# Understanding the FAA Regulatory Framework for Docked BVLOS Operations

- Event: NestGen ’25
- Published: March 7, 2025
- Length: 33:18
- Watch: https://nestgen.org/library/watch/1LHOSVVJZm4/

> The transcript of a recorded NestGen session, for reading or for use with an AI tool. It comes from the video's
> captions; automatic captions can mishear names and terms.

## Transcript

**[0:20]** so yeah hello everyone um welcome to another Power House session at NestGen 2025 I'm J and today we will be exploring the evolution in aerial security understanding the FAA regulatory framework for docked BB loss operations so I'll just quickly play this short introductory video for you guys perfect so think about it traditional drone operations rely on visual line of sight operators watch screens and then react but what if drones could operate autonomously

**[1:24]** from a dog detecting and responding to threats before they escalate that's exactly what we're going to unpack today and for that we have akaki Kula with us it's my pleasure to introduce Our Guest Mr akaki akaki is a recognized expert in BB loss operations with a background in air traffic control and significant contributions to FAA policy development and unmanned aerial systems his work on FAA initiatives and the implementation of rigorous safety protocols has played a key role in advancing BB loss operations and integrating drones into the national airspace so welcome akaki before we start this session I would like to have a big shout out to our sponsors for the day for making this possible and uh just to run down a few housekeeping rules um we are going to have a live Q&A session you can drop your

**[2:25]** Q&A questions into the box anytime and akaki will address them during the final segment this session is being recorded So if you miss anything do not worry you can always rewatch it later and last but not the least engage with us share your insights thoughts and favorite takeaways on LinkedIn and Twitter and use hash nesg 2025 and the top three posts will receive special NES gen hampers so over over to you akaki the stage is all yours thank you Jay uh hi everyone uh yeah my name is aulia U let me share screen okay J let me know when I'm there we go I think I'm sharing right yes you are akaki yeah okay thanks yeah uh my name is akaki kulia uh

**[3:31]** um I have uh more than 20 years experience I think uh in aviation field uh started as an air traffic controller then moved to the uas Drone world and since 2014 supporting fa NASA and bunch of different things mostly related to the uas starting from 2020 uh really dive into uh drone world and the US detect Andoid world so been working with a couple of companies with their technology and then um doing quite a lot of um waiver applications for the companies to uh get the operational approval in the US so yeah doing a bunch of uh things uh and today I want to talk a little bit about kind of like what kind of like regulatory environment we have in the US uh regarding specifically for the don't drop operations um so uh let's let's start maybe with the yeah with the part 107 rule right so

**[4:38]** this rule probably a lot of you heard about it and probably a lot of you operate under that is that it is uh rule for us operations for vloss right like Vision line of sight and it is suitable mostly for the small scale operations so when this rule was written I think uh I think exactly 10 years ago don't remember exactly I think 2014 2015 uh it was mostly for the hobbyists right like for the small drone operation operators who wanted to fly around their house maybe or like do some kind of like roof inspection on their house or uh again like for this small um uh small uh operators and then um there was no rule to how to operate that so that's why fa came up with this rule it is again for the small scale operations right so there are some Provisions there are some uh regulations there uh which um uh let's say you are not

**[5:41]** allowed to uh do a BV loss operations right B Be onl Visos operations or obso people you're based on this rule you're not allowed that but uh you can require a waiver and exemption from this Ro so that's a lot of people are doing been helping them so yes you know you can fly BV loss operate BV loss uh if you get a waiver from the uh FAA same goes with the Ops over people uh there are certain um regulations which can be Exempted so let's say yeah BB loss Ops over people there's altitude and couple of others uh uh and these speos uh waivers usually what we're talking about today is uh mostly ref to the specific uh locations and uh they have a bunch of other limitations if you've seen one of the pros actually there's a public website uh part 107 waiver where you can go and like see all the waivers issued uh by the

**[6:44]** FAA it's public information there's a link for that so you can easily find that so in that there's a bunch of like standard uh limitations and then there are specific operational limitations you won't really find specific uh like details of the actual let's say my my operation but you can have maybe like more or less an idea what's going on there but going back to like uh it has uh all these waivers have like specific locations and limitations so couple of companies you might heard to they actually got the um uh non-geographically constrained uh waivers right so technically they can operate whever they want but this doesn't necessarily mean that hey you know you go somewhere from specific location and then fly there you still have to do your homework so still um while it is non-geographical uh constraint it is you have to comply with certain rules and

**[7:46]** limitations there H and specifically for uh this rule as I said that it was designed for specifically for um small operators then by the time I think there was no like big companies who were like looking at like package delivery or like long linear infrastructure inspections and so on so for instance even part 107 uh itself it doesn't necessarily allow uh the commercial operations for hire so if you want uh if you want to hire someone to like deliver your package uh that entity cannot do that they have to become this part 135 operator right like like a commercial like a kind of like Airline uh um operator and then you have to hire them and so on there are some uh loopholes how you can avoid this and so on I won't go into details for this but uh still a lot of like let's say like big players uh I think they're around I guess

**[8:48]** up to 10 companies maybe not five to 10 let's say like that uh who already obtained this part 135 uh certification for them so they can operate as an airline and then do package delivery or other big scale operations so again uh they maybe can operate part 107 rule but they have to be this part 135 uh today I'm not talking actually uh about the another rule uh another general rule which is part 91 which is usually um usually public entities like um drawn as a First Responders like police or other government entities are using this part 91 uh operations uh on their behalf so that's kind of like a different I think most of the audience here what we have is mostly uh for on 107 R so uh it was um go to the next slide yeah so uh what challenges we have uh while operating uh under part 107 specifically for docked uh docked uh drones right so

**[9:53]** and then I listed here several there probably a bunch more or less depending on who you are part uh first and foremost uh da right detect and avoid it's pretty close to me so that's why I always highlight that but um we have to you know like for good or bad like we have to uh detect uh other crude aircraft either they're Cooperative or non-cooperative but we have to detect those and then eventually uh avoid those how do we do these uh let's say specifically for corporative traffic it's kind of uous now that uh adsb uh in like you have to have adsb in and then you detect everyone who is uh uh have uh adsb out signals so you detect them quite far out and then you eventually somehow avoid them uh another kind of like a big elephant in a room is this uh non-corporate traffic which are not transmitting adsv signals so

**[10:56]** this the number of this um aircraft depending on the airspace uh usually they're not a lot but they're still there in some airspaces they are legally uh uh they they can legally fly they can legally fly even without the r radio right so in these kind of situations um we need to somehow detect this traffic so um there are a bunch of different uh Solutions how we do this you know it is a radar visual or acoustic or different solution especially now there are like bunch of companies who can provide you depending on what's your appetite for that like what is your actual operational area some solution might be suitable for some area another for another um and another one what I don't want to talk about is the C2 and specifically actually maybe yeah like a link right between the op Center uh to the ground station and to the vehicle so this is uh becoming more and more an issue when

**[11:59]** we talk about the uh do B loss operations and especially with the remote operations because imagine if you uh have the op Center somewhere in one location and then you actually have the dock which is kind of like unmanned right like no one goes there it's like totally automated in one location let's say it's some kind of power plant and then eventually a drone which like departs from this drone and then does inspection and comes back so basically this link between um op Center to this ground station or SL dock to the vehicle it is very important that we have really good uh connection right so uh and then you have to uh think about the latencies between you know the final operator and the Drone so and um maybe it's not a big issue uh specifically for the docked uh drones because the usually the distance from the uh

**[12:59]** dog to the Drone is not that big so usually there's a good C2 collection but I've seen um multiple waivers when um uh people think that you know the daa is the biggest problem but it appeared that actually a good C link was a problem so you know they they mitigated the uh air risk but like they couldn't have a solution for good CO2 uh C2 link so that was a problem so you know like they could fly theoretically to like don't know 20 kilm but you know there C2 link was not so just new operations yeah specifically if you have this remote operator somewhere out there uh it is very important to have this like really good link uh between op Center to ground station eventually to that vehicle uh uh ground risk I think that's pretty obvious overflying over people not involved in your operations um eventually like yeah in 107 rule we have to think about how are we mitigating risk of people on

**[14:05]** the ground when we are overline them if something happens with a drone uh what how we reduce the risk there are a bunch of uh uh ways to do this let's say the first uh now it's kind of becoming more and more popular putting a hair shut on the a drone itself and then reducing that's why uh that way the kinetic energy something happens they go parachute then it comes down slowly uh another thing is let's say like Sheltering play shelter right like so uh people can be under some roof or something or they wear Helmet or you just like notify all those people who are let's say in your power plant when you inspect you just notify them that hey there's a drone operation in these hours please wear helmets and so on so uh why I put it here is that as we go into like more and more operations uh specifically with a with a dog drones when actual you know human operators are not

**[15:11]** there so it could be uh it could be uh pretty like some people might get kind of used to it so like like you don't even like pay attention that anymore right it's like regular so that you know like wearing Helmet or like shelter and so on that's pretty important uh autonomy and automation so this is a when I was putting this uh a bullet point here I was kind of like laughing at myself because I can talk about this like three hours but I I'll try to do in 30 seconds so uh basically Regulators do not and you're plan for the waivers like Regulators do not really like the word autonomy so just try to stay away from the word and then put uh highly aut automated operations because you know autonomy is like very heavy word you know like and to be honest probably at this point we don't really have fully autonomous systems you know

**[16:14]** they're uh they're highly automated but like uh if if it goes to some decisions they don't necessarily take those decisions by themselves right so uh what Regulators like to have and they they acknowledge all of this and then and they say like okay it's highly autonomous or highly automated systems there should be some sort of like a pilot in the loop or on the loop or like be pilot manager so on right so uh having that some human oversight over the operations is very important so uh I I've been warned by a lot of uh Regulators like just don't use this word autonomy you can you can use it for your marketing purposes and so on but like uh when you go to the uh regulator um it's highly automated right and uh the last one which which is very important and I think becoming an issue uh uh more and more and uh I think we have to talk more about that and

**[17:17]** actually I give give Kos to flight Bas for this like integration right I know like what a lot of people um when they're starting want to operate uh uh BV laws or even vws right so you are getting different Technologies from different uh companies So eventually to integrate this into one entity and then have like actual uh operation it's it's not an easy task so uh like kudos to you guys to FlytBase that like integrating like different Services under one umbrella and then uh providing the service to the customers I think that is very important and then it is it will become uh more complex and complicated in the future and then the companies who are trying to do this uh aggregation of different sensors let's say like different uh services and then offering to the customers um that is uh that is like

**[18:20]** really really important and then it's easier for the uh for the Regulators also like cuz when they see that oh these guys are using FlytBase like say right so okay they know what is flight bays are uh capable of so it's like having this uh name and then recognition from the different Regulators it really helps so yeah this integration uh I think uh different companies will be uh becoming bigger and bigger so I think it's it's good because you know I can go and buy a lot of like different services or different hardware and software and try to integrate myself probably I won't do that right like that's why I go on a market and then see what can I uh what other companies can offer me uh okay next slide so yeah drone does and shielded Ops um uh waivers right so um usually these uh waivers are

**[19:20]** um proved on certain limitations and certain uh areas right so usually they are on the plant routes with the strect GE fense which is kind of like a normal uh what is really interesting is like our rpic or uh pilot should be located in the US so they tell you that okay you know if if the rpac is not at the side it is okay but that that operational Center should be in the US uh you have to make sure that um uh the take of and Landing site is clear of obstacles and any humans which is kind of like normal right and then that that drone the UAV should be within um and I put here this like 50 to 200 feet of the infrastructure or a or about ground level like Shield basically in this shielded airspace at this point we don't necessarily have any specific number or distance where uh fa says that okay this is

**[20:21]** a distance which is in the shielded bubble right so it is uh it is uh dependent on actual uh conops actual location airspace and so on so what started couple of years ago I think uh they started with a 50 ft bubble basically 50 ft within infrastructure or above ground level and then I think like last year and like several um months ago they even increased this to like 200 fet so you know 200 feet bubble around the infrastructure or uh ground level uh and uh the last Point here that operations should be conducted only on the uas and docking station that was identified in the conop so if for some reason you're changing your drone or your docking station eventually you have to reapply for it could be probably like simple reapplication but you know it's not it's not the same system so you have to reapply

**[21:24]** for the W uh and I guess this is another topic I can uh uh talk for like 3 hours maybe uh but uh basically what we talked about though uh before was that part 107 Rule and waivers and so on So eventually starting I think 2020 uh it was a Aviation ruem committee uh which basically everyone from the industry came out like hey you know we need some uh solutions to uh scale up the BOS operations right like a lot of people want to uh do B loss operations so what we do so they came up with a recommendations it was like months long process and uh eventually the the biggest recommendation was that hey we need to have the specific rule which would be for uh BV loss operations so uh thenf started working on that so if they say like okay thank you guys you know for

**[22:26]** your recommendations and then it was kind of announced that they will start work uh on part 108 um long story short we're expecting that to come out uh sometime end of NE last year it did not so we're expecting now that it will hopefully come out in coming uh coming uh months I would hope and uh we as an industry we will have like two months to um uh comment on this rule uh then eventually fa will uh collect all these comments adjudicate them and then come up with the um final rule the best case scenario it would be end of from my point of view also like uh it would be uh end of this year but I don't know a lot of things could happen it could get delayed so what to expect now in uh in uh in this new rule right and then these are kind of my

**[23:29]** assumption so like uh don't judge me on this but this is what I expect um that I think we'll have some sort of like shielded operations will be somehow codified so at this point shielded operations there uh there's no even not even any definition from the FAA or I think any I think maybe Trans Canada has it but FAA doesn't necessarily have anything like what is sh operation no one knows so there will be some sort of like definition of that and maybe a distance uh I anticipate that there will be some sort of Da will be required for most of the advanced operations you know big package delivery throughout let's say uh big areas and so on um it will be uh and we heard about that that yes it will be a lot of references to the industry standards so uh let's say rtca or STM or sa for that matter uh there are a bunch of different standard development organization working on US Standard so this rule will specifically say like hey if you want to have C2 uh there

**[24:34]** is a standard for that so you have to comply with that or if you don't comply why don't you comply and so on so it would be like references uh what we what this is also speculation there might be some kind of like um U um less strict requirements for the Ops and uh operations in moel because Mel is we know that you have to have adsp uh out so maybe there will be some kind of like less strict requirements there we don't really know uh we'll have probably more gr ground risk categories because right now we have uh rural suburban and urban so uh we'll have probably more categories and then um last uh not least is software management system right so I think we'll have uh specific requirements for like what kind of software is controlling your dock or your drone and um uh who can make the changes on that how often you're changing uh the software and

**[25:35]** so on uh I think I have a last uh uh slide and then we go into uh questions what to not to expect again these are my speculations uh I don't expect that we'll have a millions of drones in the sky all of a sudden I I definitely don't expect that uh that everyone can fly BB loss and then everyone can fly in in any airspace or any geographical area no I think we still will have uh pretty strict requirements from the uh regulator it will be just like a more Baseline because sometimes I've seen that we will submit like more or less similar waiver for two different companies and then they've been asked uh go uh to submit different documentation so I think what we'll have with the part 108 we'll have more like streamline Baseline requir ments from the regulator and that way uh we can be prepared for that uh I'm going to stop right now and then maybe we can go into q& a

**[26:39]** j sure akaki thank you so much uh for this informative session on the BB loss waiver and I'm sure your insights on the approval criteria and the best practices for securing the waivers is going to help our audience today so let's quickly just go to the Q&A box we have a couple of questions here um so the first question is how do organizations transition from traditional visual based drone operations to BV loss autonomous flights okay so that that's a that's a good question um I always tell people that um it is good idea to start small and then increase right like hey if you if you're not experienced like do vloss operations you know get those hours and then those hours really help when you submit to the fa or any regulator that say like hey

**[27:42]** I've done this many hours of operations uh doing this right and then eventually like when you're comfortable and then you know sometimes uh sometimes you like V loss but eventually you could be like kind of BV loss right like so kind of like transitioning and then uh going into the BB loss that's really good idea uh it gives you more confidence to you to in your operations and then um again like uh showing to the regulator that you're not you know this like someone who like wrote like five pages and then want all of a sudden fly into class the airport or Class B airport or that matter that so just showing your progress from you know V LW to BB loss it's it's a good idea and then it's a good idea also for you that like you train you know like you will find out a lot of things about your uh uh system so yeah that's that kind of like Smooth transition I recommend to

**[28:47]** everyone right um so we have another question uh what measures ensure that dock BB loss operations compliant with evolving FAA guidelines and Industry standards yes so again uh what we hoping that maybe in the new rule we will have some sort of uh more clarity about that at this point there is no specific regulation which uh regulates the dock uh docks and so on so it's very much kind of like a back and forth with the regulator like hey what do you do with that would but uh what is also good maybe that there are not necessarily a lot this dock uh uh companies right they're probably like several so more or less regulator kind of maybe already knows where they about so uh just to uh if you're not a manufacturer of that and you know if you're buying from someone probably right like

**[29:51]** try to get as much documentation from them and then just like be uh like ready to answer those questions so uh hopefully we'll get more uh certain like regulations and uh I'm not aware of any standards but is specifically working on the dogs uh maybe in the future if you know this becomes more and more uh popular probably we'll have more uh content about that right um we have a question from David are you seeing wavers being issued when no human observations is uh being used on the physical side only using a remote pilot monitoring the screen in a command center offsite Yes actually we're seeing seen a couple of those and uh that's why when I was in one of my slides when I was uh talking about that good link between the op

**[30:54]** Center to the dock to the drum so yes I think eventually that's the future that's what everyone wants to do uh and then uh we are going towards there and then just to have that good connection good organization of your operations that would be really vital I think like moving forward right um so I think we'll take one last question um does part 107 prohibit China products and what kind ah good question uh part 107 doesn't uh so it's a it's a it's a it's a it's a rule about the operations so what do you have uh what kind of like a rule uh what kind of product you have on your uh basically 107 doesn't say anything about the origin of your uh technology specifically that you might be prohibited for something

**[31:57]** else I don't know there's a lot of things going on right but at this point I haven't seen so far I haven't seen anything so far prohibiting anything based on the origin of the country maybe in the future but specifically I don't think it would be in the rule or in part 108 rule that you'll be like hey like no China product or something I don't I don't see it specifically seen in this specific rule maybe some other uh um regulation or some rules come out but yeah this is purely about the operations right right so I guess we've covered all the questions from the Q&A box uh sincere thank you to you akaki for sharing your insights and yeah a big thank you to our audience as well for your active participation and making this session as amazing as always yeah so uh signing off enjoy the rest of Nan 2025 thank you so much

**[32:59]** uh thank you yeah bye bye