Beyond Part 107: What Part 108 Means for the Future of Drone Pilots


Why New FAA Rules Could Redefine BVLOS, Training Standards, and the Role of Manufacturers in Drone Safety
“Part 108 opens a door—not just for new rules, but for new responsibilities.”
In a pivotal episode of The Unmanned Podcast, host Matt Hernandez leads a roundtable discussion with three of the industry's top voices: Josh Olds, CEO and Co-Founder of the Unmanned Safety Institute (USI); Alex Mirot, USI’s VP of Product Development and Co-Founder; and Rob Knochenhauer, Director of Regulatory Affairs at Censys Technologies. Together, they unpack the FAA's newly proposed Part 108 rule—a long-anticipated regulatory shift that promises to expand drone operations beyond visual line of sight (BVLOS).
From certification pathways and training requirements to implications for OEMs and safety culture, this conversation delivers a masterclass in what's next for commercial UAS operations.
Q: Matt, let’s start with the big picture: what makes Part 108 such a game-changer?
Josh Olds: Part 108 is the most comprehensive proposal we’ve seen from the FAA since Part 107 launched in 2016. It's not just a rule change—it's a structural overhaul of how drone operations can scale in the U.S. It opens the door for routine BVLOS operations, but more importantly, it introduces new levels of accountability, like mandatory training standards and defined crew roles. This is a serious pivot toward aviation-grade professionalism.
Alex Mirot: Right. 107 gave us the ability to get drones in the air commercially, but it was always limited by line-of-sight constraints. Part 108 addresses that constraint directly and provides a framework to do more—safely. It requires not just a knowledge exam, but documented, repeatable training across crew positions, system types, and operational contexts.
Rob Knochenhauer: From a manufacturer's standpoint, the stakes are huge. Part 108 outlines certification paths not only for operators but also for equipment. That means UAS manufacturers need to prove airworthiness and operational reliability. It brings a level of rigor that mirrors traditional aviation—and that’s a big shift for the industry.
Q: Let’s dive into that. What does this mean for training providers and workforce development?
Josh Olds: It legitimizes what USI has been building for a decade. Training is no longer a nice-to-have. It’s mandated. Part 108 requires documented safety management systems (SMS), risk mitigation strategies, and aircraft-specific training. That fits directly into our Safety Levels 1 through 4 and ASTM-aligned certifications.
Alex Mirot: Absolutely. This is about turning drone pilots into aviation professionals. 108 explicitly defines crew roles—Remote Pilot in Command, Visual Observers, System Technicians—and requires competency in each. It raises the bar and creates a demand for training programs that can deliver real-world readiness.
Matt Hernandez: So this also transforms how schools and partners approach UAS programs, right?
Josh Olds: Correct. Educational institutions need to start thinking like aviation academies. It’s not just about passing the Part 107 test anymore. It’s about building a workforce that can plan, operate, and manage risk in complex airspace environments.
Rob Knochenhauer: And it means training partnerships need to be robust. OEMs like Censys will need to align with training providers to ensure crews are proficient on specific platforms. It’s not just plug-and-play anymore.
Q: Rob, what’s your perspective on the OEM responsibilities outlined in Part 108?
Rob Knochenhauer: It’s a seismic shift. Under Part 107, operators carried the entire burden of proving safety through waivers. Now, under 108, manufacturers must validate system performance, provide documentation, and possibly participate in pilot training. That’s a welcome evolution—it levels the playing field and raises standards across the board.
Josh Olds: It also incentivizes manufacturers to design with training and operational transparency in mind. That’s something we’ve been advocating for: aircraft that are not only safe, but teachable.
Alex Mirot: And it changes how manufacturers think about product lifecycle. If you’re going to be held accountable for safety and training, your support ecosystem has to evolve. It’s not just about selling hardware.
Q: One of the most exciting parts of the conversation was about safety culture. What did 108 get right here?
Alex Mirot: It nailed the importance of SMS. For the first time in UAS regulation, we see a mandate for documented, auditable safety practices. That includes hazard reporting, mitigation strategies, crew communication protocols—all things USI teaches at Safety Level 3 and Safety Level 4.
Josh Olds: We've long believed that aviation safety isn’t just a checklist—it’s a mindset. What 108 does is establish a regulatory expectation for that mindset. That’s a major win for everyone who’s been building these systems from the ground up.
Rob Knochenhauer: I’d add that for OEMs, this helps us speak the same language as operators and regulators. SMS isn’t just a box to check. It becomes part of how we design, support, and refine our platforms.
Q: Are there any blind spots or potential challenges in the current draft of Part 108?
Josh Olds: There are still gray areas—especially around how training institutions will be evaluated and who gets to certify what. There’s a lot of language about "acceptable" training without detailing what that looks like. That’s where the industry needs to step in with consensus standards.
Alex Mirot: And the timelines. Transitioning from waiver-based ops to certified ops is not going to happen overnight. There needs to be a roadmap for implementation, funding, and workforce upskilling. It can’t be a cold switch.
Rob Knochenhauer: From a regulatory affairs lens, enforcement will be critical. If manufacturers and operators are held to these new standards, there needs to be consistency in how the FAA inspects and evaluates compliance.
The Era of Ad Hoc is Over
As the roundtable made clear, Part 108 isn’t just a new rule—it’s a cultural shift. It creates defined career paths, demands accountability from OEMs, and elevates training to a professional necessity. It signals that the days of ad hoc, waiver-based BVLOS are numbered.
For USI, it's validation. For the industry, it's transformation. And for drone pilots and program leaders, it’s time to step into a new era of responsibility and opportunity.
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🎧 Looking for more resources on Part 108? Listen to the full episode now!