What are Part 108 Permitted Operations?
Part 108 permitted operations are lower-risk BVLOS drone flights authorized through one of eight FAA permit categories, each with specific fleet limits, weight restrictions, and population density constraints. Permits offer a streamlined approval process with 24-month validity, making them ideal for commercial operators seeking routine beyond visual line of sight capabilities without the enhanced oversight requirements of certificated operations.
The FAA's Part 108 Notice of Proposed Rulemaking introduces two distinct pathways for authorizing beyond visual line of sight drone operations: operating permits and operating certificates. Understanding which pathway aligns with your business model is essential for planning your transition from current Part 107 operations to the new BVLOS framework.
This guide breaks down the eight permit categories, compares them against certificated operations, and provides practical guidance for determining which authorization pathway fits your operational needs.
Table of contents
- Quick comparison: permits vs certificates
- The 8 permit categories explained
- Understanding population density categories
- Permitted operations requirements
- Certificated operations requirements
- Which path is right for your operation
- Application process and timeline
- Industry use cases
- Frequently Asked Questions
- Implementation considerations
- In summary
Quick comparison: permits vs certificates
Before diving into specific categories, understanding the fundamental differences between permits and certificates helps frame the decision-making process.
| Feature | Operating Permit | Operating Certificate |
|---|---|---|
| Risk Level | Lower-risk operations | Higher-risk operations |
| Fleet Limits | Category-specific limits | No fleet size limits |
| Population Density | Categories 1-3 only | Categories 1-5 |
| Validity Period | 24 months | Ongoing with oversight |
| SMS Required | No | Yes |
| FAA Oversight | Standard | Enhanced |
| Application Advance | 120 days | 120 days |
| Hazmat Carriage | Prohibited (limited exceptions) | Permitted with authorization |
Permits are designed for operators conducting routine BVLOS operations in less complex environments. Certificates accommodate larger-scale operations requiring flexibility across diverse operational scenarios.
The 8 permit categories explained
The Part 108 NPRM establishes eight distinct permit categories, each tailored to specific commercial and recreational use cases. Fleet limits, weight restrictions, and population density constraints vary significantly between categories.
Package delivery
The package delivery permit supports commercial drone delivery services operating in residential and suburban environments.
| Specification | Limit |
|---|---|
| Fleet Size | 100 aircraft |
| Maximum Weight | 55 lbs |
| Population Density | Category 3 or less |
This category anticipates the growing demand for last-mile delivery services while restricting operations to areas with moderate population density. Operators planning large-scale delivery networks may need to pursue certificated operations for urban coverage.
Agriculture
Agricultural permits accommodate precision farming applications including crop monitoring, spraying, and seeding operations.
| Specification | Limit |
|---|---|
| Fleet Size | 10 aircraft |
| Maximum Weight | 1,320 lbs |
| Population Density | Category 1 only |
The higher weight allowance of 1,320 pounds enables heavy-lift agricultural drones carrying spray tanks and spreading equipment. Category 1 population density restriction limits operations to very sparse rural areas, which aligns with typical agricultural environments.
Aerial surveying
The surveying permit covers commercial surveying operations including mapping, inspection, and data collection missions.
| Specification | Limit |
|---|---|
| Fleet Size | 25 aircraft |
| Maximum Weight | 110 lbs |
| Population Density | Category 3 or less |
This category supports surveying and inspection businesses conducting routine data collection across diverse project sites. The 110-pound weight limit accommodates most commercial survey platforms with LiDAR and photogrammetry payloads.
Civic interest
Civic interest permits cover government-related drone operations including public safety, infrastructure monitoring, and community services.
| Specification | Limit |
|---|---|
| Fleet Size | 25 aircraft |
| Maximum Weight | 110 lbs |
| Population Density | Category 3 or less |
Local and state agencies conducting infrastructure inspection or public safety missions can operate under this category. The fleet limit of 25 aircraft supports multi-agency deployment while maintaining manageable oversight requirements.
Training
Training permits authorize organizations conducting pilot training programs for Part 108 operations.
| Specification | Limit |
|---|---|
| Fleet Size | 10 aircraft |
| Maximum Weight | 1,320 lbs |
| Population Density | Category 1 only |
The higher weight limit ensures training programs can prepare pilots for the full range of Part 108 aircraft types. Category 1 restriction confines training operations to very sparse areas, minimizing risk during skill development.
Demonstrations
Demonstration permits support promotional events, trade shows, and technology showcases.
| Specification | Limit |
|---|---|
| Fleet Size | 50 aircraft |
| Maximum Weight | 110 lbs |
| Population Density | Category 2 or less |
The higher fleet limit of 50 aircraft enables coordinated multi-drone demonstrations. Category 2 population density allows operations in sparse areas while still permitting some audience presence.
Flight testing
Flight testing permits authorize manufacturers and developers conducting aircraft testing and development operations.
| Specification | Limit |
|---|---|
| Fleet Size | Unlimited |
| Maximum Weight | Varies |
| Population Density | Very sparse areas |
No fleet limits apply to flight testing, recognizing that development programs may require numerous test aircraft. Operations are confined to very sparse areas to minimize ground risk during experimental flights.
Recreation
The recreation permit provides a pathway for hobbyists seeking BVLOS capabilities beyond current recreational rules.
| Specification | Limit |
|---|---|
| Fleet Size | 1 aircraft |
| Maximum Weight | 55 lbs |
| Population Density | Category 3 or less |
Single-aircraft restriction maintains recreational character while enabling extended-range flying. This category requires formal permit application rather than the simplified processes available for visual line of sight recreation.
Understanding population density categories
Part 108 defines five population density categories that determine where permitted and certificated operations can occur. These categories are based on population distribution data and geographic thresholds.
| Category | Definition | Environment Type |
|---|---|---|
| 1 | Farther than 1 statute mile from any cell of 10+ people | Very sparse rural |
| 2 | Within 1 statute mile of cells with 10+ people | Sparse rural |
| 3 | Within 1 statute mile of cells with 25+ people | Suburban |
| 4 | Within 0.5 mile of cells with 100+ people | Urban |
| 5 | Within 0.5 mile of cells with 2,500+ people | Dense urban |
Permitted operations are restricted to Categories 1-3, which covers very sparse, sparse, and suburban environments. Operations in Categories 4-5 require operating certificates with enhanced safety measures and FAA oversight, as detailed in the Federal Register publication.
Understanding your typical operating environment helps determine whether permits meet your needs or if certificates are required for operational flexibility.
Permitted operations requirements
Operating permits offer a streamlined authorization pathway with specific requirements that differ from certificated operations.
Validity and renewal
Permits remain valid for 24 months from issuance. Operators must apply for renewal before expiration to maintain operational continuity. The renewal process evaluates continued compliance with Part 108 requirements and any changes to operational scope.
Fleet and operational limits
Each permit category specifies maximum fleet sizes that cannot be exceeded under permit authorization. Operators approaching fleet limits who anticipate growth should consider transitioning to certificated operations, which impose no fleet restrictions.
Documentation requirements
Permitted operators must maintain operations manuals covering equipment specifications, maintenance procedures, personnel responsibilities, and emergency protocols. While less extensive than certificate requirements, these documentation standards ensure operational consistency and regulatory accountability.
Personnel requirements
All permitted operations require designated Operations Supervisors and Flight Coordinators meeting Part 108 qualification standards. Personnel must complete TSA security threat assessments before conducting operations. Tracking personnel qualifications becomes essential for maintaining compliance.
Prohibited activities
Permitted operations cannot carry hazardous materials except in limited circumstances with specific authorization. Operations in Category 4-5 population density areas are not allowed under permits regardless of other factors.
Certificated operations requirements
Operating certificates provide expanded capabilities with corresponding increases in regulatory oversight and operational requirements.
Four certificate categories
Certificates are available in four categories that mirror commercial permit types:
- Package Delivery
- Agriculture
- Aerial Surveying
- Civic Interest
Training, demonstrations, flight testing, and recreation do not have certificate pathways, as these activities are appropriately scoped for permit-level oversight.
No fleet size limits
Certificate holders face no restrictions on fleet size, enabling scaling operations to meet business demands. This flexibility supports enterprise-level deployments serving multiple geographic regions or high-volume service models.
Population density access
Certificated operations can operate in all five population density categories, including dense urban environments. Category 5 operations require detect-and-avoid systems capable of identifying non-cooperative aircraft, adding technology requirements beyond lower-density operations.
Safety Management System
All certificated operators must implement formal Safety Management Systems with four core components: safety policy, safety risk management, safety assurance, and safety promotion. SMS requirements ensure systematic approaches to risk assessment and continuous improvement.
Enhanced FAA oversight
Certificate holders receive greater FAA scrutiny including regular audits, compliance reviews, and reporting requirements. This oversight relationship provides accountability while enabling operational flexibility not available under permits.
Which path is right for your operation
Selecting between permits and certificates depends on several operational factors that vary by industry and business model.
Choose permits if
Your operations primarily occur in suburban or rural areas falling within Categories 1-3. Current fleet size remains well below category limits with no immediate growth plans requiring expansion. Operations follow predictable patterns that fit within specific permit category definitions. Your organization prefers streamlined compliance requirements without SMS implementation overhead.
Choose certificates if
Business requirements include operations in urban or dense urban environments. Fleet size exceeds permit category limits or growth projections anticipate exceeding limits. Operations span multiple categories or require flexibility to adapt to diverse client requirements. Your organization already maintains SMS infrastructure or has resources to implement formal safety management.
Industry considerations
Utilities and energy companies conducting routine infrastructure inspections in rural corridors may find permits sufficient. Those requiring urban substation inspections or dense-area coverage need certificates.
Construction operations on suburban project sites can operate under surveying permits. Urban high-rise projects or large portfolio management across diverse locations benefit from certificate flexibility.
Agricultural operators conducting field-scale operations typically fit within agriculture permit parameters. Large agribusiness operations managing multiple properties may prefer certificate flexibility despite permit adequacy for individual operations.
Delivery services must evaluate geographic coverage requirements. Suburban-focused services can scale to 100 aircraft under permits. Urban delivery networks require certificates for Category 4-5 access.
Application process and timeline
Both permits and certificates require applications submitted at least 120 days before intended operations begin. This advance timeline allows FAA review while operators complete preparation activities.
Application components
Applications must include operational area specifications with geographic boundaries, population density assessments, and estimated daily operation volumes. Personnel qualifications documentation demonstrates Operations Supervisor and Flight Coordinator readiness. Aircraft information confirms airworthiness acceptance status.
Review and approval
FAA review evaluates application completeness, operational feasibility, and compliance with Part 108 requirements. Additional information requests may extend review timelines. Operators should plan for potential delays when scheduling operational launches.
Maintaining authorization
Ongoing compliance requires current personnel qualifications, aircraft airworthiness, and adherence to operational limitations. Drone operations software helps track compliance elements across growing operations. Significant operational changes may require application amendments.
Industry use cases
Utilities inspection
A regional utility conducting power line inspections across rural service territory operates comfortably under aerial surveying permits. Category 1-2 population density along transmission corridors falls within permit restrictions. Fleet of 15 inspection aircraft remains below the 25-aircraft limit.
Agriculture services
Commercial agricultural service provider with 8 spray drones serving multiple farms operates under agriculture permits. 1,320-pound weight allowance accommodates heavy spray rigs. Category 1 rural operating areas align with farm locations. Fleet management tools coordinate scheduling across client properties.
Urban delivery
Last-mile delivery service targeting metropolitan customers requires certificates for Category 4-5 urban access. No fleet limits support scaling to meet demand. SMS implementation ensures systematic safety management across high-volume operations.
Multi-service provider
Drone service company offering surveying, inspection, and agricultural services evaluates options based on growth trajectory. Current operations fit within respective permit categories. Anticipated expansion into urban inspection markets suggests certificate investment for long-term flexibility.
Frequently Asked Questions
Can I switch from a permit to a certificate?
Yes. Operators can apply for operating certificates at any time, including while holding active permits. The 120-day application timeline applies to certificate applications. Operators should plan transitions to avoid operational gaps between permit expiration and certificate approval.
What if my operations span multiple permit categories?
Operators conducting activities across multiple categories need separate permits for each category. A company providing both agricultural services and aerial surveying requires permits in both categories with corresponding fleet and operational limits applying independently to each.
How do fleet limits work if I hold multiple permits?
Each permit category specifies its own fleet limit. Operators holding multiple permits must comply with the fleet restrictions for each category independently. Consult the final rule for specific guidance on how fleet limits apply across multiple permit types.
What happens if I exceed permit restrictions?
Operating beyond permit limitations constitutes a regulatory violation subject to enforcement action. Operators approaching limits should apply for additional permits, transition to certificates, or adjust operations to remain compliant. Systematic flight logging helps prevent inadvertent violations.
Implementation considerations
Organizations evaluating Part 108 pathways should assess current operations against permit category definitions. Mapping operating areas to population density categories reveals whether permits provide adequate coverage or certificates are necessary for operational flexibility.
Personnel development represents a critical preparation element. Identifying and qualifying Operations Supervisors and Flight Coordinators takes time that cannot be compressed once final rules publish. Starting qualification documentation now positions teams for rapid authorization when Part 108 takes effect.
Technology investments should align with chosen pathways. Certificate operations in Category 4-5 areas require detect-and-avoid capabilities that represent significant aircraft system investments. Drone operations platforms supporting SMS documentation streamline certificate compliance while providing value for permit holders as well.
In summary
Part 108 permits and certificates provide distinct authorization pathways serving different operational profiles. Permits offer streamlined access to BVLOS capabilities within defined limits, making them ideal for operators with predictable, lower-risk operations in suburban and rural environments. Certificates enable scalable operations across all population densities with corresponding investment in safety management infrastructure.
The eight permit categories address specific industry needs from package delivery to agricultural operations. Understanding category-specific limits for fleet size, aircraft weight, and population density helps operators select appropriate pathways. Organizations anticipating growth or diverse operational requirements should evaluate certificate flexibility against permit simplicity.
With final rules expected by early 2026, operators should begin pathway evaluation and preparation activities now. Early planning ensures readiness to operate when Part 108 takes effect.
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This guide reflects information from the FAA Part 108 NPRM published August 7, 2025. Requirements may change in the final rule. Consult the official FAA documentation and aviation legal counsel for compliance decisions.
