Determining the performance of small UA;
9. Physiological effects of drugs and alcohol;
10. Aeronautical decision-making (ADM) and judgment;
11. Airport operations; and
12. Maintenance and preflight inspection procedures.

6.6.1.1 A part 61 certificate holder who has completed a flight review within the previous 24 calendar-months may complete an initial online training course instead of taking the knowledge test (see paragraph 6.7).

6.6.1.2 Additional information on some of the knowledge areas listed above can be found in Appendix B.

6.6.2 Recurrent Test. After a person receives a remote pilot certificate with an sUAS rating, that person must retain and periodically update the required aeronautical knowledge to continue to operate a small UA in the NAS. To continue exercising the privileges of a remote pilot certificate, the certificate holder must pass a recurrent aeronautical knowledge test within 24 calendar-months of passing either an initial or recurrent aeronautical knowledge test. A part 61 pilot certificate holder who has completed a flight review within the previous 24 calendar-months may complete a recurrent online training course instead of taking the knowledge test.

FAA’s Discussion on Section 107.61 Eligibility from the Final Small Unmanned Aircraft Rule

The NPRM proposed establishing eligibility requirements for a part 107 airman certificate and specifying when a certificate would be issued. The NPRM proposed that an applicant must be: (1) at least 17 years of age; (2) able to read, speak, write and understand the English language; and (3) vetted by the Transportation Security Administration. Additionally, the NPRM proposed that the applicant must pass an initial aeronautical knowledge test and self-certify, at the time of application, that he or she does not have a medical condition that could interfere with the safe operation of a small UAS. As discussed in more detail below, the process for issuance of a remote pilot certificate will be as follows. First, an applicant will have to take and pass an initial aeronautical knowledge test. After taking the knowledge test, the applicant will be provided with an airman knowledge test report showing his or her test results. If the applicant passed the test, the applicant will then fill out an application for a remote pilot certificate using either the FAA’s electronic application process (referred to as the Integrated Airman Certification and Rating Application (IACRA) system) or a paper application. The FAA
will then forward the applicant’s information to the TSA for security vetting to determine whether the applicant poses a security risk. Once TSA notifies the FAA that the applicant does not pose a security risk the FAA will issue an electronic temporary remote pilot certificate to an applicant who applied through the IACRA system. This temporary certificate (valid for 120 days after receipt) will be issued within 10 business days after receipt of an electronic application, and it will allow the applicant to exercise all the privileges of a remote pilot certificate with a small UAS rating. Once all other FAAinternal processing is complete, the FAA will issue the applicant a permanent remote pilot certificate.

Holders of a part 61 pilot certificate other than student pilot who have completed a flight review within the previous 24 months will have the option of a different certification process. These pilot certificate holders will be allowed to substitute completion of an online training course for the small UAS aeronautical knowledge test. Upon completion of the training course, the part 61 pilot certificate holder will then go to one of the following authorized portals: an FAA Flight Standards District Office (FSDO), a designated pilot examiner (DPE), an airman certification representative (ACR) for a pilot school, or a certificated flight instructor (CFI). The certificate holder will provide his or her remote pilot certificate application and supporting documentation to that portal to verify the applicant’s identity, fill out the pertinent portion of the application, and then forward the completed application to the FAA Airman Certification Registry. Because a part 61 pilot certificate holder has already been vetted by TSA, he or she will be issued a temporary remote pilot certificate with a small UAS rating, valid for 120 days, immediately upon the FAA’s receipt of the completed application via IACRA. Once all other processing is complete, the FAA will issue a permanent remote pilot certificate.

The FAA emphasizes that part 61 pilot certificate holders are not required to use the process discussed in the previous paragraph and can instead apply for a remote pilot certificate by taking the small UAS initial aeronautical knowledge test. Part 61 pilot certificate holders who pass the knowledge test will not be required to submit their application to a FSDO, DPE, ACR, or CFI. Instead these certificate holders may submit their applications via IACRA. Because these certificate holders have already been vetted by TSA, they will be issued a temporary remote pilot certificate, valid for 120 days, upon FAA’s receipt of their application via IACRA regardless of the method they use to qualify for the certificate (i.e. knowledge test or online training course).

a. Minimum Age
The NPRM proposed that a person must be at least 17 years of age to be eligible for a remote pilot airman certificate with a small UAS rating. This minimum age would be consistent with existing FAA minimum age requirements for the sport pilot, recreational pilot, and private pilot airman certificates with an airplane or rotorcraft rating. The FAA also invited comment on whether to adopt a minimum age of 16 years, which would be consistent with existing FAA minimum age requirements for the sport pilot and private pilot airman certificates with a glider or balloon rating. After review of the comments, the FAA adopts a minimum age of 16 for a person to be eligible for a remote pilot certificate with a small UAS rating.

Fourteen commenters, including the Small UAV Coalition, AUVSI, and NAMIC, all agreed that the proposed minimum age of 17 generally strikes an appropriate balance between safety and operational viability for low risk small UAS operations, ensuring that baseline safety is enhanced without unduly burdening low risk small UAS operators or their operations. These commenters argued that the NPRM’s proposal is consistent with the requirements for other pilot certificates and, at this time, there is a lack of data and evidence to support lowering the age to 16. The commenters added that although persons under the age of 17 are already allowed to operate model aircraft, it is unclear if there is a strong need for allowing younger remote pilots to operate non-hobby and non-recreational small UAS.

University of North Dakota’s John D. Odegard School of Aerospace Sciences added that 16-year-old student pilots are accompanied or monitored by an instructor, whereas, a small UAS operator would effectively be unmonitored. Federal Airways & Airspace also agreed with limiting the certification age to 17 years old, and pointed out that the National Institute of Mental Health has stated on their website that the rate of death by any injury of those aged 15 to 19 years old is six times higher than that for individuals aged 10 to 14 years old. Federal Airways & Airspace also mentioned that studies have shown that the human brain does not reach maturity until the early 20s, and the CDC states that those aged 16 to 19 are almost three times more likely than 20-year-olds to be in a fatal motor vehicle accident.

Several commenters recommended raising the minimum age above. Commenters including the General Aviation Manufacturers Association (GAMA), Textron Systems, and Aerius Flight, recommended an 18-year-old eligibility requirement for small UAS operators, because it aligns with existing airman certification standards for other commercial flight operations. One commenter asserted that 18 is the appropriate age for an operator certificate because it is the age at which an individual is an adult and able to enter into legally binding contracts. The Air Line Pilots Association and Transportation Trades Department, AFL-CIO said small UAS operators should hold a commercial pilot certificate, and should therefore be a minimum of 18 years old. Several commenters recommended the minimum age requirement be raised even higher, to 21 or 25 years old. Conversely, 36 commenters, including NBAA, AIA, and the Kansas Farm Bureau, argued that the minimum age should be lowered to 16. One commenter asserted that: (1) flying a manned aircraft is considerably more complex than operating a small UAS; and (2) a small UAS has no people on board who would be injured in the event of an accident. Many other individuals argued that because of all the operating constraints contemplated by the NPRM, a 16-year-old should be able to safely operate a small UAS without exposing anyone to undue risk.

Nine commenters asserted that a minimum age of 16 would also align with current requirements for glider and balloon pilots. One commenter argued that the NPRM does not provide any justification to support why the operator of a small UAS must be older than a sport pilot, recreational pilot, or private pilot airman with a glider rating,129 or a student pilot of a glider.130 NBAA stated its belief that a lesser risk exists for small UAS operations conducted within the confines of the rule when compared to glider and balloon operations conducted within controlled airspace.

One of the commenters from the Center for Information & Research on Civic Learning and Engagement (CIRCLE) argued that the minimum age should be dropped to 16. The commenter conducted research that it claimed supports the proposition that 16- year-olds have the same capacity for sophistication as 21-year-olds. Although the research is geared towards younger individuals voting in local elections, not operating aircraft, the commenter believed that it makes a general statement about the intellectual capacity of minors at the age of 16.

Prioria Robotics argued that the FAA should allow an apprenticeship-like certificate to be held by those younger than 18. Others argued that the minimum age for independent operation of a small UAS should be 16. One individual suggested that if the operator is under the age of 16, he or she should be required to be accompanied by a qualified operator who is over the age of 18.

The Washington State Department of Transportation, Aviation Division suggested that, with regard to minimum age, in many cases the maturity level difference of an operator between ages 16 and 18 may be imperceptible. This commenter suggested lowering the minimum age to 16 would rule out the likelihood of willful underage violation and provide a legal path forward for younger operators. The commenter also pointed out that in many states a driver’s permit can be obtained at age 15 and driver’s license at age 16.

The Kansas Farm Bureau also argued that the added year available for academic use, education, and experience are positives for future UAS operators. DJI similarly noted that a lower age limit could increase academic use of small UAS because more high school age students could be operators. Also, commenters argued that a high age limit would inhibit curiosity and innovation among younger people who are exploring the capabilities of UAS.

The Colorado Cattlemen’s Association did not object to the proposed minimum age requirement, but noted potential value in reducing the minimum age to 16 years old. The commenter noted that, while this approach would be a slight deviation from the current age requirement for non-commercial airman certificates, it would be consistent with the recognized lower risk associated with small UAS operations. The commenter also noted it would accommodate UAS operations for those beef producers who run family operations, many of which include older teenagers.

The FAA agrees that a certain level of maturity is required to operate any aircraft responsibly in the NAS. The FAA originally proposed a minimum age of 17 because it is consistent with existing FAA minimum age requirements for the sport pilot, recreational pilot, and private pilot airman certificates with an airplane or rotorcraft rating—the baselevel certificates authorizing pilots to operate these two categories of aircraft while not under the supervision of an instructor. However, the FAA does not use a minimum age of 17 for all part 61 pilot certificates. As noted in the NPRM and by the commenters, the proposed minimum age of 17 is not consistent with existing FAA minimum age eligibility requirements for sport and private pilot airman certificates with a glider or balloon rating. After further consideration, the FAA has determined that the risk posed by a small UAS operation is comparable to the risk posed by a glider or balloon operation. Balloon and glider operations generally take place during daytime visual meteorological conditions and are limited to a relatively confined geographical area. Balloon and glider aircraft also tend to be lighter and slower-moving aircraft, limiting the harm to people and property on the ground in the event of a mishap. Similarly, small UAS operations do not take place at night or in instrument meteorological conditions, and are operated in a limited geographical area as necessary for the remote pilot to maintain visual line of sight. Analysis of safety data for balloon and glider operations suggests that there is no significant difference in accident rates for 16-year-old pilots compared to 17- or 18-year-old pilots. Because the risk of a part 107 small UAS operation is comparable to the risk of a balloon or glider operation and because the minimum age for glider and balloon operations is 16,131 the FAA will lower the minimum age in this rule to 16 years old.

The FAA also notes that a minimum age of 16 is consistent with its current practice of allowing airmen conducting a small UAS operation under a section 333 exemption to hold a sport or private pilot certificate with a glider or balloon rating. Although the FAA does not track the age of persons operating small unmanned aircraft under section 333 exemption grants, the agency is not aware of any specific safety concerns associated with 16-year-old private pilots or sport pilots operating small UAS. The FAA notes that lowering the minimum age to 16 will also enable additional small UAS agricultural operations, such as those described by the Colorado Cattlemen’s Association.

Several commenters, including AIA, the Virginia Commonwealth University Honors Students, and the New Jersey Institute of Technology suggested that the minimum age should be no greater than 16. As noted in AIA comments, AIA and others believe that a driver’s license issued from within the U.S. should be considered as a prerequisite for a remote pilot certificate. The commenters recommended mimicking the process to obtain a driver’s license, in which a person first obtains a learner’s permit and then, following months of training and test-taking, obtains a license. This would enable 16-year-olds (depending on their State of residence) to obtain a certificate. According to the commenters, maintaining currency of the driver’s license would also imply certain motor skills, vision, and a minimal level of medical fitness to operate UAS.

Several individual commenters said the minimum age should be lowered even further to 14 years old. The commenters pointed out that 14-year-olds are capable of having certain after-school jobs, and are allowed to operate a glider or balloon as a student pilot. Event 38 Unmanned Systems said that it sees no logical reason for a minimum age requirement, and that anyone who can pass the operator test should be allowed to fly a UAS. Two other commenters also said there should be no minimum age requirement.

The FAA disagrees with commenters who suggest that the minimum age be less than 16 because age 16 is the youngest age at which a person can be certificated to operate an aircraft independently in the NAS. Because a remote pilot certificate allows people to operate their small UAS independently, it is critical that those people possess the maturity necessary to operate in a safe manner. The FAA also disagrees with commenters who provided the example of a driver’s license and a learner’s permit as a justification for lowering the minimum age below 16. In most states, the driving privileges of people under the age of 16 are significantly limited compared to the privileges granted at age 18. According to the Governors Highway Safety Association, most states do not permit full driving privileges until 17 or 18 years of age. These privileges include high-risk situations such as the ability to drive unsupervised at night or with a certain number of passengers. The FAA also notes that driving a car does not use the same skills as operating a small UAS. For example, in order to successfully drive a car, drivers have to learn skills, such as parallel parking and making three-point turns, which have no applicability to small UAS operations. Requiring a U.S. driver’s license as a prerequisite to obtaining a remote pilot certificate would impose the cost of acquiring those skills on people who do not currently possess a driver’s license without a corresponding safety benefit. Accordingly, this rule will not require remote pilot certificate applicants to hold a driver’s license.

In response to commenters who recommended a lower minimum age to enable academic uses, or the suggestion for an apprenticeship-like certificate for those under 18 years of age, the FAA notes that this is unnecessary because this rule allows an uncertificated person to manipulate the controls of a small UAS, provided that: (1) they are under the direct supervision of a certificated remote pilot in command; and (2) the remote pilot in command is capable of taking over controls at any time during the flight. The FAA also notes that, depending on the purpose of the operation, small UAS operations conducted by community groups and non-profit organizations may be considered recreation or hobby operations, which are not regulated under part 107 if conducted in accordance with Public Law 112-95, section 336.

The Agricultural Technology Alliance, Illinois Farm Bureau, and GROWMARK suggested that the FAA treat age eligibility to operate a small UAS in the same manner as the operation of farm equipment—i.e., allowing individual State labor laws to control. Though it did not explicitly advocate for the use of State labor laws to determine eligibility, Predesa pointed out that child labor laws would apply to minors participating in commercial operations. The commenter recommended the FAA consider mandating an adult visual observer to assist a minor with an operator certificate when operating a small UAS for commercial purposes. The commenter also recommended that the FAA consider mandating an adult visual observer to assist a minor with an operator certificate when operating a small UAS for education in a private program for fee, in a university setting, or in a public school system.

The FAA does not agree with the recommendation to adopt State labor laws to set the minimum age requirement. State laws are not uniform, and this could result in a patchwork of regulations that would apply uneven requirements depending on one’s State of residence. The FAA also notes that not all operations conducted under part 107 will be commercial. For example, as discussed in section III.C.4 of this preamble, recreational 133 Section III.C.4 of this preamble contains further discussion of model aircraft operations. small UAS operations that do not meet all of the criteria specified in Public Law 112 95, section 336 will be conducted under part 107.

The FAA disagrees with Predessa’s suggestion that an adult visual observer should be mandated in order to assist a minor with a remote pilot certificate (i.e. someone between 16 and 18 years of age) when operating a small UAS. As discussed previously, the FAA currently allows 16-year-old pilots to operate, without supervision, glider and balloon manned aircraft and small UAS (under a section 333 exemption). The FAA has not observed an adverse effect on safety as a result of the pilot in those operations being 16 rather than 18 years old. Thus, while the FAA agrees that a visual observer enhances safety by providing additional situational awareness to the remote pilot, it is not necessary to mandate a visual observer based on the age of the remote pilot certificate holder or the type of operation being conducted.

Accordingly, the FAA has amended proposed § 107.61(a) to lower the minimum age to be eligible for a remote pilot certificate with a small UAS rating to 16 years old. The FAA notes, however, that an academic institution is permitted to establish its own (more restrictive) policies and procedures for operational small UAS training, which may include requiring the presence of adult visual observers for students who are younger than 18.

b. English Language Proficiency

In the NPRM, the FAA proposed to require that applicants for a part 107 airman certificate be able to read, speak, and understand the English language. These proposed English-language requirements would be consistent with all other airman certificates issued by the FAA, as well as the international standard for aircraft operations accepted by ICAO. However, the FAA also proposed an exception for people who are unable to meet one of the English-language requirements due to medical reasons. Such a person would be eligible for a certificate, but the FAA would be able to specify limitations on the certificate to account for that person’s medical condition.

Five commenters expressed support for requiring airman-certificate applicants to be able to read, speak, and understand the English language. There were no comments opposing this aspect of the proposal. Accordingly, this rule will require that applicants for an airman certificate be able to read, speak, and understand the English language. Three commenters opposed the proposed exception to the English-language requirements. One of these commenters stated that there should be no exceptions to the English-language requirement, while another commenter stated that there should be no
exception for persons whose medical reasons would preclude them from effectively communicating procedures or reading flight logs. A third commenter stated that a person who cannot speak English should not be permitted to operate anywhere near people on the ground because that person would be unable to communicate safety-relevant information to people in the vicinity of the operation.

Limiting the exception for the English-language requirements of this rule would impose a needless burden on airman-certificate applicants who have a medical condition. Specifically, if an applicant cannot read, speak, or understand the English language, the proposed exception would allow the FAA to impose restrictions on that applicant’s certificate ensuring that the person’s English-language inability does not adversely affect safety. For example, if an applicant is unable to communicate using speech, then the FAA may restrict that applicant’s certificate to operations where speech is not necessary for the safe operation of a small UAS.

Restrictions issued under this provision will be specific to each applicant, and as such, the FAA cannot make the categorical statements suggested by the commenters as to what will or will not be permitted for applicants with a specific English-language inability. The FAA notes that its English-language regulations for other airman certificates have a similar exception for applicants who have a medical issue, and the FAA has not observed any adverse safety effects from having this exception in the regulations. Accordingly, this final rule will retain the proposed exception for people who are unable to meet one of the English language requirements due to a medical condition. 14 CFR 107.61(b). However, the FAA emphasizes that, as with other airmen, it may specify limitations on a person’s airman certificate to ensure that the person’s medical condition does not endanger the safety of the NAS.

c. No Airman Medical Certificate Required
For the reasons discussed below, this rule will not require an airman medical certificate but will prohibit a person from manipulating the flight controls of a small UAS or acting as a remote pilot in command or visual observer if he or she knows or has reason to know that he or she has a physical or mental condition that would interfere with the safe operation of a small UAS.

The FAA received approximately 115 comments from organizations and individuals on this subject. Several commenters stated than an airman medical certificate is not necessary to operate a UAS. Other commenters suggested adding a requirement for an airman medical certificate.

The FAA disagrees that a medical certificate should be required in this rule. With certain exceptions, the FAA currently requires an airman medical certificate for exercising the privileges of a student pilot certificate, a recreational pilot certificate, a private pilot certificate, a commercial pilot certificate, and an airline transport pilot certificate. The primary reason for medical certification is to determine if the airman has a medical condition that is likely to manifest as subtle or sudden incapacitation that could cause a pilot to lose control of the aircraft, or impair the pilot’s ability to “see and avoid.” Small UAS operations present a lower risk than manned operations to manned aircraft and non-participating people on the ground, especially because the operations do not involve any human beings onboard the aircraft who could be injured in the event of an accident. Additionally, unlike manned-aircraft operations, remote pilots and visual observers will be operating within a confined area of operation, subject to operational limitations intended to minimize the exposure of the small unmanned aircraft to manned aircraft in flight and people on the ground. Because of these operational limitations, traditional FAA medical certification is not warranted for remote pilots or visual observers. The FAA also notes that the risks associated with pilot incapacitation are similar to the risks associated with loss of positive control. As discussed in that section, risks associated with loss of positive control are mitigated in this rule through: (1) preflight inspection of the control links, (2) a speed limit of 87 knots, and (3) a prohibition on operations of small unmanned aircraft over people not directly participating in the operation. Just as § 107.49(a)(3) will require remote pilots to ensure that all links between ground station and the small unmanned aircraft are working properly, § 107.17 will require the remote pilot in command to abstain from small UAS operations if he or she knows or has reason to know that he or she has a physical or mental condition that would interfere with the safe operation of the flight.

Federal Airways & Airspace, ALPA, and several individual commenters expressed concern about the lack of a required vision exam. General Aviation Manufacturers Association and Aerospace Industries Association suggested that remote pilots hold a valid U.S. driver’s license to ensure a basic eye exam.

The FAA considers the visual-line-of-sight requirement for the remote pilot, the person manipulating the flight controls of the small UAS (if that person is not the remote pilot), and the visual observer (if one is used) to be able to see the aircraft’s direction, altitude, and attitude of flight to be preferable to a prescriptive vision standard. Even with normal vision, it is foreseeable that a small unmanned aircraft may be so small that the operational space must be reduced to meet the visual-line-of-sight requirements of § 107.31. Therefore, any demonstration of completing a vision exam would be less effective than this rule’s visual-line-of-sight requirements, and as such, the FAA will not adopt a vision exam requirement in the final rule.

The FAA also disagrees with comments suggesting the FAA require a U.S. driver’s license. According to the DOT Office of Highway Policy Information, 13 percent of the population aged 16 or older does not hold a state-issued driver’s license. As such, requiring a U.S. driver’s license would create an undue burden for many remote pilots without an equivalent increase in safety because the skills necessary to obtain a driver’s license are not the same as the skills needed to pilot a small UAS. Further, the FAA has historically allowed pilots of gliders and balloons to exercise the privileges of their pilot certificates without requiring a medical certificate or U.S. driver’s license, and this practice has resulted in no adverse effects on the NAS.

The Golden Gate Bridge, Highway and Transportation District supported the proposed requirement to disqualify persons with known physical or mental conditions that could interfere with the safe operation of the aircraft. Conversely, DronSystems commented that it would be impossible to enforce a prohibition on operations if an operator knows he or she has a medical condition that could interfere with the safe operation of the small UAS.

The FAA notes that a similar regulatory provision already exists in part 61. Under § 61.53, a pilot certificate holder is obligated to abstain from acting as pilot in command during a period of medical deficiency. The requirement of § 61.53 applies regardless of whether or not a pilot certificate holder also holds a medical certificate.

One individual suggested that the FAA provide a list of disqualifying medical conditions.

The FAA has not established a list of disqualifying medical conditions under § 107.17 because there are a wide range of small UAS operations that could be affected differently by different medical conditions. For example, a person who is incapable of moving his fingers would not be able to safely operate a small UAS whose control station interface is manually manipulated with the fingers. However, that person may be able to safely operate a small UAS whose control station is operated through voice controls. A person participating in a small UAS operation is responsible for knowing his or her physical and mental limitations and evaluating whether those limitations would allow him or her to safely participate in the specific small UAS operation that he or she is considering. If that person is unsure as to the limitations of his or her physical or mental condition, he or she should consult with a physician. The FAA emphasizes that those with a medical history or who are experiencing medical symptoms that would prevent them from safely participating in a small UAS operation or that raise a reasonable concern cannot claim to have no known medical conditions.

One commenter stated that residents of Alaska have a disproportionately high rate of “seasonal bipolar disorder” or “polar night-induced solipsism syndrome,” and that Alaskans might therefore be disproportionately affected by this provision. This commenter suggests that the FAA remove “bipolar disorder—or at the least bipolar disorder and related conditions ‘with seasonal pattern’—from the list of mental conditions which may prevent someone from being able to operate” a small UAS.

The FAA notes that the commenter is referring to a list of medical conditions enumerated in § 67.107(a)(3), § 67.207(a)(3), and § 67.307(a)(3), referring to a candidate for a first, second, or third class medical certificate to have no established medical history or clinical diagnosis of a bipolar disorder. However, as discussed previously, part 107 does not include a list of disqualifying medical conditions. A person with bipolar disorder would violate § 107.17 only if his or her bipolar disorder was such that it would interfere with the safe operation of a small UAS.

The FAA also notes that in the NPRM it proposed to require that an applicant for an airman certificate must submit a certified statement attesting to his or her physical and mental condition at the time of the application. However, upon further review, the FAA has decided to remove this provision from the rule because an applicant’s medical condition at the time he or she submits his or her application for a remote pilot certificate may change prior to operation of the small UAS.

d. Flight Proficiency and Aeronautical Experience
Because of the significantly reduced risk associated with small UAS operations conducted under part 107, the NPRM proposed to not impose flight proficiency or aeronautical experience requirements on applicants seeking a small UAS airman certificate. However, the FAA invited comments on whether flight proficiency or aeronautical experience should be required. For the reasons discussed below, this rule will not require applicants for a remote pilot certificate with a small UAS rating to demonstrate flight
proficiency or aeronautical experience.

Several commenters, including NBAA, Colorado Cattlemen’s Association, and NetMoby, agreed with the NPRM that the FAA should not require small UAS operators to demonstrate their proficiency in operating a small UAS prior to obtaining an operator certificate. These commenters reasoned that requiring a proficiency test is unnecessary because small UAS are not very difficult to operate and the test could be cost prohibitive for some operators. NetMoby added that there will be a market incentive for manufacturers to ensure that future operators are capable of flying their UAS.

Other commenters, including the AFL-CIO, AIA, and NAAA, disagreed with the proposal and suggested that the FAA require small UAS operators to demonstrate their proficiency in operating a small UAS prior to obtaining a remote pilot certificate. Some of the commenters asserted that this would be consistent with testing requirements used for part 61 pilot certificates.

Aviation Management and Modovolate Aviation suggested requiring a practical test or demonstration of aeronautical knowledge for certain aircraft or flying conditions (e.g., those weighing more than 4.4 pounds, operation beyond visual line-of-sight), but not for others (e.g., micro UAS, operation in only Class G airspace). Virginia Commonwealth University Honors Students suggested that separate tests should be required for each type of small UAS.

As discussed in section III.E.3.a of this preamble, small UAS operations conducted under this rule will operate in a confined area of operation. As a result of this confined area and due to the very low weight of the small unmanned aircraft, small UAS operations conducted under part 107 will generally pose a very low risk as compared to manned aircraft. As such, flight proficiency and aeronautical experience requirements (which apply to part 61 pilots) are unnecessary for remote pilots of a small UAS.

Flight proficiency testing is also not necessary for small UAS operations because, unlike a manned aircraft pilot, the remote pilot of a small UAS can easily terminate flight at any point. The light weight and lack of people onboard the small unmanned aircraft provides the remote pilot of that aircraft with a multitude of safe landing options. The remote pilot also has the option to sacrifice the small unmanned aircraft because there are no people onboard who would be endangered by that action. Conversely, a manned aircraft can only land at a location that can safely accommodate its large weight. The landing of a manned aircraft must also be accomplished in a manner that does not endanger the people onboard the aircraft. Because of the ease with which the flight of a small unmanned aircraft can be terminated and because of the overall low risk posed by small UAS operations that will be conducted under part 107, this rule will not include practical testing or flight experience requirements for a remote pilot certificate.

The FAA notes, however, that certain operational restrictions of part 107, such as operations within visual line of sight, are waivable if the applicant can demonstrate that his or her operation can safely be conducted under the terms of a certificate of waiver. In processing a waiver, the FAA may request additional mitigations, such as a demonstration of remote pilot proficiency, to ensure that the operation can be conducted safely.

The Nez Perce Tribe requested that the FAA provide additional flexibility to small UAS operators by allowing them to qualify for an operator certificate either via a written test, a practical test, or a demonstration of aeronautical experience. In response, the FAA notes that practical testing, aeronautical experience, and knowledge testing measure different things. Knowledge testing determines whether an applicant has acquired proficiency in the areas of knowledge being tested. Practical testing and aeronautical experience determines the applicant’s flight proficiency. Although practical testing and aeronautical experience may be used to assess some level of a person’s knowledge, the aeronautical knowledge test is the method used to directly assess an applicant’s knowledge. In this case, the FAA has determined that a remote pilot needs to have acquired the knowledge needed to safely operate a small UAS because small UAS operations will generally pose a very low risk as compared to manned aircraft. Thus, an aeronautical knowledge test is the appropriate vehicle to determine whether an applicant for a remote pilot certificate has acquired the necessary knowledge.

e. Formal Training
The NPRM did not propose to require formal training, but it invited comment on whether passage of an FAA-approved training course should be required either instead of or in addition to the aeronautical knowledge test. After reviewing the comments, the FAA has determined that it will not impose any specific training or flight instruction requirements for small UAS remote pilot certificate applicants.

Many commenters, including NAFI, NAAA, and A4A, stated that the FAA should require individuals to attend a training course before obtaining a small UAS operator certificate. NAFI asserted that an applicant may be able to pass an initial knowledge test through rote memorization and retain little useful information or application after passing the knowledge test. According to NAFI, the present FAA test management systems do not allow for the robust, multi-version testing that is truly able to test to the application level of learning. Commenters argued that training should encompass various topics and forms such as scenarios, multi-rotor aircraft, educational contact time from a flight instructor, and simulations.

Conversely, National Roofing Contractors Association, NBAA, Southern Company, Aerospace Industries Association, and Nez Perce Tribe argued that the FAA should not require a training course. Aviation Management suggested that the FAA make informational and training materials available online and also create online training programs, but should not require training courses. National Roofing Contractors Association, NRECA, and Team Rubicon suggested allowing industries to have tailored certification processes or training specific to their needs, or to allow agencies and organizations to conduct tailored in-house training.

The FAA took a risk-based approach to defining the airman certification requirements for small UAS remote pilots, and in light of the contained nature of operations, opted not to propose specific training, flight experience, or demonstration of proficiency in order to be eligible for a certificate. A remote pilot certificate applicant’s knowledge of small UAS, as well as regulations concerning safe operations in the NAS, can adequately be evaluated through an initial and recurrent knowledge tests. A person who has acquired the pertinent knowledge will pass the knowledge tests while a person who has not done so will fail the test.

In response to commenters’ concerns about rote memorization, the FAA notes that in addition to passing the initial knowledge test, remote pilot certificate holders will also have to pass a recurrent knowledge test every two years to ensure that they have retained the knowledge necessary to safely operate in the NAS. Further, remote pilot certificate holders will also be subject to continuing FAA oversight. The FAA emphasizes that under 49 U.S.C. 44709 and § 107.7(b), the FAA may reexamine a certificated remote pilot if it has sufficient reason to believe that the remote pilot may not be qualified to exercise the privileges of his or her certificate.137 Because the qualification framework for the remote pilot certificate is based on aeronautical knowledge, a reexamination under section 44709 and § 107.7(b) would be limited to the certificate holder’s aeronautical knowledge. The reexamination may be conducted using an oral or written knowledge test.

A prescriptive formal training requirement is not necessary in this rule. Instead, this rule will allow remote pilot certificate applicants to attain the necessary aeronautical knowledge through any number of different methods, including self-study, enrolling in a training seminar or online course, or through one-on-one instruction with a trainer familiar with small UAS operations and part 107. This performance-based approach is preferable because it will allow individuals to select a method of study that works best for them. These methods of study will then be validated by whether or not the individual is able to pass the knowledge test. As noted in OMB Circular A-4, performance-based standards are generally preferable in a regulation because they allow the regulated parties “to choose the most cost-effective methods for achieving the regulatory goal and create an incentive for innovative solutions.”

The FAA will publish Advisory Circulars to assist remote pilots in operating small UAS safely in the NAS. The FAA Safety Team (FAASTeam) will also host online training courses. These training courses could be used as one method of studying for the knowledge test. Lastly, because there is already a robust network of nearly 700 testing centers located throughout the country set up to administer FAA knowledge tests, the FAA has opted not to establish new standards for small UAS remote pilot testing centers.

f. General Requirement for Initial Aeronautical Knowledge Test
The NPRM proposed requiring applicants for a remote pilot airman certificate with a small UAS rating to pass an initial aeronautical knowledge test to demonstrate that they have sufficient aeronautical knowledge to safely operate a small UAS. The FAA adopts the provisions as proposed with three changes. First, as discussed in III.F.2.i below, the FAA exempts part 61 pilot certificate holders from the requirement to complete an initial knowledge test as long as they satisfy the flight review requirements of their part 61 pilot certificate and complete an online training course within the preceding 24 months. Second, as discussed in III.F.2.h below, the FAA will require that pilots with military experience operating unmanned aircraft pass an initial knowledge test in order to obtain a remote pilot certificate with small UAS rating, and pass a recurrent knowledge test every 24 months subsequent in order to continue to exercise the privileges of that certificate. Many commenters, including National Association of State Aviation Officials, NAAA, ALPA, and NAMIC, supported the FAA’s proposal to require an initial aeronautical knowledge test in order to operate a small UAS. Conversely, several commenters opposed the initial aeronautical knowledge test. Commenters argued that initial testing is “overkill” and the FAA should treat small UAS pilots like part 103 ultralight vehicle pilots and not require airman certification or testing. The commenters further argued that all testing is unnecessary and inappropriate.

The FAA disagrees with the commenters who asked that the knowledge test be abolished. Title 49 U.S.C. 44703 requires the FAA to ensure that an airman certificate applicant is qualified and able to perform the duties related to the position to be authorized by the certificate.

Here, in order to meet its statutory obligation to determine that an applicant for a remote pilot certificate possesses the knowledge necessary to safely operate in the NAS, the FAA is requiring that those persons pass an initial aeronautical knowledge test. Knowledge testing is the most flexible and efficient means for ensuring that a remote pilot possesses the requisite knowledge to operate in the NAS because it allows the applicant to acquire the pertinent knowledge in whatever manner works best for him or her. The applicant can then take and pass the aeronautical knowledge test to verify that he or she has indeed acquired the pertinent areas of knowledge.

NAFI recommended that an applicant should be required to obtain an instructor endorsement to take the initial aeronautical knowledge test. SkyView Strategies suggested that to protect the public from a poorly prepared UAS operator who receives a passing grade but gets important questions wrong, the UAS operator should be required to present to a flight training instructor his or her written test results, noting areas where knowledge is lacking.

The FAA disagrees with the recommendation that an applicant should be required to obtain an instructor endorsement to take the initial aeronautical knowledge test. While an instructor endorsement is generally required for part 61 pilot certificates, the significantly reduced risk associated with small UAS operations conducted under part 107 would make this framework unduly burdensome in this case. Instead, a stand-alone knowledge test is sufficient to verify the qualification of the remote pilot certificate applicant.

Because the aeronautical knowledge test will determine whether an applicant possesses the knowledge needed to safely operate a small UAS, a separate flight instructor endorsement should not be required to take the knowledge test. The FAA also notes that the costs associated with failing and having to retake the knowledge test will provide an incentive to applicants to pick a method of study that maximizes the chance of them passing the aeronautical knowledge test on the first try.

The FAA also does not agree that a certificate applicant should be required to present to a flight instructor his or her knowledge test results for remedial training. The FAA maintains that if a candidate is “poorly prepared,” then that person is unlikely to pass the knowledge test.

The University of Arkansas Division of Agriculture suggested that a more appropriate “aeronautical knowledge exam” needs to be developed with input from UAS users. It further suggested that the FAA should periodically revisit the scope of the aeronautical knowledge test as operational experience data increases. FAA knowledge test banks are continuously updated to address changes to the industry, safety, and special emphasis areas. While the FAA responds to industry and user community feedback, the small UAS knowledge test bank is developed internally within the agency to protect the integrity of test.

g. General Requirement for Recurrent Aeronautical Knowledge Test
The FAA proposed that a certificated remote pilot must also pass a recurrent aeronautical knowledge test every 24 months. Like the flight review requirement specified in § 61.56, the recurrent knowledge test provides the opportunity for a remote pilot’s aeronautical knowledge to be reevaluated on a periodic basis. The FAA adopts this provision as proposed, with one change. As discussed in III.F.2.i, the FAA exempts part 61 pilot certificate holders from the requirement to complete recurrent knowledge tests as long as they satisfy the flight review requirements of § 61.56 and complete an online training course every 24 months .

ALPA, AOPA, AUVSI and several other commenters supported the requirement for a recurrent knowledge test. Conversely, Colorado Cattlemen’s Association and a few individual commenters argued that a recurrent knowledge test is unnecessary. The Colorado Cattlemen’s Association explained that small UAS operations present a substantially reduced risk as compared to manned-aircraft operations. Therefore, the commenter argued, it is appropriate to impose different, and in some instances lesser, operational requirements.

The FAA disagrees with the notion that no periodic reevaluation of knowledge is necessary. Knowledge of rules, regulations, and operating principles erodes over time, particularly if the remote pilot is not required to recall such information on a frequent basis. This is a fundamental principle of airman certification, and it applies to all FAA- certificated airmen. For part 61 pilot certificate holders, the flight review, conducted under § 61.56, specifically requires “[a] review of the current general operating and flight rules of part 91” in addition to maneuvers necessary to safely exercise the privileges of the certificate. Likewise, the FAA considers a recurrent knowledge test to be an effective means of evaluating a remote pilot’s retention of knowledge necessary to safely operate small unmanned aircraft in the NAS. Because of the reduced risk posed by small UAS, the FAA is not requiring remote pilots to demonstrate a minimum level of flight proficiency to a specific standard or recency of flight experience in order to exercise the privileges of their airman certificate.

Drone Labs suggested extending the time period between recurrent tests to 5 years, and/or making the test available online to ease recertification. Kansas Farm Bureau recommended a 6-year interval between recurrent tests, similar to the interval for renewal of a driver’s license.

The FAA does not agree that the recurrent testing interval should be longer than two years. Unlike the privileges afforded by a driver’s license, which are exercised on a frequent basis by most drivers, many holders of remote pilot certificates may only exercise their privileges occasionally or may not regularly conduct operations that apply all of the concepts tested on the aeronautical knowledge test. For example, a remote pilot in command may spend years never operating outside of Class G airspace, and then may move to a different location that requires him or her to begin conducting small UAS operations in Class D airspace. Based on experience with manned pilots, those persons who exercise the privileges of their certificate on an infrequent basis are likely to retain the knowledge for a shorter period of time than those who exercise the privileges of their certificate on a regular basis.

Further, as unmanned aircraft operations increase in the NAS, the FAA anticipates the possibility of further changes to rules and regulations. By requiring evaluation on a two-year cycle, the FAA is able to ensure that remote pilots are aware of the most recent changes to regulations affecting their operations.

The FAA acknowledges, however, the burden associated with in-person testing every two years. As such, the FAA intends to look at (in the Operations of Small Unmanned Aircraft Over People rule) alternative methods to further reduce this burden without sacrificing the safety benefits afforded by a two-year recurrent knowledge check.

h. Pilots with Military Experience
The NPRM proposed allowing pilots with military experience operating unmanned aircraft to take the recurrent knowledge test in lieu of the initial knowledge test in order to be eligible for an unmanned aircraft operator certificate with a small UAS rating. For the reasons discussed below, this rule will require pilots with military experience operating unmanned aircraft to comply with the initial and recurrent knowledge testing requirements discussed in the previous sections.

NBAA, Small UAV Coalition and Texas A&M University agreed with the proposed rule requiring only a recurrent knowledge test in lieu of the initial knowledge test to qualify for a UAS operator airman certificate. Prioria said that military UAS operators and OEM-certified UAS operators should be grandfathered in without the need to take an initial knowledge test because their prior operational experience should suffice. In addition, Aviation Model Code of Conduct Initiative, Boeing Commercial Airplanes, Small UAV Coalition, and others supported accepting existing pilot credentials, especially military pilot credentials, in lieu of requiring those pilots to take an initial knowledge test or obtain a separate small UAS certificate. ArgenTech Solutions suggested that FAA should put a time limit on when military experience is acceptable for taking the recurrent knowledge test. In contrast, ALPA and others suggested that an initial knowledge test, rather than just a recurrent test, is appropriate for applicants with military experience flying UAS. ALPA noted that such pilots do not necessarily have experience operating in the NAS, and therefore cannot be assumed to be familiar with all the subject areas included in the initial test. ALPA also pointed to the wide variety of UAS used in the military and suggested that a given pilot’s experience may not necessarily be relevant to the operation of a small UAS in the NAS. ALPA also stated that the FAA should review a military pilot’s specific training, skills, and experience before determining what “supplemental training, knowledge testing, or skills demonstration” might be needed.

Similarly, one commenter asserted that experience operating military UAS is not relevant to the operation of a civil small UAS, and that therefore those with military experience should be subject to the same testing requirements as other applicants. Another individual echoed ALPA’s concern that military operations are conducted almost exclusively in military airspace, not in the NAS. One commenter, while supporting an initial-test exemption for applicants with military experience, added that former military UAS pilots do not necessarily understand civil operations in the NAS.

Planehook Aviation, NOAA, DOD, and an individual commenter said that the prior military experience provision proposed in § 107.75 should apply to both military and nonmilitary COA UAS operators. One commenter provided supporting reasoning stating that “[t]here are several non-military Federal agencies that have well established sUAS programs and, as is the case with NASA, they have decades of experience with sUAS and operating sUAS in the NAS.” NOAA argued that there are no practical differences between NOAA pilots and military pilots because they are both trained in the same facilities. DOD raised a similar argument, asking that the rule recognize DOD civilian and contractor personnel that have a level of training equivalent to military personnel. One individual suggested that the FAA allow civilian operators with a minimum of 1,000 logged hours as operators of UAS for government and military agencies to qualify for taking the recurrent knowledge test instead of the initial test.

The FAA agrees with commenters who expressed concern about applicants obtaining a remote pilot certificate to operate civil small UAS without passing an initial knowledge test. The levels of training and certification for unmanned aircraft differ greatly between branches of the armed services, and therefore there is no consistent training the FAA can use as a comparison to its requirements in order to credit military UAS pilots. Further, many of the required knowledge areas for the part 107 initial knowledge test, such as airspace classification, airport operations, and radio communications, are not consistently covered in training across all branches of the U.S. military. Accordingly, at this time, this rule will not allow military UAS pilots to bypass the initial aeronautical knowledge test. This applies to NOAA UAS pilots as well, because, as NOAA pointed out, they are trained in the same military facilities.

The FAA notes, however, that in some cases, government and military UAS pilots are trained as pilots of manned aircraft, in which case they may qualify for a part 61 pilot certificate through military competency. Specifically, manned-aircraft military pilots are frequently able to qualify for a part 61 pilot certificate under § 61.73 without taking a practical test by providing specific documentation and passing a military competency knowledge test. Provided those pilots obtain a part 61 pilot certificate and meet the flight review and online training course requirements discussed in the next section, they may qualify for a remote pilot certificate with small UAS rating without having to take any UAS knowledge test.

i. Credit to Holders of Part 61 Pilot Certificates

For the reasons discussed below, this rule will allow part 61 pilot certificate holders (other than the holders of a student pilot certificate) with current flight reviews to substitute an online training course for the aeronautical knowledge testing required by this rule.

Airborne Law Enforcement Association and Texas A&M University-Corpus Christi, suggested requiring only the recurrent knowledge test for part-61-certificated pilots. Numerous commenters also suggested that holders of part 61 airman certificates should be required to take only the recurrent knowledge test, not the initial knowledge test, or should be exempted entirely from knowledge-testing requirements. One commenter suggested that the holders of private, commercial, and ATP certificates who have operated UAS under exemptions be exempted from the initial knowledge test requirement. Another commented that non-military COA pilots should be permitted to take just the recurrent test, since the applicants will usually hold at least a private pilot certificate. One commenter stated that those applicants who hold part 61 pilot certificates should be required only to complete UAS-specific modules as part of the existing FAA Wings program. Another commenter stated that there should be a provision to enable existing small UAS pilots with a certain amount of logged PIC time to fly a small UAS without having to take a knowledge test.

The FAA agrees with commenters who suggested that requiring part-61-certificated pilots who satisfy the flight-review requirements of § 61.56 to take an initial or recurrent knowledge test is unduly burdensome. Through initial certification and subsequent flight reviews, a part-61-certificated airman is required to demonstrate knowledge of many of the topic areas tested on the UAS knowledge test. These areas include: airspace classification and operating requirements, aviation weather sources, radio communication procedures, physiological effects of drugs and alcohol, aeronautical decision-making and judgment, and airport operations. Because a part 61 pilot certificate holder is evaluated on these areas of knowledge in the course of the part 61 certification and flight review process, reevaluating these areas of knowledge on the initial and recurrent knowledge tests conducted under part 107 would be needlessly duplicative.

However, there are UAS-specific areas of knowledge (discussed in section III.F.2.j of this preamble) that a part-61-certificated pilot may not be familiar with. Accordingly, instead of requiring part-61-certificated pilots who are current on their flight reviews to take the initial and recurrent knowledge tests, this rule will provide those pilots with the option to take an online training course focusing on UAS-specific areas of knowledge. Just as there is an initial and recurrent knowledge test, there will also be an initial and recurrent training course available to part 61 pilot certificate holders. Those certificate holders will be able to substitute the initial training course for the initial knowledge test and the recurrent training course for the recurrent knowledge test. To ensure that a certificate holder’s UAS-specific knowledge does not become stale, this rule will include the requirement that a part 61 pilot certificate holder must pass either the recurrent training course or the recurrent knowledge test every 24 months.

The FAA emphasizes that the online training course option in lieu of taking the knowledge test will be available only to those part 61 pilot certificate holders who satisfy the flight review required by § 61.56. This is to ensure that the certificate holder’s knowledge of general aeronautical concepts that are not included on the training course does not become stale. Part 61 pilot certificate holders who do not meet the flight review requirements of § 61.56 will be unable to substitute the online training course for the required aeronautical knowledge test. Thus, under § 107.63(a)(2), a part 61 pilot certificate holder seeking to substitute completion of the initial training course for the initial aeronautical knowledge test will have to present his or her logbook upon application for a remote pilot certificate with a small UAS rating to demonstrate that he or she has satisfied this requirement. The applicant will also have to present a certificate of completion showing that he or she has completed the initial online training course.

The FAA also notes that the above discussion does not apply to holders of a part 61 student pilot certificate. A person is not required to pass an aeronautical knowledge test, pass a practical (skills) test, or otherwise demonstrate aeronautical knowledge in order to obtain a student pilot certificate. Further, student pilot certificate holders who have received an endorsement for solo flight under § 61.87(b) are only required to demonstrate limited knowledge associated with conducting a specific solo flight. For these reasons, the option to take an online training course instead of an aeronautical knowledge test will not extend to student pilot certificate holders.

j. Areas of Knowledge on the Aeronautical Knowledge Tests and Training Courses for Part
61 Pilot Certificate Holders The NPRM proposed that the initial aeronautical knowledge test would test the following areas of knowledge: (1) regulations applicable to small UAS operations; (2) airspace classification and operating requirements, obstacle clearance requirements, and flight restrictions affecting small unmanned aircraft operation; (3) official sources of weather and effects of weather on small unmanned aircraft performance; (4) small UAS loading and performance; (5) emergency procedures; (6) crew resource management; (7) radio communication procedures; (8) determining the performance of small unmanned aircraft; (9) physiological effects of drugs and alcohol; (10) aeronautical decision-making and judgment; and (11) airport operations. The NPRM also proposed the following areas of knowledge for the recurrent knowledge test: (1) regulations applicable to small UAS operations; (2) airspace classification and operating requirements, obstacle clearance requirements, and flight restrictions affecting small unmanned aircraft operation; (3) official sources of weather; (4) emergency procedures; (5) crew resource management; (6) aeronautical decision-making and judgment; and (7) airport operations.

For the reasons discussed below, this rule will remove obstacle clearance requirements and add maintenance and inspection procedures as areas of knowledge that will be tested on both the initial and recurrent aeronautical knowledge tests. Further, aviation weather sources will be removed from the recurrent aeronautical knowledge tests. Except for these changes, this rule will finalize all other areas of knowledge as proposed in the NPRM.

With regard to the initial and recurrent training courses for part 61 pilot certificate holders, those courses will only cover UAS-specific areas of knowledge that are not included in the training and testing required for a part 61 pilot certificate. Thus, the initial training course will cover: (1) regulations applicable to small UAS operations; (2) small UAS loading and performance; (3) emergency procedures; (4) crew resource management; (5) determining the performance of the small unmanned aircraft; and (6) maintenance and inspection procedures. The recurrent training course will cover: (1) regulations applicable to small UAS operations; (2) emergency procedures; (3) crew resource management; and (4) maintenance and inspection procedures.

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