Part 107 vs COA
Hey, all.
I'm a new program manager for a very new LE UAS program in Illinois.
I'm currently weighing whether or not it's worth starting down the COA path. Long term, my goal is to get FAA authorization to fly our M300 RTK over people, BVLOS, and visibility <3 SM. All the guides I'm seeing uploaded to LEDA presuppose you already have your COA. But my understanding is that you can also get these waivers under Part 107.
I'm hesitant to pursue COA mainly for two reasons. One, I doubt my big bosses are willing for all the liability to fall on the agency. Two, I wonder how burdensome monthly FAA reporting will be on top of our other patrol duties? I want the authorization ecosystem at my agency to be sustainable and relatively hands-off, in the event I leave.
Are such waivers worth pursuing under Part 107?
There is definitely more than one way to skin the cat on this one. It really depends on your airspace and the mission. Is there a reason you want to be able to fly "over people"? We typically will just offset and not worry about that "flight over people" aspect, since we have zoom capability. So you really don't need that waiver, unless you plan to literally fly and hover over people, which will demand some mitigation like parachute system or something.
The monthly reporting is not a big deal. It's a few boxes to check and input and submit, but if you're flying mostly under 107 and have a few COA flights, reporting a few COA flights per month is not big deal.
Now, the city of Gresham, my former agency, operates off of both part 107 airspace waivers and COAs, depending on the mission and altitude needs. A large portion of the city is in Class D airspace, and a lot of missions are flown in Portland, near Class C airspace at PDX. This means there are some areas that are 0ft grids and a COA is necessary, taking the Part 107 waiver out of the picture. If you have any bit of controlled airspace, I would recommend both part 107 and COA, just to have the ability to fly up to 400 ft anywhere in your jurisdiction. There are just a few hurdles to jump through on the COAs like calling the ATCT before and after the mission to coordinate if you're going to be flying above the P107 altitude restrictions.
If you're looking for a <3SM waiver, you might as well just do a SGI (Special Government Interest) waiver the day of the operation, instead of a standing COA for that. You can call/email the SOSC with the application/request and coordinate with them and they will work with you on that. Usually it will involve a TFR for that area, since you'll be operating BVLOS basically, but it's certainly possible. There is a lot to unpack on all of this stuff, and we will probably work on unpacking it into a video for our members at some point in the near future. Hopefully that helps!