Section 107.73 Knowledge and training

By | March 22, 2021

Are you interested in understanding what you need to study for your  initial knowledge test or current training as defined by section 107.73?

In this article we will discuss (1) the Part 107 initial knowledge test, (2) the recurrent training (3) practice Part 107 initial (4) actual language from 107.73, and (5) the FAA’s commentary on knowledge tests from the preamble to the Small Unmanned Aircraft Rule.


Part 107 Initial Knowledge Test

If you want to fly commercial in the United States, you’ll most likely be flying under Part 107 which requires a remote pilot certificate. To obtain for the first time a remote pilot certificate, you’ll need to take and pass a Part 107 initial knowledge test. If you are a current Part 61 certificated manned pilot, you have an option of going another method. See my step-by-step instructions page on how to obtain your remote pilot certificate.

The Part 107 initial knowledge test contains 60 questions and you have 120 minutes to take it. The subject areas on the exam are: (1) regulations, (2) airspace, (3) weather, (4) loading and performance, (5) operations, and (6) Night. You’ll need to pass the exam with a score of 70% or higher.


Part 107 Recurrent Training

Individuals who have obtained their remote pilot certificates have to maintain their aeronautical knowledge currency by one of the methods in Section 107.65 (a)-(b) which says,

A person may not exercise the privileges of a remote pilot in command with small UAS rating unless that person has accomplished one of the following in a manner acceptable to the Administrator within the previous 24 calendar months:

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

(b) Completed recurrent training covering the areas of knowledge specified in § 107.73;

We used to have recurrent knowledge exams but the 2020 Operations Over People rule changed things to allow just recurrent training which can be done online or in-person.

You might be wondering questions about currency, I have addressed these issues elsewhere:


Part 107 Practice Initial Knowledge Exam Quiz


Actual Language of Section 107.73 Knowledge and training

An initial aeronautical knowledge test and recurrent training covers the following areas of knowledge:

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

(b) Airspace classification, operating requirements, and flight restrictions affecting small unmanned aircraft operation;

(c) Aviation weather sources and effects of weather on small unmanned aircraft performance;

(d) Small unmanned aircraft loading;

(e) Emergency procedures;

(f) Crew resource management;

(g) Radio communication procedures;

(h) Determining the performance of the small unmanned aircraft;

(i) Physiological effects of drugs and alcohol;

(j) Aeronautical decision-making and judgment;

(k) Airport operations;

(l) Maintenance and preflight inspection procedures; and

(m) Operation at night.


FAA’s Commentary on Section 107.73 from the:

2020 Operations Over People and Night Rule

3. OPERATIONS AT NIGHT
This rule allows routine operations of small UAS at night under two conditions. First, the remote pilot in command must complete a current initial knowledge test or recurrent training, as applicable, to ensure familiarity with the risks and appropriate mitigations for nighttime operations. Second, the small unmanned aircraft must have lighted anti-collision lighting visible for at least 3 statute miles that has a flash rate sufficient to avoid a collision. The requirements for operations at night are discussed in Section IX of this preamble.

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REMOTE PILOT TESTING AND TRAINING REQUIREMENTS
Part 107 previously required initial small UAS remote pilot applicants and small UAS remote pilots to complete either an initial aeronautical knowledge test or a recurrent aeronautical knowledge test within the previous 24 calendar months prior to operating a small UAS. This final rule revises these regulations to require recurrent training instead of a recurrent aeronautical knowledge test. This final rule maintains, as proposed, the provision that people who hold a part 61 pilot certificate (other than holders of a student pilot certificate) and have completed a flight review within the previous 24 calendar months in accordance with § 61.56 may continue to complete either initial training or recurrent training. The final rule also harmonizes the subjects covered in the testing and training. The FAA is updating the related testing and training materials to add new information about night operations. The changes to the remote pilot testing and training requirements are discussed in Section X of this preamble.

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IX. Operations at Night
A. Proposed Requirements and Comments Received
The NPRM proposed to permit routine operations of small UAS at night, subject to specific requirements. The FAA proposed to amend § 107.29 to permit operations at night when: (1) The small unmanned aircraft has an anti-collision light that is visible for 3 statute miles, and (2) the remote pilot in command has completed an updated knowledge test or recurrent training, as applicable, to ensure familiarity with the risks and appropriate mitigations for nighttime operations. Additionally, the FAA proposed adding the anti-collision lighting requirement to the list of regulations subject to waiver in § 107.205.

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The updated testing and recurrent training required to conduct night operations will be made available on the FAA website on March 1, 2021. This date provides a 15 day period for new applicants or current Remote Pilot Certificate holders to complete the updated testing or training, as applicable, for those who seek to conduct night operations on the effective date of this rule.

After the effective date of this rule, remote pilots operating under a waiver received prior to the effective date will be allowed to continue to operate at night under the provisions of that waiver without meeting the updated recurrent training requirement for a period of 60 days. All night waivers issued prior to the effective date of this rule that authorize deviation from § 107.29 Daylight Operation terminate on May 17, 2021. This date provides time for waiver holders to come into compliance with this rule and allow the holder to request a new certificate of waiver, if applicable, prior to the termination date.

Several commenters suggested the night operation testing and training be separate from the general part 107 training. One commenter suggested the FAA offer incentive licensing endorsements, in which a certain minimum score on the night operations section of the part 107 knowledge test would allow the remote pilot to operate a small UAS at night. Some commenters, including Airlines for America (A4A), recommended the FAA impose a nighttime practical training requirement for remote pilot certification, particularly for pilots who do not hold a part 61 certificate or related nighttime endorsement. The inclusion of night operations does not introduce a level of complexity to the operations conducted under part 107 that would necessitate practical training. A single curriculum for both the aeronautical knowledge test and recurrent training will cover all necessary topics for operations under part 107. To operate at night, all remote pilots must either take the updated initial knowledge test or complete the applicable recurrent training that includes the new subject areas on night operations. In this regard, it is necessary to standardize the training and testing; incentive licensing endorsements the FAA issues for other skills are not appropriate for knowledge testing or training. The standardization this rule provides is appropriate for small UAS operations at night.

A few commenters requested the Agency decline to require pilots who have certificates under part 61 to complete recurrent training specific to night operations. The Agency disagrees. Small UAS operations at night have operational needs and safety requirements that differ from manned aircraft operations at night. This rule requires part 61 pilots to take the recurrent training in its entirety, including those sections pertinent to night operations, despite having taken manned-aircraft-specific nighttime training for their part 61 certification. Several commenters made suggestions regarding the content of the test and course material. Some commenters, including AOPA, AMOA, and AAMS, suggested the initial testing, initial training, and recurrent training for night operations emphasize collision avoidance with other unmanned aircraft and manned aircraft. They asked whether the additional testing for night operations will specifically address limited depth perception and difficulty of perceiving reference points during night operations. Under this rule, in addition to the existing testing and training that addresses collision avoidance, additional subject areas will address night physiology, lighting requirements, and night illusions from the perspective of the remote pilot.

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One commenter suggested the Agency require one or more visual observers who have taken the night vision test to participate in operations at night. The visual line of sight requirement in part 107, combined with other requirements, is sufficient to address the risk associated with night operations; therefore, this rule does not require a night vision test for remote pilots or visual observers. One commenter said the proposal would impose more cost on the operator and increase the barriers to UAS night operations. Another stated the additional testing and training requirements would not improve the safety of night operations. This rule establishes the recurrent training process, the completion of which will be free of cost to remote pilots. This rule does not impose any changes to the costs of the initial knowledge test.

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X. Part 107 Remote Pilot Knowledge Testing and Training
The NPRM proposed to maintain the initial knowledge test requirement and initial training requirement for persons seeking to obtain a remote pilot certificate with a small UAS rating.[76] However, with respect to recency of experience requirements, the FAA proposed to require recurrent training every 24 calendar months in lieu of the recurrent knowledge testing.[77] Additionally, the NPRM proposed to add a knowledge area covering operations at night for the initial knowledge test, initial training, and recurrent training. The NPRM also proposed to revise the list of knowledge areas for remote pilots, requiring inclusion of the same list of knowledge areas on both the initial knowledge test and the recurrent training for pilots who hold a remote pilot certificate under § 107.65(b). As for pilots who already hold a pilot certificate under part 61 as described in § 107.65(c), the NPRM proposed to require the initial and recurrent training to cover identical knowledge areas. For the reasons discussed below, the Agency adopts these proposed amendments without change.

A. Recurrent Training and Aeronautical Knowledge Recency
Prior to this final rule, § 107.65(a) and (b) required persons to complete either an initial aeronautical knowledge test or a recurrent aeronautical knowledge test within the previous 24 calendar months prior to operating a small UAS. This final rule revises § 107.65(b) to allow remote pilots to take recurrent training instead of a recurrent aeronautical knowledge test. People who hold a part 61 pilot certificate (other than a student pilot certificate) who have completed a flight review within the previous 24 calendar months in accordance with § 61.56 may continue, under § 107.65(c), to complete either initial or recurrent training covering the areas of knowledge specified in § 107.74.

Recurrent training ensures remote pilots maintain ongoing familiarity with small UAS operations and the provisions of part 107. Moreover, remote pilots can complete recurrent training online, which provides a less costly option and results in the remote pilot maintaining a level of knowledge comparable to receiving recurrent testing. The FAA’s use of online training enables the FAA to adapt the training as necessary as technology or regulations change.

The rule continues to allow an eligible person who holds a part 61 pilot certificate (other than a student pilot certificate) to complete training on the knowledge areas specified in § 107.74 when seeking a remote pilot certificate.[78] Furthermore, the rule allows all remote pilots to complete recurrent training online every 24 calendar months, in place of a recurrent knowledge test. The rule amends the aeronautical knowledge test and training requirements for remote pilots provided in §§ 107.73 and 107.74 to include a new knowledge area related to operating a small UAS at night. For more information about the testing and training on the night operations knowledge area, please see Section IX.B.

This final rule requires the initial knowledge test and the recurrent training cover identical areas of knowledge under § 107.73. Similarly, for eligible part 61 pilots, the initial training and recurrent training will cover the same knowledge areas under § 107.74. The FAA is concurrently updating the part 107 Airman Certification Standards (ACS), the initial aeronautical knowledge test, the part 107 certification course for eligible part 61 pilots, and the recurrent training.[79] The updated aeronautical knowledge test and updated training replaces the current knowledge test and training after the effective date of the rule. Both the updated aeronautical knowledge test and the updated training will be available on March 1, 2021.

NASAO asked that the recurrent education make pilots aware of updates to operating rules, rather than retesting the initial knowledge test. One commenter believed there should be a “grading scale” to ensure pilots have stayed current on operations and regulations. Another commenter agreed that it was likely that operators would need to take refresher training, but suggested that if an individual scores above a certain level on their initial knowledge test, the FAA exclude that person from having to take recurrent training. Several commenters objected to the current 24-month interval for the testing and recurrent training process. Commenters recommended a range of intervals for recurrent training from 36 months to 5 years, or eliminating altogether for “professional operators.”

Part 107 requires the recurrent training to cover applicable regulations relating to small UAS rating privileges, limitations, and flight operation. As a result, recurrent training will ensure remote pilots are aware of current and updated operating rules. While a high score on an initial aeronautical knowledge test may demonstrate initial competency, knowledge is perishable and degrades over time. Online recurrent training allows remote pilots to maintain critical knowledge and keep abreast of dynamic issues, including changes to regulations, that arise while ultimately completing the updated knowledge requirements related to operating small UAS. Additionally, the Agency finds the 24-month interval an appropriate time period. This recurrent training interval is consistent with the requirement for manned aircraft pilots meeting the requirement to complete a flight review as required by § 61.56. On completion of this recurrent training, a printable completion certificate is available to demonstrate aeronautical knowledge recency in accordance with the revisions to § 107.65. The FAA provides educational material on the FAA website about updates to operating rules. AOPA commented that the FAA should not be the exclusive provider of the required knowledge training because there are numerous training courses offered by industry that might be more effective and better meet the needs of the unmanned aircraft operator. Another commenter asked the FAA to clarify what training would qualify.

The Coalition of Airline Pilots Association suggested the FAA require all small UAS operators to meet the same operational recency and testing requirements that are currently in place for manned commercial airman certificates. ALPA noted that a person who manipulates the flight controls of a small UAS should be a certified pilot and pass a knowledge test, but objected that the proposed requirement would allow an individual to be granted a remote pilot certificate without assurance of practical experience with a small UAS. Several commenters recommended specific practical training requirements, including flight training for operations over people and at night. One commenter believed an unprepared remote pilot may have to resort to manual flight operation and may not be qualified for that operation. AUVSI commented that any mandatory training involving operations over people should be competency-based. They also recommended the FAA consider how industry initiatives could support a new training requirement to help ensure that small UAS operations occur safely and in accordance with the rules. Another commenter wrote a higher level of training should be required to operate a small UAS commercially.

The Agency continues to find that formal training, a practical test for the issuance of a part 107 remote pilot certificate, and testing requirements similar to those for part 61 commercial pilot certificates, are not necessary. As discussed in the 2016 final rule, the limitations of many small unmanned aircraft (e.g., size, ease of landing, lack of people on board), combined with the operational restrictions of part 107, minimize the need for flight proficiency testing or formal training. A prescriptive formal training requirement is not necessary for part 107 operations. Instead, this rule allows 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 allows individuals to select a method of study that works best for them.[80] The FAA maintains this rationale for operations over people and night operations. While the introduction of operations over people and night operations may introduce additional complexity to the NAS, the FAA developed the design and operational requirements of this rule to balance the risk associated with the incremental integration of small UAS. This rule discusses those risk mitigations in more detail in Sections VI and IX, respectively.

The FAA understands formal training would be overly burdensome to an applicant. By requiring a person to only take a knowledge test for certification, allowing online recurrent training, and not requiring formal training, the FAA anticipates that this will result in cost savings for remote pilots, as discussed in the regulatory impact analysis. In addition, requiring formal training and a practical test would not be consistent with the original framework of part 107.[81] The FAA does not find it necessary to require practical testing to obtain a remote pilot certificate. This approach is consistent with the risk-based framework the 2016 final rule established.[82]

One commenter expressed concern that requiring the recurrent training to be identical to the initial training for part 61 pilots would be duplicative. Commenters asked the FAA to review the areas already covered in the Private Pilot Airman Certification Standards and keep duplicative or conflicting subject areas to a minimum. Another commenter suggested that part 61 should include certification to be a remote pilot.

As discussed previously, knowledge degrades over time and requiring recurrent training provides assurances that experienced remote pilots remain aware of the specifics of operating a small UAS. Additionally, as noted in the NPRM, the FAA finds it necessary to ensure consistency in remote pilots’ knowledge of the topic areas for the safe operation of small UAS. To compensate for the differences between manned aircraft and small unmanned aircraft, the list of knowledge areas includes topics that are specific to small UAS operations. For example, determining the performance of a manned aircraft is distinct from the manner in which a pilot should determine the performance of a small UAS; in this regard, the preflight check requirements of § 107.49 are distinct from those codified in part 91 and in other, similar regulations specific to manned aircraft.

Several commenters objected to the cost associated with the initial knowledge test and other commenters recommended the FAA lower the test costs. However, one commenter wrote that everyone who owns a small UAS should have to pass the initial knowledge test and recurrent testing to eliminate the threat of people flying dangerously. One commenter objected to having to pay a third party for recurrent testing. Some commenters wrote that section 44809 of the FAA Reauthorization Act of 2018 requires the FAA to develop a test for recreational operations that can be administered online and that this should be extended to part 107 remote pilot certification, thereby reducing the cost to $50 associated with the initial knowledge test.

The FAA clarifies that part 107 does not mandate formal training to obtain a remote pilot certificate, and any cost that a part 107 applicant incurs for formal training is at their discretion. Additionally, on March 1, 2021 the FAA will provide free, online recurrent training to all remote pilots. The FAA enters into contracts for testing delivery through a third party vendor. The FAA’s rationale to contract the initial test through knowledge testing centers remains the same as it was in the 2016 final rule.[83] This delivery model allows the FAA to enter into a contract that provides a zero cost model to the U.S. government and to the taxpayers. The testing vendor has many locations throughout the United States that are close to large and small population centers, therefore the requirement to take a knowledge test at a testing location is not an undue burden on applicants. The third party vendor is allowed to charge the contract rate to administer a knowledge test; however, that amount is not to exceed $160. The FAA Reauthorization Bill of 2018 requirement for the FAA to have an online test for limited recreational operators does not apply to part 107 remote pilot certification.

B. Other Comments Related to Initial Testing or Recurrent Training
Several commenters expressed concern about the risks of people without certification or training operating small UAS. Other commenters, referencing certification of pilots and mandatory registration for equipment, stated that all operators should be licensed regardless of size or weight of small unmanned aircraft. The FAA agrees that persons operating small UAS in the NAS should have appropriate aeronautical safety knowledge, knowledge of applicable rules, and knowledge of airspace constraints before operating in the NAS. Part 107 rules require that all small unmanned aircraft are registered and operated by a certificated remote pilot. The FAA currently requires initial testing or training before the issuance of a remote pilot certificate with a small UAS rating for operations under part 107.

Multiple commenters requested that both testing and training be provided online, with several commenters specifically recommending that the initial knowledge test be available online. The FAA agrees that in-person recurrent testing under part 107 is no longer necessary for part 107 certificate holders. Therefore, to meet the recency requirements under § 107.65, any person who holds a part 107 certificate may maintain recency of experience by completing an online training course. For security reasons, the initial knowledge testing must be done in person, similar to the regulatory framework for training under part 61.

A commenter suggested that test questions for each online test be pulled randomly from a larger set of questions so an applicant cannot take the same test over and over until the applicant achieves a score of 100 percent and would be required to learn the material. The part 107 knowledge tests are created from a large bank of questions that were specifically drafted for small UAS remote pilot certification. Although it is possible that a person could take the part 107 knowledge test enough times that they would eventually see all of the questions, and possibly get them all correct, this is not very probable especially given the mandatory 14-day waiting period required before a person can retake the knowledge test after a failure.[84] In addition, a person who is not prepared for the test, and does not have a working knowledge of the material, will have a very low probability of passing the test. The FAA will continue to administer knowledge testing in the same form and manner that has proven effective for many years.

A commenter recommended the FAA define minimum standards for training that would allow certain people to conduct operations without requiring a waiver to operate over people or at night. This rule adopts routine night operations and operations over people without the need for waivers. Additionally, under part 107, the FAA does not maintain minimum standards for training like those in part 61. For example, an applicant for a remote pilot certificate with a small UAS rating does not have to show that they have received formal training from a certified instructor on the National Airspace System. As there are two pathways for remote pilot certification, an applicant will have either met a minimum testing standard via a knowledge test or they will have taken training which will also test their knowledge. All persons who hold a remote pilot certificate will also need to maintain currency by taking currency training every 24 months from the month in which they take and pass the knowledge test or training for certification. The updated knowledge areas for the testing and training requirements are the minimum standard for small UAS operations conducted under part 107.

Some commenters proposed the Agency tailor the part 107 knowledge test to specific types of operators or certain topics and have different tests based on the type of operation. A few commenters recommended the part 107 knowledge test be redesigned to better test commercial small UAS pilots piloting skills and safe operations. These commenters noted the part 107 knowledge test appeared to derive from manned pilot standards and the Pilot Handbook of Aeronautical Knowledge (PHAK), which the commenters argued do not apply directly to small UAS flights. Another commenter asked for knowledge and testing specific to small UAS operations over people, such as first aid training. A commenter suggested the FAA have two separate knowledge tests: A basic test for hobbyists and small businesses, etc., and a more complex test for large commercial operations, large, fixed-wing small unmanned aircraft, or those flying in urban areas or all over the country.

All test questions were developed specifically for the part 107 remote pilot certification. Some of the required test questions, however, are also applicable to manned aircraft, such as questions related to airspace regulations that apply to all aircraft. The FAA carefully evaluated the knowledge test areas to ensure they remain comprehensive. The small UAS Airman Certification Standards and knowledge test contain each of the topics required for knowledge and testing, and the Agency does not consider remote pilot first aid training a necessary requirement for such low-risk operations. The requirements are the same for anyone flying under part 107; therefore, the knowledge and training should be the same for all certificated remote pilots under part 107.

Some commenters suggested passing the part 107 knowledge test or the level of the remote pilot’s training and experience should permit them certain privileges. A commenter wrote that passing the part 107 test should grant part 107 pilots the ability to fly over people and beyond line of sight. A commenter requested the FAA add levels of additional authorization for a remote pilot to fly over people, carry payloads, or fly at night based on their levels of training and experience added as ratings to the certificate. One commenter stated that part 61 pilots should have more “capability and freedom,” as they have already demonstrated their responsibility by obtaining a part 61 certificate. Another commenter asked the FAA to educate businesses that use remote pilots without a part 107 certificate to conduct commercial small UAS operations.

The FAA declines to add authorizations or ratings to the remote pilot certification in this final rule. A person who holds a remote pilot certificate is afforded all privileges of the certificate. The FAA has taken the approach of tailoring its requirements for night operations and operations over people with the expectation that all part 107 pilots have the same level of certification. The Agency did not propose authorizing routine beyond visual line of sight operations in this rulemaking; therefore, adding authorizations or ratings to address such operations is beyond the scope of the rule. Additionally, part 107 does not prohibit payload-bearing operations, but the small unmanned aircraft and any payload must be less than 55 pounds and must follow all applicable regulations for safe operation. Remote pilots who operate a small UAS under part 107 without an FAA-issued pilot certificate are subject to the FAA’s Compliance and Enforcement Policy. Additional educational material is available on the FAA website.[85]

2016 Small Unmanned Aircraft Rule

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.

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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.