FAA Part 108 Explained for BVLOS Operations

For years, commercial drone operations in the U.S. have been humming along under a set of rules known as Part 107. It's been a solid framework, but it has its limits. Think of Part 107 as the local city streets for drones—perfect for short trips where the pilot can always see their aircraft, but full of stop signs that prevent any kind of long-distance travel.

Every time an operator wanted to fly further, they had to navigate the special, time-consuming waiver process with the FAA. This created a huge bottleneck, stopping industries like package delivery, infrastructure inspection, and emergency response from truly scaling up.

Enter the proposed FAA Part 108. This is a complete game-changer. It’s the blueprint for building a national highway system for drones, designed from the ground up for efficient, long-range commercial flights.

From Pilot Responsibility To Organizational Safety

One of the biggest shifts with Part 108 is moving from individual pilot responsibility to a comprehensive, organization-wide safety culture. Part 107 puts most of the operational burden squarely on the shoulders of the Remote Pilot in Command (RPIC).

Part 108, on the other hand, demands that the entire organization adopt a proactive safety system—a mindset much closer to that of a commercial airline than a lone operator.

This is all about creating a standardized, scalable framework for Beyond Visual Line of Sight (BVLOS) operations. If you're new to the concept, our guide explaining Beyond Visual Line of Sight operations is a great place to start.

This visual really captures the essence of Part 108. It's about tearing down those individual stop signs and building a streamlined system designed for growth and efficiency.

Part 107 vs Part 108 At a Glance

To really understand the change, it helps to see the two rule sets side-by-side. The table below breaks down the core differences between the current Part 107 framework and what Part 108 proposes.

Regulatory Aspect	Part 107 (Current)	Part 108 (Proposed)
Primary Scope	Visual Line of Sight (VLOS)	Beyond Visual Line of Sight (BVLOS)
Operational Model	Pilot-centric; case-by-case waivers for BVLOS	Organization-centric; standardized certification for BVLOS
Safety Focus	Remote Pilot in Command (RPIC) responsibility	Organization-wide Safety Management System (SMS)
Scalability	Limited; waivers are slow and non-transferable	High; designed for repeatable, large-scale operations
Authorization	Specific operational waivers or exemptions	Part 108 Air Carrier Certificate

This comparison makes it clear that Part 108 isn't just an update—it's a fundamental restructuring of how the FAA approaches advanced drone operations. It’s a move from containment to managed integration.

The Dawn of Standardized BVLOS

The new framework was officially introduced in a Notice of Proposed Rulemaking (NPRM) on August 5, 2025. This proposal is a direct answer to the frustrations of the old system, where getting a BVLOS exemption was a complex, slow, and unpredictable process that held back commercial growth.

The introduction of FAA Part 108 isn't just an update; it's a structural overhaul. It establishes the safety systems and certifications needed for drones to become a routine, trusted part of the national airspace.

This new path is absolutely critical for any business looking to run missions that go far beyond the operator's direct view. The rest of this guide will break down exactly what this means for your operations and how you can prepare.

Understanding the Role of Safety Management Systems

At the very heart of the proposed FAA Part 108 is a concept that pulls the drone industry right alongside the highest standards of crewed aviation: the Safety Management System (SMS).

If you’ve ever wondered how major airlines maintain such an incredible safety record, the SMS is a massive piece of that puzzle. It's not just a dusty binder full of rules or a simple checklist you run through before takeoff.

Think of an SMS as the central nervous system for your entire drone operation. It’s a living, breathing framework designed to proactively find, analyze, and shut down risks before they ever have a chance to turn into an incident. This approach flips safety on its head—it’s no longer a reactive chore but a core part of your company's culture.

This SMS requirement is one of the most significant changes coming with Part 108. Making it mandatory for all commercial BVLOS operators is a huge step forward. After all, SMS has been a cornerstone in crewed aviation since the International Civil Aviation Organization (ICAO) adopted it back in the early 2000s, and it became mandatory for U.S. commercial airlines under Part 121 back in 2015.

The Four Pillars of an Effective SMS

To keep things from getting too abstract, the FAA breaks down the SMS into four distinct but totally interconnected pillars. Getting a handle on these is your first step to building a safety culture that’s not just compliant, but genuinely effective.

1. Safety Policy: This is your foundation. It's your organization’s official, top-down commitment to safety, spelling out the "why" and "who" of your program.

2. Safety Risk Management (SRM): This is where you get proactive. SRM is all about actively hunting for hazards, figuring out the risks they pose, and putting controls in place to knock those risks down to an acceptable level.

3. Safety Assurance: Think of this as your "check and balance." It’s how you keep an eye on your safety performance to make sure the controls you put in place are actually working.

4. Safety Promotion: This one is all about the people. It’s about building a strong safety culture through training, open communication, and making sure everyone feels safe reporting concerns without fear of blame.

These four pillars don't exist in a vacuum. They work together in a continuous loop of improvement, making sure your operation not only starts safe but stays that way as it grows.

A Real-World SMS Example for a Drone Company

Let's make this concrete. Imagine a drone logistics company that delivers critical medical supplies. Here’s how they’d apply the four pillars:

• Pillar 1 - Safety Policy: The CEO issues a formal policy that states safety trumps all commercial targets, period. The document lays out the exact responsibilities of the Chief Pilot, maintenance crew, and remote operators, creating a crystal-clear chain of command for any safety-critical decision.

• Pillar 2 - Safety Risk Management: While planning a new delivery route over a suburb, the team spots a new hazard: a construction crane that just went up. They use their SRM process to assess the risk of a mid-air collision and implement a control—shifting the flight path by 500 meters to create a safe buffer. For a deeper dive, check out our complete guide to drone risk management.

• Pillar 3 - Safety Assurance: The company makes a software check mandatory before every flight to verify that all geofencing and detect-and-avoid systems are online. Plus, after every 100 flight hours, they run internal audits on flight logs, searching for any weird patterns that might signal a growing risk.

An SMS isn't a document you create once and forget. It's an active, ongoing process that embeds safety into every decision, from the executive office to the remote pilot in the field.

• Pillar 4 - Safety Promotion: They create a non-punitive reporting system where pilots feel safe speaking up. One day, a pilot has a brief loss of command-and-control link near a tall building. Instead of hiding it, they report it immediately. This allows the company to investigate the signal interference, share what they learned with all pilots, and update procedures to avoid that area, making the entire operation safer for everyone involved.

How Part 108 Flips the Script on Pilot and Operator Responsibility

One of the biggest changes coming with Part 108 is a total rethink of who’s in charge. Under the Part 107 rules we’ve all grown accustomed to, nearly all the weight of safety, compliance, and in-flight decisions falls on the Remote Pilot in Command (RPIC). That model works perfectly for simple, one-off flights, but it’s a massive bottleneck for any company trying to scale up complex drone operations.

Part 108 completely flips this script. It shifts the primary burden from the individual pilot to the organization itself.

To really get this, think about the difference between a solo freelance delivery driver and a logistics giant like UPS. The freelancer has their own driver's license and is single-handedly responsible for their vehicle, their driving record, and every package they handle. Their certification is personal.

UPS, on the other hand, operates under a massive company-wide certificate. Yes, every driver is trained, but the company is the one responsible for the entire system—the maintenance schedules for the trucks, the route-planning software, and dispatcher protocols. The company builds the safety framework, and the FAA certifies that framework. This is exactly the model Part 108 brings to BVLOS drone operations.

From Individual Licenses to Organizational Authority

This new approach totally changes how certification works. Instead of just focusing on individual pilot licenses under Part 107, FAA Part 108 moves to a model of organizational accountability for BVLOS missions. It’s a lot like how commercial airlines operate—the company builds out its own safety management systems and is responsible for internally credentialing its staff. As industry experts at DARTdrones point out, this is a major transition for the drone world.

What does this mean for you? It means your company will be on the hook for creating its own FAA-approved training and qualification programs for pilots and everyone else involved in the operation.

A Two-Tiered System: Permits vs. Certificates

The FAA gets that not all BVLOS operations are created equal. Flying a drone over a farm is worlds apart from delivering packages in a dense city. So, they’ve proposed a two-tiered system for authorization to match the level of oversight with the level of risk.

Here’s a look at the two tiers:

• Operating Permits: Think of these as the entry-level option for lower-risk, more straightforward BVLOS work. This is for missions with minimal public exposure, like agricultural spraying over a private field or inspecting a long pipeline in a remote area. The application process here is expected to be much less intense.

• Operating Certificates: These are reserved for the heavy hitters—higher-risk, complex operations. We're talking package delivery in a bustling urban core or flying over crowded areas where the risk to people and property is significantly higher. Getting a certificate will require a much more rigorous safety demonstration, including a bulletproof Safety Management System (SMS).

This tiered system is a smart move. It allows the FAA to apply the right amount of scrutiny without crushing lower-risk operators under unnecessary red tape, which should help spur innovation while keeping things safe where it counts.

New Roles, New Responsibilities

This shift to an organizational focus means we’re going to see new, specialized roles emerge—it’s not just about the pilot anymore. While the job titles might differ from company to company, the core functions are essential for building the safety ecosystem that Part 108 demands.

Key Operational Roles Under Part 108:

Role	Primary Responsibility	Example Task
Operations Supervisor	Manages the entire BVLOS mission from a high level, making sure all systems and people are working together.	Overseeing multiple drone flights from a remote operations center (ROC) and making the final go/no-go call.
Flight Coordinator	Handles the strategic deconfliction and real-time airspace management for the drone.	Coordinating with air traffic control when needed and tweaking flight paths to steer clear of other aircraft.
Remote Pilot	Directly manipulates the drone's flight controls, though for automated missions, this is often a supervisory role.	Taking manual control for takeoff and landing, or to react to something unexpected in the air.
Maintenance Personnel	Keeps the drone airworthy through scheduled inspections, repairs, and software updates.	Running a pre-flight hardware check and logging every maintenance action according to the company’s SMS.

This structure makes it clear that safety is a shared, system-wide responsibility, not just one person's burden. Every single role is a piece of the safety puzzle, and that’s the real goal of the FAA Part 108 framework.

Essential Technology for Part 108 Compliance

Flying a drone Beyond Visual Line of Sight (BVLOS) is a massive leap of faith. You’re trusting your technology to do what your eyes used to do. The proposed FAA Part 108 rule gets this, which is why it mandates a specific suite of technologies. These systems aren't just fancy add-ons; they're the absolute foundation for safe and scalable BVLOS operations.

Here's a simple way to think about it: A Part 107 pilot is like a driver who can see the road, other cars, and pedestrians with their own eyes. A Part 108 operation is more like an advanced self-driving car, relying on a whole network of sensors, data links, and software to navigate the world without incident.

Let's break down the core pieces of this tech stack.

Remote ID: The Digital License Plate

The most fundamental piece of the puzzle is Remote ID. Think of it as a digital license plate for your drone. It continuously broadcasts basic identification and location data, letting air traffic control, authorities, and other aircraft know who you are and where you are.

This isn't just about accountability. It's about creating situational awareness for everyone in the sky. For any BVLOS flight under Part 108, Remote ID is completely non-negotiable. It’s what keeps your drone from being just another anonymous blip on a screen.

Detect-and-Avoid: The Electronic Eyes

When you can't see your drone, your drone has to be able to "see" for itself. That’s the job of a Detect-and-Avoid (DAA) system. The best analogy is the driver-assist system in a modern car, which uses radar and cameras to spot obstacles and prevent a crash.

A drone's DAA system works the same way, using onboard sensors to spot other aircraft—both crewed and uncrewed—and automatically steer clear of them. This is the single most important safety feature that replaces the pilot's eyeballs. A drone's ability to sense its surroundings is paramount, and you can learn more about what's out there in our guide to sensors for every drone pilot.

DAA tech generally falls into a few categories:

• Acoustic Sensors: These systems "listen" for the sound of other aircraft, making them great for detecting low-flying planes or helicopters nearby.

• Radar Systems: By bouncing radio waves off objects, radar can spot other aircraft from far away, even in bad weather like fog or rain.

• Electro-Optical (EO/IR) Sensors: These are powerful cameras, both visual and infrared, that use smart software to identify and track potential collision threats.

Command and Control Links: The Unbreakable Connection

Finally, none of this tech matters if you can't talk to your drone. That’s where Command and Control (C2) links come in. The C2 link is the data connection that sends your commands to the drone and relays critical information—like altitude, speed, and battery level—back to you.

For short-range VLOS flying, a standard radio link is usually fine. But for the long-distance missions common under Part 108, the FAA is going to demand much more robust and redundant C2 systems.

A lost C2 link during a BVLOS flight is a critical failure. Part 108 will mandate systems with built-in redundancies, like a primary satellite link backed up by a cellular (4G/5G) connection, to ensure the connection is never broken.

To pull it all together, here's a quick look at the core systems that will be mandatory for Part 108 flights.

Mandatory Technologies Under Part 108

Technology	Primary Function	Safety Goal
Remote ID	Broadcasts drone identity and location data.	Ensures accountability and situational awareness for all airspace users.
Detect-and-Avoid (DAA)	Senses and maneuvers around other aircraft or obstacles.	Prevents mid-air collisions when the pilot has no direct line of sight.
Command & Control (C2) Link	Maintains a stable data connection between the pilot and the drone.	Guarantees the pilot can always control the aircraft, even from miles away.

This trio of technologies—Remote ID, DAA, and a rock-solid C2 link—forms the essential safety net for Part 108. Each one addresses a specific risk of flying out of sight, and together they make it possible for drones to safely share the skies. Getting these systems in place is the first real step toward getting your operations ready for the future.

Preparing Your Part 108 Application

Getting your FAA Part 108 certification might look like a mountain of paperwork at first glance, but it’s much more manageable when you break it down. Think of it less as a bureaucratic checklist and more as a guided process for building a truly professional, safety-obsessed drone operation. The FAA isn't just looking for forms; they're looking for proof of a deep, company-wide commitment to safety.

The whole thing kicks off with some serious internal review. Before a single document gets written, you need a rock-solid understanding of what you’re actually planning to do. What kind of missions are you flying? Where will they be? And, most critically, what could possibly go wrong?

Phase One: Internal Audit and Risk Assessment

Your first move is a full-blown self-audit. This isn’t a quick once-over; it's a deep dive into the reality of your planned Beyond Visual Line of Sight (BVLOS) flights. The goal here is to draw a clear box around your operations and pinpoint every single hazard that comes with it.

Start by asking the tough questions:

• Operational Scope: Are you inspecting remote pipelines in the middle of nowhere, delivering packages in a quiet suburb, or surveying massive farms? Each one of these has a completely different risk profile.

• Airspace Analysis: What’s the airspace like where you’ll be working? Are you near an airport, flying over populated areas, or out in uncontrolled airspace where you're pretty much on your own?

• Environmental Factors: You’ve got to think about typical weather patterns, the terrain you’ll be flying over, and anything that could mess with your GPS or communication signals.

Getting this assessment right is the foundation of your entire application. It’s what you’ll use to build your Safety Management System (SMS), and it shows the FAA that you've already thought through all the ways a mission could fail.

A successful Part 108 application is built on a foundation of proactive risk identification. You must demonstrate that you not only understand the risks of your specific operation but have also implemented robust, documented strategies to mitigate them.

Phase Two: Building Your Documentation Package

Once you’ve got your risks mapped out, it's time to create the documents that tell your story. This is where you take all that planning and turn it into the formal package the FAA needs to see. It should be a complete and convincing narrative of how seriously you take safety.

These are the key pieces:

1. Safety Management System (SMS) Manual: This is the heart and soul of your application. It has to clearly outline the four pillars of your SMS: your Safety Policy, your Safety Risk Management process, your Safety Assurance methods, and your plan for Safety Promotion.

2. Technology Compliance Dossier: Pull together all the paperwork for your required tech. This includes everything on your Remote ID solution and the specs for your Detect-and-Avoid (DAA) system. You'll need data to prove your gear meets the necessary performance standards.

3. Training Program Outline: Lay out your complete training and qualification program. It should cover everything from initial to recurrent training for pilots, maintenance crews, and anyone else in a key role, proving you can build and maintain expertise in-house.

This phase is intense, but it's where you truly demonstrate your operational maturity. If you're coming from the world of waivers, you'll immediately notice the level of detail here is much higher. You can get a better sense of the jump by understanding drone waivers and regulations and how they compare.

Phase Three: Assembling and Submitting Your Application

With all your documents meticulously prepared, the final step is to put it all together and send it in. Organize everything logically. Make sure every section is clearly labeled so an FAA reviewer can find what they need without a scavenger hunt. Remember, a well-organized application hints at a well-organized operation.

Before you hit "submit," do one last review. Get a fresh pair of eyes on it—someone who isn’t familiar with the application—to check for clarity and catch any small mistakes. That final polish can prevent unnecessary delays. Submitting a clean, professional, and thorough package shows you're ready to join the ranks of certified FAA Part 108 operators and unlock the next level of what you can do with your drones.

Real-World Impacts Across Key Industries

To really get what FAA Part 108 is all about, you have to look past the dense regulatory text and see the business models it unlocks. For years, Beyond Visual Line of Sight (BVLOS) operations have been stuck in a frustrating loop of one-off waivers, making it impossible to scale up. Part 108 is the rule that finally shatters that barrier, creating a clear, standardized path for industries to make drones a core part of their daily work.

Think about an energy company managing thousands of miles of remote pipelines. Under the old Part 107 rules, inspections were a slow, expensive grind. Crews had to either walk the lines or burn cash on helicopters. With Part 108, that same company can now launch autonomous drones from a single command center to patrol hundreds of miles every day. Using thermal sensors, these drones can spot potential leaks in a matter of hours, not weeks. It’s a massive leap in proactive safety and environmental protection.

Transforming Logistics and Healthcare

Now, let's picture a logistics giant trying to change the game in medical deliveries. The old waiver system made setting up a dependable drone network between city hospitals a nightmare. You had to contend with heavy traffic, complex airspace, and endless red tape.

Part 108 completely flips the script. By establishing a certified operational framework, the company can create approved flight corridors to zip time-sensitive materials like blood samples and organs across the city. Suddenly, a one-hour drive through gridlock becomes a 15-minute flight. That’s a time-saving that can literally be the difference between life and death.

Of course, this all hinges on meticulous flight planning and sticking to ironclad safety rules. For example, understanding and navigating specific flight conditions, like the cloud ceiling aviation rules, is absolutely critical for keeping these BVLOS missions safe and compliant.

Precision Agriculture at Scale

Finally, imagine a massive agricultural operation overseeing huge swaths of farmland. In the past, checking on crop health was a reactive chore based on random spot checks. But Part 108 lets the farm deploy a fleet of BVLOS drones armed with multispectral cameras to scan thousands of acres around the clock.

The systemic approach of Part 108 is what makes these scenarios a reality. It moves beyond individual pilot waivers to certifying entire operational systems, enabling businesses to plan, invest, and scale with confidence.

This constant flow of data gives farmers the intel to apply water and fertilizer with surgical precision, slashing waste and boosting crop yields. The result is a more sustainable and profitable farming model, all powered by the efficiency that standardized BVLOS operations bring to the table. Each of these examples points to a fundamental shift—we're moving from limited, tactical drone use to strategic, system-wide integration that creates incredible new value.

Common Questions About FAA Part 108

Whenever new regulations like FAA Part 108 come on the scene, a flood of questions is sure to follow. It’s completely normal. This new rule is a big shift from the old way of doing things, so let’s clear the air on some of the most common questions drone operators are asking.

Getting these key points straight will help you see exactly how Part 108 fits into the bigger picture of drone regulations and what it really means for your operations.

Does Part 108 Replace Part 107

No, and this is a big one to get right. Part 108 absolutely does not replace Part 107. Think of them as two different tools for two different jobs. Part 107 isn't going anywhere; it will still be the rulebook for all standard drone flights that happen within the pilot's visual line of sight (VLOS).

Part 108 is a specialized, add-on rule built specifically to create a clear, standardized path for flying Beyond Visual Line of Sight (BVLOS). It’s designed to fill a gap that, until now, was only handled through a slow, painful case-by-case waiver process.

Is a Safety Management System Required for Small Operators

Yes. If you want to fly commercial BVLOS missions under FAA Part 108, you must have a Safety Management System (SMS). There’s no getting around it, and your company size doesn't matter.

But don’t let that scare you. The FAA is clear that an SMS should be scalable. In other words, the complexity of your safety system just needs to match the complexity of your drone operations.

A small outfit flying simple crop survey missions will have a much more straightforward SMS than a massive company running a drone delivery network in a city. The whole point is to have a system that makes sense for the level of risk you’re actually dealing with.

When Will Part 108 Become a Final Rule

The proposal for Part 108—the Notice of Proposed Rulemaking (NPRM)—has already been out for public comment. Once that window closes, the FAA gets to work sifting through all the feedback to draft the final version of the rule.

While government timelines can always be a moving target, industry experts are betting that the final rule will be published within 12 to 24 months after the NPRM. This is your window of opportunity. Use this time to start building out your safety protocols and operational plans so you're ready to hit the ground running the day it becomes official.

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At JAB Drone, we're committed to helping you stay ahead of these important regulatory changes. To keep up with the latest drone news, expert analysis, and in-depth guides, explore more at https://www.jabdrone.com.