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Amid Increased Interest in Part 135 for Social Distancing, FAA Says Existing Framework Allows for Most Operations Needed Right Now

BY Zacc Dukowitz
16 April 2020

Politico recently reported that drone companies are eager to help in the COVID-19 fight, but being held back by the FAA.

Drone companies say they can step up . . . but regulators at the FAA have largely stuck to their guns, saying their rules remain the same and they aren’t doing anything outside their typical approvals.


Specifically, drone companies are being held back because they are not able to make drone deliveries Beyond Visual Line of Sight (BVLOS).

To do this, companies need to hold a Part 135 certification. But getting a Part 135 is a long, difficult process that involves five in-depth phases.

Currently, only two companies have Part 135s—Alphabet’s Wing and UPS’ Flight Forward—while several other companies, including Amazon Prime Air and Zipline, are in the process of applying for their Part 135.

Photo credit: UPS

Given the urgent need for drones to help with medical deliveries right now, Zipline’s CEO Keller Rinaudo has expressed frustration about delays in its Part 135 application, saying, “The technology is already saving thousands or tens of thousands of lives in other countries . . . It’s really a question of the U.S. joining the club.”

So What Can Be Done to Fight COVID-19 without a Part 135?

We reached out to the FAA to ask about what can be done under the existing regulatory framework to help with the fight against COVID-19.

And it turns out there is a lot that can be done without having a Part 135—even drone delivery, so long as it’s within Visual Line of Sight (VLOS).

The FAA is enabling drone use for COVID-19 response efforts within our existing regulations and emergency procedures. Our small unmanned aircraft rule (Part 107) and Certificate of Authorization process allow operators to transport goods and certain medical supplies . . . provided the flight complies with all provisions of the rule or authorization.


Note: Public safety agencies can choose to fly drones for work under either Part 107 or a COA (or both), while private citizens can only fly for work under Part 107.

Work at a public safety agency? Learn more about choosing between Part 107 and a COA.

Image source

Here are four of the most common types of operations in the COVID-19 fight, which are all allowed under the existing regulatory framework.

1. Making Drone Deliveries to Support Social Distancing

Both the Part 107 rules and COAs allow operators to make package deliveries within VLOS, so long as the drone remains within state boundaries and carries non-hazardous materials.

This means that medical deliveries of test kits, most prescription drugs, and blood (so long as it’s not known to be infected with COVID-19 or other hazardous diseases) are allowed without special permission from the FAA. It also means that food or deliveries of essential items are allowed.

Where could you use VLOS drone delivery? Here are a few scenarios:

  • Delivering food to a nursing home to avoid direct contact with those at the most risk right now
  • Carrying medical supplies or blood samples short distances to minimize human contact
  • Transporting goods, food, or prescriptions to a relative from a parked car to help maintain social distancing

2. Using a Drone as a Loudspeaker

The Part 107 rules also allow a drone to be used as a flying loudspeaker, as do COAs.

This is one of the most common use cases we’ve seen for drones in the COVID-19 fight. The benefit of this use is that drones can help public safety agencies broadcast safety messages to large groups of people without requiring workers to get physically close to them, which could increase their risk of infection.

In the U.S., the towns of Chula Vista, CA and Elizabeth, NJ are currently using drones equipped with loudspeakers to broadcast messages about public safety. This tactic is also being used in countries around the world, and will likely grow in the U.S. in the coming weeks.

3. Using a Drone as a Flying Visual Thermometer

Some countries have used drones equipped with thermal cameras to take people’s temperatures remotely in order to help with the COVID-19 fight.

This is also an operation allowed under either Part 107 or a COA, so long as the drone is flown VLOS.

4. Using Drones to Spray Disinfectant

We haven’t heard about this use case here in the U.S., but other countries—notably China—have used retrofitted agriculture drones to spray disinfectant.

Using this approach can help cover large areas in a short period of time, and would also be allowed here in the U.S. under Part 107 or a COA.

Fast-Tracking COVID-19 Waiver and Special Government Interest Requests

In addition to operations currently allowed under Part 107 or a COA, the FAA told us that they are working hard to fast-track all COVID-19 waivers and Special Government Interest (SGI) requests that they receive.

Note: An SGI is “approval for operations that directly support appropriate government, health or community officials during a natural disaster or other emergency situation.” Find out how to apply for an SGI here on the FAA’s website or submit a waiver request through the FAA’s Drone Zone.

The FAA also issues special approvals, some in less than an hour, for flights that support emergency activities . . . The agency’s Systems Operations Security Center is available 24/7 to process emergency requests. Safety is the top consideration as we review each request.


To date, the FAA has issued 10 COVID-19-related SGIs.

Here is the breakdown of the number of SGIs granted and the specific Part 107 regulation(s) waived for the operation:

  • 7 Site Survey (107.41)
  • 1 Media Related (107.41)
  • 2 Related to Southern Border Activities (107.29, 107.31, and 107.51)

The public safety agencies that received these SGIs include the Los Angeles Fire Department, the City of Norfolk Police Department, the City of Syracuse Fire Department, the County of Washington (NY) Department of Public Safety, and the Township of Union (NJ) Police Department.

Why Aren’t There More COVID-19 SGIs?

When asked about the relatively low number of SGI requests related to the COVID-19 fight, the FAA pointed out that this indicates the current system is working as it should.

That is, the low number of SGIs indicates that special permissions are not required for most of the operations needed right now in the COVID-19 fight, since these operations can be done under the existing regulatory framework.

Other Ways Drones Are Being Used in the U.S. to Fight COVID-19

How else are drones helping in the COVID-19 fight here in the U.S.?

Here are a few ways.

Wing’s Drone Delivery Program in Christiansburg, VA

The people of Christiansburg, VA are taking full advantage of their drone program to support social distancing measures.

We’ve actually seen a significant uptake in our service, with those customers that we are having order from our service, so we’ve had some record-breaking days over the last couple of weeks.

– Alexa Dennett, Spokesperson for Wing

The program is going so well that Wing has expanded its offerings, adding two more companies and more products to the items that can be received via drone delivery.

Photo credit: Wing

DJI Donates 100 Drones

DJI has announced its plans to provide 100 drones to public safety agencies in the hardest-hit parts of the U.S. to help in the COVID-19 fight. Some of these drones are being provided as a donation while others are part of an extended loan program.

The initiative includes supporting hardware and software, and comes with training, technical support, and repair service.

Photo credit: DJI

Do you think drone delivery companies should have their Part 135s fast-tracked right now, or do you think there are plenty of operations available to fight COVID-19 without taking that step? Share your thoughts in this thread on the UAV Coach community forum.

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