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BVLOS UAS Operations: FAA Certification and Waiver Counsel

The Legal Problem

Beyond visual line of sight (BVLOS) UAS operations represent the commercial frontier for drone delivery, infrastructure inspection, and autonomous aerial systems. They also represent the most legally complex category of UAS operation. Under 14 C.F.R. Part 107, BVLOS operations require either a waiver under § 107.200 (demonstrating that the operation can be conducted safely) or a type-certificate-based operational authorization for more routine, scalable deployments.

The FAA BVLOS waiver process requires a detailed operational safety case addressing airspace awareness, collision avoidance, communication link reliability, and emergency procedures. This safety case is both a regulatory document and a legal artifact: it defines the conditions under which the operation is authorized, and any deviation from those conditions exposes the operator to regulatory enforcement and civil liability.

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guibert.law Insight

The FAA BVLOS waiver is operation-specific, not operator-specific. A waiver granted for inspection of a specific power line corridor does not authorize BVLOS operations in a different airspace environment. Operators who expand BVLOS operations beyond the specific parameters of their waiver are operating without authorization — creating both enforcement exposure and uninsured liability risk.

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