What is Part 108?

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 14 CFR Part 108 applies to all civil uncrewed aircraft operations conducted beyond visual line of sight, with limited exceptions. It covers both small and larger UAS and replaces the previous patchwork of waivers and exemptions for routine BVLOS. The rule is structured to work alongside Part 107 (for VLOS operations) and Part 91 (general operating rules), creating a cohesive regulatory ecosystem.

 Operating Permits (Subpart D) for lower-risk operations, typically in rural or sparsely populated areas and Class G airspace.

Operating Certificates (Subpart E) for higher-risk or larger-scale operations, such as flights over populated areas or in more complex airspace, which require a formal Safety Management System (SMS) under Part 5.

Part 108 establishes clear baseline requirements, including:

• Mandatory integration with  approved ADSP services for strategic deconfliction and traffic awareness.
• Use of approved Detect and Avoid (DAA) systems capable of maintaining “well-clear” from other      aircraft and obstacles.
• Conformance monitoring to ensure the aircraft stays within its approved operational intent.
• Pre-flight planning, weather assessment, and contingency procedures.
• Strict prohibitions against operations that would endanger life or property, reckless      behavior, or interference with manned aircraft.

These rules apply uniformly whether operating under a Permit or Certificate.

  Operators must equip their UAS with:

• Remote ID broadcast capability
• Electronic conspicuity ADS-B Out or equivalent where required)
• Reliable command-and-control links with lost-link procedures
• Approved DAA systems meeting performance standards
• Appropriate lighting and marking for visibility

Performance standards are largely outcome-based, allowing innovation in technology while requiring operators to demonstrate that their chosen solutions achieve the required level of safety.

  Part 108 introduces the new role of Flight Coordinator for supervisory oversight of automated or multi-aircraft operations. The Remote Pilot in Command (RPIC) retains ultimate responsibility, but day-to-day monitoring can be shared. Clear procedures for transfer of control, emergency response, and record-keeping are required.

We are still waiting for the Final Rule and there will be 180 days before it goes into effect, but If you have a current operation under Part 107, 44807 Exemption, or just getting started and you want to be ready with a Permit or Certificate feel free to reach out to us.